The very title of the document contains word “pandemic”, which was not declared, that is, the very title of the document on disinformation and lies already contains disinformation and lies.
Further quote:
“An infodemic is an overabundance of information, both online and offline. It includes deliberate attempts to disseminate wrong information (it is directly about the pandemic – remark of the plaintiffs) to undermine the public health response and advance alternative agendas of groups or individuals. Mis- and disinformation can be harmful to people’s physical and mental health; increase stigmatization; threaten precious health gains; and lead to poor observance of public health measures, thus reducing their effectiveness and endangering countries’ ability to stop the pandemic.
Misinformation costs lives. Without the appropriate trust and correct information, diagnostic tests go unused, immunization campaigns (or campaigns to promote effective vaccines) will not meet their targets, and the virus will continue to thrive.
Furthermore, disinformation is polarizing public debate on topics related to COVID-19; amplifying hate speech; heightening the risk of conflict, violence and human rights violations; and threatening long-terms prospects for advancing democracy, human rights and social cohesion”.
There is no doubt that the WHO itself together with the Government of the Russian Federation, by illegally using term “pandemic”, have created the negative consequences that are quoted here and which can rightfully be attributed to these terms.
Thus, it is already formulated in the WHO document that as a result of the infodemic, disinformation and panic, society and me received:
· harm to the physical and mental health of people; the increased stigmatization; jeopardizing critical health gains; and generating disregard for public health measures, thereby reducing their effectiveness and limiting the ability of countries to put an end to lies and misinformation;
· false rumors and information that takes people's lives;
· false rumors leading to polarization of public opinion on issues related to COVID-19;
· provoking hate speech; increasing the risk of conflict, violence and human rights violations; and jeopardizing long-term prospects for strengthening democracy, human rights and social cohesion.
Here the statement by the Research Institute of Hygiene and Health Protection of Children and Adolescents should be added “From April 27 to May 26, 2020, the Federal State Autonomous Institution "National Medical Research Center for Children's Health” of the Ministry of Health of Russia carried out a study “Health condition of schoolchildren during distance learning in the period of COVID-19 epidemic”.[12]
It is based precisely on the fact that there is an epidemic and a pandemic as a basis for adopting a decision to isolate children.
The anonymous survey involved 29779 schoolchildren in classes 5-11 living in cities (70% of respondents) and rural areas (30% of respondents) in 79 regions of Russia.
According to the results obtained, as a result of isolation and distance learning, 80% of schoolchildren showed unfavorable mental responses, as well as:
“It can be stated that only 13.4% of schoolchildren have a favorable medical, psychological and social adaptation to the conditions of self-isolation and distance learning. 30.7% of respondents have signs of computer vision syndrome, and 4.2% - carpal tunnel (“carpal”) syndrome typical for professionals related to information and communication technologies and their means of support. An integral part of the implementation of online learning is the use of headphones, among which the most accessible for teenagers are plug-in in-ear models. According to experts, including the WHO, the use of such models increases the risk of development of hearing and nervous system disorders. The survey demonstrated that 72.5% of teenagers use headphones. Approximately, every fifth student used them for no more than 1 hour, and the same number of teenagers - no more than 2-3 hours a day, and over the third of the respondents (39.8%) - 4 or more hours a day.
The vast majority of schoolchildren (73.1%) showed that they used a smartphone for lessons. This situation should be considered as very alarming and unacceptable, since smartphone capabilities do not provide the necessary conditions for the visual work of schoolchildren in accordance with hygienic requirements. The diagonal of the device screen does not allow achieving the necessary optimal parameters for the visual work of the font design of the content of educational information. With regular and long-term use during training sessions, a smartphone should be considered as a serious risk factor for the development of visual pathology in children and adolescents. The use of digital devices is largely associated with the tasks of distance learning: participation in online lessons (50.2% of respondents), doing homework (79.9%), searching for information (62.1%), reading (16.4% of children). More than 77.1% of respondents spent 4 hours or more daily with digital gadgets, and 42.7% of them - at least 4-6 hours, and 34.5% of schoolchildren have "screen time" of 7 hours or more..”.
Thus, distance learning introduced due to the panic, “pandemic” and “epidemic” of COVID-19, caused direct harm to the mental and physical health of most children, including ours, who were sent to distance learning.
To varying degrees, adults sent into isolation or distant work, or education experience similar mental and physical health outcomes. Thus, every third Russian complained of a depressive mood in connection with the COVID-19 pandemic, sociologists found out. At the same time, the number of people who had suicidal thoughts of at least once has increased by 2 times[13].
The press and the Internet are full of articles about depression in people as a result of a “pandemic” - and these same articles themselves create this panic[14], being largely false and criminal, if only because they are based on the assertion that there is an “epidemic” or “pandemic”
It should also be stated that it will take many years to restore the economy and the psyche of our society, trust in the state and medicine, in each other after the lies and misinformation created, and this lawsuit is part of the mechanism for restoring trust.
In accordance with the provisions of the Constitution of the Russian Federation and Art. 151 of the Civil Code of the Russian Federation, if a citizen has suffered moral harm (physical and moral suffering), by actions that violate his personal non-property rights or infringe on non-material benefits belonging to the citizen, as well as in other cases provided for by law, the court may impose on the offender the obligation of monetary compensation for the specified harm.
