Uni4 Rights Society is excited to offer our ‘Research Department’ area. Current developments and historical information is available to be viewed (EG: scientific research papers, news articles, arbitration wins, etc) back to the beginning of this attack on our rights and freedoms.
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|52 Alternatives changing daily
|Hamilton clinic to use monoclonal antibody treatment for high-risk covid-19 patients. [44 pages]
|A-10 CMOH statement article “Moore’s Admissions
|'The worst is behind us': Ontario's top doctor (Chief Medical Officer of Health Dr Kieran Moore) speaks on covid-19 omicron spread. Link to similar
|A-11 Letter to UBC and supporting study
|Letter to UBC -Re: UBC plan to de-register students who have not declared their covid-19 vaccination status. [..some of the measures on campus - such as ongoing mandatory rapid tests for unvaccinated students and staff and related employment academic sanctions are not useful in preventing the transmission of covid-19….] [Worth a read!]
*With supportive study of Feb 1 2022. Original Letter Here.
|A-18 Two Articles by Robin Koerner - "The Unvaccinated Had it Right"
|How The "Unvaccinated" Got It Right (page 1)
Fact-Check This Facebook ~ Feb 14 2023 (page 13)
Robin Koerner is a British-born citizen of the USA, who currently serves as Academic Dean of the John Locke Institute. He holds graduate degrees in both Physics and the Philosophy of Science from the University of Cambridge (UK) [22 pages]
|A-20 Investigation into Vaccines Announced by State of Florida
|Governor Ron DeSantis held a roundtable discussion joined by Surgeon General Dr Joseph Ladapo and world-renowned physicians, researchers and public health experts to discuss adverse events of the mRNA covid-19 vaccines and announced new, aggressive actions to hold the federal government and Big Pharma accountable.
|A-21 State of Florida Release of Data re Vaccine Safety
|Health Alert on mRNA covid-19 Vaccine Safety
The State Surgeon General is notifying the health care sector and public of a substantial increase in Vaccine Adverse Event Reporting System VAERS reports from Florida after the vaccine rollout
|A-22 Lancet Study and covering article: Feb2023-Natural Immunity vs. Vaccination
|Past SARS-CoV-2 infection protection against re-infection: a systematic review and meta-analysis
Since January, 2021, several studies14, 15, 16, 17: have documented the effectiveness of past COVID-19 infection in reducing the risk of re-infection, including the extent to which immunity wanes over time.18
|A-24 Memorandum: CMOH-Similar level of infectiousness
|Vaccination is highly effective for preventing SARS-CoV-2 infection and serious outcomes when infection occurs, including against the Delta variant. However, recent data from the Delta variant shows that when breakthrough cases occur, fully vaccinated individuals have similar levels of infectiousness as in unvaccinated cases
|A-46 Covid-19 daily epidemiology
|Summary of COVID-19 cases across Canada and over time. Contains detailed data about the spread of the virus over time and in different regions of the country. Includes breakdowns by age and sex or gender. Provides an overview of hospitalizations and deaths, testing, variants of concern and exposures
|A-47 Only 3.8% covid deaths had no comorbidities
|Alberta's reporting of comorbidities questioned after boy, 14 removed from COVID-19 death count
|A-48 More than 81% of covid deaths in people over 65yrs
|COVID-19 vaccines (initial doses and boosters) and preventative measures for COVID-19 are important, especially if you are older or have multiple or severe health conditions including those on this list… […are safe and effective….]
|A-50 Dr Kieran Moore CMOH, internal memorandum
|Recent data from the Delta variant shows that when breakthrough cases occur, fully vaccinated individuals have similar levels of infectiousness as in unvaccinated cases.
|A-51 Third Dose recommendation
|Evidence is emerging that vaccine effectiveness against asymptomatic infection and mild covid-19 disease may decrease with time and that currently authorized covid-19 vaccines may be less effective against the Delta variant which could contribute to increased transmission of infection
|A-53 Studies funded to assess effects on menstruation
|NIH funds studies to asses potential effects of covid-19 vaccination on menstruation
|A-54 Spikevax, Moderna, VAED, missing long term safety and effectiveness data, etc.
