Afidavit Plea notarized and submitted for review to the Grand Jury Foreman

Steffen Rowe




Case No. _______________


United States of America, Inc







    COMES NOW the plaintiff, Steffen Rowe, pro se, and for a complaint for criminal and civil grievance filed herein against the defendant, United States of America, Inc. respectfully states and alleges:

  1. That plaintiff is a resident of New York State and has been for at least sixty (60) days prior to filing this action. That this action arose in New York as well as all 49 other states.  

  2. That defendant is a full time resident of New York.  

  3. That this cause of action occurred since 9/16/1986 which unlawfully mandated under 42 U.S.C. 300aa-27 the force of vaccination against the individuals and entities responsible for the initiation, enactment, enforcement, and continued allowance of the unconstitutional and thus fraudulent whether premeditated or by accidental actions of the Children's Vaccine Injury Act enacted in 1986 within the 42 U.S.C 300aa-27.

  4.  That this complaint brings the United States of America, Inc is in violation of the 5th Amendment, the Nation is forbidden to deprive any one “of life, liberty, or property without due process of law.”

  5. The current court system is in violation of the u.S. Constitution and thus is non-compliant with their private contract with mankind.

  6. This complaint brings the United States of America became the United States of America Corporation without the disclosure of the facts and without a vote of the people. 

  7. The United States of America, Inc. has violated the fundamental rights of the people, through unlawful policy, unlawful statutes, words, or by force is therefore considered an act of treason as stated in Title 18, U.S.C. Sec, 2381.

  8. This lawsuit is brought as a proposed class action against Merck for unlawfully monopolizing the United States of America market for Mumps Vaccine by engaging in a decade-long scheme to falsify and misrepresent the true efficacy of its vaccine.

  9. Specifically, Merck fraudulently represented and continues to falsely represent in its labeling and elsewhere that its Mumps Vaccine has an efficacy rate of 95 percent or higher. In reality, Merck knows and has taken affirmative steps to conceal by using improper testing techniques and falsifying test data that its Mumps Vaccine is, and has been since at least 1999, far less than 95 percent effective.

  10. Merck designed an even more scientifically flawed methodology, this time incorporating the use of animal antibodies to artificially inflate the results, but it too failed to achieve Merck's fabricated efficacy rate. Confronted with two failed methodologies, Merck then falsified the test data to guarantee the results it desired. Having reached the desired, albeit falsified, efficacy threshold, Merck submitted these fraudulent results to the Food & Drug Administration. 

  11. In 2004 Merck submitted its application for approval for ProQuadB, a combination vaccine containing mumps, measles, rubella and chickenpox vaccines, certifying the contents of the application as true even though Merck knew the statements about the effectiveness of the Mumps Vaccine were, in fact, false. At no time during this application process did Merck disclose to the FDA the problems of which it was aware (or should have been aware) relating to the significantly diminished efficacy of its Mumps Vaccine. Accordingly, in 2005, the FDA approved Merck's application for ProQuadB. 

  12. Merck sought and secured FDA approval to change the labeling for M-MRBII -which is composed of Merck's mumps, measles and rubella vaccines -to reflect an almost 40 percent reduction in the minimum potency of the Mumps Vaccine component. It did this while leaving its false representations of efficacy unchanged. And it did this fully appreciating that if the current, higher potency vaccine had an efficacy rate far lower than the falsely represented 95 percent, there was no way the vaccine would achieve that efficacy with significantly less attenuated virus in each shot. 

  13.  Merck has now known for over a decade that its Mumps Vaccine is far less effective than advertised publicly and represented to government agencies. As Merck profited from its unlawful scheme, health care providers around the country have purchased millions of doses of Mumps Vaccine, with questionable efficacy, at artificially inflated prices.

13. Throughout the Class Period, Merck manufactured, produced, sold and shipped substantial quantities of Mumps Vaccine in a continuous and uninterrupted flow of transactions in interstate commerce throughout the United States including within this District State of New York. Merck's unlawful activities that are the subject of this Complaint were within the flow of, and have had a direct and substantial effect on, interstate trade and commerce. 

