C. Balance of Equities (Hardships) and the Public Interest

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.

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).