I. NATURE OF THE CASE

1. This is a civil rights case brought by citizens of the United States of America, from different states across the Union, against the Defendants for, among other things, burdening the voting rights of 160 million people.

2. The Plaintiffs allege the following on behalf of themselves and others similarly situated against Defendants for damages, declaratory relief, and to enjoin them from further unconstitutional and unlawful acts, omissions, orders, agreements and certifications concerning the Plaintiffs’ rights of due process, equal protection, and to vote and speak freely.

3. Plaintiffs, as citizens of the United States of America (American Citizen(s)), bring this action to halt, and seek redress from the unconstitutional acts and omissions of the Defendants enforced pursuant to the Civil Rights Act, 42 U.S.C. §§ 1983, 1985, 1986 & 1988 (Civil Rights Act), and the Constitution of the United States of America.

4. At all material times, the Defendants engaged in concerted action to interfere with the 2020 presidential election through a coordinated effort to, among other things, change voting laws without legislative approval, use unreliable voting machines, alter votes through an illegitimate adjudication process, provide illegal methods of voting, count illegal votes, suppress the speech of opposing voices, disproportionally and privately fund only certain municipalities and counties, and other methods, all prohibited by the Constitution.

5. The Plaintiffs have been damaged and, unless the Defendants are enjoined, will continue to suffer the loss of their individual right to vote, freedom of speech, due process and equal protection under the laws and Constitution of the United States of America (Constitution).

CLICK HERE FOR LINK TO COURT FILING

CLICK HERE FOR THE ACTUAL LAWSUIT

Affidavit of Larry D. Cook 

State of California

Los Angeles County 

            I, Larry D Cook, being first duly sworn, do herby state, under oath, as follows: 

• My name is Larry D. Cook and I was born on November 23, 1964 in Bremerton, Washington.

• I have lived in Los Angeles, Los Angeles County, CA for over 15 years.

• I am a registered voter in Los Angeles County and have voted in most elections, including the 2020 Presidential election held on November 3^rd, 2020.

• During early 2015 California Senator Richard Pan and California Senator Ben Allen introduced SB 277, a vaccine mandate bill that would eliminate religious vaccine exemptions for children who attend public and private schools in California. [1]

• I vehemently oppose any and all governmental medical mandates on moral, scientific and health grounds and absolutely believe that the rights of the Individual – especially regarding legally forced medical intervention – outweigh any perceived or real “disease threat” to the Community at Large.

• I believe that every Person has the unalienable right to refuse any and all medical treatment and the right to remain unmolested by Government, Business, and other entities; that our bodies are Sovereign; that the sole responsibility for medical treatment and procedures rests within the autonomy of the Individual, or legal guardians when minors are involved.

• In early 2015, and in response to the potential egregious violation of Personal Sovereignty as outlined in CA SB277 – the CA vaccine mandate bill – I created a brand, STOP MANDATORY VACCINATION, to express my views and the views of experts, scientists, parents, medical professionals, activists and others to the Public at Large why we oppose mandatory vaccination (in all its iterations).

• My brand, Stop Mandatory Vaccination, included numerous properties including a website (StopMandatoryVaccination.com), a Facebook PAGE and a Facebook GROUP, as well as an email list, which were my primary properties. Facebook Pages “broadcast” to “followers” while Facebook Groups allow “members” to easily interact with each other based on shared or common interests.

• Through unique messaging, video interviews, vaccine injury and death stories, public health arguments against vaccine mandates, expert testimony, medical opinion and numerous other communications through my Stop Mandatory Vaccination website, Facebook PAGE, Facebook GROUP and email list, by the end of 2018 I had grown a formidable INFLUENCE which included over 125,000 followers and an average of 2 million reach on my Facebook Page per month, well over 150,000 members in my Facebook Group with a 1 million engagement per month, over 50,000 visits per month to my website and an email list of over 45,000 subscribers. I had also paid Facebook over $35,000 for advertising and had paid to “boost” posts to reach targeted audiences through my Facebook Page. For the most part, up to this point, my messaging was not censored.
• In 2016 I voted for Donald J Trump to be President for two primary reasons: 1) He was on the Republican ticket and Republicans have by and large voted AGAINST vaccine mandates (while Democrats have primarily voted FOR vaccine mandates),[2]and 2) Donald J Trump has stated publicly that he has concerns about vaccination and that vaccines are linked to autism (and they are). [3][4]

• On February 14, 2019 Rep. Congressman Adam Schiff(D-CA), “sent a letter to Sundar Pichai and Mark Zuckerberg, the Chief Executive Officers of Google and Facebook, respectively, to express concern that the company’s platforms including YouTube, Facebook and Instagram, are surfacing and recommending information that discourages parents from vaccinating their children, contributing to declining vaccination rates which could reverse progress made in tackling vaccine-preventable diseases,” [5]which was a blatant call for CENSORSHIP and certainly a violation of the First Amendment. [6] The “science” on vaccination is NOT settled. [7]

