The summons — seven claimants sue seventeen defendants

Vurich.374465/LSC

This case is being handled by Mr A.G.W. van Kessel, advocate at the law firm Van Kessel Advocatuur, with offices at Orionweg 47E, (8938 AG) Leeuwarden, and by Mr P.W.H. Stassen, advocate at the law firm Stassen & Kemps advocaten, Nachtegaallaan 6, (5611 CV) Eindhoven;

Today, the fourteenth of July two thousand and twenty-three,

at the request of:

1. Mr [claimant 1], residing at [redacted];

2. Ms [claimant 2], residing at [redacted];

3. Mr [claimant 3], residing at [redacted];

4. Ms [claimant 4], residing at [redacted];

5. Mr [claimant 5], residing at [redacted];

6. Ms [claimant 6], residing at [redacted];

7. Mr [claimant 7], residing at [redacted];

all of whom, for the purposes of this case, elect domicile at the office address of Mr P.W.J. Stassen, advocate at the law firm Stassen & Kemps, with offices at Nachtegaallaan 6, (5611 CV) Eindhoven, who has been appointed as advocate in these proceedings and will act as such;

and all of whom also elect domicile at the office address of Mr A.G.W. van Kessel, advocate at the law firm Van Kessel Advocatuur, with offices at Orionweg 47E, (8938 AG) Leeuwarden, who has been appointed as advocate in these proceedings and will act as such;

I, Andries Ietse Haan, bailiff with a place of business in The Hague, with offices there at Regulusweg 11,

HAVE SERVED NOTICE:

TO PROCEED, WITHIN FOURTEEN DAYS OF THE SERVICE OF THIS WRIT, TO A WRITTEN AND UNCONDITIONAL ACKNOWLEDGEMENT THAT THE DECLARATORY JUDGMENT CLAIMED AS THE PRIMARY CLAIM IS ALLOWABLE, BY SENDING A WRITTEN, SIGNED STATEMENT TO THAT EFFECT TO THE CLAIMANTS’ ADVOCATES AT POSTBUS 7004, 5605 JA EINDHOVEN, THE NETHERLANDS.

THIS WITH THE EXPRESS NOTICE THAT, IF THIS DEMAND IS NOT COMPLIED WITH, THIS WRIT WILL BE FILED WITH THE COURT AS A WRIT OF SUMMONS, AND THE AFOREMENTIONED DEBTOR, IF HE DOES NOT COMPLY, OR DOES NOT COMPLY IN TIME, WITH THE ABOVE DEMAND, IS

AND HAVE SUMMONED

(public officials)

1. Mr Everhardus Ite HOFSTRA, residing in [redacted], who is being summoned by separate writ;

2. Mr Jaap Tamino VAN DISSEL, residing in [redacted], who is being summoned by separate writ;

3. Ms Maria Petronella Gerarda KOOPMANS, residing in [redacted], who is being summoned by separate writ;

4. Mr Mark RUTTE, residing in [redacted] at an address which he has asked to be kept confidential, serving my writ at that address and leaving a copy of it and of the exhibits referred to in it at: the aforementioned address, in a sealed envelope bearing the particulars prescribed by law, because I found no one there with whom a copy could validly be left;

5. Ms Sigrid Agnes Maria KAAG, residing in [redacted], who is being summoned by separate writ;

6. Mr Hugo Mattheüs DE JONGE, residing in [redacted], who is being summoned by separate writ;

7. Mr Ernst Johan KUIPERS, residing in [redacted], who is being summoned by separate writ;

8. Mr Diederik Antonius Maria Paulus Johannes GOMMERS, residing in [redacted], who is being summoned by separate writ;

9. Mr Wopke Bastiaan HOEKSTRA, residing in [redacted], who is being summoned by separate writ;

10. Ms Cornelia VAN NIEUWENHUIZEN, residing in [redacted], who is being summoned by separate writ;

(pharmaceutical industry)

11. Mr Albert BOURLA, residing at an address known to the petitioner in New York, United States of America, who is being summoned by separate writ;

(mass media)

12. Ms Giselle Jacqueline Marie-Thérèse VAN CANN, residing in [redacted], who is being summoned by separate writ;

13. Mr Paul Edwin JANSEN, residing in [redacted], who is being summoned by separate writ;

(non-governmental organisation (NGO, WEF))

14. Mr Feike SIJBESMA, residing in [redacted], who is being summoned by separate writ;

15. Mr William Henry Bill GATES III, residing at an address known to the petitioner in Medina, Washington, United States of America, who is being summoned by separate writ;

16. Ms Agnes Catharina VAN DER VOORT-KANT, residing in [redacted], who is being summoned by separate writ;

17. The legal entity under public law THE STATE OF THE NETHERLANDS, having its seat in The Hague (“the State”), which is being summoned by separate writ;

TO:

appear on Wednesday 22 November 2023 at 10.00 hrs, not in person but represented by an advocate, at the hearing of the District Court of the Northern Netherlands, Leeuwarden location, which hearing will be held in the courthouse at Zaailand 102, (8911 BN) Leeuwarden;

WITH NOTICE THAT:

a. if a defendant fails to appoint an advocate or fails to pay the court registry fee referred to below in time, and the prescribed time limits and formalities have been observed, the court will grant judgment in default against that defendant and will allow the claim described below, unless it considers that claim unlawful or unfounded;

b. if at least one of the defendants appears in the proceedings and has paid the court registry fee in time, a single judgment will be given between all parties, which will be deemed a judgment after defended proceedings;

c. on appearance in the proceedings, a court registry fee will be charged to each of the defendants, payable within four weeks from the time of appearance;

d. the amount of the court registry fees is set out in the most recent annex to the Civil Cases (Court Fees) Act (Wet griffierechten burgerlijke zaken), which can be found, among other places, on the website: www.kbvg.nl/griffierechtentabel;

e. a person of insufficient means will be charged a court registry fee for persons of insufficient means as set by or pursuant to law, if, at the time the court registry fee is charged, he has submitted: 1st: a copy of the decision granting legal aid, referred to in Article 29 of the Legal Aid Act (Wet op de rechtsbijstand), or, if this is not possible due to circumstances that cannot reasonably be attributed to him, a copy of the application referred to in Article 24(2) of the Legal Aid Act; or 2nd: a statement from the board of the Legal Aid Council, referred to in Article 7(3)(e) of the Legal Aid Act, showing that his income does not exceed the incomes referred to in the general administrative order under Article 35(2) of that Act;

f. defendants who appear through the same advocate and file identical pleadings or put forward an identical defence will, on the basis of Article 15 of the Civil Cases (Court Fees) Act, be charged a joint court registry fee only once;

IN ORDER TO:

then hear the following claim made and conclusions drawn, on the grounds set out below and on behalf of the claimants, hereinafter jointly referred to as “[claimants]”:

Contents

Definitions and reading guide — 2

Definitions — 2

Reading guide — 2

Exhibits / USB stick — 3

Introduction — 3

Core of this case — 3

Interest and purpose of this case — 4

Claims — 5

Defendant parties — 6

Public officials — 6

Hofstra — 6

Van Dissel — 8

Rutte — 10

Kaag — 13

De Jonge — 15

Kuipers — 20

Gommers — 22

Hoekstra — 24

Van Nieuwenhuizen — 28

Pharmaceutical industry — 29

Bourla — 29

Mass media — 33

Van Cann — 33

Jansen — 37

Non-governmental organisation (NGO, WEF) — 39

Sijbesma — 39

Gates — 43

Semi-public sector — 48

Kant — 48

Lareb does not provide data by batch number — 49

Kant carries out a cover-up operation for the benefit of the Covid-19 project — 50

Kant’s cover-up — 50

Government — 53

Examples of excesses — 54

WEF partner Gates invests in the Dutch WEF partner Heineken — 54

The State and its officials violate the provision of Article 162 of the Code of Criminal Procedure, which is fundamental to a state governed by the rule of law — 55

The State threatens unvaccinated citizens of the Netherlands with death via national television — 56

Claimants’ damage — 56

Unlawful conduct by defendants — 57

Infringement of a right — 58

Acting in breach of a statutory duty — 58

Acting in breach of what is proper in society according to unwritten law — 60

Establishing liability, conditio sine qua non — 61

Group liability — 62

Offer of proof — 62

Jurisdiction of the District Court of the Northern Netherlands, Leeuwarden location — 62

Petitum (relief sought) — 63

Definitions and reading guide

Definitions

1. A number of terms are defined in the text of this summons. To avoid confusion, a number of central terms are set out and explained here already.

2. Covid-19: Wherever this summons refers to Covid-19, this always means the life-threatening lung disease, pretended by the WHO, caused by the alleged Sars-Cov-2 virus. The use of the term Covid-19 in this summons in no way means that the claimants acknowledge that there was a life-threatening lung disease caused by a dangerous pathogen. Nor does the use of the term Covid-19 mean that the claimants acknowledge the existence of the Sars-Cov-2 virus. On the contrary, the claimants take the view that Covid-19 is a project, deployed by NGOs and financed by the World Bank, which project is being carried out by, among others, the defendants.

3. Pandemic: Wherever this summons refers to a pandemic, this always means the Covid-19 pandemic pretended by the WHO. The use of the term pandemic in this summons therefore in no way means that the claimants acknowledge that there was a health risk caused by a dangerous pathogen. On the contrary, the claimants take the view that there is no evidence whatsoever for this.

4. Covid-19 vaccine / Covid-19 injection: Wherever this summons refers to a Covid-19 vaccine or a Covid-19 injection, this always means the injection fluid which the defendants claim is a medicinal product that is supposedly safe and effective in protecting against the pretended Covid-19 disease. The use of the term Covid-19 vaccine or Covid-19 injection in this summons in no way means that the claimants acknowledge that it is a medicinal product. On the contrary, the claimants take the view that there is no evidence of any medicinal effect of the Covid-19 vaccine, so that it is not a medicinal product.

Reading guide

5. As regards the facts presented in this summons with respect to the defendants, [claimants] assert, and also offer to prove further if necessary, that at the time they committed their unlawful conduct all defendants knew of all the facts and circumstances that [claimants] put forward in this summons.

6. In order to avoid repetition, the facts and circumstances that concern the individual defendants in particular will mainly be set out separately for each of them. The order in which the defendants’ unlawful conduct is described in this summons has been chosen deliberately, with the aim of avoiding a deluge of information. For these reasons, the claimants urge that this summons be read in the order presented and in its entirety, so as to obtain a complete picture of the assertions on which the claimants base

the unlawful conduct of each of the defendants.

Exhibits / USB stick

7. As regards the exhibits submitted, a number of them consist of video material. In this connection, this summons is accompanied by a USB stick containing the complete summons, including all exhibits and the video material arranged by exhibit number.

8. Where, in submitting the paper exhibits, only a number of pages of a document are submitted and the complete document is submitted on the USB stick, the following applies: [claimants] thereby submit the complete document placed on the USB stick to your court as an exhibit and as evidence.

9. For all videos, a download suitable for Windows Media Player has been placed on the USB stick. Its label always refers to the corresponding exhibit number. As regards the video material submitted by [claimants], it is expressly noted that [claimants] submit the complete video material placed on the USB stick to your court as an exhibit and as evidence.

Introduction

Core of this case

10. The officially used worldwide narrative concerning Covid-19 is that there is a Covid-19 pandemic caused by a new coronavirus called Sars-Cov-2. On 28 February 2020 this worldwide official narrative was introduced in the Netherlands by the OMT as part of the RIVM. Following this introduction of the narrative, the RIVM reported, among other things, the following in its letter to the Ministry of Health, Welfare and Sport of 28 February 2020:

‘... The virus has now been named SARS-CoV-2, the disease is called Covid-19 ...’

11. The letter from the RIVM to the Ministry of Health, Welfare and Sport of 28 February 2020 is submitted as EXHIBIT 1. In an open letter on the WHO website of 12 March 2020, the WHO informed the world that there was a so-called Covid-19 pandemic and that it was working with the World Economic Forum (WEF) to give the private sector a role in it. As EXHIBIT 2, [claimants] submit a copy of the open letter on the WHO website dated 12 March 2020. According to the official narrative, this pandemic could only be fought if everyone had themselves vaccinated against it with Covid-19 injections. If not everyone was vaccinated, this would endanger the most vulnerable in particular [fn 1]. Vaccination was said to be the only way out of the pandemic, and those who had themselves vaccinated therefore did so not only for themselves, but above all for others. The message has always been that the Covid-19 injections had been extensively tested and were safe and effective.

12. According to the defendants, this narrative forms the basis of their actions. The Covid-19 policy based on this narrative was accepted, embraced and implemented by the defendants without question. All this without any thorough societal, scientific, economic and ethical debate having taken place on it. The defendants maintain that their actions based on this narrative are in the interest of humanity and of public health in particular.

13. [Claimants] had Covid-19 injections administered because the defendants gave them every reason to do so. [Claimants] trusted the defendants because of their positions in society, their knowledge and their responsibilities. In the absence of a thorough public debate on the correctness of the narrative, there was no reason for [claimants] to doubt that the Covid-19 injections had been extensively tested and were safe and effective, and that having them administered would be a benefit to themselves and their fellow human beings.

14. The Covid-19 injections have caused [claimants] serious personal injury.

15. After the damage to health had occurred to them and to many others around them, [claimants] began to ask questions about the narrative concerning the Covid-19 injections. This was what prompted [claimants] to search for what really happened around the alleged pandemic.

16. Over time, an overwhelming amount of information has become available which makes it plausible that the narrative used by the defendants cannot possibly be true. It also follows from that information that the defendants must have known that this narrative was not true. As a result, [claimants] have come to see the defendants’ conduct in a very different light and conclude that the defendants have acted unlawfully towards them. [Claimants] will substantiate their assertions in this respect with evidence in these proceedings.

17. [Claimants] want your court to examine whether their claims are allowable and to decide on them on the basis of what they put forward as the grounds for their claims in these proceedings.

Interest and purpose of this case

18. [Claimants] bring these proceedings on the basis of their legal interest in obtaining the compensation they claim and the declaratory judgment to be formulated below.

19. The motivation of [claimants] to bring these proceedings is prompted in part by the public interest in the fact-finding process that is necessary in order to decide on the claims of [claimants] at law. In view of this public interest, [claimants] seek to serve not only their own interest, but also, and not least, the interest of their fellow human beings.

20. The aforementioned public interest cannot be overstated. The positions of [claimants] and the defendants are irreconcilable and diametrically

opposed to each other. The same opposition is emerging in society and is the cause of great social tensions.

21. [Claimants] want to bring the truth about Covid-19 to light through the intervention of the judiciary.

22. In the context of fact-finding, [claimants] point to two important facts which the judiciary must not disregard. The first is the fact that all defendants form part of a larger whole that is mainly enclosed and led by NGOs. These private entities are numerous and have in common that they present themselves as benefactors. The actions of this larger whole are to a large extent led by defendant sub 15, hereinafter referred to as “Bill Gates”. For this purpose a partnership was set up in the year 2000 under the name Gavi, The Vaccine Alliance (hereinafter referred to as ‘GAVI’). On the GAVI website [fn 2], its influence and its connection with all aspects of vaccination are aptly depicted by means of the following image.

[Image: GAVI alliance diagram; legible labels include “Independent individuals (9)”, “Governments donor countries (5)” and “Bill & Melinda Gates Foundation”.]

