Natural Solutions Foundation

United States District Court for the District of Columbia
Civil Action No. 1:09-cv-01924 (RBW)

Gary Null, Rima E. Laibow, et al.,
Plaintiffs,

v.

U.S. Food and Drug Administration, et al.,
Defendants.

DR. LAIBOW’S SECOND DECLARATION IN SUPPORT OF COMPLAINT

Rima E. Laibow, MD, New York State Medical License #111813, declares under penalty of perjury pursuant to 28 U.S.C. 1746 that the following information is true to best of my knowledge and belief and that if called to testify in this matter I could testify competently to these facts.

1. I am a Plaintiff in this matter. In addition, I am a licensed physician and graduate of Albert Einstein College of Medicine. Furthermore, I have carefully studied the history of immunization through vaccination and have published on the topic.

2. In my considered professional opinion, to a reasonable degree of professional certainty, I find that there is no significant scientific agreement that any influenza vaccine prevents influenza epidemics or pandemics or, for that matter, protects those who are vaccinated from contracting influenza. There is, however, significant professional opinion that influenza vaccines provide no protection or efficacy in the face of adverse-event risk, which would be totally absent in those who have never had influenza vaccines. In the peer-reviewed scientific literature, I further find that competent scientific investigation leads to the conclusion that the use of live virus mist vaccines may very well increase the incidence of the disease. Those children who have been vaccinated have a 3-fold increase in hospitalizations for all causes compared to those children naïve to vaccination for influenza. Children vaccinated with live–cold-adapted-influenza-virus vaccines have an even greater likelihood of neurological and other disorders that have no known cures.

3. One example of the growing scientific agreement that there is no emergency upon which to base the April 25, 2009 Pandemic Declaration followed by the October 23, 2009 Declaration of National Emergency is that both morbidity and mortality from Swine Flu are completely unknown and, given the current state of laboratory testing and identification of the virus, unknowable. As a three month-long CBS News investigation reported, nearly 90% of alleged “Swine Flu” (2009 -H1N1-A) cases were something else.1 Though the Defendant CDC has claimed to stop counting cases, the Defendants initially were “counting” all respiratory illness and death in the absence of accurate laboratory tests as though they were caused by 2009-H1N1-A. Based on the findings of the CBS News investigation, such a position is simply contrary to the evidence and flies in the face of all respectable scientific and epidemiological methodology.

4. Further, an NIH media release of October 21, 2009 shows that influenza vaccines have a range of what the proponents consider to be immune system responses in up to 36% of the test subjects. The induction of an immune system response of some sort, not necessarily a disease-protective one in little more than one-third of the population puts that response squarely in the placebo response range. The close link between the mind and the immune system is very well known: results like these are seen with sugar pills and saline injections. This level of immune response is well within the range of placebo results. This immune system response has not been proven to be associated with any protective benefit. This is the case because the immune response that occurs following vaccination is substantively different from that which occurs when, in the absence of formaldehyde, thimerisol, aluminum, gentimycin, Polysorbate 80, squalene, foreign proteins, adventitious viruses, malignancy-causing and otherwise, and other vaccine ingredients and/or contaminants, a virus is encountered by the immune system from natural contact.

5. I have further considered the largest meta-study of all U.S. influenza vaccine uptake and vaccination-related outcomes, by David A. Geier, Paul G. King, and Mark R. Geier, published in the respected Journal of American Physicians and Surgeons, that showed no significant protection from the flu for the vaccinated.2

6. My conclusion is that there is no significant public health benefit to be expected from the Defendants’ carefully orchestrated disinformation campaign in favor of the Vaccines. Rather, the Vaccines’ approvals demonstrate a clear and present danger to the public, released by the Defendants, in the form of the Vaccines, owned, approved, recommended and provided by the Defendants through agents of the Defendant CDC’s choosing, to the detriment of the Plaintiffs.

7. It is my professional opinion that nasal mist vaccines provide a continuing contagion for those who have not been exposed to the vaccines that places unvaccinated persons at potential serious risk. Since the nasal mist vaccines cause both shedding of infectious viruses in the absence of disease in the vaccinated person AND shedding in the presence of the disease which the nasal vaccine is, according to its manufacturer, designed to produce. Thus, whether the people volunteer for the nasal mist vaccine or are given the vaccine on a mandated basis or refuse the vaccine, they WILL be exposed to not only the bioengineered cold-adapted versions of three “seasonal influenza viruses” but also a cold-adapted version of a novel virus that the WHO, FDA and the President of these United States have declared to be of nearly inestimable harm to humans. Thus, those who do not take the vaccine are being exposed against their will by their own government to four live influenza viruses, one of which that government claims could kill them.

8. I would not be able to walk the streets of my home State of New York, where I have lived since 1968, without risk of exposure to the live viruses in the live-virus vaccines that the Defendants have unleashed on an unsuspecting public or some mutated live virus or viruses spread by the person or persons in whom one or more of the inoculated live viruses mutated. I therefore petition this Court to recognize my standing to sue to protect myself from the underlying, unlawful vaccine approvals and disinformative recommendations, pronouncements, and pro-vaccination infomercials promulgated by the Defendants.

I certify that the above statements by me are true and accurate; I am aware I am subject to punishment as for perjury if any are willfully false.

October 28, 2009

Rima E. Laibow MD