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The following account is public knowledge and filed online in PACER. The case is M. B. pro per v. Respironics CA LLC et al. ( now a defunct Philips subsidiary) Case in Federal District Court, Southern District of California : 3:23-cv-00580-GPC-VET Intro to first amended complaint This is an action by plaintiff, who was subjected to defendant’s corporate wide SARS-CoV-2 (COVID-19) Vaccination Program (“Vaccine Mandate”) and was wrongfully terminated for refusing to comply. In this action, plaintiff claims that application of the Vaccine Mandate to him constituted unlawful invasions of inalienable rights to his privacy and bodily autonomy – including the right to make an informed decision to decline the COVID-19 vaccine injection. The defendants’ invasion of plaintiff’s privacy rights was compounded by defendant’s lack of due diligence or reckless neglect on not informing employees of the true risks and lack of benefit of the COVID-19 vaccines, information defendants suppressed to use the Vaccine Mandate as an opportunity, a pretext to a massive reduction in force across their North America operations without incurring severance and unemployment expenses. Plaintiff brings this complaint (‘Complaint’) suing all named defendants herein for economic, non-economic, compensatory, consequential, and punitive damages under peremptory international norms (codified into California statutes) that ban any form of coercion of experimental medicine, under the inalienable right to privacy and bodily autonomy expressly protected in the California Constitution, under the Fair Employment and Housing Act, and under other provisions of law pursuant to the causes of action claimed herein. Plaintiff has strong convictions that the allegations made herein violated his constitutional and civil rights, and that defendants acted in bad faith by terminating his employment after 9 years of excellent service to the company for unreasonable cause. Plaintiff exercised his inalienable rights and refused to receive any COVID-19 injections, was illegally terminated by defendants, and denied the benefit of severance because he exercised his rights. Application of a Vaccine Mandate to each employee thus constituted an unlawful employment practice, defendants lacked a genuine justification based on actual belief and reasonable basis, it was unable to show a vital business necessity for employees to be injected, and the Program was not shown to be tailored to be no broader in scope than necessary to meet business necessity. Defendants also engaged in unlawful retaliation under FEHA when it terminated employees including plaintiff or others for resisting or opposing application of defendant’s unlawful Program. Plaintiff claims he was wrongfully terminated by defendants when they falsely claimed he resigned from his job for personal reasons. Plaintiff alleges he was actually discharged under the pretext of not complying with a companywide vaccine mandate issued from Philips North America operations and, that defendant enforced their own mandate, without duress from any government policy at time of discharge, and not for reasons of safety as they claimed. Plaintiff alleges he was discriminated against for a sincerely held religious belief among other serious and justified objections to the vaccine mandate that were stated in the letter. Plaintiff alleges many of his personal rights, afforded by the constitution of the United States and the constitution of the State of California, particularly his right to privacy, were violated by defendants not responding to plaintiff’s letter. Plaintiff also alleges defendants violated an implied covenant of good faith and fair dealing by defendants’ fraudulently declaring and recording an untruthful reason and cause for his discharge. Plaintiff alleges these defendants’ actions created a stigma on plaintiff’s professional reputation and his lifelong, untarnished employment record that has disadvantaged and possibly permanently damaged his ability to gain new employment. It's very difficult to engage an attorney against the vaccines. But that shouldn't stop anyone who has a will and a sense of liberty and lots of faith. Fight!