​ By Anna Von Reitz

Some people might not be familiar with the verb "to dissemble", but we all need to become familiar with it, because there is a lot of dissembling going on. 

It basically means to deliberately conceal something or obfuscate it, so that one's attention is misdirected or deflected from whatever the Dissembler wishes to obscure. Like the truth.  And in this case, the truth about the Nuremberg Code and the protection it provides us from accepting any forced medical procedure or therapy at all.  

Together with casting doubts and slander, dissembling is one of the chief tools in the propagandist toolbox.  

A few days ago, I wrote an article explaining that forced vaccinations are a violation of the Nuremberg Code.  Note the word, "forced".   In fact, any forced medical procedure or therapy is against the Nuremberg Code. 

All medical procedures and therapies must have fully informed and freely given consent to the extent possible --- which means that people who are conscious and able to decide things for themselves remain in control of their medical destiny.  

It's only when you are in desperate straits and unconscious that medical professionals are allowed to step in and make decisions "for you".  

This is all cut and dried and set in cement since the 1940's, but now, we have people trying to dissemble it and water it down and reinterpret the Nuremberg Code as applying only to medical experimentation.  

Not. 

The Code itself explains exactly what it applies to, and even though the cases giving rise to the Code arose from medical experiments in Concentration Camps and involved forced medical experimentation on unwilling subjects, the core of the Nuremberg Code rose to the occasion and outlawed all kinds of forced medical procedures and therapies. Not just experimental procedures.  Not just experimental therapies. 

Any medical procedure or therapy that you don't want to participate in, you have the full, free, and unprejudiced right to refuse.  Period.  

Go back and read Article 6, Sections 1 and 3, of the Nuremberg Code for yourselves. 

Don't take anyone else's word for it.  Not even mine.  Be sure.  And make good use of the information if anyone comes to your door with a needle in hand. 

Another good one to quote in their faces is their own cherished Roe vs. Wade decision, the excuse for allowing abortion on demand.  My body.  My choice.  That applies to every aspect of your body, what you take out and what you put into it, too.  

The same dissembling article draws attention to the fact that the Nuremberg Code doesn't make vaccination illegal.  Who said it did?  They are deliberately creating a False Argument as a means to obfuscate. 

The Nuremberg Code makes FORCED vaccination illegal---along with all other forced medical procedures and therapies.  The Nuremberg Code doesn't single out vaccinations or any other procedure or therapy --- it outlaws all forced procedures and therapies with the same broad brush.  

So if you want to be vaccinated, after being fully informed of all the possible downsides and consequences, after understanding exactly what the vaccine contains, after understanding that you will have extremely limited rights of recourse if you voluntarily take the injection and something goes wrong---- then you are free to take your chances and do as you will.  It's your choice.  

The Nuremberg Code won't protect you from your own fully disclosed consent. 

But it will protect you from being imposed upon by politicians and "private security forces" hired by banks that are colluding in this scheme to defraud America under color of law.  

The Nuremberg Code gives you full standing, if they attempt to violate it and force any kind of involuntary or undisclosed vaccination on you by any means---- whether by wrestling you to the ground or by threatening to deprive you of any other right or privilege, including the right to travel and use public facilities. 

All indications are that we are entering a very dark chapter in American history. You will need to stay alert and stay informed, and you are not being given straight information from any of the commercial media channels or their acolytes and paid trolls.  You need to read things with a critical eye and be able to discern the tricks the propagandists employ.  

I am posting (below) an example of a dissembling "News" article so that you can see exactly how they dissemble the actual important information and misrepresent it to mean something else: https://www.boomlive.in/world/do-vaccinations-violate-human-rights-under-the-nuremberg-code-8308

Now read the actual Nuremberg Code Sections --- Article 6, Sections 1 and 3.  

Then stand your solid ground against forced medical procedures of any kind and also against all the dissembling BS artists out there, because they are multiplying like bunnies in spring.  
  
You can take a stand against this Plague of Liars, by joining other like-minded and alert Americans who have reclaimed their birthright political standing and who are now undertaking the responsibility of self-governance--- concerning their health and all other matters--- via their State Assembly.  

Go to: www.TheAmericanStatesAssembly.net

----------------------------

See this article and over 2800 others on Anna's website here: www.annavonreitz.com

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​We have the choice to use either "lawful money" or "government script"----- at least in theory, but in fact, they have established a coercive monopoly leading to conditions of "monopoly inducement"----- the only currency made readily available is the "Federal Reserve Note" or checks, etc., all "denominated" in Federal Reserve Notes------ so how to you force the rats to use "lawful money"?

Well, you can't really force them to literally use lawful money, because they don't have any, but you can force them to "denominate" whatever currency is being used "as" lawful money. In other words, even though they don't have actual United States Silver Dollars, you can force them to pretend that they do and credit your account accordingly "as if" every digit related to your account was representing a United States Silver Dollar.

The key is to realize that the word "personal" has been redefined for their purposes to mean "corporate" and that the corporation uses "Federal Reserve Notes" as currency, so that when you cluelessly set up a "personal checking account" you are in fact setting up a "corporate checking account" for a government corporation franchise operated "in your NAME"------ and every digit passing through that account is being "presumed" to represent "Federal Reserve Notes".

Unless you object and inform the bank that yours is a "private account" and that all deposits to and transfers from the accounts associated with your name must be "denominated" as "lawful money"---- your account will be presumed to belong to the federal corporation franchise they are running in your NAME and all deposits and withdrawals will be considered "Federal Reserve Notes" ----- corporate monopoly money as well. Even worse, the bank will presume that the funds in these corporate franchise accounts belong to the corporation(s) and not to you; this is how they propose to have the ability to seize your bank accounts, 401K's, etc. I recommend informing the local banks with a simple letter instructing them to denominate all funds deposited to and transferred between and out of accounts held in your name as lawful money.

​ By doing this, you put the banks on the griddle if they ever try to "nationalize" your accounts, because you have chosen to operate using lawful money--- which is not their "money". Be sure and use US Certified Mail Return Receipt Requested when you send the letter and retain the receipt when you receive it back to give plausible proof of your action. 
​

CHRISTOPHER JAMES MESSAGE TO TRUCKERS AND WORLD - THERE IS NO JURISDICTION OVER WE THE PEOPLE
https://www.bitchute.com/video/0H8PGHx3Sz6a/

The Questions to Ask
http://www.paulstramer.net/2022/02/the-questions-to-ask.html

3508. No "Emergency Powers" Exist -- Nor Any "State" Immunity http://annavonreitz.com/noemergencypowersexist.pdf

3509. Oh, Ye.... http://annavonreitz.com/ohye.pdf

Educate Yourself - Learn More: http://annavonreitz.com/

For All The State Jural Assemblies - 26 The National Jurisdiction: Soilhttp://www.paulstramer.net/2019/02/for-all-state-jural-assemblies-26.html

The American States Assemblies
https://tasa.americanstatenationals.org/

Correct Your Political Status 
https://tasa.americanstatenationals.org/correct-your-status/

3510. A Message to RCMP http://annavonreitz.com/messagetorcmp.pdf

Are You New To This Information? Get Up to Speed Fast!
Read the Following...Educate Yourself
http://www.annavonreitz.com/order.html

No Middle-man, No Banks, No Government, etc.
https://youtu.be/twvV2gNINk8

Take back your Credit. Mortgages & Debts has ended. It's never too late. Why is it hidden from you? Plus a Special Message to Canadians
https://youtu.be/QvvLaypLWHM

​Liability for the Production and Sale of Vaccines
Potential liability for vaccine-related injuries has received much attention as a deterrent to vaccine manufacturing. A variety of approaches to the issue have been suggested, but there have been few attempts to determine the magnitude of the problem or to analyze basic trends in the interpretation of laws in this area. This chapter provides such an analysis and examines the ways in which the state of the law influences decisions that ultimately affect vaccine availability and innovation.
Go to :State of the Law Liability for injury resulting from vaccination is a matter of state law. Thus, there are potentially 51 different sets of rules on this subject in the United States.

No vaccine-related product liability litigation resulting in a publicly available opinion has occurred in most jurisdictions, and in many there has been no liability litigation related to drugs. Although it is possible by extrapolation from other product liability cases to predict how these states would handle vaccine cases, any such extrapolation might prove inaccurate.
The subject of product liability has become increasingly controversial over the past few years. Manufacturers have complained about the costs, the unpredictability of the law, and the unavailability and cost of insurance.
A majority of states have enacted statutes relating to some aspect of product liability actions.
1 Legislation at the federal level has been considered extensively, but has not been passed. 
2 A manufacturer who produces and sells a defective vaccine that creates a risk of significant injury to the recipient is liable to any person injured by that defect under the principles stated in section 402A of the Restatement of Torts 2d.
3 This is thought to be the law in every American jurisdiction. The key portion of section 402A states:
One who sells any product in a defective condition unreasonably dangerous to the user or consumer or to his property is subject to liability for physical harm thereby caused to the ultimate user or consumer. . . . [The rule applies although] the seller has exercised all possible care in the preparation and sale of his product.
Cases holding manufacturers or others liable for allegedly defective vaccines administered to humans are very rare.
4 The reported cases are:

• Griffin v. United States, in which the U.S. government was held liable because the Division of Biologics Standards of the National Institutes of Health released a batch of Sabin polio vaccine that did not conform to its own regulatory standards (the manufacturer settled), 351 F. Supp. 10 (E.D. Pa. 1972), aff'd in part, rev'd in part and remanded, 500 F.2d 1059 (3d Cir. 1974);
• Grinnell v. Charles Pfizer & Co., in which the manufacturer was held liable for virulent particles in Salk killed-virus vaccine, 274 Cal. App. 2d 24, 79 Cal. Rep. 369 (Dist. Ct. App. 1969);
• Four cases in which the manufacturers of quadrivalent vaccine (diphtheria, tetanus, pertussis, and poliomyelitis) were held liable because new preservative activated the pertussis component, Tinnerholm v. Parke-Davis & Co., 285 F. Supp. 432 (S.D.N.Y. 1968), aff'd, 411 F.2d 48 (2d Cir. 1969), Stromsodt v. parke-Davis & Co., 257 F. Supp. 991 (D.N.D. 1966), aff'd, 411 F.2d 1390 (8th Cir. 1969), Vincent v. Thompson, 79 Misc. 2d 1029 (N.Y. 1974), and Ezagui v. Dow Chemical Corp. 598 F.2d 727 (2d Cir. 1979);
• Gottsdanker v. Cutter Laboratories, in which live particles were found in Salk killed-virus vaccine, 182 Cal. App. 2d 602, 6 Cal. Rptr. 320 (Dist. Ct. App. 1960); and
• Sandel v. State, in which pus was found in typhoid vaccine, 115 S.C. 168, 104 S.E. 567 (1920).

A manufacturer is not liable for harm caused by a nondefective product due to its inherent or unavoidable dangerousness. Thus, if a properly manufactured vaccine will cause harmful side effects in some portion of the recipient population, the manufacturer of the vaccine is not liable for those side effects.