23. As the second important fact for the fact-finding process, [claimants] point out that the parties shown in the image above, because of their worldwide influence, have it in their power to determine the narrative concerning Covid-19 and the Covid-19 injections, and have indeed determined it.

24. Only the truth can remove the oppositions identified above and take away social tensions.

Claims

25. [Claimants] claim a declaratory judgment that the defendants are jointly and severally liable for all damage resulting from the unlawful acts committed by the defendants as a group and individually, as described in this summons.

26. [Claimants] claim from the defendants compensation for the personal injury and financial loss they have suffered as a result of the Covid-19 injections, to be assessed in follow-up proceedings for the determination of damages (schadestaatprocedure) and settled in accordance with the law.

Defendant parties

Public officials

Hofstra

27. Defendant sub 1, hereinafter referred to as ‘Hofstra’, is associated in a personal capacity as an expert with the Outbreak Management Team (hereinafter referred to as ‘OMT’) of the National Institute for Safety and the Environment (Rijksinstituut voor Veiligheid en Milieu, hereinafter referred to as ‘RIVM’), and in that capacity is also professionally associated as a physician with the Municipal Health Service of Fryslân [fn 3] (hereinafter referred to as ‘GGD’). In the control of infectious diseases in the Netherlands, the Centre for Infectious Disease Control of the RIVM (hereinafter referred to as ‘CIb’) has an advisory and coordinating role. Hofstra is also chairman of the Dutch Association for Infectious Disease Control (NVIB) and is an adviser at the network centre, where Hofstra’s work consists of writing scenarios for exercises in the field of infectious diseases and supervising those exercises from a so-called response cell. As EXHIBIT 3, [claimants] submit the declaration of interests which Hofstra submitted to the OMT and which shows the aforementioned positions.

28. Through his membership of the OMT, Hofstra had all the information concerning Covid-19 and the Sars-Cov-2 virus that the OMT needed in order to arrive at the best possible advice with regard to fighting the pandemic [fn 4]. This advice was always followed and resulted in the narrative that vaccination was the only way out of the pandemic being accepted by [claimants] as uncontested and true.

29. Hofstra’s advice was always in line with the final advice of the OMT. The OMT did not have data from which, on careful study, the scientific conclusion could be drawn that there was a threat to public health requiring government intervention, let alone the mass administration of Covid-19 injections. At the time this advice was given there was no excess mortality. As EXHIBIT 4, the claimants hereby submit a data table from CBS (Statistics Netherlands) which shows no excess mortality.

30. Hofstra knew that healthcare capacity was not under threat. To the extent that this capacity appeared to be limited at all, this was the result of government healthcare policy, including the use of an unsuitable PCR test and the years-long scaling down of healthcare capacity. As EXHIBIT 5, information is submitted concerning the dismantling of Dutch healthcare capacity set in motion by the government from 1972 onwards. It is noted in this connection that, as regards the size of healthcare capacity for the period after 2018, the government no longer makes any data available. Defendant sub 8, in his capacity as chairman of the intensive care association, stated in an interview in 2021 that the number of IC

beds had been reduced to a total of 950 beds. As EXHIBIT 6, the claimants hereby submit an article from De Telegraaf dated 21 October 2021 which shows this statement by Gommers. When defendant sub 6 took office in 2017, the Netherlands still had 2,056 IC beds.

31. Hofstra is an important participant in the Covid-19 project, which will be described further below. Hofstra placed his positions at the OMT, the NVIB and the Network Centre at the service of carrying out this Covid-19 project. He did so, among other things, by writing scenarios for pandemic exercises held in connection with the Covid-19 project and, as chairman of the NVIB, by leading a misleading pro-Covid-19 vaccination campaign in cooperation with the GGDs for the benefit of the Covid-19 project. All this while Hofstra, as a member of the OMT, knew that the Covid-19 injections did not serve the health of the Dutch population, including [claimants], but served to make it possible to carry out the Covid-19 project. These assertions will be substantiated at length further on in this summons.

32. Hofstra did everything he could to make the mass Covid-19 injection campaign a success for the benefit of the Covid-19 project. In an open letter on the NVIB website of 17 April 2021, Hofstra writes the following about this:

‘... From the start of the pandemic, we at the GGDs have been continuously engaged in carrying out and scaling up source and contact tracing, testing, vaccinating and advising municipalities, institutions and all inhabitants of the Netherlands. At the GGDs, thousands of people have been hired and trained in a very short time in order to perform all tasks as well as possible. And everyone is working incredibly hard to tell people that they have tested positive and to carry out source and contact tracing, or to explain to disappointed callers that unfortunately it is not yet their turn for a vaccination. These are sometimes not easy conversations ...’

As EXHIBIT 7, [claimants] submit a copy of Hofstra’s open letter dated 17 April 2021.

33. Further on in this summons it will become clear that with this open letter Hofstra deliberately misled the Dutch public, including [claimants]. In April 2021 Hofstra knew that the Covid-19 injections, or at least certain batches of them, were life-threatening. Hofstra also knew at that time that the Covid-19 injections offered no protection whatsoever against the alleged virus.

34. Hofstra should have spoken out against the advice of the OMT and, as a physician, should also have opposed the actions of the GGD in which citizens, including young people from the age of 12, were induced by a so-called ‘jab bus’ (prikbus) at schools to take a Covid-19 injection without parental consent. Because all this was advised by Hofstra, or at least because he did not speak out against it, [claimants] continued to follow the narrative and had the Covid-19 injections administered.

35. Hofstra is to blame for the fact that, as a physician, OMT member, chairman of the NVIB and adviser at the Network Centre, he did not take his responsibility and thereby acted with a lack of the due care owed in society towards [claimants], resulting in the damage suffered by [claimants].

[Claimants] would not have had (or could not have had) the Covid-19 injections administered if Hofstra had performed his task with the required due care owed in society. The advice of the OMT would then have been different, or at least Hofstra would have publicly opposed this advice, as a result of which [claimants] would have been sufficiently warned and would not have had the Covid-19 injections administered.

Van Dissel

36. Defendant sub 2, hereinafter referred to as ‘Van Dissel’, has been director of the CIb since 15 August 2013. As already indicated above, the CIb is part of the RIVM. In that capacity Van Dissel is chairman of the OMT. According to the CIb website, the CIb is the point of contact for the World Health Organisation (hereinafter referred to as ‘WHO’) and the Centers for Disease Control of the United States of America (hereinafter referred to as ‘CDC’). In the US the CDC is the equivalent of the Dutch RIVM. In that sense Van Dissel, like the other defendants, is connected to the larger whole as described in this summons. Van Dissel always publicly, knowingly and therefore intentionally defended the evidently unlawful advice of the OMT, in the knowledge that this advice was wrong and harmful and would be followed by the vast majority of the Dutch population.

37. Given Van Dissel’s expertise and the position he holds, Van Dissel created in [claimants] great confidence in the narrative that vaccination was the only way out of the pandemic and that Covid-19 vaccines were safe and effective.

38. On the eve of the vaccination phase, it was Van Dissel who, as director of the RIVM, championed the large-scale roll-out of the vaccinations. In this connection, Van Dissel knowingly cooperated in misleading the Dutch population by means of the lie that vaccination would produce herd immunity [fn 5]. Van Dissel also made possible the role of the RIVM as manager of the large-scale vaccination programme. In doing so, Van Dissel expressed the wish that all vulnerable people be vaccinated as soon as possible. As EXHIBIT 8, an online article from RTL Nieuws dated 9 December 2020 is submitted which shows this.

39. Van Dissel is to blame for the fact that, as chairman of the OMT, he did not take his responsibility and thereby acted with a lack of the due care owed in society towards [claimants], resulting in the damage suffered by [claimants]. [Claimants] would not have had (or could not have had) the Covid-19 injections administered if Van Dissel had performed his task with the required due care owed in society. The advice of the OMT would then have been different, or at least Van Dissel would have publicly opposed this advice, as a result of which [claimants] would have been sufficiently warned and would not have had the Covid-19 injections administered.

Koopmans

40. Defendant sub 3, hereinafter referred to as ‘Koopmans’, is by profession professor of virology at Erasmus MC in Rotterdam. In addition, Koopmans has since 2006 been head of the so-called Viroscience department (department of virus science) of Erasmus MC.

Koopmans is a permanently invited expert of the OMT. Since 2014 Koopmans has been associated with the WHO as a member. Koopmans always publicly supported the advice of the OMT. During the period in which Koopmans supported the aforementioned advice, she had been appointed by the WHO as a researcher and was charged with the investigation which took place in Wuhan and focused on the origin of the Sars-Cov-2 virus. The WHO ended this appointment after journalists from the United States had found out that Koopmans had a seat at the CDC in Guangdong, China, had advised in that capacity on building laboratory capacity for the detection of emerging infectious diseases, and maintained various collaborations in China in the field of research into the emergence of viruses. All this had been publicly concealed by Koopmans. As EXHIBIT 9, the claimants submit a journalistic article written by Luis Miguel and posted on the website of The New American on 12 December 2021.

41. Koopmans closely followed the trials conducted by Moderna and Pfizer for their Covid-19 vaccines. In this connection the claimants refer to the interview Koopmans gave on 10 April 2020 to Mr Bohlmeijer, Goede Gesprekken (Good Conversations) correspondent [fn 6]. As a prominent member of the WHO and of the OMT, Koopmans has all first-hand information concerning the aforementioned trials. As a result, Koopmans knew that Moderna had already started its Covid-19 vaccine trials in 2017 and that Pfizer had started its Covid-19 trials just four days after the Chinese government had released the genetic code of the pretended Sars-Cov-2 virus to the world on 8 January 2020. The claimants will go into the evidence for this assertion in more detail further on in this summons. Koopmans therefore knew that Covid-19 was a project and not a disease. Nevertheless, in carrying out this Covid-19 project, Koopmans followed the official narrative of her important principal, the WHO.

42. As regards Koopmans’ information position, it is of particular importance that Koopmans had at her disposal the Pfizer safety reports, which were then still kept secret, including Pfizer report FDA-CBER-2021-5683-0000054. It follows from the latter report, among other things, that before 28 February 2021 more than 42,000 cases had already been reported to Pfizer, of which 1,223 deaths and 11,361 cases of serious and permanent injury. Koopmans concealed this extremely disturbing information from the public. This report will be discussed later in this summons and will be submitted as exhibit 40.

43. Disinforming the public by concealing important information and spreading incorrect information is a manipulation technique that has frequently been used by the defendants. It is reprehensible and bizarre that it was precisely the defendants, including Koopmans in particular, who, from within the Dutch branch of Gavi, namely the Vaccination Alliance (Vaccinatie alliantie), set up a ‘Disinformation Think Tank’ (Denktank Desinformatie) in the last quarter of 2019. The participants in that Disinformation Think Tank are exclusively persons who are strong advocates of the mass vaccination of people. In her role as a participant in the Disinformation Think Tank, Koopmans developed and applied a ‘frame of thought’ (denkkader) aimed at steering public debate. The direction in which it was steered was exclusively pro mass vaccination. The frame of thought

used to give shape to that steering made use of the social polarisation surrounding whether or not to take Covid-19 injections. A report was drawn up following a third meeting of the Vaccination Alliance and the Disinformation Think Tank. This report includes, among other things, the following quotations:

‘... The think tank can take on several roles, precisely because of the diverse profile of its members. To deliberately engage in conversation with the middle group, the right tone must be found. It is then not only about facts, but precisely also about the (emotional) dynamics of the group. By recruiting the right influencers, with whom you can win trust, this group gets the feeling of being heard and understood ...’

‘... 4. Good to focus on various people who take a position and show leadership; these can be experts from their professional background, but you can also deploy an authentic person (e.g. a well-known footballer) to proclaim a one-off message “I am taking the vaccine” ...’

44. As EXHIBIT 10, [claimants] submit the report of the third meeting of the Vaccination Alliance and the Disinformation Think Tank.

45. Koopmans concealed her role in the Disinformation Think Tank and concealed that public debate was being steered in favour of mass vaccination by her and by the influencers recruited by the Disinformation Think Tank. It is shocking in this respect that Koopmans, in her position as a member of the OMT, had the aforementioned Pfizer report FDA-CBER-2021-5683-0000054 at her disposal and concealed precisely the information available from it, and the conclusions to be drawn from it, from the public, including [claimants]. In the opinion of [claimants], it is therefore established that Koopmans spread disinformation and that the Disinformation Think Tank in reality had precisely the aim of ensuring that the public was falsely informed by means of influencers recruited for that purpose. All this in order to make mass vaccination with Covid-19 injections – which Koopmans knew to be harmful – possible for the success of the Covid-19 project.

46. Koopmans is to blame for the fact that she did not take her social responsibility as a scientist and as a member of the OMT and the WHO and thereby acted with a lack of the due care owed in society towards [claimants], resulting in the damage suffered by [claimants]. [Claimants] would not have had (or could not have had) the Covid-19 injections administered if Koopmans had performed her task with the required due care owed in society. The advice of the OMT would then have been different, or at least Koopmans would have publicly opposed this advice, as a result of which [claimants] would have been sufficiently warned and would not have had the Covid-19 injections administered.

Rutte

47. Defendant sub 4, hereinafter referred to as ‘Rutte’, is Prime Minister of the Netherlands and a prominent member of the World Economic Forum (hereinafter referred to as ‘WEF’). As EXHIBIT 11, the claimants hereby submit the details of Rutte and his former employer Unilever as published on the website of the

WEF, together with a number of photographs showing the relationship between Rutte and the president of the WEF, Mr Klaus Schwab [fn 7].

48. Schwab is Rutte’s superior. This is apparent, among other things, from various letters from Schwab to Rutte. As an important example of such a letter, [claimants] submit as EXHIBIT 12 a letter from Schwab to Rutte dated 21 October 2020. This letter shows that ideas and plans are being forged within the WEF to reform the so-called post-Covid-19 world. In this letter Schwab instructs Rutte to ensure that the Netherlands leads these reforms in Europe. These reforms have already been referred to above as the Covid-19 project. The Covid-19 injections are crucial in this. Rutte accepted this assignment and is carrying it out on behalf of the WEF, which explains why Rutte advises the Dutch population, including [claimants], to take Covid-19 injections.

49. Rutte systematically, in cooperation with the defendants, in particular defendant sub 6, put the narrative out in many public speeches and in doing so abused his office as Prime Minister. Rutte was guilty of the ‘you do it for someone else’ doctrine, by which people who made the entirely normal choice to continue their lives in the manner customary for a flu season were cast as irresponsible and harmful to society. The Covid-19 measures taken under Rutte’s leadership had nothing to do with public health, but with carrying out the Covid-19 project. Rutte’s presentation of the Netherlands as a ‘sick patient’ and of the Covid-19 measures – with Covid-19 vaccination as their central theme – as a ‘medicine’ were ingredients that Rutte abused to mislead the Dutch population, including [claimants], in such a way that they would accept the Covid-19 measures. [Claimants] cite the following examples in this regard.

50. At the press conference of 23 February 2021, Rutte stated, among other things, the following.

‘... What we are doing today remains incredibly tense, even though they may seem like small steps. We must be very well aware of that. That is precisely why those basic rules [fn 8] are so important. And that is precisely why it is so important that we press on at full speed along the road that Hugo de Jonge will now update you on. The road which, through testing and vaccinating, will hopefully lead to a summer with far fewer restrictions ...’