  1.  At all times relevant to this action, Merck has breached its express warranties with regard to Mumps Vaccine because the Mumps Vaccine does not have the 95 percent efficacy rate represented by Merck, in violation of state express warranty laws including: (a) ALA. CODE 5 7-2-3 13; (b) ALASKA CODE 42.02.313 (c) ARIZ. REV. STAT. ANN. 5 47-23 13; (d) ARK. CODE ANN. 5 4-2-3 13; (e) CAL. COMM. CODE5 23 13; (f) COLO. REV. ST. 5 4-2-3 13; (g) CONN. GEN. STAT. ANN. 5 42~-2-313; (h) DEL. CODE ANN. TIT. 6, 5 2-3 13; (i) D.C. STAT. 5 28:2-3 13;( j) FLA. STAT. ANN. g 672.3 13; (k) GA. CODE ANN. 5 11-2-3 13; (l) HAW. REV. STAT. 5 490:2-3 13; (m) IDAHO CODE ANN. 3 28-2-3 13; (n) ILL. ST. CH. S 10 5 512-3 13; (0) IND. CODE tj 26-1 -2-3 13; (p) IOWA CODE ANN. 5 554.23 13; (q) KAN. STAT. ANN. 5 84-2-3 13;(r) KY. REV. STAT. ANN.  355.2-313;(s) LA. CIV. CODE. ANN. ART. 2520; (t) ME. REV. STAT. TIT. 1 l, g 2-3 13; (u)MD. CODE ANN., COM. LAW 2-3 13; (v) MASS. GEN. LAWS ANN. 106 2-313; (w) MICH. COMP. LAWS ANN. 440.23 13; (x)MINN. STAT. ANN. 336.2-3 13;(y) MISS. CODE ANN.5 75-2-3 13;(z) MO. REV. STAT. 400.2-3 13; (aa) MONT. CODE ANN. 30-2-3 13;(bb) NEB. REV. STAT. 2-3 13; (cc) NEV. REV. STAT. 5 104.2313;(dd) N.H. REV. STAT. 382-A:2-3 13; (ee) N.J. STAT. ANN. 12A:2-3 13; (ff)N.M. STAT. ANN. 55-2-3 13; (gg) N.Y. U.C.C. LAW 2-313; (hh) N.C. GEN. STAT. ANN. 5 25-2-3 13; (ii) N.D. CENT. CODE ANN. 41 -02-30 (2-3 13); (jj) OHIO REV. CODE ANN. 1302.26;(kk) OKLA. STAT. ANN. TIT. 12A, 5 2-3 13; (ll)OR. REV. STAT. g 72.3 130; (mm) PA. STAT. Am. TIT. 13, 23 13; (nn)RD. STAT. 5 6A-2-3 13; (oo) S.C. 5 36-2-3 13; (pp) S.D. COD. LAWS.5 57A-2-3 13; (qq) TENN. CODE ANN. 5 47-2-3 13; (rr) TEX. BUS.& COM. CODE Am. 5 2.3 13; (ss)- UTAH CODE ANN. 5 70A-2-3 13; (tt) VT. STAT. ANN. 5 2-3 13; (uu) VA. CODE ANN.8-2-313; (vv) WASH. ANN. 62A.2-3 13; (ww) W. VA. CODE 5 46-2-3 13; (xx) WIS. STAT. ANN. 5 402.3 13; and (yy) WYO. STAT. 34.1-2-3 13. 

  2. No evidence can be provided to demonstrate data to support the need for vaccines nor the impact of using them on the mass population due to the criminal negligence admitted to by the CDC, HHS, FDA, and the drug manufacturers in failing to conduct the Congressional mandated in accordance with 42 U.S.C-300aa-27 research, nor have they provided reports to the two committees, Committee on Health, Education, Labor, and Pensions of the Senate (HELP) and the Committee of Energy and Commerce of House of Representation.


                                                        PRAYER FOR RELIEF

WHEREFORE, plaintiff prays Plaintiff, on behalf of himself seeks judgment as follows:  

A declaration that Defendant's conduct is in violation of Section 2 of the Sherman Act, 15 U.S.C. 5. 2. A declaration that Defendant's conduct is in violation of state consumer protection and warranty laws. A declaration that Defendant was unjustly enriched by its unlawful conduct.  A declaration that Defendant’s terminate anything under the code of law that acts to present it as it self as as a statue of law to be immediately nullified or made a no law. Injunctive relief barring Defendant from making further misrepresentations regarding the efficacy of its Mumps Vaccine. Injunctive relief barring the United States of America, Inc from further misrepresentations regarding the efficacy of vaccinations. Injunctive relief barring the United States of America, Inc from unlawfully mandating vaccinations and forcing their unlawful will against the American individuals. Injuctive relief barring Congress from enacting unconstitutional laws. lnjunctive relief barring the United States of America, Inc from violating the Constitution as well as the Bill of Rights. 

                                                         JURY DEMAND 

Pursuant to Rule 38(a) of the Federal Rules of Civil Procedure, Right Preserved. The right of trial by jury as declared by the Seventh Amendment to the Constitution—or as provided by a federal statute—is preserved to the parties inviolate. Plaintiff respectfully demands a trial by jury. 



Respectfully submitted,


Steffen Rowe 

New York  





                             ) SS

COUNTY OF _________    )


The undersigned, being duly sworn, states on oath that he has reviewed the above named pleading and that the facts and matters contained therein are true and correct to the best of her knowledge and belief.       



Steffen Rowe


SUBSCRIBED AND SWORN TO before me this _____day of ___________, _______.



Notary Public

My Commission Expires:



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