This principle is the subject of comment k to section 402A.
k. Unavoidably unsafe products. There are some products which, in the present state of human knowledge, are quite incapable of being made safe for their intended and ordinary use. These are especially common in the field of drugs. An outstanding example is the vaccine for the Pasteur treatment of rabies, which not uncommonly leads to very serious and damaging consequences when it is injected. Since the disease itself invariably leads to a dreadful death, both the marketing and the use of the vaccine are fully justified, notwithstanding the unavoidably high degree of risk which they involve. Such a product, properly prepared, and accompanied by proper directions and warning, is not defective, nor is it unreasonably dangerous. The same is true of many other drugs, vaccines, and the like, many of which for this very reason cannot legally be sold except to physicians or under the prescription of a physician. . .. The seller of such products, again with the qualification that they are properly prepared and marketed, and proper warning is given, where the situation calls for it, is not to be held to strict liability for unfortunate consequences attending their use merely because he has undertaken to supply the public with an apparently useful and desirable product, attended with a known but apparently reasonable risk.
The qualification ''proper warning is given'' is critically important and a manufacturer will be liable if he markets a drug or vaccine with known risks and fails to warn of them, and it can be shown that the recipient would not have taken the drug or vaccine had he known of the risks. An example of this situation involving polio vaccine is Davis v. Wyeth Laboratories, Inc., 399 F.2d 121 (9th Cir. 1968). In that case, Sabin polio vaccine had been administered to the plaintiff, a 39-year-old male, in a mass immunization campaign conducted with the assistance of a sales representative of the defendant. The plaintiff had developed polio. The Surgeon General had recommended that mass programs using Sabin Type III be limited to children because of the risk of transmission of the disease to adult recipients. The mass immunization campaign involved in the case, however, included adults. The defendant's promotional materials failed to warn of the risk to adults, although the package insert did. The pharmacist who dispensed the oral vaccine did not read the package insert and did not warn the plaintiff of the risk.
The duty to warn arises from the notion that the failure to inform consumers of dangerous aspects of a product may render the product unreasonably dangerous. For instance, if an electric device operated in a certain way will blow up and cause harm to bystanders, a failure to warn the consumer of this risk so that he can avoid the harm will make the manufacturer liable for the harm. Or in the Davis case, if the plaintiff had been warned of the risk, he could have chosen not to take the vaccine, as was then recommended in the case of adults.
If a product is not sold directly to the public, but is distributed through intermediaries who can be expected to know about the product and its risks and to be responsible for informing the ultimate consumer on its proper use, then the manufacturer does not have a duty to warn the public (although it does have a duty to warn the intermediaries of risks not known to them). Prior to Davis, this exception to the duty to warn was thought to be applicable to drugs and vaccines distributed through health professionals (as contrasted with over-the-counter drugs, for which the manufacturer does have a duty to warn the user).
In Davis, the defendant manufacturer argued that its duty to warn had been satisfied by the fact that it had informed the county medical society sponsoring the mass immunization program of the risk that a vaccinee might develop polio. The court rejected this argument in the context of the mass immunization program:
Here . . . although the drug was denominated a prescription drug it was not dispensed as such. It was dispensed to all comers at mass clinics without an individualized balancing by a physician of the risks involved. In such cases (as in the case of over-the-counter sales of nonprescription drugs) warning by the manufacturer to its immediate purchaser will not suffice. . . . In such cases, then, it is the responsibility of the manufacturer to see that warnings reach the consumer, either by giving warning itself or by obligating the purchaser to give warning. Here . . . [the manufacturer] knew that warnings were not reaching the consumer. Appellee had taken an active part in setting up the mass immunization clinic program for the society and well knew that the program did not make any such provision, either in advertising prior to the clinics or at the clinics themselves. On the contrary, it attempted to assure all members of the community that they should take the vaccine. 399 F.2d 131.
The Missouri Supreme Court reached the same result in Stahlheber v. American Cyanamid Co., 451 S.W. 2d 48 (Mo. 1970), involving another mass administration of oral polio vaccine. Recipients included a 41-year-old adult who contracted polio. The manufacturer had not warned that the vaccine should not be administered to adults other than those facing special risks of contracting the disease.
The law summarized here appears to lead to the conclusion that a vaccine manufacturer need not fear liability from injuries resulting from the administration of the vaccine if
(1) the vaccine is correctly manufactured in accordance with regulatory standards and prudent manufacturing practices and
(2) the manufacturer has taken reasonable steps to ensure that the recipient of the vaccine will be warned of possible side effects. Merrill's comprehensive 1973 survey of the law of liability for all drugs concludes: "If a manufacturer adequately warns physicians [or, in the case of mass-administered vaccines, the recipient] about a drug's foreseeable adverse effects, he will escape liability unless the plaintiff can show that his injury was caused by some impurity or resulted from an unreasonably dangerous design" [Merrill, "Compensation for Prescription Drug Injuries," 59 Va. L. Rev. 1, 49 (1973)].
In two decisions, the Fifth Circuit Court of Appeals, nominally applying the law first of Texas and then of Florida, imposed liability in circumstances that would not be covered by these rules. Both decisions have been subject to criticism,5 and it is not clear how many courts would follow them today.
The first and most important of these decisions is Reyes v. Wyeth Laboratories, 498 F.2d 1264 (5th Cir. 1974). That case involved a young girl to whom Sabin oral polio vaccine was administered at a county department of health clinic in Mission, Texas. She developed polio, and her parents sued on her behalf for damages.
The manufacturer's main line of defense at the trial was that the vaccine was not the cause of the disease. Experts testified that virus isolated from a specimen of the child's stool taken on the day after she was admitted to the hospital was "probably wild," i.e., naturally occurring and not the same strain as the vaccine [498 F.2d 1270-1271]. The jury found, however, that the vaccine was the cause of the child's disease, and found for the plaintiff under the district court' s instructions.
The critical issues decided by the court of appeals were two. First, had the manufacturer discharged its duty to warn? And second, was the failure to warn sufficiently connected to the occurrence of the child's disease to support liability? Judge Wisdom wrote a unique opinion strongly affirming the judgment for the plaintiff.
In Reyes, Wyeth had played no role in the vaccination program, perhaps because it had changed procedures after its loss in Davis. It had simply shipped the vaccine in response to an order from the Texas State Department of Health. The package insert warned of the risk, and Wyeth argued that it was all that was required to discharge its responsibility. The procedures, forms, and warnings actually used in the immunization program were the responsibility of the Texas Department of Health, to which it had quite properly shipped the vaccine.
Judge Wisdom answered this argument without really meeting it. Wyeth knew that the vaccine was customarily administered in mass administration programs staffed at least in part by volunteers and nonprofessionals. Knowing that each recipient would not have individualized medical advice, it "was required to warn foreseeable users, or see that the Texas Department of Health warned them" [498 F.2d 1277]. Exactly how Wyeth was to provide these warnings at distant clinics with which it had no connection, or why Wyeth was not entitled to rely upon the Texas Department of Public Health to do its job properly, Judge Wisdom did not clarify. To the argument that Davis was inapplicable because in that case Wyeth had actively participated in the program, Judge Wisdom observed that "the present controversy, however it differs from Davis factually, invites application of the Davis principles, and the conclusion that Wyeth was under a duty to warn . . . [the recipient's parents]" [498 F.2d 1277].
The second issue confronting the court of appeals was whether there was sufficient connection between the failure to warn and the injury to the child. There was no demonstration that had the child's mother been warned of the minute incidence of polio from the vaccine she would have decided not to have her child immunized. This possibility would seem to have been extremely unlikely because polio was occurring in the area. The court first looked to Texas cases for the following rule:
Where a consumer, whose injury the manufacturer should have reasonably foreseen, is injured by a product sold without a required warning, a rebuttable presumption will arise that the consumer would have read any warning provided by the manufacturer, and acted so as to minimize the risks. In the absence of evidence rebutting the presumption, a jury finding that the defendant's product was the producing cause of the plaintiff's injury would be sufficient to hold him liable [498 F.2d 1281].
In the normal product liability case, this rule makes sense. If the consumer is warned of a danger, he or she can take steps to avoid it.
However, what was the parent confronted with the warning that Sabin polio vaccine might cause polio to do? Forgo vaccination and incur the risk of contracting polio naturally? No, said the court, take Salk killed-virus vaccine first.
Buttressing the presumption that Mrs. Reyes might have taken preventive steps is the testimony of Reyes's expert, Dr. Ramiro Casson, that some pediatricians in Hidalgo County, at least by the time of trial, had begun administering killed-virus vaccine to infants in order to build up their level of antibodies before feeding them the live-virus drug [498 F.2d 1282].
This aspect of the decision has been vigorously criticized by Franklin and Mais in "Tort Law and Mass Immunization Programs: Lessons from the Polio and Flu Episodes," 65 Calif. L. Rev. 754 (1977):
First, the court did not discuss the availability of Salk vaccine at the time plaintiffs' child was vaccinated. In fact, manufacturers discontinued making Salk vaccine and concentrated on the Sabin vaccine after the government selected Sabin vaccine for its mass immunization programs in the early 1960s. Indeed, from 1968 to 1975 no Salk vaccine was manufactured in the country, although small amounts were imported. Although the court referred to immunizations in Hidalgo County using Salk vaccine in the early 1970s, it is likely that these units were imported and not generally available. Thus, those who would have chosen Salk vaccine after being warned of the danger of Sabin vaccine would have had a difficult time obtaining the alternative.
Second, the court did not discuss the significance of the fact that the plaintiffs' child was vaccinated during an outbreak of polio in her area. When quick protection is essential, Sabin vaccine has been preferred despite the risk from the live virus. Therefore, even if Salk vaccine had been available it is unlikely that a well-informed person seeking protection would have chosen it [65 Calif. L. Rev. 761].
The Oklahoma Supreme Court did not follow Reyes in Cunninqham v. Pfizer & Co., 532 P.2d 1377 (Okla. 1976), because the evidence in that case showed that at the time of the plaintiff's vaccination in 1963, Oklahoma was in "an epidemic state." The court reversed a verdict for plaintiff and remanded, requiring the plaintiff to show that if the warning had been given, he would not have been vaccinated.
In Reyes, the court imposed liability on the manufacturer for failing to warn the recipient directly of a risk of contracting poliomyelitis from the vaccine even though the warning accompanied the vaccine and would have been very unlikely to change the conduct of the recipient, or to have prevented the child from contracting polio.
Judge Wisdom's opinion closed with an extraordinary section in which, in response to an amicus brief filed by the American Academy of Pediatrics and the Conference of State and Territorial Epidemiologists opposing liability, he took on both medical practice and the Congress. To the doctors he said:
Obviously, however, one can choose to be inoculated with killed-virus Salk vaccine, either to provide complete immunity or as a precautionary prelude to ingesting oral vaccine. This position [that no warning should be required] raises a policy consideration scarcely less urgent than the need for mass immunization from disease; the right of the individual to choose and control what risk he will take . . . [498 F.2d 1294].
To the Congress he said:
Until Americans have a comprehensive scheme of social insurance, courts must resolve by a balancing process the head-on collision between the need for adequate recovery and viable enterprises. . .. [cite] Statistically predictable as are these rare cases of vaccine-induced polio, a strong argument can be advanced that the loss ought not lie where it falls (on the victim), but should be borne by the manufacturer as a foreseeable cost of doing business, and passed on to the public in the form of price increases to his customers.
Givens v. Lederle, 556 F.2d 1341 (5th Cir. 1977), was a further extension of Reyes. Givens, like Reyes, involved Sabin oral polio vaccine. However, unlike Reyes, the vaccine had not been administered in a county health clinic, but by a pediatrician in his office. The victim was not the child but the child's mother, who had apparently contracted the polio from the vaccinated child. The pediatrician had given no warning of this or any other risk, although the risk was disclosed in the package insert.
The case had concluded in a jury verdict for the defendant in the Middle District of Florida (then part of the Fifth Circuit), on the grounds that the vaccine could not have caused the polio [556 F.2d 1343]. Reyes was handed down before the entry of judgment, however, and the trial judge granted a new trial in light of Reyes. On retrial, the verdict was for the plaintiff, and the defendant appealed.
A remarkable aspect of the Givens opinion is that the court did not rely on Florida law to support its judgment. In Reyes, the court had gone to great lengths to highlight a line of Texas cases concerning possible allergic reactions to a drug. In these cases, it was held unnecessary to warn recipients of possible allergic reactions if the number of people affected was not significant. It might appear that because the number of people who get polio from the vaccine is minute, this line of cases would suggest that no warning of the risk was necessary under the controlling Texas law. The court, however, distinguished between the cases on the ground that an allergic reaction affected only a small group of recipients, while all recipients of the polio vaccine were apparently subject to the minute risk of vaccine-induced polio [498 F.2d 1278-1279]. In contrast, the Givens opinion made no reference to Florida law. It simply followed Reyes—ostensibly applying Texas law—and treated it as Florida law.
"[A] proposed major distinction is that a county health clinic administered the vaccine in Reyes, whereas a private pediatrician did so here," said the court [556 F.2d 1344]. The manufacturer apparently was relying on the long line of authority indicating that the duty to warn in the case of prescription medicines prescribed by doctors belongs to the doctor, not the manufacturer. The pediatrician in Givens had an established doctor-patient relationship, was a trained and licensed professional, and had determined that the patient should receive the vaccine as part of her health care. This was not a case of an unadvised patient responding to the entreaties of a mass vaccination campaign.
The court responded to this argument as follows: "The administration of the vaccine by a public health nurse in Reyes is as close to the instant situation as it is to the Davis mass inoculation" [Ibid]. Testimony by the plaintiff's physician that". . . the administration in his office 'really doesn't differ' from that of the Public Health Center; 'not in the administration at all'" emphasized the similarity to the Reyes situation, rather than his role as an informed intermediary [556 F.2d 1345].
The defendant also argued that its warning to the doctor was adequate, and should protect it from liability. The warning stated:
Paralytic disease following the ingestion of live polio virus vaccines has been reported in individuals receiving the vaccine, and in some instances, in persons who were in close contact with subjects who had been given live oral polio virus vaccine. Fortunately, such occurrences are rare, and it could not be definitely established that any such case was due to the vaccine strain and was not coincidental with infection due to naturally occurring poliomyelitis, or other enteroviruses [556 F.2d 1343].
Of this warning, the plaintiff's doctor testified: "[T]he wording of the inserts states that it is a safe and effective means of immunizing the population and that the risk, if it exists, is no more than 1 in 3 million. I felt this was a very nebulous way of putting it, . . . and I did not feel there was sufficient evidence or warning to warn Mrs. Givens about this" [556 F.2d 1345]. The court held that this was sufficient evidence to sustain a jury verdict that the warning was inadequate.
Thus, the court of appeals in Givens treated as factual questions for the jury whether or not the vaccine caused the polio, and whether or not the warning was adequate in light of the actual degree of risk that the vaccine might cause the polio. This situation, in which a jury confronted with a grievously ill child or adult (who has no other potential source of financial support or redress) is asked to judge retrospectively the actions of the manufacturer, the regulatory authorities, and those responsible for the public health, tends toward a biased outcome in favor of the plaintiff.
Although Reyes and Givens were decided in conformity with the verbal formulas of previous product liability law, the skeptical reader might easily conclude that they really stood for a different and simpler rule: the manufacturer is liable for all damages caused by a vaccine. Just such a rule for all prescription drugs had been advocated in Merrill's "Compensation for Prescription Drug Injuries," 59 Va. L. Rev. 1 (1973), and that article was cited by Judge Wisdom in the policy discussion in the Reyes opinion, 498 F.2d 1294 n. 57. Even though the Fifth Circuit had no power to make law on this point for Florida and Texas (the Texas or Florida courts could repudiate these decisions at any time if they had a case in point and chose to do so), the skeptical lawyer advising a manufacturer could take as the message from the judges: manufacturers are going to pay, one way or the other.
Experience From the Swine Flu Vaccination ProgramThese issues received highly publicized national attention in the summer of 1976. The discovery of swine flu virus in a human population with resulting illness (and one death) at Fort Dix, New Jersey, in January 1976, led the CDC to recommend a national program to provide immunizations against swine flu for the population.6 The need for the program was based on the extensive morbidity and mortality experienced during the disastrous pandemic of 1918, caused by an apparently identical strain of influenza virus.
The proposals for such a vaccination program moved through the executive branch and the President to the Congress without a full appreciation of the problems presented by the threat of liability. The program was formulated and advanced on the assumption that the vaccine manufacturers would gladly produce for a fee close to cost the needed vaccine. The public health officials and government lawyers did not realize that Reyes and Givens in the district court represented an entirely new factor in the decision to produce and sell vaccines, particularly a vaccine proposed for administration to nearly the entire population in a short period.
The manufacturers and their insurance carriers, on the other hand, no doubt resented the liability burdens placed upon them by Judge Wisdom, and were perhaps not unhappy about the opportunity to have their concerns addressed in a national forum. In any case, it became clear that the program would not go forward without some legal protection for the manufacturers, who were unable to obtain insurance at a price acceptable to them and refused to carry the risk themselves, in large part because of the limited time available for safety testing.
Rapid congressional action necessitated by the need to manufacture and administer the vaccine before the onset of the flu season resulted in P.L. 94-380, effective August 11, 1976. The act provided for an exclusive remedy against the United States "for personal injury or death arising out of the administration of swine flu vaccine under the swine flu program and based upon the act or omission of a program participant" [P.L. 94-380 sec. 2(k) (2) (A)]. Program participant was defined broadly to include
. . . the manufacturer or distributor of the swine flu vaccine used in an inoculation under the swine flu program, the public or private agency or organization that provided an inoculation under the swine flu program without charge for such vaccine or its administration and in compliance with the informed consent form and procedures requirements prescribed [in the statute], and the medical and other health personnel who provided or assisted in providing an inoculation under the swine flu program without charge for such vaccine or its administration and in compliance with such informed consent form and procedures requirements.
The statute left open the possibility of the manufacturer's or other participant's liability only in the form of a right of the United States to sue any participant for the amount it had paid and the costs of defending the litigation "resulting from the failure of any program participant to carry out any obligation or responsibility assumed by it under a contract with the United States in connection with the program or from any negligent conduct on the part of any program participant . . ." [Id. sec. 2(k)(7)].
The Swine Flu Act had little to recommend it except that it made it possible to go ahead with swine flu vaccine production. The manufacturers obtained protection for one vaccine under one temporary program, but no attention to the issues on any systematic basis. The law was criticized from many points of view but, in fact, it only changed the defendant and the rules, albeit unclear, remained the same. It also thrust the government into the unfamiliar role of product liability and malpractice defendant. The preamble to section 2 (k) stated that the statute was necessary "in order to be prepared to meet the potential emergency . . . until Congress develops a permanent approach for handling claims arising under programs of the Public Health Service Act." That "permanent approach" subsequently faded as rapidly as the swine flu emergency.
The concern about the liability problems of vaccination programs so visible in the debate over swine flu carried over to the state level. To further the cause of universal vaccination and to protect participants in the process, the manufacturers, the American Academy of Pediatrics, and others sought state legislation limiting liability. In the wake of the swine flu controversy, they were successful in two states: Maryland and California. Since then, no new, relevant state legislation has passed.
The Maryland statute provides for immunity of all "program participants," including manufacturers, if the state Secretary of Health and Mental Hygiene finds that an immunization project conforms to good medical and public health practice and gives written approval. No person is exempted from liability for gross negligence, and a manufacturer is not exempted "from the duty to use ordinary care in preparing and handling a drug or vaccine" [Maryland Code sec. 18-401, revised version of Ch. 238 of the 1977 laws].
The California statute mandated the creation of a special fund to provide for the medical, institutional, supportive, and rehabilitative care required "because of severe adverse reaction to any immunization required by state law to be administered to children under 18 years of age."7 The statute also stated that "No person shall be liable for any injury caused by an act or omission in the administration of a vaccine or other immunizing agent to a minor . . . if such immunization is required by state law and the act or omission does not constitute willful misconduct or gross negligence" [California Health and Safety Code secs. 429.35 and 429.36, passed as Ch. 1097, secs. 1 and 2 of the 1977 statutes]. A California trial court has held that this statute protects manufacturers from liability [Flood v. Wyeth Laboratories, Inc., No. SW C 58664 (Superior Court for the County of Los Angeles)].
The swine flu program was not a public health success. The vaccine was successfully manufactured, distributed, and administered to over 45 million people in a relatively short period of time—a considerable administrative and logistical achievement. However, the virus did not reappear the following winter, for reasons that no one understands. Furthermore, it appeared that 1 out of 100,000 of the recipients developed Guillain-Barré syndrome (the most recent study reports a rate of 1 per 200,000)8, an unexpected and unique occurrence of unknown etiology. As a result of the publicity about side effects and the documentation of the apparent relationship between the vaccine and Guillain-Barré syndrome (GBS), a large number of claims were filed. The special liability provisions of the swine flu statute, which very well might have faded into history, proved to be important.
For the purposes of this study, the main importance of the provisions is that they resulted in a large body of litigation relating to the issue of liability for vaccine manufacture and administration. The claims and suits are summarized in Table 6.1, prepared by the Torts Branch of the Civil Division of the Department of Justice. The government has paid more than $73 million to claimants alleged to have been injured by the swine flu vaccination. Although this amount is large in absolute terms, it is less than $2 per vaccine recipient.

TABLE 6.1Swine Flu Claims, Suits, and Outcomes (as of December 15, 1983).
Because there has been so little litigation directly relevant to the liability issue for vaccine manufacture and administration, the numerous swine flu cases provide the best guide to date on the legal rights of injured recipients, the liability risks of manufacturers, and the likely results of court action. It is useful, therefore, to describe this experience at some length and to evaluate the factors that make it relevant to the general question of what vaccine manufacturers need or need not fear.
The most important decision made in connection with the swine flu litigation was a decision by the government to stipulate to liability (accept liability responsibility) for damages caused by the GBS in any case where the plaintiff could show that the GBS was caused by the administration of the vaccine. What was the basis of this stipulation to liability? Was the U.S. government taking the position that the law imposed strict liability, that the warning had been inadequate, or that the vaccine was negligently manufactured or administered?
The court in In re Swine Flu Immunization Products Liability Litigation , 533 F. Supp. 703, 718 (D. Utah 1982), reported the following:
During pretrial procedures . . . the controversial but crucial official statement of then-Secretary of Health, Education, and Welfare, Joseph A. Califano, Jr. was made.
Secretary Califano stated that with respect to those alleging GBS, the government was adopting a new policy. Persons who contracted GBS from the swine flu vaccine, in order to receive federal compensation:
[W] ill not need to prove negligence by Federal workers or others in the Swine Flu Program as required by Federal law and the law in many states. Instead claimants in most cases need only to show that they in fact developed Guillain-Barré as a result of a Swine Flu vaccination and suffered the alleged damage as a result of that condition [Statement of Secretary Califano, June 20, 1978].
Secretary Califano set out two reasons for adoption of this policy:
First, the informed consent form . . . did not warn individuals that there was a one in one hundred thousand risk that a person receiving a flu shot would contract Guillain-Barré and that one in every two million would die from the condition . . . Second, in the Swine Flu program, the Federal Government, in an unprecedented effort, actively urged millions of Americans to get flu vaccination shots and funded the nationwide campaign. Thus we have decided to provide just compensation [emphasis added] for those who contracted Guillain-Barré as a result of the Swine Flu program rather than force many individuals to prove government negligence in protracted proceedings.
The court then added: ''The Justice Department had stated that this policy was 'within the intent of the Swine Flu Act and its legislative history and was appropriate under the circumstances.' (Statement of Mr. Califano reiterating the Department of Justice policy statement)'' [533 F. Supp. 718].9 These positions attributed to Secretary Califano are difficult to interpret. The simplest explanation for the decision would have been that the tort claims act (incorporated in the Swine Flu Act by reference) conferred upon the Department of Justice the authority to represent the government in the litigation, that part of the authority to represent a client includes the authority to settle or compromise claims, and that the Department determined in light of the risks and costs of litigation that a stipulation to liability for this class of cases was a prudent litigation stance. That would require a determination, of course, that there was some risk of liability, but in light of Reyes and Givens such a determination would seem to have been quite reasonable.
The explanations attributed to Secretary Califano by the court raise a number of troubling questions. First, the Secretary said that the warning did not warn of the GBS. Does this imply that there is liability if a manufacturer fails to warn of an adverse side effect even when there is little reason to expect the side effect? If, in fact, there was no reason to warn of the side effect because there was no reason to anticipate it, then why is the failure relevant to the stipulation of liability? Second, why wasn't it sufficient to warn, as was done, of "the possibility of severe or potentially fatal reactions?" Does each possible reaction have to be separately named, or named and then described? Third, what is the relevance of the fact that the government encouraged people to get vaccinated? If that should make the government liable, then surely it should make the manufacturer liable, for the manufacturer is the one that makes the vaccination possible. And if the major point is that Secretary Califano thought there should be what in his view was "just compensation," then why was that a decision for Secretary Califano to make?10 Congress had specifically decided in the course of considering the statute not to change the liability rules. Hence, Secretary Califano's authority to interpret the law in this fashion remains unclear.11
The stipulation was limited to an admission of liability in cases where the plaintiff could prove that the GBS was caused by the vaccination. Given the fact that there is no understood causal path between the vaccination and the syndrome, that was not a trivial burden of proof. However, the suspicion about a connection surfaced early, and the Centers for Disease Control instituted an intensive surveillance system, which resulted in the halt in the program and established an apparent association between vaccination and a higher rate of GBS in the 10 weeks after vaccination. Because of this government study, which provided proof of causal connection, the Department of Justice adopted the policy of admitting liability in all cases where the plaintiff had experienced an onset of GBS within 10 weeks of the vaccination. That left for litigation those cases characterized by issues such as: (1) Did the plaintiff display symptoms of GBS within 10 weeks of vaccination? (2) What were the damages? (3) Did the vaccination cause GBS in cases in which the symptoms were not observed until more than 10 weeks after vaccination? and (4) Did the vaccination have any other adverse effects, and, if so, was there liability for them? The reported results of this litigation are summarized in Table 6.2.12

TABLE 6.2Reported Swine Flu Vaccine Cases Based Upon Manufacturers' Liability Theory.
Table 6.2 reflects the fact that the government was successful in maintaining its position in court. Almost all decisions upheld the position that the government had no liability for conditions other than GBS that appeared in the first 10 weeks after vaccination. Table 6.2 also shows the inherent unpredictability of litigation. There are six decisions that depart from this pattern. The government policy was not to settle cases that did not fit within the "GBS in 10 weeks" criterion, so these six cases should represent the only claims of the 1,600 filed that did not meet that criterion but resulted in recovery.
Overall, the cases demonstrate the phenomenon, reported by others, that a few tort plaintiffs receive a large percentage of the total recovery. This same phenomenon is also documented by Table 6.3, which breaks down total payments by size grouping. This occurs, in part, because it is only in cases with the potential for substantial damages that the incentives exist for a lawyer compensated on a contingent fee basis to make the significant investment required to pursue a legally and technologically complex case to trial.