According to Article 1101 of the Civil Code of the Russian Federation, moral damage is compensated in cash. The amount of compensation for moral damage is determined by the court, depending on the nature of the physical and moral suffering caused to the victim, as well as the degree of guilt of the tortfeasor in cases where guilt is the basis for compensation for harm. When determining the amount of compensation for harm, the requirements of reasonableness and fairness should be taken into account. The nature of physical and moral suffering is assessed by the court, taking into account the actual circumstances under which the moral harm was inflicted and the individual characteristics of the victim.
In accordance with paragraph 2 of the Decree of the Plenum of the Supreme Court of the Russian Federation of December 20, 1994 No. 10 “Some issues of the application of legislation on compensation for moral damage”, moral damage is understood as moral or physical suffering caused by actions (inaction) that encroach on the property belonging to a citizen from birth or by virtue of the law intangible benefits (life, health, personal dignity, business reputation, privacy, personal and family secrets, etc.), or violating his personal non-property rights (the right to use his own name, the right of authorship and others non-property rights in accordance with laws on the protection of rights to the results of intellectual activity) or violating the property rights of a citizen.
As a result of lies and misinformation about the pandemic and epidemic, we experienced the fear of a deadly mass disease (but over 2 years, even 4 million deaths per 7 billion inhabitants of the Earth cannot be considered such - this is as much as dying from pneumonia according to WHO (2 million per year[15]), but at the same time, the true causes of even this mortality require investigation, since there are many reasons to believe that these statistics are distorted), fear of being left without work and livelihood, fear for loved ones, panic shared by everyone, discomfort from restrictions of elementary rights - to go outside, breathe without a mask, go to visit or go to the store, the need of untested “vaccine” injections, to administer untested drugs, go to the doctor's office at any temperature rise, constant disputes and showdowns due to the fact that yesterday it was still the norm, but now it is impossible, etc.
These two years have led to constant debate among people about what is, what is not, what is right or wrong with COVID-19.
Moral damage was caused by distress due to daily disinformation by the Government of the Russian Federation, contradictions and aggression of the information provided, due to the inability to continue an active social life, going in for sports, loss of work and business, dissemination of false information, increased mortality from not very understandable reasons, which may be related precisely to the panic in the actions of the Russian Government itself, temporary restriction or deprivation of rights - to work, education, movement, due to the occurrence of depressions, fears, conflicts, even attacks of citizens on each other.
The described actions of the Government of the Russian Federation caused harm to our mental health, in connection herewith I ask you to exempt us from the state duty in accordance with Part 3) of Clause 1 of Art. 333.36 of the Tax Code of the Russian Federation - on claims for compensation for harm caused by injury or other damage to health.
In accordance with Art. 28 Code of Civil Procedure of the Russian Federation, the claim is brought to the court at the place of residence of the defendant. A claim against an organization is filed with the court at the location of the organization.
Since, according to paragraph 6 of Art. 244.20 of the Code of Civil Procedure of the Russian Federation, the plaintiffs have the right to join the claim before the debate begins, it is not possible to determine the number of plaintiffs by the time the claim is filed, and therefore I ask the Court to determine the final price of the claim by the time the debate begins.
Based on the foregoing, as well as on the basis of Articles 150, 151, 1095-1101 of the Civil Code of the Russian Federation, Chapter 22.3 of the Code of Civil Procedure of the Russian Federation
I ask the Court:
To oblige the Government of the Russian Federation to compensate for moral damages in the amount of one million rubles for each plaintiff.
Name of the plaintiff's representative
Date of
Full name and signatures of the plaintiffs (at least 20)
Annexes
1. Letter from Rospotrebnadzor 09-23278-2021-40 dated 10/25/2021
2. Letter of the Office of Rospotrebnadzor in St. Petersburg № 78-00-09/21-48337-2021 dated 31.08.2021.
3. Inquiry of the “League of Patients” dated 11.09.2021 to the Ministry of Foreign Affairs of the Russian Federation
4. Letter of the Ministry of Foreign Affairs of the Russian Federation № 11374 / dmo dated 09/28/2021
5. “Analytical report (pathogenicity and contagiousness of a new coronavirus infection (additional materials to the objection regarding the arguments of the collective administrative claim” by Federal State Budgetary Institution N.F. Gamaleya Research Center for Epidemiology and Microbiology) of the Ministry of Health of Russia (pp. 1 and 4 of Appendix № 3 to the Amended objections, Administrative file № AKPI21-77, Decision of the Supreme Court of the Russian Federation of 15.04.2021)16
6. 2 copies of the application for joining the claim for the protection of the rights and legitimate interests of a group of persons - for compensation for moral damage by the Government of the Russian Federation for the illegal use of terms “pandemic” and “epidemic”
7. 2 copies of the claim with annexes hereto
______________________
16The case considered by the Supreme Court of the Russian Federation by to the collective administrative lawsuit to the Government of the Russian Federation on the recognition of the decree of the Government of the Russian Federation of January 2020 № 66 “On the introduction of the change in the list of diseases posing threat to others” as invalid’
Translations of the official letters by the state authorities
Originals are attached below