Case 2:21-cv-00702-CLM Document 15 Filed 07/19/21 Page 64 of 67
349 B.R. at 384 (quoting Long Island R. Co. v. Int’l Ass’n of Machinists, 874 F.2d 901, 910 (2d Cir. 1989)). Like Plaintiffs Brittany Galvin (Ex. J), Aubrey Boone, Snow Mills, Angelia Deselle (Ex. H), Kristi Simmonds, Vidiella A/K/A Shawn Skelton (Ex. I), and the Estate of Dovi Sanders Kennedy, and like Diane Hallmark (Ex. K), millions of Americans have already suffered an outrageous violation of their constitutionally protected right to personal autonomy and bodily integrity, and millions more are vulnerable. According to the VAERS data, there have been 438,441 reported adverse events following injection with the Vaccines, including 9,048 deaths and 41,015 serious injuries, between December 14, 2020 and July 2, 2021. The evidence suggests the VAERS system reports only between 0.8% and 2% of all Vaccine adverse events. Plaintiffs' expert and whistleblower Jane Doe has testified that the true number of deaths caused by the Vaccines is at least 45,000 not the approximately 9,000 reported by VAERS (see Declaration at Ex. D). By contrast, the Swine Flu vaccine was removed from the market even though it caused only 53 deaths. C. Balance of Equities (Hardships) and Public Interest In each case involving a request for pretrial injunctive relief, the court “must consider the effect on each party of the granting or withholding of the requested relief.” Winter, 555 U.S. at 24. The plaintiff “must establish . . . that the balance of hardships tips in his favor.” Id. at 20. “‘[W]here the government is the party opposing the preliminary injunction, its interest and harm merge with the public interest.’ Thus the Court proceeds with analyzing whether the threatened injury to Plaintiffs outweighs the harm that the preliminary injunction would cause Defendants and the public.” Brown v. Azar, 497 F. Supp. 3d 1270, 1298 (N.D. Ga. 2020), quoting Swain v. Junior, 958 F.3d 1081, 1091 (11th Cir. 2020).
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