TABLE 6.3Analysis of Swine Flu Awards.
The six cases that fall outside the basic pattern of the swine flu claims resolution are instructive because one of the risks that concerns potential product liability defendants is the risk of the unexpected result, particularly when it may cost millions of dollars.
Also, two of the cases resulted in decisions of precedential importance that have further confounded the law in this area.
Hockett v. United States, 730 F.2d 709 (11th Cir. 1984), affirmed a verdict in favor of the plaintiff of $324,275.61. (The decision below is unreported and unavailable on Lexis™.) The plaintiff received the vaccination in October 1976. She was diagnosed as having GBS six months later, with no evidence of prior onset.
The plaintiff's proof of causation rested upon the testimony of one Dr. Eylar, described as a biochemistry professor. The court of appeals summarized his testimony as follows:
Dr. Eylar described his work with laboratory animals and experimental allergic neuritis (EAN), a demyelinating disease generally recognized by the scientific community to be an excellent animal model for human GBS. A demyelinating disease attacks myelin, the component of a sheath surrounding the nerve that serves a function similar to that of insulation surrounding an electrical wire. Dr. Eylar found that EAN can be produced in animals by injection of a protein designated as P2, when accompanied by a chemical adjuvant used to heighten the reaction. . . .
Dr. Eylar tested a sample from the same lot of vaccine given to plaintiff and found that it contained chicken P2 protein. He also tested plaintiff's blood serum and found that it contained antibodies that reacted with chicken P2. Dr. Eylar testified that he found P2 antibodies in the blood sera of approximately 50 percent of 30 people who had been vaccinated and contracted GBS and that no P2 antibodies had ever been found in the blood sera of "conventional" GBS patients (those who had not received a swine flu vaccination) [730 F.2d 711].
This summary implies that Dr. Eylar did not testify that he himself or anyone else had ever looked for P2 antibodies in the blood of GBS victims who had not received swine flu vaccine. The government countered the Eylar testimony with the testimony of Dr. Brostoff, who testified that he tested a sample of the same lot of vaccine and that it did not contain any P2 antibodies [sic, probably did not contain any P2].
The government also relied upon the CDC statistical study, arguing that because the plaintiff's GBS had begun not 10 weeks but 6 months after the vaccination there was no basis for finding causation. The district court rejected the study on the following grounds:
[T]he mere fact that the time interval in plaintiff's case was significantly longer is not dispositive. The statistics reveal a skewed bell curve relation between the vaccinations and the onset of GBS; that does not rule out the possibility of a causal relationship between the two. Dr. Daniel Bader pointed out in his deposition that the existence of a bell curve relationship doesn't mean that things that fall outside the middle part of the curve, on either side, are not associated. After ten weeks, the incidence of GBS in the vaccinated population does not fall to zero—it drops to the background incidence rate. . . .
Dr. Bader's observation that one shouldn't throw away the outside margins of the bell curve just because the majority of things occur in the middle of the bell curve is well taken. We know that the overall risk of GBS in the vaccinated population is approximately four times greater than normal, and that some of those in the vaccinated population do in fact develop GBS more than nine or ten weeks later; we also know that not all of the cases of GBS can even be explained with associations, much less proven causes. If cases such as this were to be decided on the bell curve statistics alone, no plaintiff who contracted GBS more than nine weeks after his vaccination would ever be able to recover [730 F.2d 712] [second emphasis added].
This logic, of course, treats the failure to prove the existence of a relationship as having no bearing on proof of its absence. The district court then placed heavy emphasis on the fact that the government's experts had not tested the plaintiff's blood for P2 antibodies [730 F.2d 712]. Therefore, they were not in a position to testify that P2 antibodies were not present in the plaintiff's blood.
The court of appeals affirmed, placing reliance on the fact that the district court had accepted the credibility of Dr. Eylar's testimony. "Had the P2 testimony not been in the case the plaintiff would have proven only a possibility. The P2 testimony carried plaintiff's burden, and the government's statistics and discredited attack on Dr. Eylar's P2 testimony did not eliminate that preponderance of the evidence" [730 F.2d 713].
Judge Tjoflat concurred with a separate opinion. His concurrence is revealing about the problems of dealing with issues of scientific fact in the litigation process.
Counsel for the government did not contemporaneously object to Dr. Eylar's qualifications when he was tendered as an expert; nor did counsel object to his testimony describing the experiments he conducted or the opinion he based on those experiments. See Fed. Rules Evid. 702 and 703. Such objections would not have been frivolous. Dr. Eylar's testimony has not been well received in other district courts. See Carter v. United States, No. G79-369, CA Slip op. (W.D.Mich. Jan. 15, 1984) (court "not persuaded" by Eylar and others); Iglarsh v. united States, No. 79C 2148, Slip op. (N.D.Ill. Dec. 9, 1983) (same); Pancho v. United States, No. C-79-0429, Slip op. (N.D.Cal.1983) (Eylar theory "speculative"); Kirby v. United States, No. 79-1805, Slip op. (D.D.C. July 16, 1982) ("other scientists have not duplicated the testing . . . his latest theories have not been published. . .. Dr. Eylar's testimony . . . has not been accepted by the scientific community"); Anger v. United States, No. 80-F-105, Slip op. (D.Colo. July 31, 1981) (Eylar's theories novel, unsupported, and not sufficiently similar to GBS). As the Middle District of Florida held in Mason v. United States, No. 79-614-Div-Orl-17, Slip op. (M.D.Fla. Jan. 24, 1984):
Were it not for Dr. Eylar's own statements concerning the developing nature of his theories and the obvious unreliability of his testing of the relevant vaccine lot, perhaps his theories would deserve more serious thought and discussion.
Moreover, even accepting all of Dr. Eylar's objective tests and test results as valid, the leap in logic from his findings to his conclusion concerning the causation of GBS in humans remains monumental.
By failing to make timely objection to Dr. Eylar's qualifications and testimony, and the experiments on which his opinions were founded, the government's counsel deprived the plaintiff, and the court, from further inquiry which, for all we know, may have cast Eylar in a more credible light. Certainly, justice does not require that we now give the government, having failed in its trial strategy, a second chance to prevail.
In other words, the particular attorney appearing for the government at the Hockett trial failed at the right moment and the right time (in the ex-post view of the court of appeals) to make the point that Dr. Eylar's testimony was very far from the scientific mainstream. The failure of the government attorney conferred upon plaintiff Hockett the benefit of a windfall recovery that no one else in her situation enjoyed.
In Sulesky v. United States, 545 F. Supp. 426 (S.D. W. Va. 1982), the court found that the "onset of the Plaintiff's GBS occurred on approximately February 1, 1977 . . . in the fourteenth week after the administration of her swine flu shot" [Id. at 428]. The court first found that the statistical studies did not disprove that the plaintiff's GBS had been caused by the vaccine because their basic method was to compare the incidence of GBS in the vaccinated population against a background rate, and "the actual background rate for GBS has not yet been established . . ." [Id. at 430], pointing to disagreement about the precise background rate. Then the court found "that the resolution of the causation issue turns on the testimony of the treating and evaluating physicians." Although the physicians had originally diagnosed the plaintiff as suffering from upper-respiratory illness, the treating physician testified at trial that she had GBS. In addition, the court heard ''the compelling testimony of Dean Robert Waldman which convinced the Court . . . that this case turns upon the uncontroverted diagnosis which he made based upon his evaluation of all of the medical evidence before him in the individualized case of Kathryn Sulesky."
The court took this approach, although there is nothing in the scientific literature to suggest that there is anything about an individual patient's condition or history that enables anyone to distinguish between GBS caused by a vaccination and GBS caused by something else. A treating doctor can diagnose a condition based upon his examination of the patient at the time of examination. The notion that such a doctor also has the expertise to determine the cause of the condition is one that has been discarded in areas such as proving the efficacy of drugs. In that area of the law, a drug is not approved for use because a doctor is of the opinion that a particular patient that he treated was helped by the drug. Scientific evidence is required.
In Spencer v. United States, 569 F. Supp. 325 (W.D. Mo. 1983), the plaintiff-decedent was vaccinated on November 2, 1976, and first sought medical treatment on February 25, 1977, more than 15 weeks later. That visit to his family physician was inconclusive, and he sought no further medical treatment until his hospitalization in an acute condition the morning of March 31, 1978.
[I]n comparatively rare instances in which a low-grade, chronic malady develops, and later apparently flares into acute GBS, the courts and the medical profession are divided in their conclusions as to causation. A small number of experts, including Dr. Poser [who testified for numerous plaintiffs in the swine flu cases], have recognized a related phenomenon of 'smoldering' and 'flaring' . . ." [569 F. Supp. 328].
The court then reviewed testimony of family members that the decedent had experienced "early symptoms involving the leg and hands," 569 F. Supp. 329, and concluded:
Plaintiff's expert, Dr. Poser, is obviously well qualified and familiar with all aspects of both past and current literature on the subject. The government's expert testimony was from less highly qualified witnesses. Dr. Vernon I. Rowe, a local witness, was not unimpressive, but he appeared to testify more from knowledge of orthodox theories and materials published in past decades than from current and thorough familiarity with the applicable field. It may be argued that Dr. Poser is more of an advocate, having been retained in many of the swine flu cases, but the Court found his testimony more persuasive than that of the less-knowledgeable witnesses presented by the government.
Consideration of the medical issues does not, of course, turn entirely on Dr. Poser's testimony, but a detailed review of the pertinent literature and material presented to the Court would not be worthwhile. This would tax not only the Court's understanding of the details of the medical debate but also its ability to articulate the debated issues in medically correct jargon. . .. The Court does emphasize, however, the usefulness of current expert testimony directed toward the facts of the case [569 F. Supp. 330].
Thus did "knowledge of orthodox theories and materials published" fall to the more speculative theories of Dr. Poser.
Gassman v. United States, No. 79-314-ORL-CIV-06 (M.D. Fla. June 27, 1984) involved a plaintiff who fell ill within 2 weeks after receiving the vaccine. She, however, suffered not from GBS but from what her neurologist diagnosed at the time of her discharge from the hospital as "probable vital encephalitis, probably with secondary transient cerebral ischemic episodes." Again the treating doctors testified that the condition was caused by the vaccination, principally on the ground that they had not been able to figure out what else caused it. The government's expert offered knowledge of the epidemiological literature, but little knowledge of the plaintiff. The court was impressed by the skill of the plaintiff's doctor in treatment, and therefore accepted his testimony on the issue of causation. Even the government's expert, noted the court, conceded that the plaintiff's doctor had done "an excellent job" in treating the plaintiff [Id. n. 10].
Again the court made the point that a failure to prove a statistical association does not prove that the vaccine did not cause the condition. "Although these numbers [of reported cases of neurological syndromes other than GBS] are much lower than the reported cases of Guillain-Barré syndrome (more than 500 [as opposed to 24]), and the overall incidence of encephalitic disorders among those vaccinated may not have risen significantly, clearly one cannot logically exclude the possibility that certain of these reported cases were caused by the swine flu vaccine (just as one cannot logically exclude the possibility that certain reported cases of Guillain-Barré syndrome were not caused by the swine flu vaccine)."
The court then offered a theory of causation derived from the plaintiff's experts.
It was undisputed that Mrs. Gassman's neurological syndrome included a mild polyradiculitis which produced the generalized aches and pains in her thighs beginning shortly after the vaccination. This finding by Dr. Derbenwick is significant, in the court's view, because polyradiculitis, an inflammation of the nerve roots, is characteristic in cases of Guillain-Barré syndrome. It would seen reasonable to conclude, therefore, in accordance with Dr. Derbenwick's testimony, that Mrs. Gassman most likely experienced an inflammatory response to the swine flu vaccine which, although idiosyncratic in that it occurred mainly in the brain, was pathogenetically related to the sort of inflammatory response, involving predominately the peripheral nervous system, experienced in cases of post-vaccinal Guillain-Barré syndrome.
This passage suggests that the court thought that polyradiculitis was a distinctive feature of post-vaccinal GBS, whereas, in fact, it is a feature of all GBS. There is no demonstrated association between polyradiculitis and the vaccine, only between GBS and the vaccine.
The issue of causation having been resolved in favor of the plaintiff, that left the issue of liability. The court first complained of the "unfairness" of the government's stipulation of liability in the GBS cases. "By rejecting in all other cases the interpretation it has given the swine flu act in Guillain-Barré syndrome cases, the government places an unfair burden, in the court's opinion, upon plaintiffs such as Mrs. Gassman who have proven that the swine flu vaccine caused a related neurological disorder. . .. During a hearing . . . the court inquired as to why the government's Guillain-Barré syndrome policy should not collaterally or equitably estop it from claiming in other cases that, e.g., the informed consent form was adequate" [Id. n. 16]. The court then went on to find liability on the ground that the consent form was inadequate.
The issue of the adequacy of the consent form was crucial in Gassman and the two court of appeals cases yet to be discussed. It was a brief and fairly straightforward document (see Pure Politics and Impure Science by Arthur M. Silverstein6). Under the heading "Possible Vaccine Side Effects," it said (in full): "Most people will have no side effects from the vaccine. However, tenderness at the site of the shot may occur and last for several days. Some people will also have fever, chills, headache, or muscle aches within the first 48 hours.'' Then followed a new heading, "Special Precautions." It said, "As with any vaccine or drug, the possibility of severe or potentially fatal reactions exists." If the warning was legally adequate, this was the sentence that made it so.
The court in Gassman found the warning inadequate because it was under the wrong heading and because it did not enumerate the specific complications that constituted the "severe or potentially fatal reactions." A judgment of $90,673.95 was entered.
In Unthank v. United States, 533 F. Supp. 703 (D. Utah 1982), affirmed 732 F.2d 1517 (10th Cir. 1984), the plaintiff was vaccinated on October 18, 1976, and experienced a sudden onset of severe pain in her lower back, followed by tingling and numbness in her legs and torso 4 weeks later. She was hospitalized and diagnosed as suffering from transverse myelitis. The plaintiff's experts (not the treating doctor) testified that the vaccine caused the transverse myelitis, reaching this conclusion "by ruling out other possibilities" [533 F. Supp. 710]. The defendant's expert testified, without conducting an examination of the plaintiff, that her condition was caused by a preexisting multiple sclerosis [see the summary of the expert medical testimony, 533 F. Supp. 709-713]. The court followed the theories of Dr. Poser and found causation. That left the question of liability.
The district court first rejected the argument that the warning was inadequate, relying on its own previous decision, Bean v. United States, 533 F. Supp. 567 (D. Colo. 1980). "[T]he inclusion of potential neurologic disorders resulting from the vaccine adds nothing to the knowledge that the vaccine may lead to 'severe or potentially fatal reactions'" [Id. at 715].
The court then adopted a direct path to liability. It found that the statute required compensation for all conditions caused by the vaccine—a unique construction of the statute. Alternatively, the court based liability upon Secretary Califano's concession of liability in the case of GBS. "The fact that GBS alone was singled out by Secretary Califano does not justify differing treatment for other 'closely related' disorders proven to have been caused by the swine flu vaccine" [533 F. Supp. 722]. The legal principles invoked were not clear. The district court then discussed at length the need for a national compensation program, citing all the authorities who have urged one since 1976. "The field of national immunology cries out for a more expeditious and fairer way of determining legitimate claims and compensating victims of the vaccination" [533 F. Supp. 726-727].
The court of appeals affirmed [732 F.2d 1517 (10th Cir. 1984)]. "We believe the trial court's ultimate conclusion that the federal government was liable must be sustained, not only on the ground which the trial court purported [sic] to give but on at least two additional theories . . ." [732 F.2d at 1519]. The court then threw a few new ideas into the liability debate. First, the Califano concession required liability because it really included transverse myelitis, because Guillain-Barré syndrome "is a broad, encompassing term which would include the transverse myelitis" [732 F.2d at 1520]. The court went on to reinterpret the trial court conclusion that the warning was adequate:
[E]ven though the trial court expressly purported to reject a theory of inadequacy of the informed consent in this and a previous case not appealed, we think its findings belie that conclusion. Thus we conclude that the trial court's findings, as a matter of law, support the theory of inadequate informed consent.
The court then set out its own notion of what informed consent requires. "We believe that encompassed in the duty to inform a patient of all material information, substantial and significant risks, is the duty to inform not only of risks that might occur from the particular treatment in question, but also any alternative treatments and the risk of no treatment at all."
The court emphasized the importance of the setting of the swine flu program.
A barrage of publicity aimed at overcoming the reluctance of citizens to participate included the unprecedented appearance of the President of the United States on national television to plead for a positive response. Against that background, it would be a travesty to suggest that people who hurriedly signed the standardized form presented to them were adequately informed of the risks [732 F.2d at 1521].
Based on this combination of factors, the court concluded that the government was liable under the standard of section 402 of the Restatement .3
Petty v. United States resulted in three reported decisions at 536 F. Supp. 860 (N.D. Iowa 1980), 679 F.2d 719 (8th Cir. 1982), and 740 F.2d 1428 (8th Cir. 1984), and one unreported decision, N.D. Iowa, No. C 78-4083, March 31, 1983. The plaintiff experienced severe symptoms resulting in hospitalization 8 days after his vaccination. The treating doctor diagnosed this condition as "serum sickness-like reaction to a foreign protein." The treating doctor testified that this condition was caused by the vaccination. The government presented no live medical expert, relying on depositions and exhibits.
At trial, Dr. Hyden [the treating doctor] testified that in his medical opinion the swine flu shot caused plaintiff's severe serum sickness, which in turn caused plaintiff's congestive heart failure. Dr. Hyden testified that the vaccine was a foreign protein which caused an immune complex to form, setting up an antibody-antigen reaction, which created an inflammatory condition throughout the body. Dr. Hyden testified that there was no evidence that plaintiff received any other foreign protein besides the swine flu vaccine.
. . . The Court is of the opinion that because Dr. Hyden was plaintiff's personal physician and examined plaintiff throughout the relevant times involved in this matter, that his testimony is the more convincing in this matter" [536 F. Supp. 871].
The government had not stipulated to liability for "a serum-like sickness," so the problem of liability remained. The court found liability on the ground that the information form failed to meet the standards of the swine flu statute, although there was nothing in the statute to suggest that a failure to meet its requirements would result in liability of the government. Of the form, the court said:
[B]ecause of the "hard sell" campaign, the Government has a responsibility to protect and help those citizens who volunteer for the vaccination and subsequently become ill as a result thereof. The Government should not hide behind the four corners of a complicated registration form (now argued to be a consent form) and thereby deny and avoid liability [536 F. Supp. 870].
The court of appeals reversed. The district court erred, it said, because the district court found that the liability arose under the swine flu act itself. Rather, said the court of appeals, liability was to be controlled by state law. Judge Bright, writing for the court, reversed and remanded the case to the district court for findings under the standards of Iowa's informed consent law [679 F.2d 727-729].
On remand, the district court found that the information form failed to meet the standards of Iowa law. The court of appeals affirmed. It affirmed because the Iowa statute requires disclosure of the known risks "of death, brain damage, quadriplegia, paraplegia, the loss or loss of function of any organ or limb, or disfiguring scars associated with such procedure or procedures, with the probability of each such risk if reasonably determinable." The swine flu information form had said only "the possibility of severe or potentially fatal reactions exists," failing to enumerate in detail the potential reactions and the risks of each. Because the form had failed to warn Petty of the risk of "serum sickness,'' the manufacturer would have been liable under Iowa law. The court placed particular emphasis on the government's "unprecedented promotional campaign,'' and on the Califano statement explaining the stipulation to liability for GBS. The court concluded:
[T]here is a public policy consideration favoring allocating the risk of loss among the distributors who can then absorb the cost or distribute it more easily. See Reyes v. Wyeth Laboratories, 498 F.2d 1264 n. 57 (recognizing view that burden should be borne by the government because of the societal benefit bestowed by individuals receiving the vaccine).
The court went on to make it clear that its holding was not limited to the government under the special conditions of the swine flu statute and vaccination program. It was a holding that the manufacturer would have been liable under Iowa law if it had not been for the swine flu act. "Under Iowa law, Merrill-National would have been held strictly liable for its distribution of a defective product which proximately caused Petty's injuries" [740 F.2d 1441].
Judge Bright dissented. His dissent in full [740 F.2d 1441-1442] was as follows:
I dissent. I believe that the warning Petty received before being vaccinated was adequate. Therefore the United States is not liable under either the negligence or the strict liability theory propounded by the majority.
Even assuming that serum sickness was a foreseeable risk attending swine flu vaccination, I think vaccinees received adequate warning. The information form Petty read stated that, '[A] s with any vaccine or drug, the possibility of severe or potentially fatal reactions exists.' I do not think that a more specific warning, either describing the symptoms of serum sickness or mentioning that condition by name, would have served any useful purpose in the context of this mass inoculation program. Vaccinees were warned that a small risk of severe or fatal reaction accompanied receiving the vaccine. The majority does not dispute the minimal nature of the risk, but maintains that the warning should have itemized the potential adverse reactions from the vaccine. Yet, the warning of the "possibility of severe or potentially fatal reactions" more directly, completely, and graphically describes for the lay person the hazards of receiving the vaccine than a specific itemization of adverse effects. I agree with the government and with most of the courts that have considered the issue, see supra N.6., that a detailed catalogue of every serious complication that might befall a vaccinee would have been counter productive, serving to confuse or needlessly alarm potential vaccinees without giving them any more information necessary to the making of an informed decision. I therefore reject the majority's conclusion that the failure to specify the potential adverse effects of the vaccine makes the warning inadequate when, as here, the warning aptly apprised vaccinees of the overall possibility of harm.
Because the warning was adequate, the government was not negligent. Nor is the government strictly liable under the theory that the unavoidably unsafe vaccine was rendered defective or unreasonably dangerous by the failure to give a more detailed warning.
I think the practical consequence of the court's decision is to impose so stringent a warning requirement as likely to render any future mass inoculation program infeasible, no matter how desirable.
Accordingly, I dissent.
The mixture of liability theories put forward in Petty is comprehensive. Most significantly, the court emphasizes the primary importance of the state informed consent law (as did the district court in Gassman ). The informed consent statutes have been passed in many states to provide a clear procedure by which a doctor, in the context of a direct doctor-patient relationship, can obtain consent to a medical procedure that may constitute battery. They set standards for genuine consent, requiring full disclosure. The statutes deal neither with malpractice nor product liability, nor with mass health care procedures such as a public vaccination program in which the vaccinee is not a "patient," in the usual sense, of anyone. The implication in the Petty case is that those statutes now set the standard for vaccination and that failure to meet the standard results in liability for any resulting damages, apparently liability imposed on all participants in the vaccination process. This, combined with the favorable citation of a portion of the Reyes opinion, makes Petty a notable development in the area.
What conclusions can be drawn from the swine flu litigation about the risks of a manufacturer's liability? That question depends upon the extent to which litigation occurred under circumstances similar to those that would be faced by a vaccine manufacturer. There are a number of features of the swine flu litigation that are different.
First, the government approach to the problem of defending tort claims is different from that of private parties. Defendants in tort suits with large claims make use of substantially more lawyers and legal resources than does the government. The government, in accordance with its usual tort claims procedures, assigned defense of these numerous tort claims to a small law office, assisted on an intermittent and erratic basis by generalist lawyers with many other duties from the offices of the various U.S. attorneys. This shows up in many aspects of the government defense, particularly its heavy reliance on documentary submittals and expert witnesses who had not examined the particular plaintiff. Indeed, the most straightforward explanation for the government's stipulation to liability in the "GBS within 10 weeks" cases may be that the stipulation was necessary to make the cases manageable—the stipulation left for litigation only those cases in which the government had a straightforward defense that could be submitted largely on paper.
The second important distinguishing feature is that plaintiffs under the tort claims act (incorporated by reference into the swine flu statute) do not have a right to trial by jury. All swine flu cases were tried in bench trials, in which the judges alone heard the evidence and made the findings of fact. It is widely believed that juries increase the unpredictability of outcomes, and tend to be more sympathetic to plaintiffs.
A third important distinguishing feature is that all claims under the tort claims act must be brought in the federal district courts. Many cases against a vaccine manufacturer would be brought in state courts. The differences among state courts would introduce another source of variance in such litigation. The federal district judges have lifetime tenure and historically have received premium salaries.
Although there are distinguished state judiciaries, in a "worst case" scenario a vaccine manufacturer from a distant state would face trial in a state court located in the hometown of the plaintiff, and controlled by a judge subject to frequent elections before that hometown electorate. The plaintiff's case is likely to be supported by "expert" testimony from the treating doctor, perhaps well known and respected in the community.
Fourth, the swine flu program was accompanied by much more intense publicity and news coverage than regular, ongoing vaccination programs. That news coverage may have made many more people aware of the possible connection between the vaccine and GBS, it may have made more recipients consider filing claims, and it may have made doctors more sensitive to the possibility of a GBS diagnosis in persons who received a vaccination. 13
Fifth, there is a difference between the swine flu claims and the claims that would confront a manufacturer of pediatric vaccines in an analogous situation. The swine flu vaccination program was focused on adults and particularly on older persons more likely to incur serious complications from the disease. This affected the litigation in two ways. First, older people have shorter life expectancies and any element of damages calculated over life expectancy is reduced. Second, in many states, a statute of limitations does not run against a minor. Thus, a 1-year-old who suffers injuries as the result of a vaccination may have more than 20 years before any claim is cut off by the passage of time. This makes it more difficult for the manufacturer in the pediatric case to estimate the amount of potential outstanding claims.
Sixth, it is hard to overlook the fact that the defendant in the swine flu litigation was the ultimate "deep pocket"—the government of the United States. The judges in the swine flu litigation were not confronted by a vaccine producer whose solvency and future ability to provide vaccines would be critically affected by the outcome of the litigation. The defendant, instead, was the United States, which would hardly notice the difference. This fact affected not only the reactions of the judges, but the decision to stipulate to liability, the resources dedicated by the Department of Justice to the defense of the cases, and the style of argument that could be made to the courts.14 Indeed, in retrospect it may become clear that the major mistake of the swine flu statute was to place the defense in the hands of a bureaucracy without any long-term stake in the controlling rules.
What can be concluded from the swine flu litigation?
First, the professionals close to the plight of a particular victim find it hard not to support the merits of the claim. The treating doctor, perhaps not unhappy to direct a potential malpractice claim elsewhere, provides supportive testimony. Trial judges, confronted by the hardship the plaintiff has experienced, are tempted to adopt new interpretations of the law.
Second, doctors and lawyers prefer to treat the issues as the other profession's problem. The lawyers and judges involved with a particular case focus their discussion on issues of medical fact, and ostensibly base their decisions on which medical expert's testimony is more believable. Many doctors, on the other hand, think the law should provide a solution to the problem: some are unwilling to testify, and others fail to differentiate in their testimony between established effects and ideas outside the scientific mainstream.
Third, the reaction of the courts who found liability to Secretary Califano's stipulation vividly illustrates the problem facing the manufacturers. One might argue that the manufacturers have a simple solution to the liability burden and the costs of litigation. Instead of strongly resisting liability, as they have, they could simply concede liability and settle, recovering the costs of their settlements in higher vaccine prices and avoiding all the costs of extended and unproductive disputes over issues of esoteric medical fact. That is what Secretary Califano basically did when he supported the government's stipulation of liability for GBS, but a concession of liability builds upon itself. The pressure to treat like claims alike generates an ever-expanding pool of liability if the original concession of liability is based upon no identifiable theory or principle.
Finally, the Unthank and petty opinions seriously erode any confidence that in the future a defendant faced with substantial claims could duplicate the government's basic success. In spite of the fact that the government won almost all of the cases it contested, Unthank and Petty are court of appeals' opinions strongly favoring liability. If they had been handed down early in the litigation, they might have been viewed as setting a precedent in favor of recovery for the plaintiff.
Recently, a few other cases relating to liability for the manufacture of vaccines have been reported. One is a flu vaccine case, involving an administration during the same fateful fall of 1976, but of a monovalent vaccine (Victoria A strain only) administered in a doctor's office and thus not falling within the swine flu statute [Stanback v. Parke-Davis & Co., 657 F.2d 642 (4th Cir. 1981]. The plaintiff had contracted GBS, and the defendant had not warned of the risk of GBS. The doctor testified that it was his practice not to warn patients of the type of risk, and that, although he was aware of a possible risk of GBS in the fall of 1976, he did not warn the patient and would not have warned the patient even if the package insert had been different. The district court granted a summary judgment to the defendant for failure of the plaintiff to prove a causal connection between the manufacturer's failure to warn and the plaintiff's injury. The court of appeals affirmed.
There also have been additional polio cases. The most notable is Schindler v. Lederle Labs., 725 F.2d 1036 (6th Cir. 1983), which affirmed a judgment in favor of the manufacturer on the grounds that its package insert provided adequate warning of the risk of contracting polio. The doctor had administered the vaccine under conditions that are contraindicated. Dunn v. Lederle Laboratories, 121 Mich. App. 73 (1982), also affirmed a verdict for the defendant. In Loge v. United States, 662 F.2d 1268 (8th Cir. 1981), the district court had dismissed the complaint against the United States. The court of appeals reversed on the grounds that the plaintiff's allegations that the United States had approved the vaccine in violation of its own regulations were sufficient to state a cause of action. In Fraley v. American Cyanamid Co., 570 F. Supp. 497 (D. Colo. 1983), the court held that the defendant was collaterally estopped from contesting the adequacy of a warning accompanying a dose administered in 1971 and identical to the warning in Givens.
There are two reported decisions relating to DTP. Walton v. Charles Pfizer & Co., Inc., 590 P.2d 1190 (Okla. 1979), affirmed a verdict (of $2,000, a statutory limit) against the City of Tulsa for the 1966 administration of pediatric vaccines (probably DTP, but not clear). Morris v. Parke-Davis & Co., 573 F. Supp. 1324 (C.D. Cal. 1983), an ongoing case, involves a claim based on a DTP vaccination given in 1965. The plaintiff seeks actual and punitive damages. All manufacturers who produced DTP at the time are joined as defendants because the source of the DTP is not known. A motion to strike the claim for punitive damages was denied by the court.
Caron v. United States, 548 F.2d 366 (lst Cir. 1976), affirmed a judgment of $705,606 for immunization of a 4-month-old baby with DTP, oral polio vaccine, and typhoid vaccine leading to convulsions, grand real seizures, and permanent mental retardation. The typhoid given was an adult dose. The claim was brought 10 years after the vaccination on the theory that the typhoid vaccine was administered negligently, both because the dosage was improper and because in the absence of a special risk of typhoid, it should not be given to a baby.
Lemar v. United States, 580 F. Supp. 37 (W.D. Tenn. 1984), dismissed a suit against the government for encouraging pediatric vaccination without warning of possible adverse consequences.
Calabrese v. Trenton State College, 162 N.J. Super. 145 (1978), held the manufacturer, distributor, and seller not liable for damages allegedly caused by rabies vaccine, but denied the physician's motion for summary judgment because a fact issue existed as to whether he had disclosed possible adverse side effects. Hitchcock v. United States, 479 F. Supp. 65 (D.D.C. 1979), awarded $519,051 against the united States to the wife of a foreign service officer who was given anti-rabies vaccine as "pre-exposure prophylaxis" by government doctors prior to a foreign posting. The liability was based on the failure of the government to warn of the benefits and risks of the vaccine.
Recent TrendsAs the committee completed its work, it became aware of two recent, substantial verdicts against Lederle Laboratories. It will be impossible to assess the long-term importance of these verdicts until the appeal process has been completed, because they may not, in fact, reflect the current state of the law (although the ability of plaintiffs to obtain substantial verdicts in trial courts itself reflects the present unstable state of the decisional law). In both cases, the plaintiffs advanced theories that went beyond the adequacy of the warning; they asked the juries to rule on issues of social benefit and harm and on the underlying scientific factors that contribute to the basic public policy decision to use a particular vaccine. Juries making such decisions in the liability context easily could become the de facto regulators of immunization practices in the United States: verdicts unfavorable to the manufacturers could effectively stop production of a vaccine even if a majority of juries decided against liability.
In Toner v. Lederle Laboratories, No. CV 80-1245 (D. Idaho), a jury returned a verdict of $1,131,200 in April 1984, based on the theories that the defendant's DTP preparation caused the plaintiff child's transverse myelitis and that the defendant could have marketed a safer pertussis vaccine. The plaintiff pointed to the pertussis vaccine marketed until 1975 by Eli Lilly and Company. Eli Lilly sold its rights in the vaccine to Wyeth Laboratories after questions were raised about its efficacy by a review panel of the FDA, and Wyeth never obtained a license to manufacture and market it. An appeal to the U.S. Court of Appeals for the Ninth Circuit is pending [No. 84-3906].
In Johnson v. American Cyanamid Co., No. 81 C 2470 (18th Jud. Dist., Sedgwick Co. Kansas), the jury on June 1, 1984 returned a verdict of $2 million for compensatory and $8 million for punitive damages for a parent-contact of a child who received Sabin (attenuated live virus) polio vaccine. The plaintiff argued that marketing the vaccine was negligent because the Salk (inactivated virus) vaccine is safer, and the parent was not informed that this alternative was available and equally efficacious. An appeal to the Kansas Supreme Court is pending.
The Issue of Punitive DamagesIf the Johnson punitive damage verdict is affirmed on appeal, it could significantly affect future vaccine litigation. Prior to the Johnson verdict, punitive damages were not a prominent factor in vaccine cases. Most plaintiffs' complaints did not even ask for punitive damages (information supplied to the committee by one manufacturer indicated that only 15 percent of suits involved claims for punitive as well as compensatory damages). If the verdict is affirmed, claims for punitive damages may become more prevalent.
Affirmation of the punitive damage verdict in Johnson could be interpreted as a determination by a powerful regulatory body (the common law court and lay jury) that Sabin vaccine should not be administered in the United States unless preceded by an administration of Salk vaccine to unimmunized contacts, and perhaps to the child as well. However, society generally has deemed it desirable to delegate decisions on such health policy issues to specialist groups, such as those advising the FDA and CDC—an approach viewed as appropriate by the committee.
Punitive damage awards would greatly increase the magnitude of financial risk for manufacturers because such damages can be almost unlimited in amount and can be duplicative. (Each jury, in each case, could assess an amount measured by the nature of the defendant's total conduct.)
Punitive damages generally are awarded to punish defendants for conduct that could be characterized as outrageous or as showing a reckless disregard for the safety of others. In Johnson, the argument was based on the wording of the package insert. In addition to disclosing the risk of contact polio, should the insert also have described the option of administering Salk vaccine first? The Immunization Practices Advisory Committee did not (and still does not) recommend this procedure. The Kansas court's judgment that Lederle's failure to suggest preimmunization with the Salk vaccine in its package insert meets the criteria for punitive damages is currently being appealed. In a previous case, however, the Kansas Supreme Court affirmed a punitive damage award by a jury that determined retrospectively that a package insert was insufficient [Wooderson Ortho Pharmaceutical Corp., 235 Kan. 387, 681 P.2d 1038 (1984)*].
The Johnson verdict again shows that the manner in which courts rule on questions involving a manufacturer's responsibility is highly unpredictable.
Summary of the Legal SituationUnder well-established legal principles, a vaccine manufacturer is not liable for injuries caused by a properly manufactured and labeled vaccine. In recent years, however, a few courts have acted contrary to these principles and found manufacturers liable for such injuries, possibly because the injured individual had been urged (or required) by the government to participate in the immunization program and appeared to have no other recourse for compensation.
In general, these vaccine injury claims have been decided on the basis of the doctrine of the duty to warn. This doctrine provides that, prior to the use of an unavoidably unsafe product, the user must be warned of the risks associated with it. In the case of medicines administered by health professionals, the courts generally have placed this responsibility on the health care provider. For vaccines, however, some courts have ruled that the duty to warn resides with the manufacturer, even though the manufacturer is not involved in administration. It is unclear whether the courts that have ruled in this fashion would permit the manufacturer to avoid such responsibility by obtaining a formal agreement from the purchaser stating that a warning would be given prior to administration.
In two very recent cases (presently on appeal), the plaintiffs prevailed by advancing theories of liability that went beyond the adequacy of the warning and asked juries to rule on the issues of social benefit and harm, and the underlying scientific factors that contribute to decisions to use a particular vaccine. In one of these cases, punitive damages were awarded; however, punitive damages previously have not been a significant factor in vaccine-related injury litigation.
This review demonstrates that the limits of a manufacturer's responsibilities (beyond safe manufacturing and adequate package labeling) are unclear. Some decisions appear to suggest that the manufacturer can be held strictly liable in all cases.
At the time this report was compiled, the committee was not aware of any cases holding health care providers liable for vaccine injury, except for situations involving failure to follow accepted medical procedures. It does not presently recommend any change in the rules applicable to health professionals because liability for improper administration is appropriate;* it recognizes, however, that if any proposal limiting recovery against manufacturers were adopted without provision for reasonable compensation, lawsuits might simply be redirected from the manufacturer to the administering professional. This could have deleterious effects on the willingness of health care providers to participate in immunization programs. Such a situation would require careful monitoring. Tracking shifts in litigation and recommending remedial action would be one of the functions of the proposed vaccine commission (see Chapter 7).