• Additionally, numerous, numerous mainstream media outlets began running hostile, defamatory “hit pieces” on me with demands that Facebook and other platforms shut me down entirely, including my Personal Profile, Page and Group, along with others who may challenge vaccine safety, efficacy and the “need” for mandatory vaccination. Headlines included: “Anti-Vaxxer Larry Cook Has Weaponized Facebook Ads in War Against Science,”[8] “Here’s How One Of Facebook’s Biggest Anti-Vax Communities Built Its Massive Network,”[9]and “Half of new parents shown anti-vaccine misinformation on social media – report.” [10] Hundreds of defamatory mainstream news “hit” pieces would follow, including my all time favorite (sarcasm), “Meet Larry Cook, the Villain Behind the Facebook Anti-Vaxx Scandal.” [11]

• Within several months of the all-out mainstream media AND GOVERNMENT (e.g., Congressman Schiff, but also CA Senator Pan, etc.) attack on medical freedom activists sharing why they oppose vaccine mandates, multiple platforms decided to deplatform or ban anyone who challenged vaccine mandates or who challenged vaccine safety and efficacy, including Mailchimp [12] (an email subscription provider), GoFundMe [13] (crowd funding platform), Vimeo [14] (video hosting), Pinterest [15] (visual social media) while Facebook began to REDUCE DISTRIBUTION of medical freedom Pages and Groups [16] such as my Stop Mandatory Vaccination Page and Group.

• In real world terms, reduced distribution [17] for my Stop Mandatory Vaccination Facebook Page meant that I went from an average of 2 million reach per month down to just 100,000 reach per month (5%) while my Facebook Group saw a dramatic drop in member engagement and member requests (from 300 per day to 50 per day requests).

• Additionally, Facebook turned off my ability to run advertising on their platform,[18] while YouTube demonetized my YouTube Channel [19] because I questioned vaccine safety, efficacy and the “need” for vaccine mandates.

• In 2019 the World Health Organization (WHO) declared “Vaccine Hesitancy” as a top ten threat to humanity, [20] an assertion that I personally reject, and an assertion that millions upon millions of parents, researchers, medical professionals, scientists and others wholeheartedly reject.

• My work, as Larry Cook, and as Stop Mandatory Vaccination, on Facebook and other platforms, on my website and in emails to my subscribers, among other avenues of information dissemination, included interviews with or messaging from thousands of parents, scientists, medical doctors, health professionals, researchers, elected officials and more that included (but was not limited to) discussions of:

• • Death following vaccination
  • Severe injury following vaccination
  • Chronic ailments following vaccination
  • Vaccine failure
  • Herd immunity failure
  • Scientific vaccine fraud
  • Lack of vaccine efficacy
  • Rebuttal of contemporary vaccine history
  • Vaccinated vs unvaccinated health outcomes
  • Cover-up of vaccine induced death by medical examiners
  • Homeopathy as disease treatment and prevention
  • Natural medicine
  • Natural immunity
  • And other relevant topics

• Is it the role of Social Media Companies, Elected Officials and Big Tech to be the final ARBITRATOR OF TRUTH [21] for the liability-free vaccine industry and its continuous push to force-vaccinate every living human on the planet? Or, should Social Media Companies, Elected Officials and Big Tech follow the tenants of the FIRST AMENDMENT and allow Freedom of Speech whereby citizens can engage in unrestricted dialogue about topics that may have lifelong consequences based on decisions made? Wouldn’t MORE INFORMATION from BOTH SIDES of a topic be beneficial for all involved? Or, are Social Media Companies, Elected Officials and Big Tech working on an AGENDA – together – to quash opposition to mandatory vaccination? Is this a conspiracy?

• The United States Government has paid out nearly 5 billion dollars for vaccine injury and death related claims through the National Vaccine Injury Compensation Program [22] and yet HHS claims that only an estimated 1% of vaccine injuries are even reported to the Vaccine Adverse Events Reporting System (VAERS) .[23] What if ALL vaccine injuries and deaths were actually reported and the claims were properly settled? Would the payout be in the TRILLIONS OF TAXPAYER DOLLARS? The topics of VACCINE SAFETY and VACCINE EFFICACY (effectiveness) should NOT be censored to conform to a CONSPIRACY [24] to force vaccinate every human without question when serious harm and death can and does result from vaccination!