|Government of Canada: Summary basis of decision- Spikevax (previously covid-19 vaccine Moderna). Heath Canada [94 pages]
|A-55 Pfizer documents
|Pfizer-Biontech covid-19 vaccine (Covid-19 mRNA vaccine). Heath Canada granted full approval for COMIRNATY. The vaccine was initially authorized for use in Canada under an interim order authorization on Dec 9 2020 under the name Pfizer-BioNTech Covid-19 Vaccine. [Health & Storage Info]
|A-57 Vaccine warnings and side effects
-Adding AstraZenica blood clot warning, but says vaccine is safe(Mar 23/21)
-Janssen covid-19 vaccine & the risk of thrombosis with thrombocytopenia(Apr 26/21)
-AstraZeneca covid-19 vaccine & COVISHIELD: risk of capillary leak syndrome(Jun 30/21)
-Health Canada updates PfizerBioNTech & Moderna covid-19 vaccine labels to include info on myocarditis and pericarditis(Jun 30/21)
-Health Canada updates Pfizer-BioNTech covid-19 vaccine label to reflect very rare reports of Bell's Palsy(Aug 6/21)
-Health Canada adds autoimmune disorder warning to AstraZenica, J&J covid-19 vaccines(Nov/21)
|A-58 Ontario makes covid vaccination policies mandatory in high risk settings, option to complete educational session
|Ontario Makes covid-19 vaccination policies mandatory for high-risk settings. Province to begin offering third doses of covid-19 vaccines to most vulnerable Ontarians
|A-59 Ontario document regarding Clinical trials timeline
|Ontario: Ministry of Health. Covid-19 vaccine approval process and safety. Version 3.0
|A-61 OSHA in the US does not enforce reporting of vaccine side effects to not discourage workers from receiving covid vaccines
|Occupational Safety & Health Administration (OSHA USA). …OSHA does not want to give any suggestion of discouraging workers from receiving covid-19 vaccinations or to disincentivize employers' vaccination efforts. As a result, OSHA will not enforce 29 CFR part 1904's recording requirements to require any employers to record workers side effects from covid-19 vaccination at least through May 2022
|A-64 Studies, Vaccine Effectiveness against Omicron and delta, MedRxiv
|The incidence of SARS-CoV-2 infection, including among those who have received 2 doses of covid-19 vaccines, has increased substantially since Omicron was first identified in the province of Ontario, Canada.
|A-65 US Court rules FDA must produce at a rate of 55000 pages per month until all documents are released regarding covid vaccine approvals
Public Health and Medical Professionals for Transparency
Food and Drug Administration (USA)
|A-66 - WHO statement tobacco use and covid-19
|Tobacco smoking is a known risk factor for many respiratory infections and increases the severity of respiratory diseases. A review of studies by public health experts convened by WHO on 29 April 2020 found that smokers are more likely to develop severe disease with covid-19, compared to non-smokers
|A-67 CDC R. Walensky tweets regarding a study with a reduction of the risk of Omicron Variant vs Delta Variant
|New: Study on severity of those infected with the Omicron Variant
|A-68 AEFIs for Covid-19 in Ontario
|Adverse Events Following Immunization (AEFIs) for covid-19 in Ontario: Dec 13, 2020 to Jan 9, 2022
|A-69 Transcript of Rachel Meddow Show: Dr. Fauci states in an interview
|Dr. Fauci states in an interview “when you talk about exposure and quarantine, if you are a person who is vaccinated but not boosted, verses a person who is not vaccinated, because of the greater degree of protection that you would have gotten from being boosted, they're treating people who are vaccinated but not boosted as the same risk as those who are not vaccinated at all. …."
|A-70 CMOH talks about, actual hospitalizations overestimated & Omicron much milder
|Anthony Furey: Ontario's covid response evolving big time, here's what you need to know. …"Another big move was the acknowledgement that Ontario's daily reported covid hospitalization numbers haven't been telling the full story. Dr. More confirmed that about 50% of them are currently for people who aren't actually suffering from covid but have gone to hospital with something else, like a broken leg and just happened to test positive for the virus."