51. Following on from this, De Jonge said the following about the road on which, according to Rutte, hope was to be placed:

‘... With the start of vaccination the end of the crisis has begun, but the end itself will take a while yet. That road out of the crisis runs along three tracks. Until enough people have been vaccinated, measures and intensive testing remain necessary. That we are nevertheless allowing more again while the figures are slowly rising is, as Mark already said, incredibly tense ...’

‘Vaccinating. That is going faster and faster. The millionth jab has been given. We expect to give the two millionth in mid-March, and at the end of March, the start of April, we will be at three million – if all goes well with the deliveries, of course, because the speed at which the vaccines come in determines the speed at which we can vaccinate.

There are also hopeful first signs of how the vaccines protect against transmission of the virus’

52. As EXHIBIT 13, the claimants submit information concerning the press conference given by Rutte and De Jonge on 23 February 2021.

53. During the press conference of Rutte and De Jonge of 11 May 2021, they explain what ‘step 2 of the plan for reopening society’ looks like. Rutte states, among other things, the following about this.

‘... As you know, we are on our way to what will hopefully be a fine summer thanks to the vaccinations. Hugo de Jonge will say more about that in a moment, and also about our expectations for the summer holiday and the accompanying travel advice ...’

54. Following on from this, De Jonge said the following about the expectations for the summer holiday.

‘... It may well turn out to be a fine summer. The vaccination campaign is well under way. This week the seven millionth jab will be given, and in the second half of May [2021] [fn 9] all people aged sixty or over and all people at high medical risk – such as people with leukaemia or people with Down’s syndrome – will in any case have had their first vaccination. And that is an important milestone we have been working towards ... And in addition we have succeeded in offering a first vaccine to everyone who works in care with vulnerable people ...’

As EXHIBIT 14, the claimants submit information concerning the press conference given by Rutte and De Jonge on 11 May 2021, together with, as an example, a similar press conference with the same set-up in the United Kingdom.

55. Rutte knew that the narrative concerning the so-called Covid-19 pandemic was not true and that the Covid-19 injections – in particular certain batches – cause serious bodily injury. The hope held out by Rutte was in reality nothing other than a way of misleading the Dutch people so as to allow the Covid-19 project to succeed. Rutte’s deception was unprecedentedly vile, all the more so since, at the time of his statements quoted above, he already knew that in the Pfizer trial cited above in connection with Koopmans (Pfizer report FDA-CBER-2021-5683-0000054), more than 1,200 people had by then been reported dead and, according to reports, more than 11,000 people had suffered serious permanent bodily injury after taking the Covid-19 injections.

56. On 10 October 2022 a hearing took place in the European Parliament at which Ms Janine Small, a director of Pfizer, formally admitted before the hearing committee that Pfizer had never tested the Covid-19 vaccine for preventing transmission. Rutte is aware of this. From this, too, Rutte knew that the ‘you do it for someone else’ doctrine he propagated is a lie and is intended solely to induce people, by means of psychological deception, to have Covid-19 injections administered. As EXHIBIT 15, the claimants hereby submit part of the hearing of Pfizer and the short interview by Ongehoord Nederland dated 12 October 2022,

in which Rutte is confronted with Ms Small’s statement, dismisses it as nonsense, and indicates that he still stands behind the Covid-19 vaccinations and advises everyone ‘just’ to get vaccinated with them.

57. Rutte is to blame for the fact that he did not take his political and social responsibility as Prime Minister of the Netherlands and that he thereby acted with a lack of the due care owed in society towards [claimants], resulting in the damage suffered by [claimants].

58. Rutte committed his unlawful conduct with the aim of supporting the interests of Schwab and the WEF in the Covid-19 project. Article 97a of the Criminal Code (Wetboek van Strafrecht) provides as follows in this regard:

‘Any person who enters into contact with a person or body established abroad with the aim of inducing such a person or body to provide support for preparing, promoting or bringing about a revolution (omwenteling), of strengthening such a person or body in an intention formed to that end, or of promising or providing assistance to such a person or body in this regard, or of preparing, promoting or bringing about a revolution, shall be punished by life imprisonment or a fixed term of imprisonment not exceeding thirty years or a fine of the fifth category’

59. As indicated in the reading guide, all the conduct complained of is attributed to all defendants. Thus what has been observed above with regard to Article 97a of the Criminal Code applies equally to Hofstra, Van Dissel and Koopmans.

60. [Claimants] would not have had (or could not have had) the Covid-19 injections administered if Rutte had performed his task with the required due care owed in society. The policy of the Dutch government would then have been different, or at least Rutte would have publicly opposed the narrative, as a result of which [claimants] would have been sufficiently warned and would not have had the Covid-19 injections administered.

Kaag

61. Defendant sub 5, hereinafter referred to as ‘Kaag’, holds the office of Minister of Finance and is a prominent member of the WEF. Before taking up this office, Kaag worked mainly for the United Nations (hereinafter referred to as ‘UN’), which, through the WHO affiliated with it, plays an important role in the larger whole referred to above. During her ministerial term Kaag started working for the WEF, where she forms part of a so-called think tank. In this think tank plans are devised for carrying out a total reorganisation of, among other things, Dutch society. This reorganisation is referred to by the WEF as ‘Covid-19: The Great Reset’. In order to be able to carry out the Great Reset, it is of great importance that, in countries, the ‘Sustainable Development Goals’ (hereinafter referred to as SDGs) included by the UN in Agenda 21 (from 1992) and Agenda 2030 (from 2015) become the standard for the reorganisation of societies in all countries that are members of the UN. Kaag’s participation, as a Dutch Minister, in a think tank of an

NGO, more specifically the WEF, is contrary to Kaag’s constitutional position, because the Great Reset is not in the interest of the Dutch population and therefore not in that of [claimants] either. Furthermore, the plans for the Great Reset and its impact on the entire Dutch people have never been submitted to the Dutch parliament. Devising and carrying out the Covid-19 project and the Great Reset qualifies as an unlawful act by Kaag towards [claimants].

62. Kaag presents herself as the Minister who, in the context of the Great Reset, is to coordinate the SDGs at national level and who, in that context, is a member of a stream of thinkers at the WEF. As EXHIBIT 16, the claimants submit a recording of an interview with Kaag in which Kaag presents herself as such. This recording also shows what The Great Reset will entail.

63. The Great Reset is premised on nothing being good any longer and on everything having to be done anew – without the consent or consultation of the population –, differently and therefore, according to the WEF, better. This same body of thought is imposed on the world by the UN through its Agenda 21 and Agenda 2030. In doing so, the UN uses the slogan ‘Build Back Better’. Worldwide, many politicians in positions comparable to that of Kaag have propagated this body of thought and have used the slogan ‘Build Back Better’. As Minister of Foreign Affairs, Kaag commits herself to this Build Back Better mission of the WEF and the UN. As proof of this, [claimants] submit as EXHIBIT 17 a letter from Kaag dated 27 May 2021 to the WHO (as part of the UN and affiliated with the WEF) in which she shows her broad support for the Build Back Better mission.

64. The body of thought of Kaag and her think tank, and the many subjects and systems that according to Kaag’s body of thought must be implemented in present-day society, have been visualised by the WEF in an image. This body of thought is disseminated by the WEF through its website and through the book Covid-19: The Great Reset by Klaus Schwab of 13 July 2020, which can be downloaded free of charge [fn 10]. Schwab promoted the Great Reset at the beginning of June 2020 by means of a video message from the WEF. The aforementioned image visualising the body of thought for which Kaag stands, an image and download of the book Covid-19: The Great Reset by Klaus Schwab, and the aforementioned video message are submitted by the claimants as EXHIBIT 18.

65. A core condition included in the plans for carrying out the Great Reset is the vaccination of the entire population with Covid-19 injections in order to counter an ‘existential future health crisis’ pretended in the official narrative of the WHO and the WEF. In the plans of the WEF and the WHO, the population, in particular the Millennial generation and future generations, is urged to call on the international community without delay to ensure vaccination for everyone. The message here is that no one will be safe until everyone has been vaccinated. As EXHIBIT 19, the claimants submit two video messages from Klaus Schwab of 26 January 2021 and July 2022 respectively, in which Schwab sets out the body of thought – which Kaag champions –

and states that no one will be safe until everyone has been vaccinated.

66. As a Minister and member of the WEF, Kaag champions these plans and thereby also champions Covid-19 injections. All this while Kaag knows that during the Pfizer trials mentioned several times in this summons many people died and thousands of people suffered serious permanent bodily injury.

67. The Covid-19 project is crucial in order to realise the Great Reset advocated by Kaag and the other defendants. In order to ensure that the WEF can steer and control the Dutch government in the context of the Covid-19 project, Kaag’s Ministry, among others, has ensured via the Permanent Representation (PV) that information is exchanged directly between the WEF and her Ministry. All this without the Dutch parliament being informed of it. This makes it perfectly clear that Kaag, like the other defendants, does not serve the interests of the Dutch population and therefore not those of [claimants] either. What has been stated in connection with Rutte about Article 97a of the Criminal Code also applies to Kaag.

68. As EXHIBIT 20, the claimants submit information concerning the Permanent Representation of the Netherlands in Geneva and Kaag’s answer to parliamentary questions in which she acknowledges her dual role.

69. Through her background, positions and connections, Kaag, like all the other defendants, knows that the narrative is false. In particular, Kaag abused her office as Minister by actively participating, without parliamentary consent and scrutiny, in carrying out the Great Reset and the Covid-19 project through, among other things, the private NGO, the WEF.

70. Kaag is to blame for the fact that she did not take her political and social responsibility as a politician and Minister and that she thereby acted with a lack of the due care owed in society towards [claimants], resulting in the damage suffered by [claimants]. The policy of the Dutch government would not have come about without Kaag’s unlawful conduct. Kaag should not have cooperated with the plans of the WEF and the WHO and, as a Dutch Minister, should have publicly opposed the narrative, which she failed to do.

71. [Claimants] would not have had (or could not have had) the Covid-19 injections administered if Kaag had performed her task with the required due care owed in society.

De Jonge

72. Defendant sub 6, hereinafter referred to as ‘De Jonge’, held the office of Minister of Health, Welfare and Sport in the period from March 2020 up to and including December 2021 and is a prominent member of the WEF. As EXHIBIT 21, the claimants submit a printout of a page of the WEF website which shows De Jonge’s membership of the WEF.

73. As Minister of Health, Welfare and Sport, De Jonge was responsible for the conduct of affairs within the RIVM. Under De Jonge’s leadership, the RIVM implemented and carried out the Covid-19 strategy of the WHO. This strategy rests on military psychological behaviour-influencing tactics. These tactics are based mainly on arousing great fear, in this case of a pretended deadly virus. This with the aim of misleading the population. In the Covid-19 project, this deception served to induce as many people as possible to have Covid-19 injections administered. In doing so, De Jonge fulfilled the task evidently assigned to him by the WHO and the WEF of misleading as many people as possible into having the Covid-19 injections administered. As EXHIBIT 22, the claimants submit information from the website of the national government (Rijksoverheid) in which, in implementation of the Covid-19 strategy, the aforementioned military psychological behaviour-influencing tactics were made government policy by De Jonge.

74. The WHO declared the Covid-19 pandemic on 11 March 2020. Immediately after the pandemic was declared, De Jonge carried out the task assigned to him by NGOs of deploying the aforementioned behaviour-influencing techniques against the Dutch population, including [claimants]. In response, De Jonge was confronted by many concerned Dutch citizens about the way in which he was inducing people to have Covid-19 injections administered. As an example of the latter, [claimants] refer to a plea by Mr Frank Ruesink [fn 11] on 16 April 2020, of which a video recording was made which is submitted by the claimants as EXHIBIT 23. This video shows Mr Ruesink pointing out to De Jonge that Covid-19 injections are only one of many options for countering the pretended pandemic, and praying and begging De Jonge to look at those alternatives as well. In response, De Jonge pulls a dubious face and indicates that he regards the instructions of the WHO as leading. This reaction by De Jonge can only be explained by the malicious intent with which De Jonge and the other defendants are carrying out the Covid-19 project. As proof of that malicious intent, the claimants refer to two e-mail messages, of 15 May 2020 and 25 May 2020 respectively, that came to light through Wob requests (Government Information (Public Access) Act requests). The claimants submit these messages as EXHIBIT 24. In the e-mail message of 15 May 2020, De Jonge’s Ministry states:

‘... As regards public support: when it comes to behavioural change, there is quite often a gap between the (intentional) willingness to change and actual behaviour. Cf. also indications about app use abroad. Perhaps the gap here is smaller if the carrot is dangled that there will be fewer restrictions on freedom in the future?’

75. In the e-mail of 25 May 2020, De Jonge’s Ministry states:

‘... First point: in the explanatory memorandum (mvt) we will of course also set out why this law is being placed precisely in the Wpg (Public Health Act), but the first three arguments for making a law come from the 1 May letter (the only angles on which we agree). The fourth is a kind of logic

- democratic legitimacy; - restriction of fundamental rights; - rules for a longer term than emergency ordinances, but still temporary. - flexible, so everything by ministerial regulation The point is that in doing so we are of course also implicitly admitting that the emergency ordinances lack democratic legitimacy and are a shaky basis for the restrictions of fundamental rights, but we do not say that [fn 12]. With temporariness and flexibility, emergency ordinances are actually fine ..’

76. This e-mail continues:

‘... What we do say is that the bill strikes an optimal balance for the dilemma that extending the objectives of the bill inevitably produces (that sentence was my own and I am still proud of it), because under that heading anything you like can follow. We’ll produce a few sentences tomorrow. Good night’s rest’

77. During the period of his aforementioned ministerial term, he, together with Rutte, caused enormous fear of Covid-19 among the population in many public statements. Those public statements consisted to a large extent of press conferences on television which took place following periodic OMT advice. At those press conferences, freedom-restricting Covid-19 measures were announced on the basis of the Covid-19 narrative. The message was that the measures could be lifted only if the vast majority of the Dutch population had Covid-19 injections administered. In the situation thus presented by De Jonge, De Jonge appealed countless times to humanity. He did so by constantly holding out to the public that whoever has a Covid-19 injection administered is doing a good deed, because that person is supposedly doing it for someone else. Through this great lie and deception, many people, including [claimants], felt called upon to have themselves injected with Covid-19 injections.

78. The claimants point out once again, for the sake of completeness, that the assertions they put forward in respect of each of the defendants apply to all defendants as regards their knowledge of what was really going on and of the role they played in it. Against this background it is almost incomprehensible that De Jonge, who also knew of the Pfizer trials, for example, intentionally misled so many people, including [claimants], and intentionally endangered their lives and health.

79. Illustrative of the great deception of Dutch citizens, including [claimants], by De Jonge is the interview with ‘Dit is Robbert’ on the YouTube channel ‘Open kaart’ from December 2020. In this interview, among other things, the following statements by De Jonge, shown in italics, come up. Reference is always made to the time stamp in the video. The interviewer’s questions and answers are placed in brackets. A screenshot of this video is submitted as EXHIBIT 25.

(3:36) If you had known, of course, what you would end up in, then we would of course have prepared very differently for that pandemic.

80. In this part of the interview, De Jonge conceals that he is engaged in carrying out the Covid-19 project, which involves a schedule known to him.

