Case Filed

Filed: PERK vs County of Los Angeles

FILED ON OCT 1, 2021

SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
CENTRAL DISTRICT

VINCENT TSAI, an individual;
OSCAR RODRIGUEZ, an individual;
ENRIQUE IRIBE, an individual;
MOHAMED BINA, an individual; and
SHAYNE LAMONT, an individual; and
PROTECTION FOR THE EDUCATIONAL RIGHTS OF KIDS, a
California non-profit corporation,
Plaintiffs,
vs.
COUNTY OF LOS ANGELES,
a municipal entity,
Defendant.


Plaintiffs Vincent Tsai, Oscar Rodriguez, Enrique Iribe, Mohamed Bina, Shayne Lamont and
Protection for the Educational Rights of Kids (“PERK”) allege as follows:

INTRODUCTION

In early 2020, the world discovered a novel coronavirus, Covid-19. Governments
responded with the most draconian restrictions in modern history. They closed schools and shut down industries. They banned travel and prosecuted churches. They decided which activities are “essential” and which are not.

Government employees have always been considered essential. That should not be a
surprise. Society cannot function without them. Nonetheless, as the pandemic has waned, public employees have become pawns in a political chess match, ordered by politicians on the Los Angeles County Board of Supervisors to inject themselves with an experimental medical treatment, against their will, or be fired.

The County does not have the authority to order thousands of public employees to
inject themselves with an experimental medical treatment. It does not have that authority as the sovereign or as an employer.

Moreover, on its face, the County’s so-called “vaccine mandate” (the treatments do
not qualify as vaccines under federal law) is unconstitutional because it violates public employees’ right to privacy under the California Constitution. The County must consider and offer reasonable accommodations as a middle ground between individual freedoms and collective rights. It did not do that. Instead, it viewed this sensitive personal issue through the lens of partisan politics.

The County also has to show that forced medical treatment is the least restrictive way
to mitigate the effects of Covid-19. The County cannot show that. In fact, there is mounting evidence that the experimental Covid-19 medical treatments created by Pfizer, Moderna and Johnson & Johnson do not prevent the virus from spreading. Thus, the vaccine mandate is both unnecessary and ineffective in protecting the public.

There is also mounting evidence that the “vaccines” may not be safe for some people,
as hundreds of thousands of adverse reactions have been reported to the Department of Health and Human Services, many in healthy people.

View / Download the PERK filing here:

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