|A-71 Canada has enough shots for multiple boosters
|Dr Srinivas Murthy, a British Columbia pediatrician and co-chair of the WHO's clinical research committee on covid-19, said the booster response is panicky politics not public health
|A-72 Dr. S. Chakrabarti an infectious disease specialist says virus mild, endemic, actual covid admissions much less alarming
|"… the latest wave of covid-19 is far from becoming a repeat of the pandemic's early days"… "What this is showing is that we have this mild virus right now, for the most part especially if you're vaccinated, ripping through the population and that's going to cause a lot of - and I mean this in a good way - immunity", Dr Sumon Chakrabarti, and infectious diseases specialist with Trillium Health Partners in Mississauga, Ont. said
|A-73 Dr. B Henry BC: its an overestimation of the burden Omicron is causing
|BC has joined Ontario in admitting it's covid hospitalization numbers don't tell the whole picture when it comes to who is actually sick with covid and who simply tested positive for it. Henry said that right now, BC is counting everyone in the hospital with a covid positive test as a 'hospitalization'
|A-74 Gov of Canada: Covid-19 and people with disabilities in Canada including older population and mental health
|Covid-19 and people with disabilities in Canada.
Protecting people with disabilities from covid.
The healthcare system and covid.
Infection prevention & control measures & personal protective equipment.
Covid-19 disability advisory group.
|A-75 CMOH pandemic creating stress and anxiety
|Government of Canada: Remarks from the Chief Public Health Officer. Stress, anxiety, loneliness.
|A-76 Waning protection from 2 doses
|The data shows that while having two doses does protect against severe illness among those who contract the virus, its ability to prevent infection altogether is plummeting, said Dr Peter Juni, the group's scientific director
|A-77 Alternative options
|Canada secures orders of Merck, Pfizer covid-19 antiviral pills. The federal government has signed purchase agreements with two pharmaceutical companies for their oral covid-19 treatments
|A-78 CMOH Omicron becoming the dominant variant
|Covid-19 Omicron in Ontario: Top doctor says to 'prepare for the worst', as variant spreads in fully vaccinated people
|A-79 Ontario bringing in more rapid tests as students set to return to school
|Ontario bringing in more rapid tests as students set to return to school. Rapid tests will be 'empowering' for families, MOH says
|A-80 European Union Regulators warn about repeated boosters
|Repeat booster shots spur European Warning on immune system risks. European Union regulators warned that frequent covid-19 booster shots could adversely affect the immune system and may not be feasible.
(*later the title and first two sentences were changed to reflect immune response, not immune system)
|A-81 Ministry of Health recommends 3 shots
|Ministry of Health, Ontario: Covid-19 vaccine third dose recommendations [22 pages]
|A-82 Pfizer CEO says Omicron vaccine ready in March
|New covid-19 vaccine that covers Omicron 'will be ready in March', Pfizer CEO says. … Julie Hyman: As we mentioned earlier, the JP Morgan Heath Care Conference does kick off today, a lotof CEO's speaking there….
[14 page transcript]
|A-83 Dr Juni “People who have had 2 doses and are more than 3 months after their second dose really need to behave as if they weren’t vaccinated
|How long should you wait for your third coid-19 vaccine dose?
[4 pages of information links]
|A-84 Fourth covid dose for long term care
|The Ontario government says effective immediately, it is making FOURTH covid-19 shots available to the province's long-term care residents
|A-85 Dr Juni talks about natural immunity and age being the most important factor
|"First of all, in South Africa, we only have about seven per cent of the population who are completely non-immune. All of those other people have either experienced infection, or vaccination, or both." Juni said.
|A-86 WHO- Omicron as the dominant variant, make masks and hygiene a priority
|Enhancing readiness for Omicron (B.220.127.116.11.9): Technical brief and priority actions for member states. (World Health Organization HQ) [22 pages]
|A-87 CBC Federal contracts poised to deliver 100 million vaccine doses annually for years
|Federal contracts poised to deliver 100 million vaccine doses annually for years. Contracts are for 65M doses from Pfizer & 35M from Moderna
|A-88 Moderna CEO expresses skepticism regarding booster and talks about a fourth shot in the fall
|Moderna CEO Stephane Bancel said the efficacy of boosters against covid-19 will likely decline over time and some people may need a fourth shot by the fall. "I would expect that it's not going to hold great", Bancel said during a Goldman Sachs interview referring to the strength of the single booster shots.
|A-89 No data available, no evidence of preventing transmission
|No data shows covid-19 vaccine prevents transmission: Tam
FDA takes key action in fight against covid-19 by issuing emergency use authorization for first covid-19 vaccine [32 pages]
|A-9 Premier Ford statement article
|Ford says no to mandatory covid-19 vaccination policy for hospital workers.
|A-91 WSIB used the term “coercion” regarding vaccination policies
|Actual date of doc is unknown - estimated mid 2021.