(32.53) Well, actually a vaccine has only pros. A vaccine really has only pros.

81. As will be explained at length further on in this summons, this is a Covid-19 injection that entails great health risks, so that this statement is a blatant lie.

(33.03) The existence of vaccines is a blessing for mankind, is a triumph for science. A triumph for science is that this vaccine has been developed in such a short time.

82. As will be explained at length further on in this summons, the so-called vaccines had already been developed for the benefit of the Covid-19 project before the pretended pandemic was declared by the WHO.

(33.59) And what we have done is actually make agreements with companies in advance: we are going to invest a great deal of money, would it then be possible to start production already, at the same time as the development and research of the vaccine? And that is actually how it has come about that it is now going much faster; techniques are being used that have often been tried and tested, so that is the reason it can now go much faster, but we have in no way cut corners. All safety requirements are simply being met. And that is important because confidence in such a vaccine is important. So if EMA says – the EMA is the European institute, the European medicines authority – if it says green light, then there really is a stamp of: this is sufficiently safe, sufficiently effective, you can simply start using it.

83. De Jonge speaks about investing money. In doing so he shows that he is not working for the Dutch government, but for another party which he refers to as ‘we’. After all, the Dutch government did not invest in the development and research of Covid-19 vaccines. The EMA did not declare that the Covid-19 vaccine is safe and that you can simply use it. It was an experiment which by its nature is not safe.

(35.28) You know. A vaccine, er, that is. You don’t take a vaccine for yourself, you don’t do it to protect yourself, but you actually do it to protect the people around you, the people you love. I think we should also say that to each other. I sometimes hear people say: well, I’ll have to see whether I actually want it and so on. Then I think, yes, guys, hello, er, that is not on. We are in the very worst crisis since the Second World War. We have to turn that page as quickly as possible. Er, we are weighed down by all the measures we have to take to keep that virus under control. On the front line of care at the GGDs they have been in crisis mode for ten months now. They are working themselves to the bone and you see sickness absence rising. They can barely keep it up. All we have to do is quickly go and get a little jab. And then sit there being a bit prissy saying, er, well, I’ll have to see whether I actually want it. Well, that is of course not on. I hear people say, yes, I don’t know exactly what’s in it. I don’t know exactly what’s in it. Then I think, mate, you’ve eaten frikandellen all your life and you don’t know exactly what’s in those. Er. Here it has really been tested inside out, er, whether it is sound and whether it is right and whether it is safe; side effects have been mapped. You know, this is simply the very best thing that could happen to us in this crisis. Yes, and we should thank the good Lord on our bare knees that this vaccine exists, and of course simply use it.

84. Here De Jonge applies the military psychological behaviour-influencing tactics. In addition, he intentionally gives false information about the tests and the safety of the Covid-19 vaccines. The comparison with frikandellen is unworthy of a Minister and in flagrant breach of the fundamental-rights provision of Article 7 ICCPR (NBPR).

(38.44) So England started jabbing before the EMA had said this is sound. And that was actually when there were still too few research results from that third phase, that third research phase. So you have different research phases. The third clinical phase is that the vaccine is used in a large group of people and it is checked whether there are side effects, what contraindications there are, and the result of that third clinical phase has to be submitted to the EMA, and the EMA then says this is sound or not. So it then gives a green light. And the English already started before the EMA had taken that decision. They did that with an emergency procedure. I deliberately did not do that, because I think you are then really cutting corners. And then you get people saying, yes, but is it actually sound, because not even all the research results were awaited before you started jabbing. I do not think that is responsible. So I deliberately did not do that.

85. Here De Jonge shows that he is familiar with the previously mentioned Pfizer trials and with the Pfizer safety reports, which were then still kept secret from the public, including Pfizer report FDA-CBER-2021-5683-0000054. De Jonge knew that the Pfizer trial had been in the third clinical phase since 1 December 2020 and that there were by then already many reports of deaths and serious permanent bodily injury among the participants in this third clinical trial. De Jonge concealed this crucial information. This trial, with all its dead and injured, was no reason for De Jonge to refrain from the Covid-19 vaccination campaign. In this way, too, De Jonge acts as executor of the Covid-19 project and harms the interests of Dutch citizens, including [claimants].

[A large part of the Netherlands that is perhaps still hesitating, a large part would already be tackled if they saw that you would then actually do it too] (39.38) I would have no problem whatsoever doing it in public. Or something. If that helps confidence, I would have no problem whatsoever with that. My only hesitation about doing it first is that I would then also be taking the first place of someone who needs it much more than I do. So I don’t want that, I would not find that OK, because then I am actually taking the jab that was meant for someone else.

86. Here too there is a form of behaviour influencing that is utterly impermissible for a Minister. What is extremely sad here is that De Jonge is thereby targeting young persons in particular.

(40.30) ... at that moment we will explain to your viewers why it is so incredibly important to get yourself vaccinated. That you are not doing it for yourself but to protect the people around you, and that it is perfectly safe. And will you get jabbed then too? [certainly]. That’s good.

87. As set out in this summons, the Covid-19 injections were never tested for preventing transmission before being placed on the market, so that the mantra ‘you do it for someone else’ is false and misleading. By speaking of ‘perfectly safe’, De Jonge misleads the public, including [claimants]. Incidentally, the arrangement pretended in the interview between De Jonge and the interviewer, that they would have themselves ‘vaccinated’ at the same time and that an explanation would be given to the viewers in that context, was not honoured.

88. At the end of his aforementioned ministerial term, De Jonge stated as follows during an interview for VARA OP1 on 7 January 2022:

‘... In the Netherlands we have a small, magnified minority that does not get jabbed. I simply don’t understand how, under the guise of freedom, you say: I refuse that jab, because freedom. Yes, it is precisely that jab that helps us win back that freedom from the virus. It is not the government that restricts your freedom, it is the virus that restricts your freedom ...’

89. This quotation shows how De Jonge is focused on falsely bringing about behavioural change in the context of the Covid-19 project he is to carry out. As EXHIBIT 26, the claimants submit a video of De Jonge’s interview on VARA OP1 on 7 January 2022.

90. De Jonge is to blame for the fact that he did not take his political and social responsibility as a Minister of the Netherlands and that he thereby acted with a lack of the due care owed in society towards [claimants], resulting in the damage suffered by [claimants]. The policy of the Dutch government would not have come about without De Jonge’s unlawful conduct. De Jonge should not have cooperated with the plans of the WEF and the WHO and, as a Dutch Minister, should have publicly opposed the narrative, which he failed to do. What has been stated in connection with Rutte about Article 97a of the Criminal Code also applies to De Jonge.

91. [Claimants] would not have had (or could not have had) the Covid-19 injections administered if De Jonge had performed his task with the required due care owed in society.

Kuipers

92. Defendant sub 7, hereinafter referred to as ‘Kuipers’, became Minister of Health, Welfare and Sport in January 2022, succeeding De Jonge. As far as is known, Kuipers had no political career visible to the public before this ministerial term. Before his ministerial term, Kuipers was chairman of the executive board of Erasmus MC from March 2013 to January 2022 and was thus in fact the boss of Koopmans, who had been head of the department of virus sciences there since 2006. During this period Kuipers was also a paid speaker and adviser for the vaccine manufacturer AstraZeneca.

In April 2021, before he took office as Minister, Kuipers was a fierce opponent of stopping AstraZeneca Covid-19 injections for people under sixty. This even after Kuipers’ professional peers at AstraZeneca had made it known that they regarded the Covid-19 injections as a danger to public health.

93. During the period in which [claimants] had the Covid-19 injections administered, Kuipers was regularly seen on television in his capacity as chairman of the National Acute Care Network (Landelijk Netwerk Acute Zorg, LNAZ), the network that brings together the hospitals in the Netherlands that have an intensive care department. In that capacity Kuipers ‘reported’ on an allegedly great threat of a shortage of IC beds.

94. In doing so, Kuipers made it appear as if a possible shortage could arise as a result of an expected influx of Covid-19 patients. Painting this scenario contributed considerably to the fear of Covid-19 that had already arisen in society as a result of statements by the other defendants. There was never any shortage of IC beds, despite the fact that during the years preceding the pretended Covid-19 pandemic IC capacity worldwide, and also in the Netherlands, had already been sharply reduced as a result of government policy.

95. In line with the narrative, Kuipers stressed in a television broadcast on Thursday 30 December 2020, even before the first vaccination round, that it would be crucial for staff to remain available to provide care. Kuipers was referring in particular to general practitioners, ambulance staff, and hospital staff in accident and emergency, in intensive care and on the Covid-19 wards. Kuipers considered that for this reason vaccination of these groups had to start immediately. As EXHIBIT 27, the claimants submit a screenshot of the interview on Nieuwsuur dated 31 December 2020.

96. On 30 December 2020 the third clinical Pfizer trial mentioned several times was about halfway through. Kuipers’ predecessor, De Jonge, referred to this trial in the interview with ‘Dit is Robbert’ on the YouTube channel ‘Open kaart’ from December 2020. In that interview De Jonge described the Covid-19 vaccines as ‘perfectly safe’. Pfizer was the first supplier of Covid-19 vaccines for the Covid-19 injection campaign, which started on 8 January 2021. At that time the Pfizer Covid-19 vaccine had not been authorised and, moreover, many dead and injured were already to be lamented in that trial.

97. Kuipers’ push to start administering unauthorised Covid-19 injections on Monday 4 January 2021, or on the planned date of 8 January 2021, was flagrantly unlawful. All the more so because these Covid-19 injections were in a trial which Kuipers knew had already seen many dead and injured in December 2020. In view of these facts and circumstances, Kuipers’ push to administer Covid-19 injections to all essential care staff as early as 4 January 2021 shows malicious intent. [Claimants] are of the opinion that the possible doom scenarios of shortages painted by Kuipers had no purpose other than to serve the Covid-19 project.

98. Through his television appearances and public statements before his ministerial term, Kuipers contributed significantly to the deception of [claimants], which led to [claimants] having every reason to have the Covid-19 injections administered.

99. During his ministerial term, on 15 February 2022, on the occasion of a coronavirus press conference, Kuipers was able to deliver an apparently sympathetic message by announcing as Minister that the Covid-19 measures were largely being lifted and that the Netherlands was reopening. Despite this announcement, Kuipers continued thereafter too, knowing that the narrative is fraudulent, to hold on to the ‘necessity’ of having Covid-19 injections administered to people on a large scale. Kuipers is implementing a policy aimed at this. It should be borne in mind here that the Pfizer report on the third clinical phase of 30 April 2021 was known to Kuipers. As already indicated above, Pfizer reported in this report 1,223 deaths and 11,361 people with permanent serious bodily injury. Under Kuipers’ responsibility these injections are, to this day, administered to mostly defenceless people without any form of informed consent, and the harmful effects of the Covid-19 injections are concealed by Kuipers. What has been stated in connection with Rutte about Article 97a of the Criminal Code also applies to Kuipers.

100. Kuipers is to blame for the fact that he did not take his political and social responsibility as a Minister of the Netherlands and that he thereby acted with a lack of the due care owed in society towards [claimants], resulting in the damage suffered by [claimants]. The policy of the Dutch government would not have come about without Kuipers’ unlawful conduct. As a Dutch Minister, Kuipers should have publicly opposed the narrative, which he failed to do. [Claimants] would not have had (or could not have had) the Covid-19 injections administered if Kuipers had performed his task with the required due care owed in society.

Gommers

101. Defendant sub 8, hereinafter referred to as ‘Gommers’, has been associated with Erasmus MC since 2014 as a specialist in the field of intensive care medicine [fn 13].

102. In the period from February 2016 up to and including February 2022, Gommers was chairman of the Netherlands Society of Intensive Care (Nederlandse Vereniging voor Intensive Care, hereinafter referred to as ‘NVIC’) and, according to the RIVM website, a permanently invited member of the OMT.

103. In 2009 the pharmaceutical manufacturer Pfizer and the NVIC concluded a cooperation agreement that involved more than merely providing financial support. This cooperation was carried out under Gommers’ leadership. In view of this, there are close ties between Pfizer, the NVIC and Gommers. As EXHIBIT 28, [claimants] submit an article from the Netherlands Journal of Critical Care dated 2 April 2009 which shows this.

104. Kuipers’ statements in the television broadcast of 31 December 2020, as described above in connection with Kuipers (exhibit 27), were confirmed by Gommers, who reinforced them by calling for Covid-19 injections to be administered with priority to all care workers starting on Monday 4 January 2021. When asked, Gommers indicated in this broadcast that he was free that day, so that he himself could collect the boxes of Covid-19 injections from the central warehouse in Oss.

105. On 6 January 2021 Gommers had an alleged Covid-19 injection administered and, in front of the media, sang the praises of science and the pharmaceutical industry, which had cooperated ‘really brilliantly’ and had supposedly made the Covid-19 vaccine as quickly as possible. Gommers said on this occasion: ‘We must now together make sure as quickly as possible in the coming months that everyone is vaccinated. Then we will pick up our normal lives again’. It should be borne in mind that at the time of all this, the Pfizer trial mentioned several times was about halfway through the third clinical phase, so that there was no reason grounded in the facts to sing anyone’s praises. In reality this was pure deception in order to make the carrying out of the Covid-19 project possible. The behaviour-influencing tactic Gommers used for this at that moment was characterised by a combination of presenting himself as a competent and reliable physician and displaying euphoria about a new Covid-19 injection. That combination served to arouse in the Dutch people, including [claimants], the psychological state of becoming euphoric about the Covid-19 injections themselves and having them administered just like Gommers [fn 14], so that normal life could be picked up again. As EXHIBIT 29, [claimants] submit an article from NOS Nieuws dated 6 January 2021 about Gommers’ Covid-19 injection.

106. In order to win over also those who had not had the Covid-19 injections and the later ‘boosters’ administered, Gommers adjusted his behaviour-influencing tactic. Gommers did this by giving the impression of being ‘critical’ of the Covid-19 policy. Precisely by adopting an attitude that at first sight seemed critical, Gommers won trust in particular among people working in care who were in doubt as to whether they should have a Covid-19 booster injection administered. In doing so, Gommers created the false impression that it would be possible to decide in a well-considered manner to have a Covid-19 booster injection administered. A well-considered decision can, however, only be taken when sufficient (public) information is available about the content of the Covid-19 injections and their short- and long-term effects. That information did exist, but it was kept secret from the Dutch people, including [claimants].

107. Moreover, an important argument put forward by Gommers before having the Covid-19 booster injection administered was that he would be doing this for the benefit of the patients in his hospital. In this way Gommers too made use of the mantra ‘you do it for someone else’. That argument of Gommers was also false, because there were no research results on the prevention of transmission through vaccination. On the contrary, Gommers, like Pfizer and all the other defendants, knew that transmission had never been tested, because this was evidently not relevant to the Covid-19 project.

108. In view of Gommers’ knowledge and expertise, including the report on the Pfizer trials mentioned several times and the close ties between Gommers and Pfizer, Gommers knew better than anyone that this argument was false and that what he was doing would lead to enormous damage to the Dutch population and therefore also to [claimants]. It should be borne in mind here that the Pfizer report on the third clinical phase was already known to Gommers on 30 April 2021. As already indicated above, Pfizer reported in this report 1,223 deaths and 11,361 people with permanent serious bodily injury. Under Gommers’ responsibility these injections are administered to Dutch care staff. To this day this happens with care workers without actual informed consent. Care workers are falsely persuaded by Gommers that by having Covid-19 injections administered they protect patients. As EXHIBIT 30, [claimants] submit an article on the news website NU.nl dated 29 December 2021 about the Covid-19 booster injection allegedly taken by Gommers.