Go to:Consequences of the State of Vaccine Injury Liability Law for Vaccine Production and InnovationDespite clear legal rules, the manner in which claims against manufacturers alleging liability for suspected vaccine-related injuries have been handled by the courts does not provide reliable guidelines for predicting the limits and magnitude of their liability. This combines with other organizational and scientific factors to create a situation in which vaccine supply may be threatened.15,16 Causation is difficult, if not impossible, to determine with certainty in specific cases, and there is usually no other recourse to compensation for injured individuals. In the committee's judgment, this has led to a situation in which jurors and courts may be inclined to view tort awards as a means of providing compensation, irrespective of misconduct or scientific considerations.
These circumstances require the manufacturer of a vaccine known to have certain adverse effects to engage in a gamble with very large financial stakes. If an increasing number of courts impose liability, the costs will be enormous because claims average several million dollars per case. The only way to eliminate the risk is to stop manufacturing the vaccine. If the manufacturer chooses to continue to market the vaccine, its only options are to attempt to settle claims, a strategy that could produce a general expectation of liability, or to resist claims in litigation, with the risk that unfavorable outcomes could establish liability. The cost of either strategy will be high (even if claims are defended successfully) and will have to be passed on to consumers via price increases.
To determine the exact nature of concerns over potential liability for vaccine-related injury, the committee conducted an informal survey of vaccine manufacturers. The goal was to solicit information (much of which was commercially sensitive) on the number and size of vaccine injury claims and settlements over the past decade, and on the provisions made by manufacturers for dealing with such eventualities (e.g., insurance). The committee received information from most major companies actively involved in vaccine production. The manner in which the information on these issues was available did not always permit comparisons or aggregation for publication, which was a condition agreed upon for providing such data. For these reasons, the information summarized below should not be taken as a totally comprehensive picture of the situation.
At the time of the initial survey (spring 1984), 166 suits were pending against the four responding manufacturers. The total amount paid in settlements in the previous decade for completed cases (settled or finished with the appeal process) had been $2 million, and about another $1.8 million had been spent on legal defense, not in all cases including "in-house" counsel.
The information gathered in a follow-up effort (spring 1985) revealed that about 65 additional suits had been filed in the intervening year (only a few of the previous total had been settled, some for amounts averaging $1 million; some trial verdicts were on appeal). Legal costs for the 1-year period ranged up to "several million dollars" for some manufacturers. Time series information supplied by two manufacturers indicated a sharp increase in the number of claims filed; their experiences varied considerably, but the total number of reported claims filed against them in 1983 was more than twice that filed in 1980.
Over the past two decades, pharmaceutical companies have been withdrawing from vaccine manufacturing and marketing. Increasingly, the liability situation and its consequences (i.e., litigation costs or difficulty in obtaining insurance coverage) have been cited as major factors in the decision to withdraw.17,18,19 These decisions seem to indicate that present or anticipated vaccine-related injury liability expenses are seen as an unreasonable burden (or an unacceptably risky gamble) in relation to the costs of product development and the income from sales. Such decisions threaten the nation's supply of vaccine because vaccine production in the united States is overwhelmingly dependent on commercial manufacturers.
From the data and comments submitted by manufacturers and from testimony before congressional committees,20,21 the committee concluded that the precise nature of the problem arising from vaccine injury liability cannot necessarily be measured solely in terms of data reflecting past experiences. Litigation over medical injuries in general has increased substantially during the past 10 years. The rate of malpractice claims against physicians during the 5 years between 1978 and 1983 was more than twice that of the preceding 5 years.22 The swine flu episode and publicity about pertussis vaccine risks have drawn attention to the fact that vaccines may cause injury. Also, in many states, the statute of limitations for alleged injury in childhood does not operate while the individual is a minor, thus vaccine manufacturers may be at risk of claims for many years.
Manufacturers are apprehensive that without some means of compensation for unavoidable vaccine injury and temporally related conditions, the present unclear state of the law will continue to allow them to be held liable for such conditions and penalized financially.
The future behavior of the courts and the responses of the manufacturers cannot be predicted with certainty, but the committee is concerned that the apprehensions themselves might have a negative effect. Earlier withdrawals from the market have created a situation in which the United States is reliant on one manufacturer for polio vaccine and most of its DTP vaccine (Lederle), and on another for measles, mumps, and rubella vaccines (Merck Sharp & Dohme). If apprehensions about the current unclear state of the law caused these manufacturers to withdraw, the vaccine supply and immunization programs could be jeopardized, leading to possible resurgence of these diseases. Also, the apprehensions discussed above are a disincentive to investment in the development of new (or improved) immunizing agents and to competition from new or foreign firms.23,24
Proposals to remedy the compensation and liability problems connected with vaccine injury are discussed in Chapter 8.