When determining whether a reaction to a covid-19 vaccination is work-related, the WSIB considers: 1. Whether the vaccination was a compulsory part of your employment: A vaccination will be a compulsory part of your employment if your employer has a rule or policy that requires employees to be vaccinated or if your employer uses some element of COERCION for vaccination eg: threat of termination of employment, job changes or penalties.
Page content appears different now - see additional link >>
|A-93 CDC “…similarly high SARS-CoV-2 viral loads in vaccinated and unvaccinated people”
|Statement from CDC Director Rochelle P. Walensky, MD, MPH on Today's MMWR
… Delta Infection resulted in similarly high SARS-CoV-2 viral loads in vaccinated and unvaccinated people.
|A-94 The WHO “ …current COVID-19 vaccines may need to be updated..”
|… Current covid-19 vaccines may need to be updated, to ensure that covid-19 vaccines continue to provide WHO-recommended levels of protection against infection and disease.
|A-95 – Ministry of Health highly recommends Covid-19 vaccines in pregnancy
|Published: Oct 25 2021
Covid-19 vaccines do not cause infertility.
In fact, getting all recommended doses of the covid-19 vaccine before you conceive will help protect you and your future baby from the risk of covid-19 in pregnancy.
|A-97 Doug Ford, We also know that it doesn’t matter if you have one shot or 10 shots, you can still catch COVID-19
|"You see the Prime Minister he has triple shots and I know hundreds of people with three shots, who caught covid-19, we just need to be careful, always make sure we wash our hands and move forward."
|Romaine J-Ingram-v-Alberta-(Chief Medical Officer-of-Health)
|Alberta Chief Medical Officer’s Health Orders Ruled Unconstitutional & Illegal. The illegality of these Orders was the primary argument we presented, and was successful. This case therefore stands as the only superior court decision in the country which has ruled against a pandemic government in this way.
|A majority of uninfected adults show preexisting antibody reactivity against SARS-CoV-2.This study reveals common preexisting, broadly reactive SARS-CoV-2 antibodies in uninfected adults. These findings warrant larger studies to understand how these antibodies affect the severity of COVID-19, as well as the quality and longevity of responses to SARS-CoV-2 vaccines.
|Health Canada is in BIG trouble.
Check out the disclaimer Pfizer got South Africa to sign. Same as Slovenia's. Same as Canada's undoubtedly.
"long term effects and efficacy not currently known"
"adverse events... not currently known"
WOW! Health Canada KNEW... and misled Canadians.
|200 Years Vaccines Caused Serious Harm
|25 Historical books that demonstrate vaccines have caused serious harm for 200 years
|Scientific Fraud Covid 19 Vaccine
|Scientific Fraud in Pfizer's mRNA COVID-19 Vaccine Trial -- Researchers have uncovered scientific fraud in the clinical trials for Pfizer’s mRNA COVID-19 vaccine related to the finding of DNA contamination.
|2020-07-23 _ Masking lack of evidence with politics - The Centre for Evidence-Based Medicine
|From The Centre for Evidence-Based Medicine, the efficacy of masks has been in question resulting in little to no evidence of any benefit.
|2023-02-17 _ New Cochrane Study on Masks and Covid _ City Journal
|Masks make no difference in reducing the spread of Covid, according to an extensive new reviewby Cochrane—the gold standard for evaluating health interventions.
|2023-09 _ SWISSGOVERNMENTPOLICYRESEARCHAre Face Masks Effective_ The Evidence_
|An overview of the current evidence regarding the eff ectiveness of face masks.
|2023-09-18 _ Mask mandate and use efficacy for COVID-19 containment in US States - eSciPub Journals
|We did not observe association between mask mandates or use and reduced COVID-19 spread in USstates. COVID-19 mitigation requires further research and use of existing efficacious strategies, most notablyvaccination.
|Educators For Human Rights (EFHR) submitted an open letter outlining their position on forced vaccinations:
We therefore categorically reject any notion that the union, the employer, the government or anyone else has any say in the matter of a member's health and health choices, and its disclosure.
|Legal win for two Unifor members. "They posed no health hazard to other employees. It is difficult to see what the prejudicial impact on the employer would have been by allowing Mr. Rubin and Mr. Shuparski to remain on an unpaid leave of absence."
|The Ontario Nurses' Association (ONA) has won an important and precedent-setting arbitration award against Sault Area Hospital, striking down the controversial "Vaccinate or Mask" policy introduced at many Ontario hospitals. This policy forces nurses and other health-care workers to wear an unfitted surgical mask for the entire flu season if they choose not to get the influenza vaccine.
|2022-02_Omicron and Changing Government Measures-Feb2022 AX
|Unifor knew in February 2022 that "vaccines" did not stop transmission! Published in February 2022 on Unifor.org - "Workers are not immune to infection, regardless of vaccine status or the changing of public health measures."
|2022-04-01 Backpay ordered for unvaccinated Richmond city workers - Richmond News
|A mediated resolution at the end of March means Richmond city staff members who were put on unpaid leave on Dec. 20 will be allowed to return to work and get back pay to Feb. 21. This resolution comes just days before the city lifts its vaccine mandate on April 8 when these workers would have been allowed back to work anyway.
|2021-11-03 Quebec scraps vaccine mandates for health care workers Ontario won’t require them - The Globe and Mail
|Quebec and Ontario will not be mandating health care workers to be vaccinated, with both provinces citing significant concerns about staffing levels.
|2023-10-19 EXCLUSIVE_ Health Canada Confirms Undisclosed Presence of DNA Sequence in Pfizer Shot _ The Epoch Times
|Health Canada has confirmed the presence of a Simian Virus 40(SV40) DNA sequence in the Pfizer COVID-19 vaccine, which themanufacturer had not previously disclosed.
|2022-02-22 Superior Court Decision re Unacceptible Beliefs in OUR FAVOR
|Ontario Superior Court judgement BETWEEN J.N. (Applicant), Self-Represented and C.G. (Respondent), Jesse Herman, Counsel, for the Respondent
|2023-06-15 MilitaryEXCLUSIVECanadian Military’s COVID Vaccine Mandate Violated Charter Rights Grievance Review Committee Finds
|A military administrative tribunal has found that the Canadian Armed Forces (CAF) COVID-19 vaccine mandate violated the charter rights of members who refused vaccination, saying that the policy was “arbitrary” in some aspects and “overly broad.”
|2018-12-01 V-Taking On A Giant - Vaccine Choice Canada
|The tale of a committed group of health professionals who set stunning legal precedents, despiteinsurmountable odds, to force policy change. On September 6, 2018 the Ontario Nurses’ Association (ONA) announced they won a second arbitration onthe inuenza vaccinate or mask (VOM) policy, striking down the policy at St. Michael’s Hospital and severalothers that form the Toronto Academic Health Science Network (TAHSN).
|5.3.6 CUMULATIVE ANALYSIS OF POST-AUTHORIZATION ADVERSE EVENT REPORTS OF PF-07302048 (BNT162B2) RECEIVED THROUGH 28-FEB-2021
|2022-09-21 CANLI2022canlii120371Religious AccommodationUnited Commercial workers
|IN THE MATTER OF AN ARBITRATION B E T W E E N: WILFRID LAURIER UNIVERSITY (“the University” or “the Employer”) - and - UNITED FOOD AND COMMERCIAL WORKERS UNION (“the Union”) SECOND PRELIMINARY AWARD
|2022-03-20 University of Toronto drops vaccine mandate - LifeSite
|University of Toronto drops vaccine mandate after being hit with human rights complaint. 'Vaccine mandates, including those recently renewed by Ontario universities, are scientifically questionable, ethically problematic, and misguided,' reads a paper featured on the University of Toronto's law faculty website.
|Mackenzie County Procurement Policy Regarding Mandatory Vaccination: Mackenzie County is appalled by the response to COVID-19 that the many governments and corpoations has evoked by repeatedly violating personal rights and freedoms, and this is a practise that is not tolerated on Mackenzie County worksites.
|2023-01-30 COCHRANESTUDYINJOURNALPhysical interventions to interrupt or reduce the spread of respiratory viruses - Jefferson T - 2023 _ Cochrane Library
|Physical interventions to interrupt or reduce the spread of respiratory viruses - a study from the Cochrane Database of Systematic Reviews (https://doi.org/10.1002/14651858.CD006207.pub6).
