A.

True Ott, Phd, ND

485 W. 3925 N.
Pleasant View, Utah 84414
(801) 392-1635

Petitioner in pro per

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF UTAH
OGDEN DIVISION

Dr A. True Ott, PhD, ND (Et. Al.) Case No.:

Petitioner,)

) PLAINTIFF’S PETITION FOR ) INJUNCTIVE

) AND DECLARATORY RELIEF AND DAMAGES
) FOR INTENT TO CAUSE BODILY HARM
)
) [Civ. Code 527.8]
United States Department of )
Health and Human Services, ) Judge ___________

PETITION FOR INJUNCTIVE AND DECLARATORY RELIEF AND DAMAGES

Petitioner brings this action pursuant to Civ. Code 527.8, for wrongful intent
to cause bodily harm, against Respondent, United States Department of Health and
Human Services, and in particular, for intending to administer mandatory “swine
flu” vaccinations for all American citizens, in violation of the First Amendment
to the United States Constitution.
RELIEF SOUGHT
Petitioner seeks an order to enjoin respondent from administering mandatory
“swine flu” vaccines.
JURISDICTION
Jurisdiction is conferred upon this court pursuant to Title 28 U.S.C.A. § 1331,
which authorizes original jurisdiction on the district court of all civil actions
arising under the Constitution, laws and treaties of the United States.
Jurisdiction is also conferred upon this court pursuant to Title 28 U.S.C.A. §
1343(c)(4), which grants jurisdiction to the district court of any action to
recover damages or to secure equitable or other relief under any Act of Congress
providing for the protection of civil rights.
Jurisdiction also exists pursuant to Title 28 U.S.C.A. § 1367(a), which
authorizes jurisdiction over state law claims that one so related to the other
claims in this lawsuit that they form part of the same case and controversy.
VENUE
Venue is proper pursuant to Title 28 U.S.C.A. § 1391(e), which authorizes that
a civil action may be brought in a judicial district in which a substantial part
of the vents or commissions gives rise to a civil rights claim.
PARTIES
Petitioner, Dr A. True Ott, Phd, ND on behalf of himself and US citizens and
residents in Utah, is a natural person, and is, and at all times mentioned herein
was, a resident of Weber County, Pleasant View, Utah. The agency records
described herein are situation in Weber County, Ogden, Utah.
Respondent, United States Department of Health and Human Services, (herein
described as “respondent agency”), is, and at all times mentioned herein was, a
public health agency of the United States federal government.
FACTUAL ALLEGATIONS
Petitioner, Dr A. True Ott, Phd, ND on behalf of himself and US citizens and
residents in Utah, has personal knowledge that Respondent has a well-formed plan
to act in a manner that will surely cause Petitioner serious bodily harm. HHS
Secretary Sebelius, has made public statements, online reports of planning for
mandatory vaccination of all citizens and residents of the USA, with plans for 600
million doses to be given in a two shot program.

4. The planned act complained of is to administer mandatory “swine flu” vaccines

for all Americans in the fall of 2009 pursuant to clauses in the Model State
Health Emergency Powers Act, PD51, and sections of Homeland Security, Patriot
Acts, and John Warner Defense Act, SPP 2005 Agreements between USA President Bush,
Mexican President Vincente Fox, and Canadian Prime Minister Harper.
5. The threatened bodily harm is irreversible serious injury or death.

CATEGORIES OF PROBABLE AND POTENTIAL IMMUNOTOXIC INJURY& DEATH:

1. PROBABLE ACUTE OR CHRONIC ADJUVANT TOXIN INDUCED NEUROLOGICAL , e.g. MF59

INCLUDING SQUALENE OILS PROVEN TO INDUCE ADJUVANT LUPUS, MULTIPLE SCLEROSIS TYPE
AND OTHER AUTOIMMUNE DISEASES. INDUCTION OF CHRONIC AUTOIMMUNE DISEASES,
VASCULITIS, NEUROPATHY, CELLULAR AND ANTIBODY MEDIATED END ORGAN DAMAGE AND
POSSIBLE DEATH ARE WELL KNOW TO BE CAUSED BY TOXIC ADJUVANTS. NEW PROPOSED
ADJUVANTS INCLUDE MF59, HEAVY METALS ALUMINUM, MERCURY, PLAMIDS OF RNA OR DNA OF
RABIES VIRUS, DRUGS SUCH AS METFORMIN, ETC. TO BE REVIEWED AT DISCOVERY WITH
VACCINE MANUFACTURERS FOR HHS.

2. POTENTIALLY HOT BATCHES WITH CONTAMINANT STEALTH PATHOGENS, E.G. MYCOPLASMA,

VIRUSES, FUNGI AND ACUTE OR CHRONIC ILLNESS, PLAMIDS CONTAINING RNA AND DNA
FRAGMENTS AND GENE CASSETTES.