Go to:References and Notes

• 5. See Marc A. Franklin and Joseph E. Mais, Jr. ''Tort Law and Mass Immunization Programs: Lessons from the Polio and Flu Episodes,'' 65 Calif. L. Rev. 754 (1977) (written before Givens); see also Richard A. Epstein, Modern Products Liability Law 107-110 ( Westport, Conn.: Richard A. Greenwood Press, 1980)

• 8. The entire Matter was restudied in A.D. Langmuir, D.J. Bregman, L.T. Kurland, N. Nathanson, and M. Victor, "An Epidemiological and Clinical Evaluation of Guillain-Barré Syndrome Reported in Association with the Administration of Swine Influenza Vaccines," 119 Am. J. Epidemiol. 841 (1984). It concluded that the rate was less than previously thought, 1 out of 200,000 (a total of between 211 and 246 cases), and that an incidence rate above the background rate was confined to the first 6 weeks after administration. This study explicitly recognized that these results may have been inflated by the publicity.

1.
See, e.g., Prod. Liab. Rep. (CCH) Par. 90,110-195,270 for a listing of state product liability statutes; see, generally, L.R. Frumer and M.I. Freidman, Products Liability (1984).
2.
Prod. Liab. Rep. (CCH) Par. 90,000; but see Product Liability Risk Retention Act, P.L. 97-45 (allows groups of companies to form captive insurance companies and exempts such activity from certain state regulations).
3.
American Law Institute. 1965. Restatement of Torts 2d. St. Paul, Minn.
4.
There are also cases involving animals: Lovington Cattle Feeders Inc. v. Abbott Labs., 97 N.M. 564 (1982); Pearson v. Franklin Labs. Inc., 254 N.W. 2d 133 (S. Dak. 1977); Colorado Serum Co. v. Arp, 504 P.2d 801 (Wyo. 1972); Waller v. Fort Dodge Laboratories, 356 F. Supp. 413 (E.D. Mo. 1972); Alman Bros. Farms & Feed Mill, Inc. v. Diamond Lab., Inc., 437 F.2d 1295 (5th Cir. 1971); and Anderson v. Blackfoot Livestock Commission Co., 375 P.2d 704, 85 Idaho 64 (1962).
6.
There are two extended accounts of the swine flu episode and the government's reaction to it. The first, Richard Neustadt and Harvey Fineberg, The Swine Flu Affair: Decision-Making on a Slippery Disease ( U.S. Department of Health, Education and Welfare, 1978), was written by two Harvard professors for Secretary of Health, Education and Welfare Joseph Califano, the appointee of newly elected President Jimmy Carter. The study is in very much the "how we can learn from the mistakes of the past and do it better" style, and strongly criticizes the officials of the Ford administration for having committed too early and too irrevocably to the manufacture and administration of the vaccine, so that when negative information such as the lack of further confirmations of the disease or problems in its distribution began to develop, it was impossible to reverse course and call off the program. Arthur M. Silverstein, a microbiologist at Johns Hopkins University, who had served as a congressional fellow during the episode, felt the Neustadt-Fineberg study greatly oversimplified the problem and the reasons the government reacted as it did. His study, Pure Politics and Impure Science ( Baltimore: Johns Hopkins University Press, 1981) is more thorough. Although Secretary Califano attempted to deal vigorously with the issues created by the swine flu program and its problems, in the end he, too, was unsuccessful in achieving significant gains in the institutional and legal framework within which these questions arise. It remains to be seen whether some future epidemic threat will become a tragic reality because the lesson learned from swine flu will be thought to have been: "Don't act too soon.".
7.
Esmond S. Smith, M.D., chief of California Children Services, reported in a letter to the committee November 21, 1984 that California's Immunization Adverse Reactions Fund has paid the claims of two children ($1,644.73 and $2,064.59). One claim is pending for an immunization in 1973.
9.
The document referred to is a press release issued by Secretary Califano's office in connection with the announcement that the government would agree to accept liability for cases of Guillain-Barré syndrome that arose in the first 10 weeks after vaccination. The press release was not in the record of the case. When, at Secretary Califano's deposition, the plaintiffs attempted to inquire into the reasons for the government's stipulation, counsel for the government successfully objected to the line of questioning.
10.
The "just compensation" provided by the stipulation in the swine flu litigation is substantially different from the compensation recommended by this committee because it included all the traditional elements of tort damages.
11.
These problems may explain why counsel, as reported in No. 9, desired to prevent deposition testimony by the Secretary on these issues.
12.
The information underlying Table 6.2 was assembled by Mary Koelbel, a second-year student at the University of Virginia Law School using Lexis™. There are additional swine flu decisions that are not reported either in print or in the Lexis™ data base. The Torts Section of the Civil Division, Department of Justice (DOJ), has a comprehensive litigation file of all decisions made in the swine flu litigation. Jeffrey Axelrad, director of the Torts Branch, permitted Kitch, a member of the committee, to examine this file on February 6, 1984. To base this report on information that could be easily verified by others, the summaries here are based only on publicly available information. Review of the DOJ files led Professor Kitch to conclude that there were no important differences between the outcomes reflected in the published and unpublished decisions, except that the unpublished decisions tend to be briefer, less notable, and more overwhelmingly in favor of the government. Publicly available decisions relating to procedural matters are not reflected in Table 6.2. Axelrad also prepared Tables 6.1 and 6.3. The committee appreciates the assistance provided by Axelrad.
13.
The CDC study attempted to determine the rate of vaccine-induced GBS by comparing rates for the vaccinated and unvaccinated populations. It then attempted to check for the possibility that doctors had been more ready to make a GBS diagnosis of patients who had been vaccinated by comparing objective measures of the severity of the condition in the vaccinated and unvaccinated victims. GBS is not a well-defined disease complex. The study found that these measures were on average the same in the two populations. That check, however, does not rule out the possibility that medical personnel were quicker to consider a possible GBS diagnosis in the vaccinated population after the widespread publicity about the possible connection. Langmuir, Bregman, Kurland, Nathanson, and Victor, "An Epidemiological and Clinical Evaluation of Guillain-Barré Syndrome Reported in Association with the Administration of Swine Influenza Vaccines," 119 Am. J. Epidemiol. 841,, 865-866 (1984), explicitly recognizes this problem. "However, it is only reasonable to believe that the history of a swine influenza vaccination in the individual patient may well have influenced his physician to more seriously consider both the diagnosis of Guillain-Barré syndrome and the reporting of the case if so diagnosed. In addition, patients who had received swine influenza vaccine may well have sought medical care more promptly" [Id. at 865-866].
14.
Indeed, it is telling that when the General Accounting Office studied the processing of swine flu claims at the request of Rep. John A. Durkin, no attention was paid to the question of whether the claims being paid were valid claims under the statute, but only to why the Department of Justice was taking so long before it authorized payment [U.S. GAO letter B-199297 (January 14, 1981)].
15.
National Immunization Work Groups. 1977. Reports and Recommendations of the National Immunization Work Groups. McLean, Virginia: JRB Associates.
16.
U.S. Congress, Office of Technology Assessment. 1980. Compensation for Vaccine Related Injury. Washington, D.C.: U.S. Government Printing Office.
17.
Pettinga, C.W. 1983. Vaccine Innovation in the Private Sector. Paper prepared for an Institute of Medicine Conference on Barriers to Vaccine Innovation, November 28-29, 1983, Washington, D.C.
18.
Mason, J.O. 1984. Testimony on H.R. 5810 before the Subcommittee on Health and the Environment, Committee on Energy and Commerce, U.S. House of Representatives, December 19, 1984, Washington, D.C.
19.
Shaw, D. 1984. Testimony for Wyeth Laboratories on H.R. 5810 before the Subcommittee on Health and the Environment, Committee on Energy and Commerce, U.S. House of Representatives, December 19, 1984, Washington, D.C.
20.
Johnson, R.B. 1984. Testimony for Lederle Laboratories on H.R. 5810 before the Subcommittee on Health and the Environment, Committee on Energy and Commerce, U.S. House of Representatives, December 19, 1984, Washington, D.C.
21.
Sarett, L.H. 1982. Testimony for Merck & Company before the Subcommittee on Investigations and General Oversight, Committee on Labor and Human Resources, U.S. Senate, July 22, 1982.
22.
American Medical Association. 1983. Physicians' Professional Liability Experience, Socioeconomic Monitoring Systems Detailed Tabulations. Chicago, Ill.: American Medical Association.
23.
Beale, A.J. 1985. Modern approaches to the development of vaccines: perspective of a traditional manufacturer. Pp. 377-381 in Vaccines 85. Molecular and Chemical Basis of Resistance to Parasitic, Bacterial, and Viral Diseases, R.A. Lerner, editor; , R.M. Chanock, editor; , and F. Brown, editor. , eds. Cold Spring Harbor, N.Y.: Cold Spring Harbor Laboratory.
24.
Medicine in the Public Interest. 1984. Impediments to Vaccine Research. Boston, Mass.: Medicine in the Public Interest, Inc.

​Rumble — ARTICLE of DECLARATION OF INDEPENDENCE:
https://beachbroadcast.com/whats-happening/f/the-2nd-declaration-of-independence---power-back-to-the-people

 
​By Anna Von Reitz

This is not a comment about the content of the so-called Second Declaration of Independence that has been circulated on the web, because I haven’t read it.

I don’t have to read it to know that it is another British Barrister’s trick—- and here’s why.

Ever heard of a “Chain of Title”? 

If you have claim to a piece of property — any kind of property— and that claim is based on a title or contract that is transferred over time, you must be able to demonstrate a step by step valid ownership
Interest transferred to you by the original grantor or patent-holder.

This is called a “Chain of Title” because each transfer of ownership represents a link in the “chain” linking the property to you.

Guess what happens if one link fails?

The chain of title breaks and you are out of luck. 

The same thing happens with all such claims and contracts.  Write this in big letters:  If there is a break between you and the original contract, you lose it.

That is what has happened to our Federal Subcontractors as a result of their own actions, and now they are trying to bait us into similarly castrating ourselves.

The “Second” Declaration is a lawyer’s trick  to sucker us into destroying our own claim to all that The Declaration of Independence established.

If you accept a “Second” Declaration of Independence, you cause a break between you and the original Declaration of Independence, and as a result, you lose all that your Forefathers won —- your land, your soil, your independence, your sovereignty, your Natural Unalienable Rights— all tossed away by your own hands.

And wouldn’t our enemies love that, if we were stupid enough to “voluntarily” forfeit all that our Forefathers won,  by accepting a “Second” Declaration of Independence?

We don’t need any “Second” Declaration of Independence.  The original still stands as glorious today as it ever was and ever shall be. And it is the only bedrock source of American independence and sovereignty.

Lose our direct connect to the original Declaration of Independence or foolishly exchange it or give it away for anything else, and we lose everything.

So did our Mothers’ raise stupid children? 

Despite Bill Gate’s claims about how stupid Americans are, we are not that stupid by a long shot. 
----------------------------

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2946. "Second" Declaration of Independence? No Contract  http://annavonreitz.com/seconddeclaration.pdf

​​By Anna Von Reitz
​As we have taught and observed since the beginning, there were three (3) Federal Subcontractors operating under three (3) separate Constitutions -- an American Subcontractor, a British Subcontractor, and a Holy Roman Empire Subcontractor. 

All of these Subcontractors were staffed and operated by Federal Citizens. 

The American Subcontractor was staffed by United States Citizens, as defined by 2 USC 253, Chapter 28, Subsection 1. 

The British and HRE Subcontractors were defined within the Constitutions themselves, and so, their political status is attached to and defined by and only exists so long as their Constitutions stand.  See Article 1, Section 2, Clause 2 and Article 1, Section 3,  Clause 3.  

From the very first, then, our American Federal Subcontractor, known as the Federal Republic, was staffed by Americans who claimed their birthright identity as State Nationals, but additionally qualified under 2 USC 253, to perform as Federal United States Citizens.  

This is known as Dual Citizenship, where one person owes citizenship obligations to two (2) body politics and two governments at the same time.   

Americans are either (1) State Nationals, or (2) State Citizens, one or the other, no wishy-washy.  We don't recognize Dual Citizenship at all.  From our perspective, Federal United States Citizens are State Nationals of the State they were born in and are accountable to our country and our government via State Public Law.  

But from the Federal standpoint, Americans can be Dual Citizens, and have to act as Dual Citizens, if they are going to work for the Federal Government.  

That includes the Federal Republic.  

So Federal Republic United States Citizens are Americans who are State Nationals protected under the Constitutions as State Nationals, but they are additionally under obligation to serve the Federal Republic in foreign international and global jurisdictions.  

For example, you might be a New York State National serving as a Federal United States Citizen, and those two political identities would together define your Dual Citizenship as a Federal Republic Employee operating under The Constitution for the united States of America..  

As British Territorial Government Employee, you would also be a Dual Citizen, but one of your political status obligations would be to the government of Great Britain, and the other would be to the Territorial United States Government operating under The Constitution of the United States of America. 

Ditto with respect to the Municipal United States Government and its Employees --- one citizenship obligation would be to the Holy Roman Empire, and the other to the Municipal Government of the United States operating under The Constitution of the United States.  

Our American Federal Republic ceased operating in 1860, as a result of its oversight and funding being disrupted by the Secession of the Southern State-of -State Governments from the original Confederation.  

There is no British Federal Republic. 
There is no Municipal Federal Republic. 

In recent years things have gotten so slack that members of the  Municipal Congress have been allowed to choose other citizenships --- for example, a Senator could choose to act as a Municipal citizen of the United States and an Israeli citizen, or a Congresswoman could act as a Municipal citizen of the United States and a Libyan citizen.  

This has eroded any sense of loyalty to their Employers and sped the corruption of what is supposed to be "our" Federal Government, or to be more exact, to be "representing" our Federal Government ----because these people are no longer subject to any form of American Public Law.  As Municipal citizens of the United States, they answer to the Pope.  As citizens of China or Lebanon or Russia, they stand under the laws of their own adopted foreign countries.  

This same corruption is what has led to "Globalism" and it is really just another example of deceiving and defrauding the American people who voted for these monsters in Good Faith, assuming that these foreign Vermin were their own long-lost American Federal Republic Congress---- and would be operating under the same laws and constraints as their Federal Congress.  

Fraud vitiates everything under Roman Civil Law, and the Pope is obligated to shut these Vermin down.  They are his responsibility.  

He has owned them as slaves and not only must he set them free upon discovery of the Great Fraud, he must see to the arrest of the criminals among them who have committed such outrageous crimes against humanity and against The Constitution of the United States.  

As for the British Territorial Government, they are messing around seeking shelter from the storm they helped create, and are now proposing to pass themselves off as our long-lost American Federal Republic.  

What they need to do is to turn the reins back over to the actual Federation of States, which is the only entity on Earth with the power and provenance and the prior-established right to save their bacon.  

They should all come clean and come home instead of fooling around trying to establish a "new" republic for themselves; as British Territorial Citizens they have no right to issue gold or silver money and cannot create any new republic for themselves based on our credit. 

Their only way forward is for the American-born employees of "the" United States of America (under whatever name they are now calling their corporation-- I think it's "The Republic of The United States"--Inc.) to come home, adopt their American State National political status as half of their Dual Citizenship, re-charter, and operate under The Constitution for the united States of America. 

There is no safety elsewhere, because of the Great Fraud, and because of the Operation of Law that returns all delegated powers to the Delegator upon Breach of Trust or incompetence or failure to perform.  Our unincorporated Federation of States doing business as The United States of America has offered a port in the storm, but under our terms. 

They have to stand under our Public Law while operating on our land, must honorably perform according to our Federal Constitution, and must accept the obligations of Federal United States Citizens as half of their Dual Citizenship.

Then they can claim to have a valid association with us and can function under our oversight as an instrumentality of the American Government and can operate under The Constitution for the united States of America. 

Not otherwise.  

It seems that they have recently realized their numerous mistakes and in desperation are trying to front a "Second Declaration of Independence" -- but as we pointed out, Territorial United States Citizens don't have a political status related to us in the absence of a Constitution, and if they attempt to adopt a "Second" Declaration of Independence, they instantly lose all that was won under The Declaration of Independence.  

They become rebels and renegades, stateless and homeless, starting over from Ground Zero, recognizable as international pirates---- and we will still have all our rights and prerogatives intact.

If they want to enjoy the gains that our Forefathers made in The War of Independence, they will have to come home. 


It is past time for the so-called White Hats to talk to the actual people of this country and to our much-betrayed international government, which is, as ever, our unincorporated Federation of States doing business as The United States of America.  

----------------------------

See this article and over 2900 others on Anna's website here: www.annavonreitz.com
​
2955. Federal Dual Citizenship -- Why It's Important  http://annavonreitz.com/federaldualcitizenshipimportant.pdf

2952. About "Q"  http://annavonreitz.com/aboutq.pdf

2953. No More Fakes and No More Cuckoo Birds, Either  http://annavonreitz.com/fakesandcuckoobirds.pdf

2954. Killing the Beast -- Notice How They Did It  http://annavonreitz.com/killingthebeast.pdf

2955. Federal Dual Citizenship -- Why It's Important  http://annavonreitz.com/federaldualcitizenshipimportant.pdf

2956. Public Notice to Pope Francis and the World  http://annavonreitz.com/publictopopefrancis.pdf

2957. Once More. Slowly  http://annavonreitz.com/oncemoreslowly2.pdf

View All At annavonreitz.com/

https://www.whitehouse.gov/wp-content/uploads/2021/01/The-Presidents-Advisory-1776-Commission-Final-Report.pdf

​“I know no safe depository of the ultimate powers of the society but the people themselves ; and if we think them not enlightened enough to exercise their control with a wholesome discretion, the remedy is not to take it from them, but to inform their discretion by education. This is the true corrective of abuses of constitutional power.” – Thomas Jefferson
​We all have a role to play in 'Draining the Swamp' and defending our constitution and way of life. Join the NATF Now! http://national-taskforce.org

July 22, 2020
Shared by ourgreaterdestiny
How man is seduced into servitude
Thanks to Phil for meaningful insight.
Keith Knight https://www.bitchute.com/channel/KeithKnightDontTreadOnAnyone/ interviews James Corbett about The Politics of Obedience: The Discourse of Voluntary Servitude the 16th century treatise on tyranny and obedience by Étienne de La Boétie.

James and Keith highlight some of the book’s key insights and detail how they apply every much to our situation today as they did when they were written

Show notes. https://www.corbettreport.com/interview-1563-keith-knight-and-james-corbett-dissect-voluntary-servitude/
Letter to Humanity by John St. Johnby The New Agora | Jul 17, 2020
You are not a slave to be used and abused… but a Sovereign divine being created in the image of our creator…
So Please: all I ask is that you take a little time to do the research, checkout the thousands of independent Doctors, Scientists and Expert Specialists that have studded for years and have put their lives on the line to bring you the TRUTH.

COVID19 is Our Chance to end this Tyranny once and for all! Read more at https://newagora.ca/letter-to-humanity-by-john-st-john/
Free societyFreedom is an inside job.
Now is the time.

Spread the word.

Thank you.

Sincerely,
Doreen A Agostino
Without Prejudice and Without Recourse
http://freetobewealthy.net
Sent via hardwired computer
All wireless turned off to safeguard life

By Anna Von Reitz

This really isn't so hard to understand. When you take a job, you have conditions of employment that you accept or reject.
When you work for the Federal Government corporations, you ride for the brand, wear the uniform, take on the title, and if they tell you to get vaccinated, you do.
For the rest of us, who have taken the time to pay attention and to declare and record our proper political status, it's voluntary. We can take the vaccination or not.
That's what this is about and it's nothing so very difficult to grasp.
But if you don't want to get lined up and punctured like steers in a feedlot getting ear tagged, better beat your feet to: 
www.TheAmericanStatesAssembly.net and get moving.
We have a little pin about the size of a credit card that simply says: "Public Notice: I am not your Employee or Dependent."
This serves Notice to any public employee, military person or Federal Civil Service or State of State worker, that you are their Employer and not subject to their rules and commands.
As long as you know who you are and have your evidence established on the public record, whether you get vaccinated or not is your choice.
If you let them "presume" that you are a U.S. Citizen or Municipal "citizen of the United States" ---- it will be their choice.
Don't wait.
----------------------------

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By Anna Von Reitz

If you have no responsibility for your actions in commerce (that is, if you accept no liability), you have no right to conduct commerce.  