109. Gommers committed his unlawful conduct intentionally and evidently with the aim of having Covid-19 injections administered to care workers, with the foreseeable consequence that these people would suffer injury as a result and that healthcare capacity would therefore decrease. It stands to reason that the defendants then attribute that decrease to (the pretended disease) Covid-19, so that Covid-19 measures will then once again be falsely legitimised. This is a crucial part of the unlawful act committed jointly by the defendants, which amounts to carrying out the Covid-19: The Great Reset project. Worldwide, this approach has been the same among officials in the same position as Gommers. What has been stated in connection with Rutte about Article 97a of the Criminal Code also applies to Gommers.

110. Gommers is to blame for the fact that he did not take his social responsibility as an authoritative OMT member and chairman of the NVIC and that he thereby acted with a lack of the due care owed in society towards [claimants], resulting in the damage suffered by [claimants]. The Covid-19 policy would not have come about without Gommers’ unlawful conduct. Gommers should not have misled [claimants] and, in view of his scientific and social position, should have publicly opposed the Covid-19 narrative, which he failed to do.

111. [Claimants] would not have had (or could not have had) the Covid-19 injections administered if Gommers had performed his tasks with the required due care owed in society.

Hoekstra

112. Defendant sub 9, hereinafter referred to as ‘Hoekstra’, took office in 2017 as Minister of Finance, a ministerial post Hoekstra held until 10 January 2022. As of 10 January 2022 Hoekstra became Minister of Foreign Affairs. Hoekstra is a prominent member of the WEF and is therefore familiar with the WEF’s plan, already cited in the introduction of Kaag, for a complete

reorganisation of society (Covid-19: The Great Reset). As EXHIBIT 31, [claimants] submit a printout of the WEF website on which Hoekstra is shown as a member of the WEF.

113. Hoekstra is a champion of the project Covid-19: The Great Reset and regards Schwab as a dignitary. For this reason Hoekstra addresses Mr Schwab as ‘Your Excellency’. Schwab has deployed Hoekstra in the Netherlands as one of the important executors of the Covid-19 project. The relationship between Schwab and Hoekstra is reflected in the fact that Schwab, in turn, through his secretary, addresses Hoekstra as ‘Dear Minister’. It should be borne in mind here that, given his appointment as Minister, according to Dutch etiquette it is Hoekstra who should be addressed as ‘Excellency’, and not Schwab. As EXHIBIT 32, [claimants] hereby submit a copy of a letter from Hoekstra to the person he calls ‘Your Excellency’.

114. In the introduction to this summons it was put forward that Covid-19 is a project deployed by NGOs and financed by the World Bank. Having arrived at this point in the summons, [claimants] will further explain their perspective on the relationship between the defendants and the WEF, and in particular between Hoekstra and the WEF. The WEF is a foundation under Swiss law. This legal form is comparable to what in the Netherlands is a stichting. It is therefore a private organisation which, when it was set up, had no formal position with any national government whatsoever. As EXHIBIT 33, [claimants] hereby submit a copy of an extract from the Swiss commercial register concerning the registration of the WEF there. The articles of association of the WEF are also submitted herewith.

115. On 3 June 2020 Schwab and the then future King of England announced, via an online meeting, the start of the project Covid-19: The Great Reset. Subsequently the WEF sent out the written invitations for the major meeting in Davos, Switzerland, of January 2021, named ‘The Great Reset’. Hoekstra was also invited to it. Hoekstra received the invitation for it on 10 July 2020. As EXHIBIT 34, [claimants] submit the information on the meeting ‘The Great Reset’, together with Hoekstra’s correspondence with the WEF in response to it.

116. [Claimants] wish to explain further to your court what it means, in their perspective, that the defendants have become involved with the WEF and advocate the body of thought of Covid-19: The Great Reset. In this connection [claimants] refer first of all to Schwab’s book entitled ‘Covid-19: The Great Reset’, which the WEF makes accessible to everyone via its website (see note 9 to this summons). This book was published online by the WEF in July 2020. On the basis of the information contained in this book and the events factually described in it, [claimants] conclude that this book was written in 2019 and was made ready in the course of 2020 for publication in July 2020.

117. The defendants share the body of thought that Schwab recorded in Covid-19: The Great Reset. Schwab describes in his book that the Covid-19 pandemic crisis has ushered in the decisive moment at which a great many

things in the world will have to change for ever. [Claimants] refer in this connection to a number of quotations:

‘It is our defining moment - we will be dealing with its fallout for years and many things will change forever.’

118. According to this body of thought, all the ‘structural flaws’ (weeffouten) in the world will be exposed by the Covid-19 pandemic crisis. In this connection the following quotation is illustrative.

‘most notably social divides, lack of fairness, absence of cooperation, failure of global governance and leadership - now lie exposed as never before and people feel the time for reinvention has come.’

119. According to this body of thought, nothing will ever return to the ‘old’ normal. In this connection the following quotation is illustrative.

‘Nothing will ever return to the ‘broken’ sense of normalcy that prevailed prior to the crisis because the coronavirus pandemic marks a fundamental inflection point in our global trajectory’

120. According to this body of thought, the old world as [claimants] knew it will disappear completely. In this connection the following quotation is illustrative.

‘The World as we knew it in the early months of 2020 is no more, dissolved in the context of the pandemic’

121. According to this body of thought, radical and enormous changes will soon be coming our way, which will have major consequences for the life of everyone, including [claimants]. In this connection the following quotation is illustrative.

‘Radical changes of such consequence are coming that some pundits have referred to a ‘before coronacrisis (BC)’ and ‘after coronacrisis (AC) era. We will continue to be surprised by both the rapidly and unexpected nature of these changes - as they conflate with each other, they will provoke second-, third-, fourth- and more-order consequences, cascading effects and unforseen outcomes.’

122. According to this body of thought, a radically new ‘normal’ will be created. In this connection the following quotation is illustrative.

‘In so doing, they will shape a ‘new normal’ radically different from the one we will progressively leaving behind.’

123. In view of the defendants’ body of thought described above, including that of Hoekstra, [claimants] conclude that the defendants, with their Covid-19: The Great Reset project, are engaged in carrying out an unprecedented and radical change among the Dutch population. The Covid-19 injections make

evidently part of this project. This is evident because the Covid-19 injections were explicitly named by Schwab with the words: ‘Nobody will be safe, if not everybody is vaccinated’. As proof of this statement, [claimants] refer to their exhibit 19.

124. [Claimants] refer once again in this connection to their exhibit 32, with which a letter from Hoekstra to Schwab dated 14 February 2019 was submitted. In that letter Hoekstra, in his capacity as Minister, wrote to Schwab that he would very much like to work with him on bringing about technical and political developments leading to further (financial) globalisation. Hoekstra conducted this correspondence in secret and without a mandate from the Dutch parliament (the people’s representatives), and therefore also without the consent of [claimants]. In view of the WEF’s body of thought, the content of this letter cannot be interpreted otherwise than as an unconditional commitment by Hoekstra, in his position as Minister of Finance, to cooperate fully with the project Covid-19: The Great Reset. Hoekstra did in fact provide that cooperation, for which purpose he abused his office as Minister of Finance.

125. As already indicated above, as part of the Covid-19 project the message is given to the public that no one will be safe as long as not everyone has been inoculated with Covid-19 injections. For the Great Reset to be able to succeed, it is crucial that the crisis be presented as a crisis of unprecedented scale requiring unprecedented measures. With an unprecedented financial ‘support package’, Hoekstra ensured that the perception was created among [claimants] that there really was a crisis of unprecedented scale caused by a new coronavirus. Without Hoekstra’s cooperation, the carrying out of the Covid-19 project in the Netherlands would not have been possible, for lack of access to the Dutch treasury. What has been stated in connection with Rutte about Article 97a of the Criminal Code also applies to Hoekstra.

126. As a Minister and member of the WEF, Hoekstra champions the Covid-19 project and thereby also champions Covid-19 injections. All this while Hoekstra knows that the reports in the Pfizer trials mentioned several times in this summons have shown that the Covid-19 injections have cost many people their lives and have led to serious permanent bodily injury in thousands of people.

127. As a result of the fear of the alleged new coronavirus fed among [claimants] by Hoekstra and the other defendants, of its unprecedented consequences, and of the idea propagated as the solution to it that unprecedented drastic measures were necessary, [claimants] took their decision to have the Covid-19 injections administered in great fear.

128. Hoekstra is to blame for the fact that he did not take his political and social responsibility as a Minister of the Netherlands and that he thereby acted with a lack of the due care owed in society towards [claimants], resulting in the damage suffered by [claimants]. The policy of the Dutch government would not have come about, and could not have been carried out, without Hoekstra’s unlawful conduct. Hoekstra should not have cooperated with the plans of the

WEF and the WHO and, as a Dutch Minister, should have publicly opposed the narrative, which he failed to do.

129. [Claimants] would not have had (or could not have had) the Covid-19 injections administered if Hoekstra had performed his task with the required due care owed in society.

Van Nieuwenhuizen

130. Defendant sub 10, hereinafter referred to as ‘Van Nieuwenhuizen’, was Minister of Infrastructure and Water Management from 26 October 2017 up to and including 31 August 2021.

131. On 28 March 2020 Van Nieuwenhuizen took so-called emergency measures by means of a regulation. These emergency measures had the direct effect that licence applications for the gene-therapy-based Covid-19 injections no longer had to be accompanied by an environmental risk assessment (milieurisicobeoordeling, MRB), that the submission of views (zienswijzen) by third parties was no longer possible, and that the decision periods were greatly shortened. These procedural relaxations had no basis in the facts. The state of emergency invoked for them did not exist. Van Nieuwenhuizen had neither the power nor the mandate to suspend the international Aarhus Convention as a fundamental right. As EXHIBIT 35, [claimants] submit the ministerial regulation of Van Nieuwenhuizen dated 28 March 2020.

132. By introducing the aforementioned regulation, the obligations resting on Van Nieuwenhuizen under the Aarhus Convention [fn 15] were grossly violated. This convention obliged Van Nieuwenhuizen to consult the public on the introduction into the environment of genetically modified organisms, which, according to the text of the regulation, Van Nieuwenhuizen deliberately did not do. The regulation considers the following in this regard.

‘Pursuant to Article 6 of the Aarhus Convention, the Netherlands is obliged, within the framework of national legislation, where possible and appropriate, to consult the public before permitting the introduction into the environment of genetically modified organisms. In the case of combating COVID-19, it is considered necessary to deviate from this and to have licensing take place not in accordance with the UOV (uniform public preparatory procedure), but in accordance with the regular preparatory procedure.’

As EXHIBIT 36, [claimants] submit the first two pages of the Aarhus Convention [fn 16].

133. Through the aforementioned course of action, the Dutch population, including [claimants], was deliberately kept ignorant by Van Nieuwenhuizen of the fact that the Covid-19 injections offered involved participation in a clinical trial, of the fact that the Covid-19 injections are based on gene therapy, and of the fact that, as a result of the regulation, important safeguards for the safety of people and the environment for obtaining a licence no longer applied.

134. Worldwide, persons in a position comparable to that of Van Nieuwenhuizen acted in the same way, as a result of which the lack of information identified above occurred worldwide. The fact that all defendants cooperated in this speaks volumes as regards the assertion of [claimants] that the defendants act unlawfully as a group.

135. When Van Nieuwenhuizen acted unlawfully on 28 March 2020, the third clinical phase of the Pfizer trial, mentioned several times above, had not even begun. As a result, a convention intended precisely to provide protection in a situation such as the present one was blindly deviated from. This shows malicious intent on the part of all defendants and of Van Nieuwenhuizen in particular. What has been stated in connection with Rutte about Article 97a of the Criminal Code also applies to Van Nieuwenhuizen.

136. Van Nieuwenhuizen is to blame for the fact that she did not take her political and social responsibility as a Minister of the Netherlands and that she thereby acted with a lack of the due care owed in society towards [claimants], resulting in the damage suffered by [claimants]. The policy of the Dutch government would not have come about without Van Nieuwenhuizen’s unlawful conduct. Van Nieuwenhuizen should not have intentionally violated the Aarhus Convention and, as a Dutch Minister, should have publicly opposed the narrative, which she failed to do.

137. [Claimants] would not have had (or could not have had) the Covid-19 injections administered if Van Nieuwenhuizen had performed her task with the required due care owed in society.

Pharmaceutical industry

Bourla

138. Defendant sub 11, hereinafter referred to as ‘Bourla’, trained as a veterinarian and has since 1993 been an executive at the pharmaceutical manufacturer Pfizer, which is established in the United States. In Bourla’s long career at Pfizer, Bourla became familiar with the facets of the business operations in all divisions of Pfizer. In 2018 Bourla became the second in command at Pfizer. With effect from 1 January 2019 Bourla was promoted at Pfizer to chief executive officer (CEO), and with effect from 1 January 2019 he took all the important decisions at Pfizer.

139. Bourla is a ‘contributor’ to the WEF and Pfizer is a ‘member’ of the WEF. Bourla is a champion of the WEF body of thought and of Covid-19: The Great Reset. As EXHIBIT 37, [claimants] submit information from the WEF website which shows the ties of Bourla and Pfizer with the WEF.

140. Bourla has stated in public statements that in 2020 he urged Pfizer’s employees to develop a Covid-19 vaccine rapidly. In doing so, by his own account, Bourla pointed out that the vaccine to be developed had to be safe and effective. According to Bourla, production of

the Covid-19 ‘vaccines’ was started on his instructions before approval by the American Food and Drug Administration [fn 17] (hereinafter referred to as ‘FDA’). According to Bourla, Pfizer’s strategy lay in the ‘vaccines’ being ready immediately after approval by the medicines authorities. As EXHIBIT 38, [claimants] submit a screenshot of a video message of 14 December 2020 which shows the foregoing. [Claimants] note in this connection a striking similarity between the choice of words of Bourla and De Jonge, where Bourla stated that the Covid-19 injections had been developed ‘without cutting corners’, while De Jonge, on 26 December 2020, in the same context spoke of ‘in no way cut corners’ (‘op geen enkele manier de bochtjes afgesneden’).

141. In an open letter from Bourla [fn 18] published on Pfizer’s website on 15 October 2020, Bourla makes several promises and commitments to the world population. The importance of transparency with regard to the development of the ‘vaccine’ is emphasised by Bourla in this letter. Bourla assures the public that authorisation for ‘public use’ can only be granted by the medicines authorities if Pfizer has successfully demonstrated that three conditions have been met. Only once it has been demonstrated that the ‘vaccine’ under development is effective, is safe, and can be produced at a consistently high quality can approval for ‘public use’ come into consideration, according to Bourla. As EXHIBIT 39, [claimants] submit a printout of Bourla’s letter dated 15 October 2020.

142. For Europe, a conditional approval followed at the end of 2020 in accordance with Article 14(7) of EC Regulation 726/2004, under which Pfizer was obliged, according to a fixed timetable, to collect all kinds of information in the field of the administration of the Covid-19 injections and submit it to the EMA. It is therefore established that the Covid-19 injections administered to [claimants] were administered in the context of a clinical trial. The EMA has determined that this trial will run until at least August 2024.