|2022-12-06 Islandhealthawardwagesreligiousdiscrimination2022 CanLII 127683 (BC LA) _ Island Health v United Food & Commercial Workers Local 1518 _ CanLII
|Island Health (the "Employer") v United Food & Commercial Workers Local 1518 (the"Union"), 2022 CanLII127683 (BC LA) https://canlii.ca/t/jv1w0, retrieved on 2023-08-19
|https://www.canlii.org/en/bc/bcla/doc/2022/2022canlii127683/2022canlii127683.html?autocompleteStr=2022 CanLII 127683&autocompletePos=1
|2022-10-07 FLORIDASTOPT 18-39VACCINEMRNA20221007-guidance-mrna-covid19-vaccines-doc
|Based on currently available data, patients should be informed of the possible cardiac complications that can arise after receiving a mRNA COVID-19 vaccine. With a high level of global immunity to COVID-19, the benefit of vaccination is likely outweighed by this abnormally high risk of cardiac-related death among men in this age group. The State Surgeon General now recommends against the COVID-19 mRNA vaccines for males ages 18-39 years old.
|2022-01-13 QSupreme Court of US (1)
|SUPREME COURT OF THE UNITED STATES Nos. 21A244 and 21A247 21A244 v. National OSHA .vs. Ohio OSHA ON APPLICATIONS FOR STAYS
|2021-10-28 44 Studies on Vaccine Efficacy that Raise Doubts on Vaccine Mandates ⋆ Brownstone Institute
|44 Studies on Vaccine Efficacy that Raise Doubts on Vaccine Mandates As some people have now been vaccinated for more than half ayear, evidence is pouring in about Covid vaccine effi cacy. Thegestalt of the fi ndings implies that the infection explosionglobally that we have been experiencing– post doublevaccination in e.g. Israel, UK, US etc. –may be due to the vaccinatedspreading Covid as much or more than the unvaccinated.
|2004-06-30 SCC 47 (CanLII) _ Syndicat Northcrest v. Amselem _ CanLII
|Syndicat Northcrest v. Amselem, 2004 SCC 47 (CanLII),  2 SCR 551 The WCB and Saskatchewan submit Amselem and the referencedline of cases are distinguishable from Ms. Horner's situation in onefundamental respect: the impugned release in Ms. Horner’s situation does notseek to waive Ms. Horner's s.15(1) Charter rights on a go-forward basis.
|2023-04-21 City went too far in worker crackdown over COVID vaccines judge rules - Chicago Sun-Times
|City went too far in worker crackdown over COVID vaccines, judge rules In a case that applies to members of several unions, an administrative law judge for a state agency rules the city has to reinstate workers and make up for lost wages and benefits.
|20231210 PrivyCouncil3Image 202528
|Excerpt from the 1996 Canadian National Report on Immunication.
|2023-09-10_Addressing the Covid-19 Human Rights Abuses and Restoring Law and Order
|Dr Tess Lawrie, MBBCh, PhD from 'A Better Way to Health' writes: These past few years, dangerous vaccines and other unhealthy Covid-19 policies promoted, mandated and implemented by those in authority have led to widespread human rights violations. Is the problem fundamentally that we don't know or have forgotten our rights? It's an honour to have International Human Rights and Constitutional Law specialist Dr Willem van Aardt as an Expert Advisor to the World Council for Health. His authoritative book Covid-19 Lawlessness is now available in the WCH's new shop at https://shop.worldcouncilforhealth.org/ I highly recommend it!
|Appendix A-98 – Dr. Moore recommends end to mandatory immunizations for LTC home staff, Mar 9.22
|Ontario will remove mandatory masking rules in scholls and most public settings as of March 21 2022, the day students return from March Break.
|Appendix A-63- US Supreme court documents regarding mandatory covid vaccinations, supporting A-62, Jan 2022.
|Various court documents regarding mandatory covid vaccincations.
|Appendix A-60 – Warnings from other countries, supporting document A- 45
|Warnings from other countries - In November 2021, Berlin health authorities stated people aged under 30 in Germany should only receive the Bointech/Pfizer COVID-19 vaccine as it causes fewer heart inflamations in younger people than the Moderna shot. Hmmmm.
|Teamsters Union vs Purolator Arbitration