3. DANGERS OF USE OF RNA AND DNA PLASMA ANTIGENIC AMPLIFICATION IN NEW TEST
VACCINES CAN EPIGENETICALLY SWITCH ON GENES CAUSING SERIOUS IMMEDIATE HEALTH
DANGERS, ACUTE AND CHRONIC AUTOIMMUNE DISEASES AND CANCER CELL TRANSFORMATION
ONCOGENETIC INDUCTION

4. PROBABLE FASTER A H1N1 VIRAL GENETIC RECOMBINANT SUBSTRAIN CLADES GENERATION,

WITH POTENTIALLY HIGHER CASE INFECTIVITY AND CASE FATALITY RATES WITH THE USE OF
NEWER RNA VACCINATION TECHNOLOGIES

5. VACCINATION INDUCED DEPRESSION OF IMMUNE PROTECTION AGAINST PRIMARY INFLUENZA

INFECTION AND GREATER CASE FREQUENCY AND MORE SERIOUS CASE MOBIDITY AND HIGHER A
H1N1 CASE FATALITIES
 6. The threat is imminent because of clauses in the Model State Emergency
Powers Act and statements made by Respondent, HSS Secretary Sebelius and US
President Obama. Planned vaccination programs are poised to start as soon as
contracted vaccine manufacturers have stocks available to HHS in early as August
2009 to October 2009. HHS has announced that schools, first line health and
policy and military will be the first to be vaccinated. HHS will be operating as
a proxy for US transfer of Pandemic Preparedness and Medical Martial Law under the
co-ordination of the WHO, as Pandemic Level 6 has been already declared prior to
filing this petition for injunction.
7. An action for money damages alone is insufficient to restore petition to
his status quo ante after the threatened harm because irreversible serious injury
or death cannot be remedied financially. Medical research, scientific and
technical experts, and prior case reports will be provided at Discovery.
8. The threatened harm to Petitioner, Dr A. True Ott, PhD, ND on behalf of
himself and US citizens and residents in Utah, outweighs any substantial harm to
the Respondent because to mandate “swine flu” vaccinations will cause irreversible
injury or death to Petitioner, whereas to not mandate “swine flu” vaccinations
will cause no physical harm to Respondent, or the US population from the
Petitioner prevention of mandatory A H1N1 vaccination.
9. There is no substantial public interest that will be contravened by this
Honorable Court issuing an injunction favoring this particular Petitioner. HHS
proposes that A H1N1 vaccination program protection of the general public from a
completely novel rapidly changing virus, makes this program of no benefit and
greater danger to the public.
10. Similar mandatory US Federal HHS, Ford Administration mandatory Swine
Vaccination caused the death of between 30 to 60 citizens, and Guillaine-Barre
ascending paralysis in over 500 US citizens, and other major and delayed
autoimmune disorders. Legal settlement of a US Class Action suit was successful
against the US Federal Swine Flu Vaccine Program 1976 of the Ford Administration
HHS.
11. There is a substantial likelihood that Petitioner will prevail in this
action, because the facts obtained in the record by discovery will reveal that
Respondent has knowingly conspired to mandate a “swine flu” vaccine program on the
American public in fall 2009. Discovery of vaccine suppliers, medical experts,
researches and published literature, will prevail in proof of toxic adjuvants,
dangerous RNA and DNA technologies, contaminated batches with viruses,
mycobacteria, and stealth pathogens, and lack of efficacy of the vaccinated
procedure for public protection against primary influenza infection or prevention
of acute or chronic complications.
12. There is a substantial likelihood that petitioner will prevail in this
action, because the facts obtained in the record by discovery will reveal that the
vaccines proposed for mandatory administration by Respondent contain untested or
toxic contaminants.
13. The United States Department of Health and Human Services is a public
health agency of the United States federal government.
14. A temporary injunction is necessary to protect Petitioner and US Citizens and
Residents of Utah from the threatened harm.

REQUEST FOR HONORABLE COURT TO PROVIDE AN INJUNCTIVE ORDER

WHEREFORE, Petitioner moves this Honorable Court to enter an ordering enjoining
Respondent HHS Health and Human Services, US Federal Agency, from Mandatory A H1N1
Vaccination Program, and granting such other and further relief as circumstances
may warrant:
For an injunction ordering Respondent to refrain from administering mandatory
“swine flu” vaccinations;
That the Court declare the respective rights and duties of the petitioner and
respondent under the regulation in question and that by its declaration and
judgment the court declare that the regulation has no application to petitioner,
Dr A. True Ott, PhD, ND on behalf of himself and US citizens and residents in
Utah, in this matter; or, that, if it does, it is unconstitutional, invalid, and
void;
For a permanent injunction, enjoining respondent and their agents, servants, and
employees, and all persons acting under, in concert with, or for them from
administering mandatory vaccines;
For costs of actual damages sustained by the petitioner, including damages for
mental suffering [Civ. Code § 1798.48(a)].

For the costs of the action together with reasonable attorney’s fees as determined
by the court [Civ. Code § 1798.48(b)];
For costs of the suit herein incurred; and,
For such other and further relief as the court may deem proper.
Signed:_____________________________ Dated:_____________________

VERIFICATION
I, Dr A. True Ott, PhD, ND, am the petitioner in the above-entitled action. I
have read the foregoing petition and know the contents thereof. The same is true
of my own knowledge, except as to those matters which are therein alleged on
information and belief, and as to those matters, I believe it to be true.
I declare under penalty of perjury under the laws of the State of Utah that,
the foregoing is true and correct.

Signed:_____________________________ Dated:_____________________

BEFORE ME personally appeared Dr A. True Ott, PhD, ND who, being by me first

duly sworn, executed the foregoing in my presence and stated to me that the facts
alleged therein are true and correct according to his own personal knowledge.

_______________________
Notary Public
My commission expires: