Fedc4

94. The defendants, for their parts and in their official capacities, oversee and are responsible for the
disbursement of congressional tax appropriations made to the Department of Health and Human Services,
including funds appropriated for the integration of HPV vaccine into medical treatment of female children in the
District of Columbia Public school system of Washington.
95. The defendants, in their official capacities, have engaged in activities that violate the Due Process of law and
Equal protection of the Fourteenth Amendment to the United States Constitution by funding, with congressional
taxpayer appropriations made pursuant to Article 1, Section 7, of the Constitution, experimental medical
treatment that violate and deprived children of their right to life.
96. The defendants have been and are responsible for the use of federal taxpayer appropriations to integrate
HPV vaccine as a substantive and integral component of medical services provided by the DHHS to school
children in the District of Columbia of Washington Public School system, in contrast to limited funding availability
to accommodating those injured by the use of the HPV drug.
97. The integration of HPV vaccine provided by the DHHS to schoolchildren under Bill – 030 HPV Vaccination
and Reporting Act of 2007 school program into the medical services promote activities that expose children to
greater harm to their right to life because the side effects negates any potential benefit claimed by the
experimental vaccine.
98. The defendants' actions in using taxpayer money to integrate HPV vaccine as part of the medical treatment
protocol of children vaccine without ever existing a childhood HPV epidemic, or never proven the results of HPV
vaccine value as a cure to cervical cancer, violate the fundamental principle of Due Process of the law and Equal
protection of the law of the Fourteenth Amendment to the United States Constitution by using congressional
taxpayer appropriations, made pursuant to the taxing and spending provision of the Constitution, to support
activities that deprived children of their right to life.
99. The defendants' actions in disbursing and utilizing taxpayer money to support the integration of HPV vaccine
into the VFC's medical treatment protocols, including out-patient treatment, give the appearance of the
government's official support for and advocacy of activities that deprived children of their right to life.
100. The defendants' actions in utilizing taxpayer money to support the integration of HPV vaccine and
mandatory treatment into the modality of health care treatment by the District Department of Health in the District
of Columbia of Washington gives support to and the appearance of the endorsement of activities that deprived
children of their right to life -- that is the very premise of their actions, i.e., that children deprived of their right to
life is necessary for effective treatment.
101. The disbursement of congressional appropriations, made pursuant to article 1, Section 7, of the United
States Constitution, for the purpose of supporting DHHS integration of HPV vaccine and mandating the treatment
into the DC's health care treatment programs for female children attending DC school and DC female children
citizen, gives actual and apparent government endorsement and advancement of activities that deprived children
of their right to life.
102. The actions of the defendants in utilizing congressional taxpayer appropriations to endorse and support
advocacy of activities that deprived children of their right to life violate the Due Process of the law and Equal
protection of the law of the Fourteenth Amendment to the United States Constitution pursuant to 42 U.S.C.
§1983.
103. The actions of the defendants in violating the Due Process of the law and Equal protection of the law of the
Fourteenth Amendment to the United States Constitution are injurious to the constitutional interests of the
plaintiff individually, and to female children in its representative capacity as the majority receiver of this
experimental drug in DC public school, because the defendants' actions compel the children, in which the
majority are Black children, to burden their health by supporting the establishment, endorsement and
advancement of activities, under the HPV experimental drugs endorsed by governmental official, that deprived
them of their right to life, to which the plaintiff object.
WHEREFORE, the plaintiffs demand judgment as follows:
a. For judgment declaring that congressional taxpayer disbursements made by the defendants have been used
in violation of the Due Process of the law and Equal protection of the law of the Fourteenth Amendment to the
United States Constitution;
b. For an order enjoining the defendants from continuing to disburse and use appropriations in violation of the
Due Process of the law and Equal protection of the law of the Fourteenth Amendment to the United States
Constitution;
c. Allocating no taxpayer funds towards this specific vaccine;
d. For an order requiring the defendants to establish rules, regulations, prohibitions, standards and oversight to
ensure that future disbursements are not made and/or used to fund activities without full disclosure of financial
interests, meetings, and negotiations that took place leading up to issuance of the order that include
experimental vaccines as a substantive integral component of the DC's medical treatment protocols for children;
e. For judgment awarding such further relief as the Court deems just and equitable; and
f. For judgment awarding the plaintiffs their reasonable costs, disbursements and attorneys' fees as allowed by
law.
Dated this _16_ day of January, 2009.
                                                                                                      Ndaba
                                                                                                      Washington DC
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