Plaintiffs: A group of persons according to the list of applicants, as well as those who have joined in accordance with the law
Tverskoy District Court
Moscow city
Plaintiffs: A group of persons according to the list of applicants, as well as those who have joined in accordance with the law
A person acting in defense of the rights and interests of the group of persons
Full name
Address:
Tel.
Respondent:
Government of the Russian Federation
Address: 103274, г Moscow, Krasnopresnenskaya embankment, 2
CLASS ACTION STATEMENT OF CLAIM FOR COMPENSATION OF MORAL DAMAGE
A group of persons - citizens of the Russian Federation – consisting of more than 20 people applied to me with written statements in accordance with paragraph 6 of Art. 244.22 of the Civil Procedure Code of the Russian Federation to protect in court their rights and legitimate interests violated, in our common opinion, by the unlawful actions of the Government of the Russian Federation expressed in the public and repeated use of the concepts of “pandemic” and “epidemic” in 2020-2021 in relation to disease COVID-19, being a lie and misinformation of the entire population, which created a panic causing us moral harm (physical and moral suffering).
According to paragraph 17 of Article 1 of the Federal Law of the Russian Federation “On the sanitary and epidemiological wellbeing of the population” № 52-FZ of March 30, 1999, epidemics include infectious diseases that rapidly spread among the population. According to the same article, it is the presence of an epidemic that makes it possible to classify such a disease as an infectious disease that poses a danger to others, which, in turn, allows restricting the rights of citizens, for example, in accordance with clause 6) part 1 of Art. 51 of the entitled law.
By virtue of paragraph 5.5. of the Regulations on Federal Service for Surveillance on Consumer Rights Protection and Wellbeing (Rospotrebnadzor) - it informs the state authorities of the Russian Federation, state authorities of the constituent entities of the Russian Federation, local governments and the population about a sanitary and epidemiological situation, posts information about the epidemiological situation on its website including information on exceeding epidemic thresholds [1].
There has been no official announcement of the COVID-19 epidemic in Russia. This is confirmed by:
· the absence of a corresponding official announcement on the website of Rospotrebnadzor and in the press;
· Letter of Rospotrebnadzor 09-23278-2021-40 dated 10/25/2021, - probably, this is a response to an inquiry by deputy of the State Duma of the Russian Federation M.G. Delyagin[2] which says “No epidemics of plague, cholera, smallpox and other dangerous infectious diseases have been recorded on the territory of the Russian Federation in the period from 2020 to the present time”, and COVID-19 is recognized as a disease that poses a danger to others [3] ;
· Letter of the Office of Rospotrebnadzor in St. Petersburg №. 78-00-09/21-48337-2021 dated 08/31/2021 (personal data of the recipient are hidden at his request), which says that “the concept of an epidemic and an epidemic threshold in relation to COVID-19 is currently not applicable”.