Remember that little factoid as we go along.  

Now see:  The National Childhood Vaccine Injury Act (NCVIA)

If you look up the legislation referenced above or cruise the Wiki World interpretation of life after death, you will see that this POS was sold to the public as a reaction to Big Pharma black-mailing Congress.  


They threatened to discontinue manufacturing vaccines altogether because the harm to children caused by their vaccines was costing them too much money as a result of injury and liability suits.  

Their product was causing harm and they knew it.  And they didn't want to be responsible for it.   

So Congress knuckled to their Primary Donors and passed the NCVIA holding the pharmaceutical corporations harmless no matter what harm their vaccines do, and shuffled off the "painful part" of paying the victims onto me and you.  

And this, unknown to all but personal injury lawyers, is the way it has been since 1986.  

If you take a vaccine, voluntarily or involuntarily, and it injures, maims, or kills you, the only redress is to sue the government --- that is, take it out on yourself and your neighbors as extra debt and taxes.  

This set  Big Pharma free of any accountability for what they put in vaccines.  Rat poison, mercury, ant crap, anything at all is fair game for them.  They can shoot you up and pollute your blood and screw up your DNA and laugh all the way to the bank.  

They can get the Flunkies in Congress to pay them $1000 a shot out of the public treasury for providing this "service" too.  

And now this current situation presents "the rest of the story", because---wait for it....wait for it....wait for it! ------ "the government" which is really a private, for-profit corporation in the business of providing governmental services, is bankrupt.  

If you have been following along --- the only right of redress or remedy left to the victims of bad vaccines since 1986 has been to sue the government, and now, you can't even do that, because "the government" is bankrupt.  

So, La-Dee-Dah, there you have it, the entire plan to kill people via vaccination, and leave nobody at all financially responsible for the damage inflicted.

And, please note, this means that all the pharmaceutical corporations producing all these vaccines are out of business, right along with the "government" --- because the right to conduct commerce is dependent on your acceptance of liability for what you do.  

Tell everyone you know.  And get moving.  Locate your pitchforks. 

Go to: www.TheAmericanStatesAssembly.net   Learn what you can do to protect yourself and your family and your country.  

Please read the quote below and reflect.  No truer words have ever been spoken:  

“We now live in a nation where doctors destroy health, lawyers destroy justice, universities destroy knowledge, governments destroy freedom, the press destroys information, religion destroys morals, and our banks destroy the economy.”  -- Chris Hedges

----------------------------

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To support this work look for the PayPal buttons on this website. 

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(Natural News) Preliminary data from a clinical trial involving more than 100 covid-19 patients in Ecuador has resulted in a claimed 100 cure rate within four days, according to Andreas Kalcker who is closely following the results of the effort. The tests were carried out by the Asociacion Ecuatoriana de Medicos Expertos en Medicina Integrativa, […]
via BREAKING: Researchers claim 100 percent covid-19 cure in 100+ patient trial in Ecuador, using intravenous chlorine dioxide — The Searchlight

By Anna Von Reitz

Your Government is supposed to be staffed by you.

It's decisions are supposed to be made by you. 

It's primary responsibility is to protect you and your property assets at all costs and all comers.  

That's why governments exist.

And that is the only reason for any government to exist, ever. 

But what if your government doesn't protect you?

What if, instead, your government preys upon you, threatens you, harasses you, and makes you miserable and fearful?

Then something is terribly wrong. 

Six generations of Americans have been preyed upon, threatened, and harassed by something posing as "their" government.

It isn't our government.

It's a substitute government run by two Federal subcontractors.

So these people are our employees, indirectly, but they are being told what to do by foreign governments controlled by foreign Principals: the Holy See, the British Monarch, and the Lord Mayor of London.   

Those foreign governments are under contract to provide us with certain enumerated "governmental services". 

They have been exercising "Delegated Powers" and operating "in our names".

They are supposed to operate under the limitations and in accordance with their employment contracts called the Constitutions. 

Instead, they've been colluding to evade their obligations under the Constitutions. 

And they've been misdirecting our Employees to racketeer against us and to misidentify our political status, to impersonate us, and to defraud us.

So instead of protecting us, these Hired Helpers have operated in Breach of Trust and harmed us. 

They've done exactly the opposite of what your government is supposed to do.

But do you notice something?  Do you see what's missing?

You are. 

You are supposed to be self-governing.  You are supposed to be running Your Government.

Not your Hirelings.

So, we noticed what was wrong a long time ago.  And we dusted off our laurels and we got to work.

And we talked to our friends and neighbors (those who would listen) and we explained what was wrong and we learned more as we went.… and, we organized the government we are supposed to have: Your Government. 

There's just one problem.  We are supporting it.  We are putting our time and money into it.  We are building it up and restoring it. We are doing our "job".

But where are you? 

If you want a government that protects you, a government that doesn't steal from you, harass you, threaten you, or harm you --- then, it's high time that you start backing Your Government and participating in it and supporting it with your money and your skills and your time. 

We are taking up collections for projects to advance the restoration of Your Government, to fund our Peacekeeping Officials and Officers, to run our State Assemblies, to make Your Government work the way Your Government is supposed to work --- a government to protect you and your family. 

When you come home to the land and soil that bore you, and start breathing as a free woman or man again, you will remember the American Dream and you will no longer bear the burdens of Federal (US) citizenship. 

You won't be subject to foreign statutory laws.

You won't worry about "Federal Agents" breaking down your doors.

You won't pay "Federal Income Taxes" anymore. 

You will have little or no reason to ever visit their courts. 

You will possess your homes and your land and soil as Freeholders -- not Tenants.

You won't pay any mortgages or utilities or property taxes.  

You will be in control your own lives again.

You will sleep sound in your beds again. 

Now think about that, and know that Your Government is what guarantees these results.  What's more important than what we have just described for you?  What greater profit can you realize by investing in anything else? 

 Go to: www.TheAmericanStatesAssembly.net and weigh in. 

We've made it simpler than ever to reclaim and regain your political identity as an American ---- so that you can come home and enjoy the protection of Your Government. 

And, if you can, send us a donation in support.  Think long and hard about the thousands that have been purloined from you to support foreign governments that have abused your trust ----and think about not having to pay those expenses anymore. 

Paypal: avannavon@gmail.com
Snail Mail:  Anna Maria Riezinger
                   Box 520994
                   Big Lake, Alaska 99652

We’ve uncovered the Great Fraud of the so-called American Civil War, which was never a war but an illegal commercial mercenary action on our shores. 

We’ve dissected the Great Fraud of the 1930’s executed by FDR and his minions.  And now, we need to face the Great Fraud of Today even as it is taking place.

The past few days have been rocked by disclosure after disclosure.  Smoking guns abound.  The extent of the travesty is now becoming clear — and along with it, the identities of those responsible and the nature of the current reality.

Out of Texas we have the Lufkin Case, where the subversion of our federal judicial system has been unearthed.  In 1991 the Congress entered a change in the Judicial Oath, altering the Oath required by the corporate Constitution in a subtle but devastating way which served to remove the judicial officers from the judicial branch of our government and place them solely under the control of the municipal legislative branch of government— that is, under the rule of the members of Congress acting as the oligarchic municipal government of the District of Columbia.

The new Oath of Office they imposed on the judicial officers may be seen at Volume 104 United States Statutes-at-Large Page 5124, otherwise shown as 104 Stat. 5124.

The new Oath of Office is very sly in that it appears to be a simple clean-up deletion of unnecessary verbiage in the old Oath of Office, but on closer examination it is clear that there are no “duties” assigned to member of the judiciary by the Constitution and as a result, this change in the Oath of Office releases the judicial officers from the obligation to “act agreeably” –that is, in conformance to the Constitution and leaves them subject only to the legislative acts of the Congress. 

This is in turn removed the judicial officers from the judicial branch of government and placed them squarely and only under the auspices of the legislative branch.

Read that— since 1991, there has been no three-branched federal government.

The judicial and legislative branches have been merged and the judicial has been made subservient to the legislative.  Moreover, the municipal government of the United States has been acting in open treason against the actual Constitution since 1991, and absolutely no decisions undertaken by these federal judicial officers since then have been in compliance with the actual Constitution. They are all null and void for cause.

This has made the widespread personage committed against the American states and people possible and profitable.  The Congress has been running the entire federal judiciary, which includes the “federated” — incorporated States of States and the STATES OF STATES courts — as an unconstitutional  legislative enforcement racket.

Our agreement with the “federal” government, which is nothing more than a for-hire governmental services corporation, very clearly states what we are owed and also very clearly sets up the structure of the government and also very clearly limits the jurisdiction of the federal courts and also very clearly requires an Oath of Office in support of the Constitution and also very clearly limits the reach of the municipal United States government to the ten miles square of Washington, DC and which also limits the territorial United States controlled by Congress to actual federal properties, such as arsenals and military installations.

So how have they run rampant like this and pretended, as in the Lufkin case, to have jurisdiction never granted to them over people and property in places like Tyler County, Texas?

It’s simple.  They unlawfully seized upon your copyright to your own name, registered it as properly belonging to their corporation, stole your identity as a living American, and pretended that you were either a Territorial Foreign Situs Trust or a Municipal ESTATE trust belonging to their corporations.  If you convert a man into a thing, you can do as you please to him—at least until he realizes what you have done.

In this way, they pretended to control you and own your assets, and therefore, also assumed the right to subject you to their in-house court system and their foreign statutory law.

Make no mistake, the authors of the bill changing the judicial Oath of Office committed treason against the actual United States and our actual Constitution and the evidence of this is clear upon the public record. 

What remains to be seen is if these snakes will self-correct or require a garden hoe to set things straight.

The Great Fraud of Today – Part Two:

Corporations Are Not Governments

During the 1990s alert financial analysts working for the Department of Defense discovered an odd thing.  Numbers weren’t adding up.  A vast amount of public money was being embezzled. As the members of what came to be known as “The Paradigm Project” dug deeper, something even more astonishing appeared. 

 Almost all of the governments on Earth were being run as private, for-profit governmental services corporations chartered under the auspices of the UNITED STATES, INC.
All these franchises named things like: FRANCE, ITALY, UNITED KINGDOM, AUSTRALIA, GERMANY, JAPAN, etc., were in turn being controlled by the UNITED STATES, INC. municipal government, an oligarchy run by members of Congress and originally limited to the “plenary” governance of the Washington, DC Municipality

So first shock– almost all the governments on Earth aren’t governments.  They are merely for-profit corporations in the business of providing government services.

Second shock —  these governmental services corporations are operated as franchises of the UNITED STATES, INC.

Third shock — the US Congress has been running all these governmental services corporations as if they were franchises owned and operated by the Washington DC Municipality, and under their “plenary” control as an oligarchy.

Now, stripping the onion another layer, the Paradigm Project discovered that not only had nearly all the traditional governments on earth been reduced to mere governmental services corporations owned and operated by the UNITED STATES, INC., but the states and people being served by these new corporations had been similarly unlawfully converted into corporate franchises. For example, Wisconsin had been reduced to a State of Wisconsin and then to a STATE OF WISCONSIN belonging to the UNITED STATES, INC.

Worst of all, living people had been reduced down to corporate entities.
An innocent American man operating under the Trade Name: Joseph Allen Smith, was reduced to a Foreign Situs Trust also named Joseph Allen Smith belonging to the State of Wisconsin: after that, Joseph Allen Smith (the Territorial Foreign Situs Trust)  was declared “missing, presumed lost at sea” and a Cestui Que Vie ESTATE trust doing business as “JOSEPH ALLEN SMITH” was created “in his name” as a franchise of the UNITED STATES, INC.

So, when the UNITED STATES, INC. goes bankrupt, what happens?
Why, all its franchises are “subsumed” into the bankruptcy.  The supposed governments of FRANCE and ITALY and GERMANY and so on, are sucked into the bankruptcy as franchises of the UNITED STATES, and so are the STATES OF STATES, like STATE OF WASHINGTON, but here’s where the Big Game lies — so are all the ESTATE trusts of the living people like JOSEPH ALLEN SMITH sucked into the bankruptcy of the UNITED STATES, INC. and considered chattel liable for its debts.

So when you hear that the UNITED STATES is “insolvent” you need to perk up your ears and pick up your pitchforks and move your butts to recoup your property out of the giant Slush Pile that the vermin have created for themselves via deceit and identity theft.

Fourth Shock: your entire earthly ESTATE is up for grabs as chattel backing the debts of the UNITED STATES, a for-profit governmental services corporation operated under the authority of the Washington DC Municipal Government run by the members of Congress.

Fifth Shock: you don’t know anything about this, because if you did, you would naturally object and that would spoil all their plans to steal your portion of everything and hand it over to their Secondary Creditors.

You are the Paramount Security Interest Holder in your name and estate. You are the Priority Creditor of the UNITED STATES and all its franchises, but they have purposefully misidentified you as a “missing person” and “ward” dependent on the UNITED STATES, so as to lay claim to your property as collateral backing their own debts.

According to their plan, YOU will be bankrupted along with all the other franchises of the UNITED STATES and your assets will be given to their Secondary Creditors, international banks that will make a “claim on abandonment” saying that the actual owners of the property are “unknown” and that the “property has been abandoned”.

Meanwhile, the Paradigm Project did the obvious thing, and foreclosed on these illegal entities masquerading as governments.  They also traced them back to the Vatican acting as Property Manager and to the Holy See, which together with our lawful government (not the corporation) and a handful of other governments on Earth, remains unincorporated.

Sixth Shock: corporations cannot and do not function as sovereign governments. 

If you are not operating your lawful unincorporated government, you have no government and no “state” to speak for you or save your bacon in international jurisdiction.
From all the foregoing, it is apparent that after the Second World War, the world governments colluded and/or were forced into agreements to operate in this fashion  It is also obvious that most of the people on Earth are in fact “stateless” until and unless they act to restore their own lawful government on the land jurisdiction, most of which have been inactive since the 1930’s.
So, time to rise and shine!  Daylight in the swamps!

The Great Fraud of Today, Part Three: Redemption

The good news for the Americans and for all people worldwide, is that the fraud was caught and the objections have been made by the unincorporated government — the actual government — of the United States.   We’re still here, still on guard, and at this point we have our fangs sunk deep into the buttocks of the perpetrators of this gigantic HOAX.

On June 29, 2017, in the eleventh hour of the Eleventh Hour, we posted the following “Judicial Notice of Claim” via email to Judge Thomas Hogan and Judge Royce Lamberth and The United States District Court for the District of Columbia:

“The American states and people that are the Paramount Security Interest Holders in all assets and collateral both registered and unregistered belonging to or claimed by or overseen by the District of Columbia Municipal Corporation, its heirs, franchises, or assigns including but not limited to the UNITED STATES, the USA, E PLURIBUS UNUM THE UNITED STATES OF AMERICA, the various STATE OF STATE franchises and Territorial State of State franchises– have been found, alive and well, and right where they ought to be.

It has come to our attention that our claims to our own land and assets have not been brought forward by our employees and so we have come to present ourselves to the court and to claim back our property which has been mis-represented as belonging to Cestui Que Vie Estate Trusts.

We are of a completely different jurisdiction and character and political status as peaceful American “vessels” engaged in International Trade, permanently domiciled on the land and soil of the organic states, and we require that our assets be returned to us and held harmless from any claim of debt related to the District of Columbia Municipal Corporation, its franchises, heirs, or assigns.

The Titles held against these bankrupt municipal corporate entities dba via ACCOUNTS designated by what appear to be names in the form: JOHN MICHAEL DOE and the corresponding territorial Foreign Situs Trusts dba John Michael Doe are hereby redeemed and reclaimed, re-conveyed and re-venued by the lawful owners to their natural jurisdiction on the land and soil of the organic states of the Union.

All titles held under color of law and subjected to both probate and bankruptcy proceedings under false pretenses must be returned to the lawful owners of record no later than July 4, 2017 by action releasing them from any further presumption of municipal or territorial citizenship absent actual proof of:

(1) a properly executed Death Certificate with a plainly stated title of “Death Certificate” stating the time, place, and manner of death signed off on by a competent coroner;

(2) proof of actual paid employment by the municipal or territorial government, including position, supervisor, hours worked, job assignments, place of employment, departmental affiliation, and other details establishing actual, true employment by a federal municipal or territorial entity;

(3) proof of voluntary “personhood” together with stated proof of intent and full disclosure as required by Public Law;

(4) proof of colored person status established by DNA analysis accompanied by a voluntary waiver of equal civil rights provisions;

(5) proof of political asylum or voluntary seeking of federal benefits under conditions of full disclosure.

The United States District Court for the District of Columbia, by and through Judge Thomas Hogan has been given prior Notice of the living status of the American states dba Alabama State, Alaska State, et alia, and of the American people who have returned en masse to the land and soil of their birth.  Copies of the Notice given have been and are being again presented to the Office of the Prosecutor at the World Court, along with a written and signed copy of this Judicial Notice of Claim, and will also be presented to the Pope, Queen Elizabeth II, and published for the world at large.”

This claim was issued and sealed under the lawful court seal of the Third Postal District of Alaska and recorded in Recording District 311, Palmer, Alaska, also on June 29th, as recording number 2017-012486-0.

What this basically tells the Judges and the Court responsible for the bankruptcy liquidation of the UNITED STATES, INC. and the Chapter 11 reorganization of the USA, INC. is that the Priority Creditors who were “missing, presumed dead” have been found and are alive and well and “returned” to their natural and permanent domicile on the land of the actual states.  We have reclaimed, redeemed, re-venued, and re-conveyed our Names/NAMES out of the bankruptcy Slush Piles.

What does this mean?
It means that the actual lawful government of the United States is still in place, still operating, and still competent to represent your interests. You are not “stateless”.   It means that instead of all those Secondary Creditors swarming in and feasting on you and your assets, they will have to give ground to the actual Priority Creditors and will not be able to make any noxious claim on abandonment.

It also means that if they continue to make any claims at all on Americans, they will have to prove those claims are valid with hard evidence.

Now, what about the rest of the world? 
 The clock is ticking.  ANGELA MERKEL can’t help you  PRIME MINISTER MAY can’t help you.  Even VLADIMIR PUTIN can’t help you, and neither could DONALD TRUMP.   They are all DEBTORS occupying corporate offices that prevent them from taking action in your behalf.

You are going to have to turn off the Boob Tube, alert your neighbors, assemble your traditional “people governments” and serve your own claims. 

Otherwise, everything will get scooped up and rolled over into the OPPT-— a universal trust and de facto “one world government” owned and operated by the Secondary Creditors.

It should be observed that the Latin root-word giving rise to the word “trust” is “trucido” which is a verb meaning to slaughter, to kill wantonly, to murder. 

And that is in effect what those responsible for this Mess have attempted to do to billions of people— to reduce them down to mere “things”—and dispose of them and their assets however the perpetrators of this vast criminal scheme might see fit. 

They have committed a paper genocide affecting billions of us, and they have tried to consolidate the paperwork and pull off the theft of the entire world via fake probate claims and equally fake bankruptcy claims to be followed by claims on abandonment.

They test drove this scheme in the 1930’s and now, they were caught red-handed, trying an updated and even worse version of the Great Fraud. 

Then, they merely stole your money and placed false titles on your land. 
Now, they meant to finish the job—-and you—-and take it all.

Time to return the favor.  The Americans have been redeemed and the Americans are the Paramount Security Interest Holders in the UNITED STATES, which means that we are also the Paramount Security Interest Holders in all the franchises of the UNITED STATES and the USA and E PLURIBUS UNUM, too.

Title, Lien, and Bond – Serve Your Own Claim

Go to my website http://annavonreitz.com
#560, #607, #620 [links below] and those three articles lay out the entire process both for your personal redemption and your land protection.
Please note that anyone can do the Corrected Deed process.
Anyone can claim protection for their land under the Private Registered Indemnity Bond for their state of the union.
The Corrected Deed process can be done right now, whether or not you have completed the process to free yourself from citizenship presumptions, because the indemnity is for your state of the union.

