Case 1:21-Cv-00894 Document 1 Filed 08/03/21 Page 1 of 45 Pageid# 1
Case 1:21-cv-00894 Document 1 Filed 08/03/21 Page 1 of 45 PageID# 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA PROFESSOR TODD ZYWICKI, ) ) Plaintiff, ) ) v. ) ) CIVIL ACTION NO.____________ GREGORY WASHINGTON, ) in his official capacity as PrEsidEnt of ) COMPLAINT FOR DECLARATORY GEorGE Mason University; JAMES W. ) JUDGMENT AND INJUNCTIVE HAZEL, in his official capacity as REctor ) RELIEF of thE Board of Visitors; ) HORACE BLACKMAN, in his official ) JURY TRIAL DEMANDED capacity as VicE REctor of thE Board of ) Visitors; SIMMI BHULLER, in hEr ) official capacity as SEcrEtary of thE ) Board of Visitors; DAVID FARRIS, in ) his official capacity as Executive DirEctor, ) Safety and EmerGEncy Management; ) JULIE ZOBEL, in hEr official capacity as ) Assistant VicE PrEsidEnt of Safety, ) EmerGEncy, and EnterprisE Risk ) Management; and ANJAN ) CHIMALADINNE, JUAN CARLOS ) ITURREGUI, MEHMOOD KAZMI, ) WENDY MARQUEZ, IGNACIA S. ) MORENO, CAROLYN MOSS, ) DOLLY OBEROI, JON PETERSON, ) NANCY GIBSON PROWITT, PAUL ) J. REAGAN, EDWARD J. RICE, ) DENISE TURNER ROTH, and BOB ) WITECK, in thEir official capacitiEs ) as MEmbErs of thE Board of Visitors, ) ) Defendants. ) Case 1:21-cv-00894 Document 1 Filed 08/03/21 Page 2 of 45 PageID# 2 Plaintiff Todd ZywiCki, by and through his attorneys at the New Civil Liberties Alliance, hereby Complains and alleges the following: INTRODUCTORY STATEMENT a. By the spring of 2020, the novel Coronavirus SARS-CoV-2, whiCh Can Cause the disease COVID-19, had spread aCross the globe. Since then, and beCause of the federal government’s “Operation Warp Speed,” three separate Coronavirus vaCCines have been developed and approved more swiftly than any other vaCCine in our nation’s history.
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