143. According to its safety report [fn 19], mentioned several times, Pfizer conducted an extensive clinical trial from November 2020 up to and including February 2021, in which the trial subjects were injected with Pfizer’s Covid-19 ‘vaccine’ known under the brand name Comirnaty / BNT162b2 [fn 20]. 29,914 women, 9,182 men and 2,990 children took part in this trial. Within one month of the start date of this clinical trial, 1,223 trial subjects died and 11,361 trial subjects suffered serious permanent bodily injury. Pfizer reports in its aforementioned safety report that they have no data on 9,400 trial subjects. For this reason it is not known whether these persons died or suffered injury as a result of the clinical trial. As EXHIBIT 40, [claimants] submit the safety report dated 30 April 2021.

144. The aforementioned safety report was kept hidden by Bourla, but was released to the public in October 2021 thanks to the intervention of the judiciary in the United States of America. The data from this report show that the Pfizer Covid-19 ‘vaccine’ is life-threatening. This safety report showed that the three conditions which Bourla had set in his earlier open letter of 15 October 2020 for being able to request authorisation from the medicines authorities could not be met.

[144, continued] If Bourla had done what he had assured the world’s population in his open letter of 15 October 2020, permission would never have been sought from the medicines authorities and the Pfizer Covid-19 injection would never have been administered to [claimants]. By his open letter and by keeping the safety report hidden from the public, Bourla deliberately misled [claimants].

145. Bourla’s deception goes much further. Safe and effective were the key words used worldwide to lure the majority of the world’s population into having Covid-19 injections. Bourla, like all the other defendants, repeated these words ad nauseam. An important motto in this was ‘you do it for someone else’ [fn 21]. The defendants, Bourla in particular, thereby implied that the Covid-19 injections would prevent transmission of the supposed virus. On the basis of this implicit message, the public worldwide, and [claimants] as well, lived under the assumption that the more people had a Covid-19 injection, the lower the chance of infection with this virus, and that only in this way could the pandemic be brought to an end.

146. Bourla knew, however, that Pfizer and other Covid-19 vaccine manufacturers had paid no attention whatsoever, in developing the ‘vaccines’, to preventing transmission of the supposed new coronavirus. Bourla knew that among the worldwide public, and therefore also among [claimants], there existed on this point a major misunderstanding – one partly brought into being by him – the importance of which cannot be overstated. The entire Covid-19 policy worldwide rested on the idea that vaccination could prevent transmission of the supposed virus, which would make ‘vaccination’ an effective means of combating the pretended pandemic. All of this is a great lie that was kept alive by Bourla and the other defendants. Had Bourla exercised the transparency he had promised, [claimants] would never have proceeded to have Covid-19 injections.

147. The lie about Covid-19 inoculations preventing transmission of the supposed virus was exposed in the European Parliament on 10 October 2022. Bourla, among others, was called for questioning by several Members of the European Parliament. Bourla refused to appear before the hearing committee of the European Parliament. He sent his colleague Ms Janine Small in his place. Before the hearing committee, Ms Small formally admitted that Pfizer had never tested the Covid-19 vaccine for preventing transmission. As EXHIBIT 41, [claimants] submit a screenshot of the hearing in the European Parliament of 10 October 2022.

148. Ms Small, delegated for this purpose by Bourla, tried to disguise what really lay behind this sensational admission by stating that it was because of ‘the speed of science’ that no research into transmission had been done. As will be explained below, the reference to ‘the speed of science’, made by Bourla and by the other defendants on many occasions, is false and a great lie. This

reference made no sense at all, because in reality the Covid-19 injections had already been developed before the pretended pandemic. [claimants] will substantiate this assertion further later in this summons.

149. On 19 January 2023, ahead of the WEF meeting in Davos, Bourla was confronted by journalists of the Canadian TV channel ‘Rebel News’ with the statement made by his colleague Small on 10 October 2022. Despite these journalists pressing him for his reaction to Ms Small’s statement, Bourla again refused to make any statement. Bourla considered it sufficient to remark ‘Have a nice day’. This shows all the more that the transparency promised in Bourla’s open letter was a great lie. Bourla thereby shows his contempt for everyone who placed their trust in him and in Pfizer, including [claimants]. As EXHIBIT 42, [claimants] submit a screenshot of the Rebel News interview with Bourla of 19 January 2023.

150. Bourla’s extremely vile modus operandi of concealing crucial information about the contents and action of Comirnaty / BNT162b2 (mRNA injections) also appears with regard to the presence of graphene oxide in every mRNA injection, whether made by Pfizer or by Moderna [fn 22]. In its Covid-19 injection package leaflet, Pfizer describes ‘tozinameran’ as the active substance, together with other substances with complex chemical names that are designated by codes, more specifically the codes ‘ALC-0315’ and ‘ALC-0159’.

151. The aforementioned codes can be explained with the help of the patent number CN 112220919A, granted in Shanghai, China, on 27 September 2020. This patent makes it crystal clear that – in particular in the mRNA vaccines against the 2019 n-CoV coronavirus – graphene oxide serves as a ‘carrier’ for lipid nanoparticles (LNPs). The Chinese patent number CN 112220919A [fn 23], granted on 27 September 2020, together with a translation of it, is submitted as EXHIBIT 43. The English-language abstract of this patent states the following.

‘The invention belongs to the field of nano materials and biomedicine, and relates to a vaccine, in particular to development of 2019-nCoV coronavirus nuclear recombinant nano vaccine. The invention also comprises a preparation method of the vaccine and application of the vaccine in animal experiments. The new corona vaccine contains graphene oxide [fn 24], carnosine, CpG and new corona virus RBD; binding carnosine, CpG and neocoronavirus RBD on the backbone of graphene oxide; the CpG coding sequence is shown as SEQ ID NO 1; the navel coronavirus RBD refers to a navel coronavirus protein receptor binding region which can generate a high-titer specific antibody aiming at the RBD in a mouse body, and provides a strong support for prevention and treatment of the navel coronavirus.’

152. In response to great public concern, so-called ‘fact-checkers’ in the media checked the assertion that the Covid-19 injections contained graphene oxide. That concern existed because graphene oxide, among other things, makes people’s blood clot. The outcome of the checks was invariably, and falsely, that it was not present, and Bourla, too, deliberately allowed this misrepresentation to persist.

153. Videos and scientific reports have appeared from highly renowned persons in which it is explained with great precision, on the basis of evidence, that graphene oxide is present as a main ingredient in all mRNA injections and primarily serves a purpose other than influencing health. In this connection [claimants] refer to a video in which Karen Kingston, by her own account a former employee of Pfizer, gives an extensive explanation of this. This explanation strengthens [claimants] in the conviction that Bourla is a very important player in the Covid-19: The Great Reset project and that the Covid-19 injections forced upon them were never intended to protect them against an alleged virus. As EXHIBIT 44, [claimants] submit a screenshot relating to a video of Karen Kingston.

154. In view of the foregoing, graphene oxide is to be classified as a main ingredient of the Pfizer Covid-19 ‘vaccine’. It goes without saying that the dreaded graphene oxide, which is highly toxic to humans, should never have been part of the vaccine, and that no one who had known about it, and certainly not [claimants], would have been willing to have this poison injected into them.

155. Bourla is to blame for having grossly violated his scientific and social responsibility as CEO of the most important Covid-19 injection manufacturer, and for having thereby acted with a lack of the care owed in society towards [claimants], resulting in the damage suffered by [claimants]. What has been stated with regard to Rutte concerning article 97a of the Dutch Criminal Code applies equally to Bourla.

Mass media

Van Cann

156. Defendant 12, hereinafter ‘Van Cann’, was deputy editor-in-chief of NOS Nieuws from 2011 and became the new editor-in-chief of NOS Nieuws (hereinafter ‘NOS’) as of 1 September 2022.

157. On its website [fn 25], the NOS sets out its mission statement based on the Media Act. It reads as follows.

‘The NOS, as an integral part of the public broadcasting system, aims to be the primary source of information in the field of news, sport and events, so that Dutch citizens are better able to form a judgement on developments in the world, enabling them to better determine their conduct. In doing so, the NOS applies the highest journalistic standards of care, reliability, independence, pluriformity and objectivity. The NOS strives to make this information accessible through all available media and to all sections of society.’

158. As (deputy) editor-in-chief, Van Cann is responsible for the course of the Covid-19 section. It was part of Van Cann’s duties to ensure that the editorial staff observed the standards applicable to journalism. As regards the internationally applicable ethical standards for journalists, [claimants] refer to the standards as adopted by the International Federation of Journalists. The most recent

edition of the standards laid down by this federation is submitted by [claimants] as EXHIBIT 45.

159. The way in which the NOS reported on the pretended Covid-19 crisis was determined by Van Cann.

160. From the start of the pretended Covid-19 crisis, that is from January 2020, Van Cann chose to use the tone, photographs and suggestions in the editorial work of the NOS to aim for maximum panic and fear among the population. [claimants] became very frightened through the NOS reporting by the idea that a deadly virus was on its way from Wuhan [fn 26]. Van Cann deliberately played on precisely this without allowing sound journalistic research. Van Cann slavishly followed the official narrative as imposed worldwide by the WHO and followed unquestioningly by all the defendants.

161. [claimants] will discuss below a limited number of examples which, as regards Van Cann’s conduct and in view of the standards applicable to her, are to say the least unacceptable.

162. First, [claimants] wish to point out that the NOS presented the first infected corona patient as a person who, because of the Covid-19 virus, changed instantly from a healthy person into someone who was (all but) dead. Dead or sick people in the street, people in hospitals and people on ventilators in intensive care: that is how the NOS portrayed an infection. This while even simple journalistic research, also in the initial phase, should immediately have raised serious questions about the authenticity of the reports that the NOS took over unquestioningly from international press agencies and other channels. On 29 January 2020 the NOS reported, among other things, in its article ‘How honest is China about the outbreak of the coronavirus?’:

‘on 9 January 2020 nCoV2019 was identified as the cause of a series of cases of pneumonia in patients in Wuhan. A day later the Chinese authorities shared the genetic code of the virus.’

A copy of this NOS article of 29 January 2020 is submitted by [claimants] as EXHIBIT 46.

163. Official EMA documents have shown that it was reported to the EMA that Moderna already in 2017, and Pfizer already on 14 January 2020, had a Covid-19 vaccine at their disposal and were busy testing these Covid-19 injections. It should be borne in mind that, for Pfizer, this would mean that Pfizer had its Covid-19 injection ready for testing within four days, and for Moderna it would mean that it had already had a vaccine against a future virus for two and a half years. In this connection, information that came to the knowledge of Member of the European Parliament Cristian Terheș, from which this follows, is submitted as EXHIBIT 47. This information shows that the Covid-19 injections were in development well before the outbreak of the pretended Covid-19 pandemic. In proof of this, [claimants] offer to have Member of the European Parliament Cristian Terheș heard under oath. The NOS and other media should have investigated this released information to the bottom and informed the public about it in full detail. In reality, the media,

including Van Cann and the NOS, instead of informing the public, applied outright censorship.

164. That there is censorship is abundantly clear from the fact that no report was made of the hearing in the European Parliament of 10 October 2022 (exhibit 41). It is shocking that Van Cann, as editor-in-chief, took part in a cover-up by which the lie that the Covid-19 injections would prevent transmission was kept alive. The statement on this by a Pfizer director, Ms Janine Small, before a hearing committee of the European Parliament should have been world news and should have gone ‘viral’.

165. That there is censorship is also apparent from the fact that no report was made of the speech by Member of the European Parliament Cristian Terheș on the outcomes of special hearing committees in the European Parliament at which board members of, among others, Moderna and Pfizer were heard. As already indicated above in relation to Bourla, important information about the safety and effectiveness of the Covid-19 injections came to light there. In two speeches by Member of the European Parliament Cristian Terheș on 11 October 2022, Mr Terheș shows that the European Parliament is being denied information about the contracts with Pfizer by the European Commission. Mr Cristian Terheș also reports the reason Pfizer gave him for withholding this information. According to Pfizer this is because of ‘commercial secrets’. Mr Cristian Terheș also draws attention to the fact that the Covid-19 injections offer no protection against transmission of the virus. Further, Mr Cristian Terheș points to the excess mortality that has risen sharply since the roll-out of the Covid-19 injection campaign. Mr Terheș also raised, on 11 October 2022, that Pfizer had reported data to the EMA on the start of the testing of the Pfizer Covid-19 injections as of 14 January 2020, while the genetic code of the pretended Covid-19 virus had become known only three days before. At Moderna the testing even goes back to 2017. All of this should have been presented by Van Cann to the Dutch population as world news, and Van Cann was responsible for ensuring that thorough journalistic research would be done into everything Mr Terheș put forward in his speeches of 11 October 2022. In this connection [claimants] submit as EXHIBIT 48 screenshots of the two speeches by Member of the European Parliament Cristian Terheș of 11 October 2022.

166. That Van Cann is responsible and liable for Covid-19 censorship is all the more apparent from the fact that she withheld from the public all information regarding all the special hearing committees set up by Members of the European Parliament in the month of October 2022. These hearing committees investigated the safety and effectiveness of the Covid-19 injections and the manner in which, already in January 2020, the purchase agreements between Pfizer and the European Commission were concluded secretly and fraudulently. On behalf of the European Commission and on behalf of the Netherlands, Ursula van der Leijen placed orders with Pfizer for more than EUR 71,000,000,000.00 (71 billion euros). The Netherlands, and with it the Dutch population including [claimants], stand jointly and severally liable as guarantors for payment of this amount, which to date has remained unpaid. It should be borne in mind here that this purchase for this amount was concluded while the Pfizer Covid-19 injections were still in the

clinical testing phase (exhibit 38). As editor-in-chief, Van Cann put all of this into a worldwide cover-up and withheld from the public, including [claimants], the awareness of the unimaginably far-reaching (possible) consequences of these shocking facts that had been established. This is incompatible with the essence of the profession of journalist and with the mission statement of the NOS.

167. In the German Parliament on 26 October 2022, the parliamentary leader of the large political party AfD (Alternative für Deutschland), Dr Alice Weidel, drew attention in no uncertain terms to the (censorship) scandals concerning (1) the questioning of Janine Small and her statement about transmission not being prevented, (2) the confirmation by the European Commission that the Covid-19 injections do not protect against infection, and (3) Ursula van der Leijen having made secret arrangements with the pharmaceutical industry about the purchase worth billions mentioned above. The extent of the damage caused by the Covid-19 injections is also named by this member of parliament as a subject that is being censored. This member of parliament leaves no misunderstanding about the personal liability of journalists such as Van Cann. As EXHIBIT 49, [claimants] submit a screenshot of the speech by Dr Alice Weidel of 26 October 2022.

168. In proof of the scandals rightly named by Dr Alice Weidel and censored by Van Cann, [claimants] submit as EXHIBIT 50 a screenshot of a video of 13 October 2022 in which European Commissioner Wolfgang Philipp confirms in the European Parliament that the Covid-19 injections offer no protection whatsoever against transmission.

169. Under the leadership of Van Cann, the NOS gave its full cooperation to conveying, in a forceful and fear-inducing way, the Covid-19 narrative that was quite obviously aimed at inducing people, through social pressure and misrepresentation, to take Covid-19 injections. This while the NOS should instead have pointed out that this meant taking part in a large-scale, worldwide experiment based on gene therapy for which there was in fact no reason.