Later, when you get your own political status cleaned up and you are officially “back on the land” you can use the Private Registered Indemnity Bond as I described for Lucretia.

READ more at http://annavonreitz.com/titlelienbond.pdf
#560 How to Correct Your Political Status and Why
http://annavonreitz.com/correctyourpoliticalstatus.pdf
#607 Dear Lucretia — Mortgage Relief — and The Rest of the Story
http://annavonreitz.com/mortgagerelief.pdf 
#620 Pay Attention! — If You Want to Save Your Butts!
http://annavonreitz.com/privateindemnitybond.pdf 

We Delivered. And Now We Need Your Help 
http://annavonreitz.com/wedelivered.pdf
Help end projected power of false authority … share widely. Thank you

Source Able Danger

Ed.’s note: What the bankers did through their private networks inside mystery schools and secret societies, was to develop dialectical materialism (an “ism” is a toxic ideology) separating the two hemispheres of the brain in order to circumvent the two hemispheres from “comparing notes.” The banking oligarchy-constructed “left channel” versus the oligarchy-constructed “right-channel”; both channels invented and maintained to conceptually stifle the renting/”goy” peasant slave class.
This way the renting/”goy” peasant slave class “protesting” their objections in the streets getting sprayed with water canons after taking out their frustrations on the police, choose their approved red or blue puppet and followed the moving hand of banker oligarch-created deception. And this deception goes on generation after generation…
Insider Bared Banker Conspiracy in KGB Interrogation (1938)
Break up the Democratic Party
Is this Penn Sate professor correct? He says the Constitution will be replaced with social credit driven by A.I. scores:
Penn State Prof: Social Credit Will Shift Law in the West “From Constitution… to Analytics and Algorithm”
Would readers like a good demo on how the renting/”goy” peasant slave class are kept in a permanent state of external fixation? It explains why very few people relatively speaking will participate in public discourse about the merits of the Constitution being replaced with an A.I.-driven score based on behavior to derive social credit. Watch this…
Lions vs Eagles Week 3 Highlights NFL 2019
________
Diabolical Thinking
Monday, September 23, 2019 | By Anna Von Reitz
Satan rules the world, they say. The Bible makes it clear that at the time of Jesus, he was already ruling the world. He doesn’t rule the Earth— just the world. So what is the world? 
The world is all the mental constructs and associated behavior that takes place. It’s the things that don’t actually exist, like corporations, foundations, trusts, cooperatives, LLC’s, pension funds, fraternities, etc., which are just built of ideas and labels and names, agreements, and “business structures”, patents and copyrights and trademarks, generally accepted accounting procedures, banking and securities laws, treaties, doctrines, dogmas, accords, conventions, conferences, and so on. 
Now that you are squarely looking at it, does it disturb you to know that Satan’s Kingdom is built of nothing but words and ideas? 
And does this now explain the need to examine your thinking? 
Thoughts are built of words. Emotions are built of thoughts. Emotions and thoughts together build actions. Actions build the world. 
But how can you build rightly, if any of the precursors are faulty? 
If you use the wrong words, or the words can be interpreted in various ways, your thoughts can go sideways. 
If your thoughts are not built on a solid understanding, your emotions have nothing to rely on and can easily be completely inappropriate. 
And with wrong thinking (wrong assumptions) and wrong emotions resulting from wrong thinking, it is all but inevitable that you will take wrong actions, too. 
We recently had an example of that in our own family. My two daughters-in-law got into a horrible cat fight over a complete misunderstanding. One said something and the other “took it wrong”. This happens all the time, and we all know that it happens, but once equilibrium is restored, we don’t take time to examine this phenomenon. 
We don’t care enough about how it happens, to examine it, so we never catch on to how this same process is utilized by Satan. 
The foundation of Satan’s kingdom is diabolical thinking which is based on the equally diabolic misuse of words. 
Deceitful words and ideas are part of the rebellion against the True God, who is the personification and embodiment of Truth. 
In the beginning, was the Word…. and in the beginning, each word had a specific function and meaning, there was one language, and everyone knew precisely what every communication meant. 
But something happened in Babylon…. words began to take on a life of their own, the meanings of words began to change and shift, and the content of thoughts sparked by words also began to change and shift and become uncertain. This, then, affected emotions and actions, too. 
More kinds of words were added to language and these “modifiers” — adjectives and adverbs — layered on more layers of possible, but increasingly uncertain meaning. 
What appears red to me, may appear green to you. 
What is “up” with relationship to me, may be “down” with relationship to you. 
So the effort to make our language more precise and meaningful at the same time caused it to be more debate-able. This is where lawyers have their stock and trade, sorting through the misunderstandings and deceits and double-entendres that lurk in business and social agreements of all kinds. 
When a bank advertises “home loans” are they offering to loan you money to build a home, or are they soliciting to borrow your home as an asset for their use? 
When you realize that the common mortgage process consists of: (1) you paying for the house; (2) conveying your own property into a trust; (3) giving the bank control of that trust; (4) which they then abuse for their own advantages…. it becomes clear that “home loans” doesn’t mean what you were led to suppose. 
The phrase was used as a “term of art” — it took on a special meaning, quite different than any common use, and nobody told you. This is Satan’s Kingdom at work. You were misled to interpret “home loans” as an offer to loan you money for a home, when in fact, it is a solicitation for you to loan your home to the bank. The exact opposite. 
The same thing happened when a group of people calling themselves the United States [Territorial] Congress “forgot” to tell you that they were acting in a “Territorial Capacity” and changed the meaning of the word “person” to mean “corporation” without telling you. 
Double score! Two deceits for the price of one! 
First, you were misled to think that they were operating as our State Delegates, and then, whenever they said “person” it suddenly meant “corporation”.  
And again, the new meaning is exactly the opposite of the old meaning. 
“Person” used to refer to you acting in your Lawful Capacity as a tradesmen or merchant or businessman of some kind, but this group of men suddenly upended that meaning of the word, and from then on, when they said “person” it meant “corporation”. 
Thus, when you see the words “personal bank account” you naturally continue to think of it as your own private property, your bank account, but when these Masters of Deception say or write the same exact words, it translates as “corporate bank account”. 
What corporation? 
Well, they provided for that, too, by stealing your identity and unlawfully converting your Trade Name (also known as a Given Name) into the name of a corporation franchise conveniently owned and operated by them. 
We are seeing this in the whole debate about “global warming”, too. There’s no scientific basis to think that carbon dioxide caused by human activity (or cow farts) is causing changes to the climate. 
This deceit, this wrong idea, has gained ground– and now we have hysterical women standing on street corners shouting like Hellfire Preachers, telling innocent people that if they don’t stop using fossil fuels “the Earth will die in eleven years!” 
This is like the hysteria caused by the publication of “The Population Bomb“. This book claimed to “prove mathematically” that population growth would “kill” the world by the late 1980’s if we didn’t all reduce ourselves to eating dirt right now. 
The 1980’s came and went and only the abject True Believers (who were not mathematicians or they wouldn’t have bought this crappola in the first place) continue to buy the ugly fantasy of the “mathematically certain” destruction of the planet because we are having babies. 
Neutering yourself for the cause proved less popular than boycotting oil products, thank the True God. 
A more “sophisticated” man or woman (not a compliment) can easily see that: (1) both these hysteria responses were promoted by false information causing wrong ideas which caused wrong emotions and wrong actions; (2) this progression of errors is being used to promote political and economic agendas designed to control and tax people. 
Nothing more. Satan’s Kingdom at work. Get the rubes to cling to their own chains. Get them to believe a false narrative that lets us tax and regulate them more, with their own agreement and consent. 
This is what I call “diabolical thinking”—- and it is the actual means by which “Satan” —or at least his Devotees— use to lie their way to success. 
It’s up to the rest of us to become such critical thinkers, such skeptics, and so true-hearted, that we are bullet-proof against this. 
Many people were startled by my statement exposing Barack Obama as a British Corporate Jock, not a Communist at all. How could I deduce that? 
It’s simple. These people always pretend to be their own target. 
This deflects attention away from what they are actually doing, causes others to have false assumptions about them and their motivations, allows them to blame their own bad behavior on their enemies, and, last, but not least, their agent gets to infiltrate the social group they are targeting. 
So if Barack Obama pretends to be a pro-black, liberal, Communist, you can be sure that he is an elitist, racist, British Agent — the exact opposite of what he pretends to be. 
This is how these people think and how they operate. Black is white and white is black, the common man is an elitist, the progressive is a Luddite, a person is a corporation, and a “home loan” involves you loaning your home (and credit) to a bank for the bank’s profit, entirely and wholly at your expense. 
At every step, you are deliberately misled and your thinking, emotions, and actions are manipulated– by deceitful use of words and phrases, by deliberately promoted false ideas and false assumptions, and then it is all kicked into action.  
It’s like using electrical shocks on a mouse in a maze to “induce” the behavior you want from the mouse. 
Want a war in Iraq? Produce some false evidence, spread a bunch of lies using the lapdog media, promote wrong ideas and assumptions, get people all pumped up, and they will reliably take whatever wrong action you want them to take. 
In such a manipulated and manipulative environment, free thinking and logical deduction are even being discouraged in the scientific community. Facts and truth might interfere with self-interested commercial and political agendas. 
This is why you must examine not only your own logic circuits, but learn how these people use verbal deceit to promote wrong actions that benefit them. 
The Pilgrim Fathers called attorneys “Masters of Deceit”, because they make their livings alternately promoting and unraveling exactly these kinds of deceits— but it’s not just attorneys steeped in this crappola. Increasingly, the corporations posing as legitimate governments— that got into their position by deceit, are using more deceit to stay in power. 
This is why ex-CIA Chief Michael Hayden spoke so glowingly about “Post-Truth America”. He wasn’t, as many people assumed, indicating any future event in which the actual Truth would be told to the American Populace. He was talking about a world completely built on lies, ruled by exactly these kinds of deceits and manipulations. He was gloating about it. He thinks its a good thing, because it allows him and people like him, to rule over good people. 
It allows him and those like him to murder, steal, corrupt, use and abuse good people, and they think we are too stupid to catch on, ever, because generations of Americans have trusted what they thought of as their government and never figured out that they have been the victims of a hostile corporate take-over, and all but overcome, by these banal deceits. 
But, Satan lost the bet a long time ago. His Kingdom is forfeit. And we are here to collect. Be of good cheer. One candle lights a lot of darkness, and the Truth is a sword.  
________
Ed.’s note: It is time to get serious:
Constitutional
Enforcement
Seminar
by
Anna Von Reitz
Publication Notice
This entire compilation is the work of Anna Von Reitz, Copyright © 2019
Anna Maria Riezinger, 7FFE22358c/o Box 520994
Big Lake Alaska 99652
Constitutional Enforcement Seminar Part – 1
This material is being provided for attendees from all military, police, and peacekeeping forces ahead of the Seminar so you can study up and have your questions ready.
__________________ Our Government (The Way It’s Supposed to Be)
You — the Unique Man or Woman — The Source of all Powers
One of the people — Your Christian Name — Your County — Local Government — County Sheriff in Control of Soil (National Jurisdiction) — your republican state (all the counties together) — The Union doing business as
The United States
One of the People — Your Lawful Person/Trade Name — Your State — Maine, for example — Your Governor in Control of Land and Undelegated Sea (International Jurisdiction) — 
The Federation of States doing business as
The United States of America
__________________
Your Legal Person/Trade Name — Your Federal State of States — The State of Maine, for example — The United States Congressional Delegation in control of Delegated Powers — The United States in Congress Assembled — The Confederation of States (of States) doing business as the
States of America
Subcontractor — British Territorial Authorities — Territorial Government — Managing Federal Territories, Insular States, and Joint Naval Operations — Delegated Powers in the International Jurisdiction of the Sea — United States Congress — doing business as
“the” United States of America
Subcontractor — Municipal Authorities — Civil Government — Managing the District of Columbia/Washington, DC — Delegated Global Powers — Municipal Services like the Postal Service and Patent Office — UNITED STATES CONGRESS — doing business as “the” United States.
____________
***
Some of you may remember when The United States Federal Marshals wore brown uniforms. Now you know why. They are International Land Jurisdiction Officers, directly employed by The United States of America — our Federation of States.
United States Marshals wore blue because they are International Sea Jurisdiction Officers and were originally employed by the Confederation — the States of America.
****
You will immediately notice two (2) things: Local Governments, the Counties dba The United States, and State Governments dba The United States of America, respectively control theNational Soil Jurisdiction and the International Land Jurisdiction belonging to the States.
The Federal Government has nothing to do with land or soil in this country, except that the British Territorial Government is responsible for managing our Territories, Possessions, and Insular “States” like Guam.
The Federal Government functions entirely in foreign jurisdictions and is under service contracts known as Constitutions which allow them to exercise certain Delegated Powers in our behalf.
In the 1700’s, “federal” was a synonym for “contract” — so the Federal Government is aContract Government. It is under contract to serve the States and People in specific, limited, and enumerated capacities. The States, in return, are under contract to pay for these services as stipulated.
Our Government (The Way It Was After the Civil War)
You — the Unique Man or Woman — The Source of all Powers
One of the people — Your Christian Name — Your County — Local Government — County Sheriff in Control of Soil (National Jurisdiction) — your republican state (all the counties together) — The Union doing business as The United States
One of the People — Your Lawful Person/Trade Name — Your State — Maine, for example — Your Governor in Control of Land and Undelegated Sea (International Jurisdiction) — The Federation of States doing business as
The United States of America
____________
States of America — Under Reconstruction. The Federal States of States — Under Reconstruction, later mothballed as State Trusts doing business as Oregon State [Land Trust], etc.
Subcontractor — British Territorial Authorities — Territorial Government — Managing Federal Territories, Insular States, and Joint Naval Operations — Delegated Powers in the International Jurisdiction of the Sea — United States Congress — doing business as “the” United States of America.
Subcontractor — Municipal Authorities — Civil Government — Managing the District of Columbia/Washington, DC — Delegated Global Powers — Municipal Services like the Postal Service and Patent Office — UNITED STATES CONGRESS — doing business as “the” United States.
____________
As you can see, our portion of the Federal Government is incapacitated, “under Reconstruction”. Reconstructing it would have been an easy matter if the American Populace had been properly informed, but they were not given correct information, so didn’t take the appropriate action.
Please go here to Constitutional Enforcement Seminar to begin your journey and struggle out of “Babylon.”

NOTICE OF ACCEPTANCE FOR VALUE
STRAWMAN’S NAME
LOCATION
CITY, STATE, [ZIP]
Date ——-
ATTN CFO
[CFO’S NAME]
[ADDRESS of Corp. Headquarters]
NOTICE OF ACCEPTANCE FOR VALUE
Dear [CFO’S NAME]
“I accept the attached charge for value and return it for value discharged per supersedeas insurance-policy-bond HJR 192 of 1933 and UCC 10-104 and 1-104 which is my congressionally designated right.”
The corporate United States created a tacit mortgage on my private property without my knowledge or consent and is using it as collateral for loans of credit and money substitutes from the non-federal Federal Reserve Bank.
Under the laws of equity, The United States cannot take private property for public use without just compensation, and put it at risk as collateral for loans from the non-federal Federal Reserve Bank without providing an Equitable Remedy for the recovery of what is due me as accrued interest for the risk of my assets and wealth.
The provisions of this Remedy are found in congressional Public Policy HJR 192 of 1933 a.k.a Public Law 73-10 that suspended the gold standard and exempts people from paying their debts since their means of paying their debts was taken away from them and replaced with money substitutes that discharge debts instead of paying them.
Public Insurance Policy HJR 192 of 1933 is a supersedeas bond that provides a Remedy for victims of President Roosevelt’s crimes of fraud, unlawful conversion, and treason, and for both Houses of Congress’ complicity in these crimes. This unlawful conversion of credit created the exemption upon which debt write-off and discharge is based, due to the 1933 Bankruptcy Reorganization of the Corporate United States — to exempt Congress from charges of treason and to indemnify me for any loss.
Your Invoice is a negative charge to the debtor — my ens legis (government-created) strawman, — but a positive charge to me as a Secured Party Creditor of the Corporate United States.
Everything in commerce under the UCC is reversed. A bill to my debtor strawman is an offer of his accepted credit to me as a Secured Party Creditor of the corporate United States.
I am therefore accepting his offer of credit for its value and returning it to you for its value as a mutual offset credit exemption exchange (MOCEE) to settle this charge on his account.
My endorsement of this presentment transforms it into a Promissory Note that discharges the charge with a mutual offset credit exemption exchange (MOCEE) per insurance-policy-bond HJR 192 of 1933.
A bill is a demand for payment in “lawful money of account of the United States” postponed to when such “lawful money of account of the United States” is restored to use.
When Uncle Sam prints a $20 dollar bill that bill must be paid upon demand by the corporate United States.
Therefore Secured Party Creditors of the corporate United States can tender a mutual offset credit exemption exchange (MOCEE) to fulfill this obligation to pay — with his personal private credit.
By accepting dollar bills in lieu of money we loan our personal credit to Uncle Sam and we are to be paid back corresponding “dollar for dollar” portions of our personal private credit when we require it; on demand.
You have my Acceptance and corresponding Promissory Note and can present it to the Secretary of the Treasury of the United States, via the IRS or any Federal Reserve Bank — or as a deduction of credit to the IRS — for US Credit Redemption in lieu of “lawful money of account of the United States.”
Accrual income can be immediately added as an asset to an existing account because accrual income is accountable as soon as it is tendered and received, instead of when collected.
When a Secured Party Creditor of the corporate United States who has no real money, subscribes to or purchases something of necessity, that he needs, his mutual offset credit exemption exchange (MOCEE) can be used to discharge his “obligation to pay”, in lieu of Federal Reserve Notes, since there is no substance backed money with which to pay.
The United States has a priority obligation to the Secured Party Creditors of the corporate United States and a secondary obligation to the non-federal Federal Reserve Bank, for the federal corporate United States’s obligation regarding its use of currency and Federal Reserve Notes.
Commercial Redemption is a legal administrative Remedy provided by both Houses of Congress on June 5, 1933, by House Joint Resolution 192 to exempt Congress from charges of treason — it’s their law, not mine.
The Collective Entity Rule makes a clear distinction between a natural person created by “God” (or “Providence” if you prefer) and the fictional person created by the state (the ens legis strawman, corporation-of-one).
The Collective Entity Rule was first articulated in Hale v. Hale, 201 US 43, 26 S.Ct. 370, 50 L.Ed. 652.
“The innocent individual who is harmed by an abuse of governmental authority is assured that he will be compensated for his injury.” — Owen.
This is strictly an administrative-contract remedy, we are not tendering payment.
There is no money to pay for anything. Contracts are already in place in the background of the state. We are simply accepting the credits they have established and are authorizing you to set-off the debt with said credits.
There is no evidence refuting the statements made in this NOTICE OF ACCEPTANCE FOR VALUE, and the undersigned believes that no such refutation exists.
If you wish to dispute this NOTICE OF INFORMATION, do not hesitate to timely reply within the next two weeks.
In witness whereof, I set my hand and seal certifying on penalties of perjury that all the statements made above are true, correct, and complete
Very truly yours, John Henry Doe, Secured Party Creditor

Source

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Rights without the know-how to enforce them are just empty promises for anyone but the filthy rich!
They are like carrots on a stick, encouraging us to be good little boys and girls, working hard and buying things to keep the economy going for the benefit of the well-to-do who can afford lawyers to fight for them!
You've been lied to long enough!
Read Luke 11:52 in your Bible to discover how long the wool has been pulled over the public's eyes by lawyers who've been running the world far too long by purposely keeping you in the dark so lawyers can get rich at your expense!
Your blindfold is coming off!
The legal profession cannot hide your #1 Right any longer!
Your #1 Right is easy-to-learn!

People complain their "rights" are being taken away.

A few are ready to fight-and-die to protect our "rights".
But only a few know their #1 Right!
In fact, the main reason we're losing so many rights these days is because too few of you know your #1 Right!