• Although there are many, many reasons why I voted for President Donald J Trump in the 2020 election, one of those reasons is that he stated publicly that he would not mandate the COVID vaccine once it is available .[25] He has also rejected national mask mandates [26] and national COVID testing mandates, which means he respects medical freedom. Medical freedom should be able to be discussed without censorship!

• Facebook not only censors vaccine related topics, but Facebook also censors COVID related topics, including proven alternative treatments for COVID, [27] disputed COVID death statistics, and many other COVID related topics that do not align with the official mainstream narrative. My posts were censored with “fact checks” and/or outright deletions and/or bans on my account use (e.g., 24 hour ban, 3 day ban, 7 day ban, etc.).

• On November 17, 2020, Facebook permanently terminated my Personal Facebook account of over twelve years with 50,000 plus followers and deleted my Stop Mandatory Vaccination Page with over 167,000 followers, without explanation. However, an Internet search produced a Newsweek article entitled, “Facebook Bans One of the Anti-Vaccine Movement’s Biggest Groups for Violating QAnon Rules,” [28] and that’s where I learned that Facebook removed me because I discussed Qanon. What’s interesting to note here is that Facebook has stated [29] that only those who “represent” Qanon will be removed, not those who discuss Qanon.

• Two hours later Twitter banned me from their platform, supposedly for “election interference.” Coordinated?

• Two days later Facebook removed my popular Stop Mandatory Vaccination Group with over 201,000 members.

• It is worth noting that Facebook not only deleted my personal account, but Facebook also deleted four other personal accounts who were admins and editors on my Facebook Group and Page. Disgraceful.

• Qof Qanon is believed to be a US Military Intelligence Operation that offers detailed information about Government Corruption and other topics through a sophisticated anonymous chat board that is then aggregated and disseminated though a number of channels, with qanon.pub being one of the many channels. Facebook has stated that “we’ve removed about 1,700 Pages, 5,600 Groups and about 18,700 Instagram accounts representing QAnon” and that the purported reason for doing so is that Qanon is a “violence-inducing conspiracy network.” [30]

• OF PARTICULAR IMPORTANCE is that Facebook (and other Qanon censors) NEVER mention any of the nearly 5,000 Q posts (since 2017) as justification for censoring Facebook Users, Pages and Groups! That’s right, not EVEN ONE POST by Q is used as an example that Q “incites violence,” “advocates for violence” or is “tied to violence.” NOT ONE POST. Surely, if Q was posting dangerous information that would influence researchers to violent acts then there must be at least one post – ONE POST – that Facebook could point to that would prove their assertion that Qanon is a “Dangerous Organization.” But they cannot, and do not, because it simply is not true.

• ELECTION INTERFERENCE. Facebook routinely and aggressively blocked, censored and/or removed content that challenged mainstream media COVID death tallies, alternative treatment options, hospitalization numbers and other disputed facts and figures to help ensure Democrat controlled states would remain “locked down” so as to push the need for mail in voting while discouraging in-person voting. Users who did so could be punished with bans. Mail in voting creates a scenario ripe for ballot harvesting and election fraud .[31]

• I believe that there was widespread vote fraud and manipulation during the 2020 Presidential Election and as such, this topic, along with the vaccination topic, along with the Qanon topic, as well as other “controversial topics,” should not be censored, “fact checked,” deleted and/or result in a ban or permanent account deletion just because the topic at hand challenges the official narrative as presented in mainstream media, the Democrat Party, the liability-free vaccine industry and other domestic and foreign controlling interests.

• INFLUENCE DEMOLISHED. Facebook, the largest modern day public square in the world that connects over 1.5 billion people in real time communication each day, [32] was my PRIMARY outreach and communication tool that allowed me to communicate with parents, medical professionals, politicians, lawyers, health enthusiasts, Patriots, and more all over America as well as the world, including Australia, United Kingdom, Brazil, France, Spain, Poland, Germany, Canada, and people of all walks of life in all countries. My vast network of 5,000 friends, 50,000 plus followers, 167,000 followers on my Page and over 201,000 members in my Group – that I spent years and years building – has been obliterated by Facebook censorship.

• REVENUE DEMOLISHED. Through Facebook I also shared online summits, donation requests, supplement recommendations and other revenue generating opportunities. Without my Facebook account because of censorship, my ability to secure ongoing revenue for my full time activist work has been demolished.