170. The very first thing that Van Cann and her NOS journalists should have done is to report what is written in the package leaflets of the Covid-19 vaccines. The package leaflets of all Covid-19 mRNA ‘vaccines’ stated [fn 27] in no uncertain terms that this is a conditionally authorised ‘medicine’ that may only be administered on a doctor’s prescription and must thereafter be monitored periodically, as part of a medical experiment, until at least 1 August 2024. Van Cann knew that this information was being withheld from the public because the package leaflets of Covid-19 injections were not handed out.

171. In proof of the fact that the Covid-19 injections are a product that has been conditionally authorised in Europe, the claimants submit as EXHIBIT 51 a Pfizer package leaflet. Reference is made to pages 66 and 67, where under E the conditions of the authorisation are set out for the period up to and including July 2024. It is remarkable that in the latest version

of the Pfizer package leaflet these conditions are no longer explicitly described.

172. Van Cann ensured that not a single scientist was able to give his or her opinion via the NOS, as a public and independent broadcaster, so as to communicate these important facts to the public. This is nothing other than censorship. In this way the false narrative was kept alive by Van Cann by means of censorship.

173. The aforementioned unlawful act by Van Cann towards [claimants] and the Dutch citizens is shocking, because it also means that the mottos ‘You do it for each other’ and ‘you do it for someone else’, propagated by the NOS under the leadership of Van Cann, rest on a great lie. This lie was evidently put into the world by Van Cann with no other purpose than to put pressure on people, through improper use of the state media, to have an experimental Covid-19 injection that has nothing to do with health, but solely with the implementation of the Covid-19 project. What has been stated with regard to Rutte concerning article 97a of the Dutch Criminal Code applies equally to Van Cann.

174. [claimants] also point out that, under the leadership of Van Cann, the NOS censored the countless reports of damage to health caused by Covid-19 injections by not including them or by dismissing them as disinformation.

175. Finally, [claimants] point out that, under the leadership of Van Cann, the NOS censored the countless scientists and concerned citizens of the Netherlands who, with the force of facts and arguments, raised the question of the legitimacy of the Covid-19 measures, by not including them or by dismissing them as disinformation.

176. As editor-in-chief, Van Cann knows the standards for journalism already cited above, which derive among other things from the Bordeaux Declaration and the code for journalism applicable in the Netherlands since 2008. The first and most fundamental duty under the Bordeaux code is the standard that the journalist must have respect for truth and for the right of the public to truth. Van Cann grossly violated that duty, with the result that [claimants] had a false picture of the situation. Had [claimants] learned that truth through the NOS – which they followed daily – they would not have had the Covid-19 injections.

177. In summary, it can be stated that Van Cann failed in her journalistic duty as editor-in-chief of the NOS. She is personally liable for the censorship she caused, on the one hand by taking part in a cover-up and on the other hand by unquestioningly adopting the official, project-driven Covid-19 narrative, while even minimal journalistic research should already have made clear that this narrative was false. The mission statement of the NOS cited above evidently applies neither to the NOS nor to Van Cann.

Jansen

178. Defendant 13, hereinafter ‘Jansen’, was editor-in-chief of the daily newspaper De Telegraaf from 1 September 2015 until 1 June 2023.

In that capacity Jansen led the editorial staff with the same editorial responsibilities and duties as set out above with regard to Van Cann. The same reproaches apply to him as to Van Cann.

179. From the outset of the pretended Covid-19 pandemic, De Telegraaf, with its newspaper and websites under Jansen’s final editorship, did everything it could to provoke great fear and panic among its readers and viewers. In doing so, under Jansen’s leadership, the instructions of the information departments of all government ministries, in particular regarding the Covid-19 narrative, were adopted unquestioningly. In view of the nature and content of De Telegraaf’s reporting on the alleged Covid-19 pandemic, there can be no doubt whatsoever that De Telegraaf, under Jansen’s leadership, allowed itself to be used as a weapon of fear against the Dutch population. Its reporting constantly carried the suggestion that there were countless infections with the pretended Covid-19 virus which, in many people, led at an unprecedented pace to serious illness, hospitalisation and death. The images chosen under Jansen’s leadership for De Telegraaf’s reporting at the start of the alleged Covid-19 pandemic were characterised by the fact that the pretended Covid-19 pandemic showed virtually nothing but death and destruction. Numbers of sick and dead were brandished without sketching any journalistically substantiated context for those numbers.

180. As EXHIBIT 52, the claimants submit a number of reports published by De Telegraaf under Jansen’s responsibility which show the foregoing. The terminology used in them is reminiscent of war rhetoric; references using terms of war contributed to the fear and panic. A fight against a virus was presented as if a war with enormous numbers of dead and wounded were going on. Another very objectionable element is that the reporting maliciously played on the idea that everything could still become much worse. With a properly functioning and sound editorial staff acting on the basis of journalistic responsibility, this would not have been possible. What has been stated above with regard to Van Cann concerning the Bordeaux Code and the code for journalism of 2008 applies equally to Jansen.

181. Insofar as Jansen might wish to defend himself by pointing to the fact that he took on ‘critical journalistic contributors’ in the persons of Ronald Plasterk or Marianne Zwagerman, [claimants] observe as follows. Both Plasterk and Zwagerman voiced a pseudo-critical sound about the handling of the pretended Covid-19 pandemic, but did not contest a single essential point of the narrative. Jansen used Plasterk and Zwagerman to give a sham opposition a platform. This was so that his readership’s confidence in the journalistic functioning of his editorial staff would be maintained, while in reality there was deliberate large-scale deception of the public. [claimants] were misled by Jansen in this way.

182. With regard to Jansen, too, the journalistic research questions concerning the Covid-19 narrative that also lay before Van Cann should have been investigated.

183. As editor-in-chief, Jansen knows the standards for journalism already cited above, which derive among other things from the Bordeaux Declaration and the code for journalism applicable in the Netherlands since 2008. The first and most fundamental duty under the Bordeaux code is the standard that the journalist must have respect for truth and for the right of the public to truth. Jansen, just like Van Cann, grossly violated that duty, with the result that [claimants] had a false picture of the situation. Had [claimants] learned that truth through De Telegraaf – which they likewise followed daily – they would not have had the Covid-19 injections. What has been stated with regard to Rutte concerning article 97a of the Dutch Criminal Code applies equally to Jansen.

184. In summary, it can be stated that Jansen failed in his journalistic duty as editor-in-chief of De Telegraaf. Jansen is personally liable for the censorship he caused, on the one hand by taking part in a cover-up and on the other hand by unquestioningly adopting the official narrative, while even minimal journalistic research should already have made clear that this narrative was false.

Non-governmental organisation (NGO, WEF)

Sijbesma

185. Defendant 14, hereinafter ‘Sijbesma’, has been a top executive at various globally operating companies, including DSM. These companies are members of the WEF. Sijbesma currently holds, among others, the positions of supervisory director of Unilever N.V., chairman of the supervisory board of Philips N.V., member of the board of trustees of the WEF, climate leader for the CO2 pricing project at the World Bank, member of the external advisory group of the International Monetary Fund, co-chair of the UN Global Center on Adaptation (‘GCA’) and ambassador of the UN World Food Programme. As EXHIBIT 53, [claimants] submit data from the WEF website on Sijbesma’s CV.

186. Sijbesma is an outspoken supporter of the ideas of the WEF, in particular of the total realignment described by Klaus Schwab in his book Covid-19: The Great Reset (exhibit 18). In order to make his personal contribution to this total realignment possible, Sijbesma is a statutory member of the WEF. In proof of this, [claimants] refer to page 2 of the extract concerning the WEF submitted as exhibit 33. In that realignment, all the factors that determine a human life are made the object of forced change by the WEF and the UN. Characteristic of this political ideology is that this forced and planned change is presented as justified by pretending that the world is weighed down by great crises that can only be solved by centralised, harsh worldwide intervention. Because of the seriousness held out for these crises and the pretension that science has a solution to these crises, a worldwide plan is being carried through by the defendants, including Sijbesma. This plan forms part of Agenda 21 (14 July 1992) and Agenda 2030 (27 September 2015) and is called ‘The Great Reset’. As EXHIBIT 54, [claimants] submit pages 1 to 3 [fn 28] of

Agenda 21. As EXHIBIT 55, [claimants] submit the first four pages of Agenda 2030 [fn 29].

187. At the start of the pretended Covid-19 pandemic, Sijbesma, by his own account, was asked by the cabinet on 26 March 2020 to scale up the testing capacity of the GGD (Municipal Public Health Service) for Covid-19 tests. He was also asked to help determine the vaccination strategy. In that connection the cabinet gave Sijbesma the title of ‘special corona envoy’. Sijbesma presented himself in this as a well-meaning volunteer. As EXHIBIT 56, [claimants] submit information from www.rijksoverheid.nl on Sijbesma’s role as special envoy for the corona crisis. His ties with the WEF were deliberately left out of consideration by Sijbesma and the defendants.

188. In his capacity as corona envoy, Sijbesma put on a piece of theatre that was widely disseminated through the media and that also misled [claimants]. Sijbesma took part in the lie that Covid-19 tests were a scarce commodity. In the interview on Buitenhof on 12 April 2020, Sijbesma spoke of major problems with purchasing Covid-19 tests. Compared with other countries, the Netherlands could supposedly buy those Covid-19 tests from the international manufacturers only with difficulty and in limited quantities, because the Netherlands applied a restrictive testing policy. As EXHIBIT 57, [claimants] submit a screenshot of the interview in question on Buitenhof of 12 April 2020.

189. One of Sijbesma’s ancillary positions is climate leader of the World Bank Group. The World Bank has an analysis and visualisation tool called ‘DataBank’, accessible to everyone via the internet [fn 30]. DataBank makes use of the so-called World Integrated Trade Solution (‘WITS’). WITS is software that the World Bank developed in cooperation with the various bodies of the UN [fn 31]. With this software users can view and retrieve information on world trade and tariffs. As EXHIBIT 58, [claimants] submit information concerning WITS as published on the WITS website.

190. In 2017, the import and export data of Covid-19 Testkits and of Covid-19 Diagnostic Test Instruments and apparatus traded between countries were registered by means of WITS. In 2017 the ‘World Customs Organisation’, as part of the World Bank, assigned to the Covid-19 Testkits the unique classification number HS-2017 with product number 3002.15. In 2017 the Covid-19 Diagnostic Test Instruments and apparatus were assigned the unique classification number HS-2017 with product number 9027.80. As EXHIBIT 59, [claimants] submit the information concerning world trade in ‘Covid-19 testkits’ and ‘Covid-19 diagnostic test instruments and apparatus’ in 2017 as it could be retrieved via WITS until 7 September 2020.

191. In 2018, too, WITS registered the import and export between countries of many millions of Covid-19 Testkits and of Diagnostic Test Instruments and apparatus. Many millions of Covid-19 Testkits were purchased by, among others, the European Union and Germany. As EXHIBIT 60, [claimants] submit the information concerning world trade in

‘Covid-19 testkits’ and ‘Covid-19 diagnostic test instruments and apparatus’ in 2018 as it could be retrieved via WITS until 7 September 2020.

192. On 7 September 2020 the data in WITS submitted above as exhibits 59 and 60 changed, in that the description in the lists no longer read ‘Covid-19 testkits’ and ‘Covid-19 diagnostic test instruments and apparatus’, but became ‘Medical testkits’ and ‘Medical diagnostic test instruments and apparatus’. This change did not go unnoticed. As EXHIBIT 61, [claimants] submit a printout of the aforementioned data in WITS as retrieved and printed via WITS on 7 September 2020. As exhibit 59 shows, the description in the lists was indeed changed, but not in the text below the lists, where the word ‘Covid-19’ was still used.

193. The situation in WITS as of 7 September 2020 described above did not last long. That very same day WITS was altered again, and the word ‘Covid-19’ was then also removed from the text below the lists. [claimants] expressly offer to prove the correctness of their assertions concerning WITS by means of witnesses and expert witnesses.

194. In view of what has been stated above concerning WITS, the picture Sijbesma gave on Buitenhof is demonstrably false. In reality this concerns a Covid-19 project that is financed worldwide by the World Bank. At the World Bank this project bears the project name ‘Covid-19 Strategie Preparedness and Response Program (‘SPRP’)’. According to the World Bank’s planning, the SPRP is expected to run until 1 April 2025.

195. [claimants] cannot escape the impression that the WITS system in reality serves as a system for monitoring the solvency of the members affiliated to the UN and the World Bank. From their research in the patent registers, [claimants] believe they can further deduce that the financial interests of the world banking family Rothschild in the Covid-19 project were anchored in, among others, the patent with number US 2020/0279585 A1. This patent bears the description ‘system and method for testing for Covid-19’; it was applied for on 17 May 2020 by Richard A. Rothschild and published on 3 September 2020. The basis of the patented invention is contained in the provisional application with number 62/240.783 of 13 October 2015. That application concerned an invention described as ‘system and method for using, biometric, and displaying biometric data’ and previously led to a patent granted under number US 2017/0229149 A1. These patents give the inventor exclusive legal and economic rights to the invention, in which people’s biometric data, combined with video images of their surroundings, are monitored centrally. As soon as that occurs, the Rothschild family has far-reaching rights on the basis of its patents. As EXHIBIT 62, [claimants] submit the patent with number US 2020/0279585 A1 [fn 32].

196. [claimants] et al. suspect that this technology patented by world banker Richard A. Rothschild is being deployed by the defendants as part of the Covid-19: The Great Reset project. The patent could then form the legal

basis for the financial claim of this world banking family in connection with the use of the patented invention by virtually the entire world population involved in the Great Reset. It is telling that the WEF speaks of its projects The Internet of Things and The Internet of Bodies. The patented invention is crucial to these projects, in which everything, and above all people’s bodies too, is connected to everything else via 5G and 6G internet technology. For [claimants] there is no doubt whatsoever that Sijbesma, in view of his positions mentioned above, is involved in this. As EXHIBIT 63, [claimants] submit information from the WEF website concerning the linking of people’s biometric data to the Internet of Things, together with an explanation of it.

197. Had [claimants] known what Sijbesma really stands for and all the things he is engaged in, [claimants] would have wanted nothing to do with the Covid-19 injections and would under no circumstances have had them.

198. It follows from the facts set out above that the defendants, including Sijbesma, know that Covid-19 is a project and not a disease, one that was in any case already being carried out before 2017 under the project name ‘Covid-19 Strategie Preparedness and Response Program (‘SPRP’)’. All of this explains why the chairman of the WEF – Klaus Schwab – was able, with prior knowledge, to publish his book ‘Covid-19: The Great Reset’ as early as June 2020.

199. As an insider of the World Bank, the UN and the WEF, Sijbesma is entirely familiar with and involved in the Covid-19 project that is meant to lead to the Great Reset. This involvement is the real reason why the cabinet, including defendants De Jonge, Rutte, Kaag, Hoekstra and Van Nieuwenhuizen, appointed him as Dutch corona envoy.