What is this "right" too few of you know?
It is your right to know how to enforce your rights!
Government isn't telling you!
Your tax-supported schools aren't teaching you.
The legal profession is doing a bang up job hiding it from you!
An old adage says, "Ignorance of the law is no excuse," yet neither government nor the legal profession has at any time in the history of the world made any genuine effort to teach the public how justice is secured in courts. Nothing about the rules of evidence. Nothing about the rules of procedure. Nothing about how to use the rules to get Justice! Nothing!
Your rights are nothing but empty promises if you don't know how (or can't afford a lawyer) to enforce them!
Think about it!
Without your #1 Right (or tens of thousands of dollars to pay lawyers) what good are all those "rights" your government promises you?
If you don't know how to enforce your rights, do you really have any?
Think carefully!
Rights without the know-how to enforce them are just empty promises for anyone but the filthy rich!
They are like carrots on a stick, encouraging us to be good little boys and girls, working hard and buying things to keep the economy going for the benefit of the well-to-do who can afford lawyers to fight for them!
You've been lied to long enough!
Read Luke 11:52 in your Bible to discover how long the wool has been pulled over the public's eyes by lawyers who've been running the world far too long by purposely keeping you in the dark so lawyers can get rich at your expense!
Your blindfold is coming off!
The legal profession cannot hide your #1 Right any longer!
Your #1 Right is easy-to-learn!

We have grown to accept the limitations, deliberate or otherwise, of the healthcare industry that is ever growing in size and its services getting more expensive by the day, the quality of services rendered continually suffers from the absence of real scientific approach, e.g. its constant use of toxic chemicals.
There seems to be a well-coordinated suppression against relevant discoveries that could have ended the use of biochemical protocols many decades ago, yet what we have is the state mandated mass inoculations that have already killed hundreds in 2017 alone.

Evidence is the "stuff" that wins cases.
Do you know how to find it?
One way is with interrogatories.
Interrogatories are written questions others must answer under oath ... or go to jail!
For example, one interrogatory I serve on opponents reads, "Identify all persons having first-hand knowledge of any material fact alleged in the pleadings of this case and, with regard to each such person, state what they know about each such fact and how they came to know it."

No matter who tries to hide it!
Rule 26(b) Federal Rules of Civil Procedure provides, "Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense — including the existence, description, nature, custody, condition, and location of any documents or other tangible things and the identity and location of persons who know of any discoverable matter. For good cause, the court may order discovery of any matter relevant to the subject matter involved in the action."
Don't be left holding an empty evidence bag!
Use interrogatories.
Our "How to Win in Court" course shows how.

Requests for Admissions are cool tools.
A request for admissions is a list of facts your opponent is required to admit or deny within a set amount of time or have those things treated as admitted!
Requests for Admissions are POWERFUL!
If you know how to use them tactically.

They are like leading questions! They find evidence your opponent tries to hide!
They can turn your opponent inside-out!
Our "How to Win in Court" course shows how.

Use Requests for Admissions ... Learn More!

You won't be treated as a pro se (representing yourself in court without a lawyer) because you will know how to do things the right way, instead of stumbling with nonsense you learned from amateurs on the internet, nonsense that does not work!
Everything is based on the official rules of procedure and evidence you will use to defeat your opponents ... rules all judges are required to enforce!
State the facts you must prove.
Use discovery to prove your facts.
Move the court for judgment.
Winning really is this simple!
This course makes it easy!
(Includes Forms & Examples)

Control judges!

Defeat crooked lawyers!
Case-winning know-how!

Quick and easy to learn!
No lawyer? No problem!
Represent yourself!
One on one consultation is also available.
Have access to personal legal guidance with step by step help when you need it on request.
Why spend days in some dusty law library trying to figure it out on your own, or trusting amateurs who don't know mud from sand?
If you can't afford a lawyer, you must have this course!
This is the only course created by a veteran attorney who knows from experience how to overcome court corruption.
Good people should never lose in court!
Justice is your God-given right!
Do not go to court without taking this course.
This will save you vasts amounts of money, grief and legal hassles.
Knowledge is Power!

Use my case-winning procedures with confidence.

Based on 33 years of winning for clients using the same legal forms, evidence tactics, case-winning procedures, and effective strategies explained here in "everyday language".
Instant access as soon as you order.
So easy anyone can learn in 24 hours!
Anyone!
That means YOU!
Learn More and Order!

Whether you're a plaintiff or defendant, you must know what smart defendants do to dodge lawsuits. If a defendant is served with a complaint, he may dodge the lawsuit by filing motions to avoid filing an Answer!
This is called the "flurry of motions".
Once a defendant files an Answer, he's locked in and misses this chance to dodge the lawsuit altogether.
Don't file an Answer if you can dodge the lawsuit with a "flurry of motions".
Inexperienced lawyers and pro se people make the mistake of filing an Answer to plaintiff's Complaint ... instead of using the flurry of motions.

• Motion to Dismiss
• Motion to Strike
  
• Motion for More Definite Statement

Each of these motions postpones the necessity of filing an Answer to the Complaint ... and gains you valuable time and evidence-gathering opportunities!
In some cases it puts an end to the case. Period!
Use your Flurry of Motions.
Our "How to Win in Court" course shows how.

by Taansen Fairmont
 
                Our hearts go out to the millions of Americans who are unnecessarily burdened with debt payments to institutions that issue Visas, MasterCard's, Discover cards, student loans, and other signature lines of credit.  The Liberty credit card and student loan debt elimination program legally cancels United States-based unsecured debts.  These include Visa, MasterCard, Discover, institutional credit card debt, student loans, and signature loans.  You can stop making payments on the debts immediately, and nullify them totally 100%, without bankruptcy, just by sending a series of letters.
                I knew one very nice senior citizen living on a fixed income who had about $43,000 in credit card debts.  She had maxed her cards out after her husband died, and she was being hounded by the so-called “creditors”.  Then from friends and family she learned that they are not creditors at all.  She used the Liberty Debt Elimination System to send a polite and professional dispute letter and affidavit, and she has not heard from the money lenders or their collection agents since.  In one case, they did persist with two more letters, and the Liberty system provided her with simple response letters to send, which only took a few minutes to prepare and mail.  This was in early 2010, and since then she has had no further contact from any of them.  She knows now, for a fact, that this is because they have been caught in their scam . . . and they would rather let it quietly go away than to litigate it and publicize it.
                Before all this happened, her lifestyle was declining.  She was less and less able to afford the right medicines, medical help, good clothing, car repairs, maintenance on her home, and especially vacations and spiritual retreats.  The debts were mounting up too much.  When she began the Liberty program, she stopped making all those payments immediately.  Then overnight she was able to begin affording better health, a better car, a better house, and greater peace of mind.  We have seen this story repeated in a thousand different ways thousands of times.  It is a really wonderful reversal of destinies for people.
                Many Liberty customers say this is the answer to their prayers.  Why negotiate, settle, modify, reduce, or consolidate, when you can outright CANCEL?  Go with what WORKS -- not mere theory.  This is one of the best things you can do to help the economy, because it withdraws support from the cartel.
                Liberty customers are protected by numerous laws, and a network of allies and professionals.  "Anyone who says it is impossible should not interrupt one who is actually doing it."
                The Liberty system has enjoyed a nearly 100% success rate since 2002, meaning no one who has followed the simple instructions completely and didn’t give up, has failed to have the debts vanish.       
                Using the Liberty system, I personally successfully cancelled over $50,000 of credit card debt involving seven cards -- Visas, MasterCards, and Discover, back in 2002.   I never had to go to court and I have not had a problem with them since.  The system has continued to work for my friends and family to this day.   So it has a proven track record now.
                This allows customers to legally and totally cancel Visa, MasterCard, Discover, American Express, student loan debts, and other unsecured lines of credit, without bankruptcy. It’s easy.  Anyone with access to a computer and Microsoft Word (or compatible) software can do it.   Just follow simple ABC instructions to put your name and personal information into three (3) powerful pages – and send them Registered Mail.  That’s it!   No attorneys needed. It’s quick – can be done in one hour.
                It’s inexpensive – just $450.  Most people spend that much or more in one or two months of debt payments.  When you realize you can, and should, stop making the payments on the debts you are cancelling with the Liberty system, right at the beginning of the process – the moment you purchase it, it is clear that the program pays for itself you are starting to pay yourself instead of the bankers.
               And, your purchase could effectively be free.   If you have $450 in credit on your card, you can take the purchase price from that, and then include that in the debt to be cancelled with the Liberty system.  (There is nothing unethical about this, as you can see in the FAQ on our website).
                Compare this $450 to programs costing $3000 and up. 
There are no other fees, and this covers an unlimited number of debts for one person for a lifetime. It has enjoyed a nearly 100% success rate.  This means basically everyone who has used this exact same system precisely as instructed, has had collection attempts by banks, lending institutions, law firms, collection agencies, and even courts, come to a halt.  The only people who failed were those who didn’t follow the instructions or who quit and gave up.  And the instructions are easy.  Basically, it just involves sending a letter Registered Mail approximately once a month for a few months until the collection efforts stop.  We provide the text of the letter.  You just fill in your name, account number, etc.
                The Liberty system is the best in America, as far as we know.  It has incorporated all the most effective techniques for debt cancellation discovered out there.  Since it has been practicing this every year since 2002, it has been continuing to augment, improve, upgrade, and become stronger.  New research is always pouring into it.  The market changes, but certain basic principles remain the same and are invincible.  The “pretender lenders” have no defense to certain allegations made in the Liberty letters, and so they remain undefeated to this day.
Question:             Ethically, I believe in paying my legitimate debts. If I have received real goods and services for the bills I ran up on my credit cards, then why is it ethical for me to not repay those debts?
Answer:               Because the money lenders were not the sources of those goods and services. The merchants who provided the goods and services were paid, but the money lenders produced nothing. Furthermore, the money lenders never loaned anything. No money ever came out of their accounts to issue your lines of credit. They pretended to make loans, when actually nothing was ever loaned. That is called fraud. That is why this Liberty debt cancelation system legally works. “La Vérité” means “the truth”.  We are simply confronting them with the truth, and they cannot deny it.
                We strongly recommend that everyone read the book The Creature from Jekyll Island, by G. Edward Griffin. It is available at Amazon.com. That book reveals the fascinating story of the creation of the Federal Reserve banking system, and how what the banks of today are “loaning” has never been true money, but rather just fictions created out of thin air, in a sophisticated strategy for the bankers to take over and enslave the world.
 
Question (related):          I would like to hear your response to the ethical  question of your system being based on the fact that the credit card issuer is being fraudulent, yet to buy your system you accept credit card payment online. If they are fraudulent then why are you accepting their form of payment for your system?
Answer:       The reason is because out of the three parties to the transaction, only one  of them is fraudulent. That is the so-called lender. You, the customer, are producing value with the hard earned money you are paying; and we, the merchant, are providing value with our hard earned product. It is ethical and sound thus far. We should be paid and you should receive good value, rightfully so. It is when the international crime syndicate called the money lenders insert themselves into the middle of the transaction and attempt to extort their cut, that we draw the line. No money came out of their accounts to issue the loan -- it was created out of thin air using the Mandrake Mechanism -- and no value came out of them either, in the way of goods or services.
                One could argue, well, they provide the medium of exchange -- i.e. the money,  and administer that system. If so, then the honest way to do it would be for them to charge a small nominal fee, such as 0.01% of every transaction worldwide, for maintaining the money system. That might be fair. It would be open, honest, transparently visible, and mutually agreed upon by everyone. But paying "back" 100% of the value of the transaction PLUS usurious interest, is nothing less than outright theft and extortion. It is a parasitic influence on the global economy and has destroyed countless lives.   That is wrong and must be stopped.
                We are not harming anyone or taking anything that isn't offered, by accepting credit cards to pay for our products. On the contrary, as sovereigns, we are exercising our God-given right to transact in commerce and provide our goods and services using whatever medium of exchange society has most agreed upon. The fact that a corrupt cabal has tried to insert itself as a fraudulent party to the transaction is the reason for our withdrawing our support from that behavior.
                For every American who implements this debt cancellation system, the economy is improved by that much.  This is because when you were making your payments to the money lenders, the people benefitting most from those payments at the top of the banking hierarchy know full well that they created the loans out of thin air, and never loaned anything.  So they’re getting trillions of dollars in free extortion money, tribute to their private offshore islands, underground cities, secret space programs, private armies, weapons and drug trafficking, war making, and other nefarious activities.  If you don’t believe this, read authoritative books like “Secrets of the Federal Reserve” by Eustace Mullin, or “The Creature from Jekyll Island” by G. Edward Griffin.  It’s well documented and there are hundreds of books, websites, and seminars revealing these facts.  There is really no controversy about it and it’s not really a secret . . . it’s just that the information hasn’t yet spread to everyone.  But the word is spreading more quickly now.
                When Liberty customers stop paying on these phony bogus debts, the economy is improved because money that was otherwise going to the international crime syndicate -- which they then use to hire armies of mercenaries to organize the banking and court systems against innocent people -- is money that is now going instead to one's own (presumably) harmless and life-supporting home living and household expenses, and perhaps education, spiritual practices, or health treatments creative and constructive projects. It is withdrawing money from what is harmful in the world and redirecting it to what is helpful. That is a most beautiful fulfillment of the purpose of ethics.
                Although it is a do-it-yourself system and has complete instructions, we also remain available for answering questions by email and phone.  People have been very happy with our customer service.
                Liberty is backed by a strong legal team who remain on standby for all customers in case assistance is needed.  In about 2% of cases, it is necessary to go to court.  Once again, 100% of the Liberty customers who have gone to court and who have faithfully used the assistance of our legal team and didn’t give up have won.  But around 98% of Liberty customers win without ever having to go to court.
               The Liberty system has even worked for people who have been sued by their credit card institutions.  They adapted the documents to the court case, and often the cases were dismissed without having to go to court.  In the very few cases where litigation followed, we have no failures.  At no further charge, we provide a zip file of powerful support documents; and, we refer these rare customers to rare lawyers who guide them to success.  They only charge a few hundred dollars – like $250 per court filing -- peanuts compared to the attorneys who charge thousands and then end up selling you down the river.  None of these customers has lost, if they followed our instructions and the lawyer’s guidelines completely and did not give up.
                The system continues to work today.  It is time tested.  It takes a few months for you to see that the pretender-lender collection attempts have definitely stopped, but they have always stopped.
               This system works far better and more consistently than commercial discharge or set off methods under the UCC, because the elite have tried to monopolize those methods for themselves, while stopping them from being honored for most people.
                We've been saying for years that the Liberty unsecured debt cancellation set has been enjoying a 100% success rate, for all those who applied it according to its instructions.   We have a list of evidences of this success on our Liberty page, from institutions like Chase, Transunion, Capital One, Citibank, and others.  For example, Transunion, the credit reporting agency, shows that the debt has been "deleted".  You can view these documents at our website under where it says “Proof That Debt Elimination Works”.
                In that section we even have one from the IRS, showing a bill for income tax owed due to the debt cancellation.  This kind of bill has been received by very few of our customers, and none of them have had to pay the income tax, because we have CPAs we refer our customers to, who can provide a legal filing category that changes the cancelled debt from “income” to a tax exempt status.  In addition to this good news, our Liberty customers now have the most absolute proof-in-writing possible -- from the Fed itself -- that the Liberty system works.
                Usually when we beat the pretender lenders, they just quietly slither away and never issue anything in writing confirming our victory, because they probably figure it would get duplicated and the word would spread far faster than it already is.  So the best we have been able to enjoy so far in this matter is their going silent and ceasing their collection efforts.  That alone has freed countless people from the tyranny of debt enslavement, so we can't complain.  But occasionally, it's nice to receive an actual written confirmation of the elimination of the debt.
                This doesn't mean that the same will happen for you, if you use the system.  More likely, your debt would just quietly go away and you would never receive anything in writing confirming it.  It's the old proverb, "no news is good news" -- meaning no more billing statements, no more collection letters, no more collection calls, and the debt has been written off. 
                The effectiveness of the Liberty system does not depend upon presenting mere philosophy to the banks.  While what they are doing may be unethical, we don't argue ethics.  The reason the Liberty system is effective is because it targets actual specific laws that they are breaking.  They cannot get around it and they cannot defeat this fact.  That's why people who have been sued have often had their cases dismissed when the Liberty documents were presented.
                In this respect, many are learning to stay away from debt reduction, negotiation, or consolidation.  They have found that it is far more expensive and stressful than cancelling the debt altogether, and in addition, it will continue harming the economy.  Why negotiate or consolidate when you can legally CANCEL, and HELP the economy at the same time?  And if you are truly honest and accurate - - how can you “reduce” or “negotiate” something that is nonexistent?  If a debt is a fraud, if it is bogus, then it is nonexistent.  Something that doesn’t exist cannot be reduced or negotiated or compromised or consolidated.  It can only be canceled - - meaning it can be acknowledged for what it always was - - a hoax.
                You may have questions that haven’t been answered here.  Please read our Frequently Asked Questions.  Yes, we are here for you - - we respond daily to email tickets submitted at our Help Desk via the Contact Us - - and we also respond to phone calls to the number at the top of our home page.  But first, we kindly ask you to please read the FAQs, to see if your question is already answered there.  Many thanks.  May you be fortunate and take the first step towards becoming debt-free!
 
Click here:  http://brillianceincommerce.com

Private law — the “law” of incorporated entities—is subservient to Public Law so the only people affected by this change are those who never committed any actual crime in the first place— just regulatory infractions like Thomas’s own trespass against the State of West Virginia, Inc.
The State of West Virginia, Inc’s “private law” considered his trespass a “felony”, but the Public Law could care less, so long as no blood is spilled and no property destroyed.
So their private corporate “law” was challenged by people owed the Public Law — that is, by people acting in their unincorporated capacity– and the rats had to admit the supremacy of the Public Law and had to release all these purported “felons” who were never their employees or dependents and who were never subject to their “private” corporate “law” in the first place.
That is good news. It means that the Perps are running scared and realizing that the Public Law is enforceable again. And why is that?
Because our State Jural Assemblies are booting up and they can see the train coming.
They have been operating under false pretenses for years and trampling everyone else’s rights and
subjecting everyone to their private corporate tribunals and holding everyone responsible for
obeying their private “code”.
Once the actual States rear their heads the jig is up for the incorporated “States of States” and they
know — thanks, by the way, to the efforts of The Living Law Firm–that the actual States and People are assembling. enforceable again.
And why is that?
Because our State Jural Assemblies are booting up and they can see the train coming.
They have been operating under false pretenses for years and trampling everyone else’s rights and subjecting everyone to their private corporate tribunals and holding everyone responsible for obeying their private “code”.
Grasp the fact that the private law is ALWAYS subservient to the Public Law when the Public Law is enforced. And that the Public Law is being enforced again as a result of the State Jural Assemblies taking place all over this country since 2015.
Because people took back their birthright political status and organized their State Jural Assemblies. That’s why the Public Law is back in effect. And that’s why the “private law” has to be brought back into compliance with the Public Law. The Public Law would not be beginning to be enforced again in this country without the State Jural
Assemblies being active again. And why are the People of the States “coming back home” and enforcing the Public Law they are owed, instead of mindlessly functioning in the “presumed” capacity of “Persons”? Because some of us worked tirelessly to expose the corporate fraud schemes and secure the Public Law again.
There are now fifty State Jural Assemblies, one for every State. And that for their own safety and the good of their country, they need to correct their own political
status records so that they are not “mistaken on purpose” for British Territorial Citizens or Municipal Government employees.
It’s the political status correction paperwork that is protecting the people from the corporate thugs and giving standing to the Members of the State Jural Assemblies and it is the State Jural Assemblies that are giving life and force to the Public and Organic Law owed to the people of this country. And it is these changes that are forcing the corporations to come to heel.
Why?
Because as long as the Public Law is being enforced, private law is always subservient to it.  If you want to be able to invoke and enforce your constitutional guarantees– do your status correction paperwork and join your State Jural Assembly.
http://www.annavonreitz.com/
New Streamlined Process
One Page Declaration — The 1779 Naturalization Act
https://tasa.americanstatenationals.org/correct-your-status/
928. Basic Package of Editable Forms - How To Correct Your Political Status  http://annavonreitz.com/basicforms.pdf