• Social Media – including Facebook, Twitter, YouTube, Instagram – along with other Big Tech platforms (e.g., Vimeo, GoFundMe, Mailchimp, etc.) should not be in the business of censoring its users in an effort to control the “official” narrative. This is UNAMERICAN and literally goes against the very principal of the US CONSTITUTION which guarantees Freedom of Speech, which INCLUDES the FREEDOM TO DISAGREE and the FREEDOM TO CHALLENGE and the FREEDOM TO OFFER ALTERNATIVES, WITHOUT REPRECUSSION!!! If social media titans are going to editorialize content on their platforms then Section 230 protections must be repealed, as advocated by President Trump. [33]

• THERFORE, I hereby demand and request an equitable remedy to this situation, which includes but is not limited to, the full restoration of my Facebook account and Page and Group WITHOUT restriction or reduced distribution, the restoration of any and all Facebook deleted “Qanon accounts” and users, the restoration of any and all Facebook medical freedom accounts, Pages and Groups (e.g., Del Bigtree’s Highwire Page [34]), as well as damages for the people who had their accounts CENSORED or DELETED (including their Pages and Groups), and I seek immediate injunctive relief for myself and everyone affected by Facebook’s vaccine, 2020 election, COVID and Qanon censorship and “fact-checking” policies.

The foregoing statement is true to the best of my knowledge and belief.

Larry D Cook, December 21, 2020

[1] https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201520160SB277

[2] https://www.politico.com/story/2019/04/16/republican-reject-democrat-vaccines-1361277

[3] https://twitter.com/realdonaldtrump/status/449525268529815552?lang=en

[4] https://twitter.com/realdonaldtrump/status/260415099452416000?lang=en

[5] https://schiff.house.gov/news/press-releases/schiff-sends-letter-to-google-facebook-regarding-anti-vaccine-misinformation

[6] https://constitutioncenter.org/interactive-constitution/amendment/amendment-i

[7] https://thetruthaboutvaccines.com/be-brave-pt1-vaccine-science-settled/

[8] https://www.thedailybeast.com/anti-vaxxer-larry-cook-has-weaponized-facebook-ads-in-war-against-science

[9] https://www.buzzfeednews.com/article/ryanhatesthis/facebook-anti-vaccination-vaxxer-communities-promotions-ads

[10] https://www.theguardian.com/society/2019/jan/24/anti-vaxxers-spread-misinformation-on-social-media-report

[11] https://www.fatherly.com/news/meet-larry-cook-the-villain-behind-the-facebook-anti-vaxx-scandal/

[12] https://www.nbcnews.com/tech/tech-news/email-marketer-mailchimp-bans-anti-vaccination-content-n1017221

[13] https://www.independent.co.uk/news/health/antivax-gofundme-ban-donation-crowdfunding-vaccines-conspiracy-a8870716.html

[14] https://vimeo.com/terms

[15] https://help.pinterest.com/en/article/health-misinformation

[16] https://about.fb.com/news/2019/03/combatting-vaccine-misinformation/

[17] https://www.nytimes.com/2019/03/07/technology/facebook-anti-vaccine-misinformation.html

[18] https://www.theguardian.com/technology/2019/nov/13/majority-antivaxx-vaccine-ads-facebook-funded-by-two-organizations-study

[19] https://www.buzzfeednews.com/article/carolineodonovan/youtube-just-demonetized-anti-vax-channels

[20] https://www.who.int/news-room/spotlight/ten-threats-to-global-health-in-2019

[21] https://www.cnbc.com/2020/05/28/facebook-has-been-an-arbiter-of-truth-here-are-examples.html

[22] https://www.hrsa.gov/vaccine-compensation/data/index.html

[23] https://childrenshealthdefense.org/news/vaccine-injury-payouts-taxpayers-on-the-hook-for-over-3-8-billion-as-vaccine-makers-rake-in-profits/

[24] https://www.dictionary.com/browse/conspiracy

[25] https://www.dailymail.co.uk/news/article-8844153/Donald-Trump-says-WONT-make-COVID-vaccines-mandatory.html

[26] https://www.rollingstone.com/politics/politics-news/trump-covid-positive-test-hospital-plane-train-mask-mandate-transportation-1070629/

[27] https://formerfedsgroup.com/wp-content/uploads/2020/12/20201212-Filed-complaint.pdf

[28] https://www.newsweek.com/facebook-bans-anti-vaccine-group-violating-qanon-rules-1548408

[29] https://about.fb.com/news/2020/08/addressing-movements-and-organizations-tied-to-violence/

[30] https://about.fb.com/news/2020/08/addressing-movements-and-organizations-tied-to-violence/

[31] https://www.whitehouse.gov/sites/whitehouse.gov/files/docs/pacei-voterfraudcases.pdf

[32] https://sproutsocial.com/insights/facebook-stats-for-marketers/

[33] https://www.whitehouse.gov/presidential-actions/executive-order-preventing-online-censorship/

[34] https://www.nbcnews.com/tech/tech-news/covid-19-vaccines-face-varied-powerful-misinformation-movement-online-n1249378