Case 2:21-cv-00702-CLM Document 15 Filed 07/19/21 Page 41 of 67
D. Whistleblower Testimony: 45,000 Deaths Caused by the Vaccines Plaintiffs’ expert Jane Doe 45 is a computer programmer with subject matter expertise in the healthcare data analytics field, and access to Medicare and Medicaid data maintained by the Centers for Medicare and Medicaid Services (CMS) (see Declaration of Jane Doe at Exhibit D). Over the last 20 years, she has developed over 100 distinct healthcare fraud detection algorithms for use in the public and private sectors. In her expert opinion, VAERS under-reports deaths caused by the Vaccines by a conservative factor of at least 5. As of July 9, 2021, VAERS reported 9,048 deaths associated with the Vaccines. Jane Doe queried data from CMS medical claims, and has determined that the number of deaths occurring with 3 days of injection with the Vaccines exceeds those reported by VAERS by a factor of at least 5, indicating that the true number of deaths caused by the Vaccines is at least 45,000. She notes that in the 1976 Swine Flu vaccine campaign (in which 25% of the U.S. population at that time, 55 million Americans, were vaccinated), the Swine Flu vaccine was deemed dangerous and unsafe, and removed from the market, even though the vaccine resulted in only 53 deaths. The gross and willful under-reporting of Vaccine-caused deaths, which is substantiated by Jane Doe’s Declaration, and also by other independent data points considered as part of Plaintiffs’ due diligence, is profoundly important on a number of levels. This evidence increases the likelihood of Plaintiffs’ success on the merits by: (1) making it impossible (a) that the DHHS Secretary can reasonably conclude, as required by § 360bbb–3(c)(2)(B), that “the known and potential benefits of [the Vaccines] outweigh the known and potential risks of [the Vaccines]”, 45
Plaintiffs’ expert Jane Doe is a whistleblower who fears for her personal safety and that of her family, and reprisal, including termination and exclusion from her chosen profession for the duration of her working life, for disclosing the evidence contained in her Declaration at Ex. D. Plaintiffs will present the Court with a motion for an appropriately tailored protective order seeking to preserve the confidentiality of Jane Doe’s identity. In the meantime, Defendants are not prejudiced, since they can respond to the substance of Jane Doe’s Declaration and challenge her expert qualification without knowing her true identity. Plaintiffs’ counsel have in their possession a copy of this same Declaration of Jane Doe, signed by the witness in her actual name.
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