200. During the Buitenhof interview of 12 April 2020, Sijbesma knew of the official narrative that (1) the Chinese authorities had made the genetic code of the supposed virus known to the world on 11 January 2020 and that (2) Pfizer, on 14 January 2020 – three days later – already had a Covid-19 vaccine that it would start testing from that same date. It is evident that Sijbesma, as special corona envoy, should have reported this to the Dutch public, including [claimants]. The whole thrust of his argument was directed at nothing other than the Great Reset.

201. Sijbesma is to blame for being an executor of the Great Reset on behalf of the WEF and, in that connection, for having deliberately misled [claimants] as to the usefulness and necessity of the Covid-19 injections. Had Sijbesma really been a special corona envoy acting in the interest of the health of the Dutch population, Sijbesma would have given honest and complete information and [claimants] would not have had (been able to have) the Covid-19 injections. What has been stated with regard to Rutte concerning article 97a of the Dutch Criminal Code applies equally to Sijbesma.

Gates

202. Defendant 15, hereinafter ‘Gates’, is one of the richest people in the world. His wealth derives to a large extent from his interests in Microsoft. He has placed most of his wealth in a foundation under American law, the Bill & Melinda Gates Foundation, which has its seat in Seattle, United States of America. According to its website [fn 33], this foundation aims to combat poverty, disease and inequality worldwide.

203. Gates is further the founder of and connected with ‘Gavi, the Vaccine Alliance’ (hereinafter ‘GAVI’). When GAVI was founded in 1999, the Bill & Melinda Gates Foundation made no less than $ 750,000,000.00 available to vaccinate children in poor countries. Through GAVI, among other channels, Gates has access to every organisation in the world and influence over, for example, governments, the WHO, UNICEF, the World Bank, the vaccine industry, research and technical agencies, civil society organisations and other private philanthropists. In this connection, Gates regularly visits Rutte in his office in the ‘Torentje’ (the Prime Minister’s office tower) at the Binnenhof. As EXHIBIT 64, [claimants] submit information from RTL Nieuws and Twitter about a number of these visits by Gates to Rutte.

204. The Bill & Melinda Gates Foundation and Gavi together are by far the largest donors to the WHO and are decisive for the WHO’s policy.

205. The Bill & Melinda Gates Foundation and Microsoft are important strategic partners of the WEF and, through their input, make an important contribution to the development of the strategy of the WEF and its Great Reset. As EXHIBIT 65, [claimants] submit information from the WEF website concerning the Bill & Melinda Gates Foundation and Microsoft.

206. Gates wants the world to believe that, besides being a philanthropist, he is also a predictor of the future. As early as 2015 Gates predicted that it would no longer be wars that threatened the future of mankind, but viruses. As EXHIBIT 66, [claimants] submit a screenshot of a TED talk show of 3 April 2015 in which Gates displays his alleged gift of prediction. As EXHIBIT 67, [claimants] submit a screenshot of a video of 27 May 2015 from YouTube entitled ‘What Bill Gates is afraid of’.

207. In the aforementioned videos, Gates, on the basis of unproven assertions about the Spanish flu and the Ebola virus, creates fear of the arrival of a deadly variant of a new corona virus. In doing so Gates presents himself as protector of the world, by among other things investing in ‘computer modeling’ of viruses and promoting new projects to be rolled out on a world scale for detecting virus outbreaks, creating enormous testing capacity and developing at lightning speed methods to be able to vaccinate everyone in the world frequently.

208. On 15 May 2018, the WEF, together with the Johns Hopkins Center for Health Security, organised in Washington DC a training session based on a simulation of a worldwide pandemic under the code name ‘Clade X: A Pandemic Exercise’ [fn 34]. The Bill & Melinda Gates Foundation is one of the major ‘Philanthropy Partners’ of the Johns Hopkins Center [fn 35]. As EXHIBIT 68, [claimants] submit a short explanation of the pandemic role-play, the trailer and the complete recording [fn 36] of the Clade X role-play. The participants were not allowed to criticise the pandemic scenario sketched in it. Clade X was a role-play in preparation for the implementation of the Covid-19 project. In this summons [claimants] have categorised the defendants according to their role in the Covid-19: The Great Reset project. In Clade X precisely those roles were rehearsed in advance, and the defendants have in essence played their roles exactly as they were rehearsed in Clade X. In fact, the pretended Covid-19 pandemic was thus rehearsed before the eyes of the world.

209. Clade X had its sequel on 18 July 2018 at a special WEF meeting in Davos. There a coming pandemic was simulated under the subject: ‘6 Ways countries can prepare for the next infectious disease pandemic’. The Netherlands, too, was amply represented at this WEF meeting. As EXHIBIT 69, [claimants] et al. hereby submit information from the WEF website concerning this WEF pandemic simulation of 18 July 2018. The evident purpose of this meeting was to make arrangements about what the future should look like after a major pandemic outbreak as rehearsed specifically in Clade X. In this connection, the information to be read in exhibit 69 includes the following:

‘... At the end of the exercise we proposed six long-term policy goals, that if enacted could prevent, or at least mitigate, the outcome of a pandemic similar in scale to CladeX:

1. Develop the capability to produce new vaccines, drugs and rapid diagnostics for novel pathogens within months, not years [fn 37] ...’

210. On 18 January 2019 the WEF and the Harvard Global Health Institute issued a so-called ‘White Paper’. It warns of an imminent outbreak of a worldwide infectious disease. By means of the White Paper, called ‘Outbreak Readiness and Business Impact Protecting Lives and Livelihoods across the Global Economy’, the WEF and the WHO prepare the affiliated countries (Agenda 2030 contracting parties) for the outbreak of a serious pandemic. As EXHIBIT 70, [claimants] submit the first three pages of the WEF Whitepaper ‘Outbreak Readiness and Business Impact Protecting Lives and Livelihoods across the Global Economy’, together with information about it from the WEF website.

211. On 18 October 2019 the WEF, together with the Johns Hopkins Center for Health Security and the Bill & Melinda Gates Foundation, organised in New York an extensive exercise of a high-level pandemic caused by an nCoV virus under the project name ‘Event 201’. The narrative with which the participants at this meeting simulate the fight against a pandemic in role-plays corresponds in essence with the narrative of the pretended Covid-19 pandemic from early 2020 until – in the Netherlands – 10

March 2023. Besides the correspondence in the narrative of a contagious virus causing many deaths, there is at Event 201, even more than at Clade X, a striking correspondence in the way in which the media, the government and the NGOs would present themselves towards the public, including [claimants], in the later pretended Covid-19 crisis. At the close of this Event 201 a number of very concrete ‘suggestions’ are given to the participants as to what must happen in a coming major pandemic. [claimants] submit as EXHIBIT 71 information concerning Event 201 from the Johns Hopkins website, together with a complete video recording of Event 201.

212. During all the simulations mentioned above, the narrative was that a vaccine had to come to save mankind.

213. According to the official narrative presented to the world two months after Event 201 as part of carrying out the Covid-19 project (the pretended Covid-19 pandemic), a new beta coronavirus was discovered at the end of 2019 from Wuhan, China, which quickly spread across the entire world and infected and killed many people.

214. The similarities between the scenario in Clade X, Event 201 and the official narrative concerning the pretended Covid-19 crisis constitute convincing proof of the fact that all these events took place within the framework of the Covid-19 project. Those preparations for the Covid-19 project, as already stated earlier in this summons, also concerned the preparation of the production of ‘vaccines’ and the filing of patent applications for those ‘vaccines’.

215. In particular on the instructions of the Bill & Melinda Gates Foundation, the pharmaceutical companies Moderna and Pfizer started as early as mid-2011 with the development of beta coronavirus mRNA vaccines. The first patent in that context was published on 28 February 2020 with number US-10702600-B1; it is based on provisional applications going back to 22 October 2015 and belongs to BioNTech GmbH and Moderna TX Inc. As EXHIBIT 72, [claimants] et al. submit the first page of the patent with number US-10702600-B1.

216. [claimants] conclude from this patent (exhibit 72) and its history that the invention on which, according to the official narrative, the Covid-19 injections are based already existed in 2015, and that there can therefore in reality have been no question of a lightning-fast development that allegedly took place at ‘Warpspeed’ and ‘The speed of science’. The statements by the CEO of Moderna before Member of the European Parliament Mr Cristian Terheș (exhibit 41) that Moderna’s clinical tests had already started in 2017 are, in view of the implications of this patent, more than plausible. In short, it is a great lie to claim that after the outbreak of the pretended Covid-19 pandemic a ‘vaccine’ was developed in a few months.

217. The Bill & Melinda Gates Foundation invested no less than $ 100,000,000.00 (one hundred million US dollars) in the development of the beta coronavirus mRNA vaccines. According to the official narrative,

the new coronavirus named Sars-CoV-2 belongs to the group of beta coronaviruses. As EXHIBIT 73, [claimants] submit information from the Moderna website and a Google search result showing the investment of the Bill & Melinda Gates Foundation in beta coronavirus mRNA vaccines.

218. On 12 December 2019 Moderna and the National Institute of Allergy and Infectious Diseases [fn 38] (hereinafter ‘NIAID’) concluded an agreement with the University of North Carolina at Chapel Hill, United States of America. This agreement bears the heading ‘Material Transfer Agreement’. It is apparent from this agreement that Moderna and the NIAID each own half of the mRNA beta corona vaccines. By this agreement the university is commissioned to carry out ‘non-humane challenge studies’ on various ‘coronavirus vaccines candidates’. These are tests in which laboratory animals – divided into groups that have or have not received the corona vaccine under test – are deliberately infected with a coronavirus, after which the action of the mRNA beta corona vaccine is assessed. It is noted in this regard that, in the same cooperation between the aforementioned parties, mRNA vaccines had already been tested since at least 2016 for, among other things, HIV. This agreement shows that the narrative that mRNA-based corona vaccines were developed after a new coronavirus broke out in Wuhan rests on a great lie. As EXHIBIT 74, [claimants] submit the Material Transfer Agreement of 12 December 2019.

219. In the context of the pretended Covid-19 pandemic, the WHO, through its Director-General Tedros Adhanom Ghebreyesus, declared to the world on 11 March 2020 that there was a Covid-19 pandemic. Gates then, in his frequent media appearances, reinforced the official Covid-19 narrative by sketching, from the start of the pretended pandemic, the picture that the world could only be saved by a medicine that would have to have an effectiveness of at least 95%. Normal medicines would not be able to achieve this effectiveness; only a corona vaccine still to be developed might be able to do so in the future. According to Gates, that vaccine would then have to be administered to seven billion people. In the early period of the pretended pandemic, Gates sketched an urgent situation in which scientists were busy developing several new vaccines. The hope, according to Gates, was that within 18 months one of these vaccines would prove successful. This picture was false. In proof of this, [claimants] submit as EXHIBIT 75 a screenshot of a video message posted by Gates on YouTube on 30 April 2020 entitled ‘The race for a Covid-19 vaccine’.

220. As demonstrated above, the reality was that, with funding from the Bill & Melinda Gates Foundation, work had already been going on for years before the pretended corona pandemic on developing a vaccine based on mRNA technology against disease caused by a beta coronavirus. All the patents for the so-called Covid-19 vaccine had been applied for years before the outbreak of the pandemic, and the animal experiments had already been carried out. Contrary to what Gates has

made out, there was no unprecedented achievement in ultimately bringing a Covid-19 ‘vaccine’ onto the market within one year instead of 18 months.

221. The reality is that the preparations for the pretended Covid-19 pandemic were made in every respect under Gates’s leadership. On the one hand the Covid-19 vaccine had already been fully prepared, and on the other hand Gates, the WHO and the WEF had already rehearsed worldwide with the parties needed to impose the measures of the pretended Covid-19 pandemic on the population, including [claimants].

222. A particularly objectionable aspect of Gates’s media appearances is that he said that, as soon as the Covid-19 ‘vaccine’ was on the market, he would make use of it immediately, regardless of which manufacturer it came from. They would all be safe and effective ‘vaccines’. [claimants] derived great confidence from this statement by Gates. At the moment Gates made this statement, namely 3 December 2020, trial subjects had already died in Pfizer’s clinical trials with its Covid-19 ‘vaccine’. [claimants] refer in this regard to what has been observed in that respect concerning Bourla about the Pfizer safety report of 30 April 2021 (exhibit 38). In proof of Gates’s statements of 3 December 2020, [claimants] submit as EXHIBIT 76 a screenshot of an interview with Gates on the Today Exclusive show as posted on YouTube under the title ‘It Looks Like Almost All The Vaccines Are Going To Succeed’.

223. Gates prides himself on his knowledge of mRNA technology and, as the largest financier of its development, knows like no other how far that technology has advanced and what it actually involves. Gates is the person par excellence who made all aspects of the development of the Covid-19 mRNA ‘vaccines’ possible. Gates followed this development closely and protected his own financial interests involved in it by means of patents, shareholdings and agreements.

224. It is inconceivable that Gates, who had every interest and every means, would not have known that in Pfizer’s clinical trials, already in the period November / December 2020, trial subjects had died and trial subjects had suffered irreparable physical injury. Moreover, in the opinion of [claimants] it is established that Gates knew that an important element of the development of the Covid-19 mRNA vaccines lay in the use of the very dangerous graphene oxide, as described in relation to Bourla. There is no doubt that Gates has intentionally done violence to the health of [claimants].

225. The influence of Gates on the Covid-19 deception intentionally brought about together with the other defendants cannot be overstated. Gates is the principal private steering factor in the policy of the WHO. This is because Gates, together with GAVI, accounts for an important part of the WHO’s budget, at least 15 per cent of it. The contracting parties to Agenda 21 and Agenda 2030, including the State of the Netherlands, comply with what the WHO prescribes. Through the Bill & Melinda Gates Foundation, Gates also sponsors various Dutch institutions, including

universities, in order to ensure that the ideas needed for the Great Reset are absorbed into the minds of as many people as possible. The latter is crucial for the Covid-19: The Great Reset project to be able to succeed. Information from the website of the Bill & Melinda Gates Foundation shows that in recent years these institutions have accepted almost half a billion euros from Gates in exchange for their cooperation in the roll-out of Agenda 2030 and the Great Reset. As EXHIBIT 77, [claimants] submit an Excel spreadsheet containing information obtained via the website of the Bill & Melinda Gates Foundation that shows the amounts and recipients registered there in this connection.

226. Gates is to blame for having prepared for years, for the benefit of Agenda 2030 and the Great Reset, the pretended Covid-19 pandemic, of which he knew that its consequences worldwide would be disastrous, and for now carrying it out. In this way Gates, in cooperation with the defendants, made it possible for [claimants] to be misled and, as a result, to have the Covid-19 injections. Without Gates’s unlawful conduct, [claimants] would not have had (been able to have) the Covid-19 injections. What has been stated with regard to Rutte concerning article 97a of the Dutch Criminal Code applies equally to Gates.

Semi-government

Kant

227. Defendant 16, hereinafter ‘Kant’, was appointed on 13 March 2013 at the Netherlands Pharmacovigilance Centre Lareb (hereinafter ‘Lareb’) as director with full authority. As of 28 December 2021, Kant exchanged this formal position at Lareb for the position of chair of the Board of Directors of Lareb. In that capacity, too, Kant has sole and independent authority. Kant has therefore been the de facto policymaker at Lareb since 13 March 2013. As EXHIBIT 78, [claimants] submit data from the Trade Register concerning Lareb.

228. Lareb is an organisation whose legal form is a foundation. Lareb is financed by the Medicines Evaluation Board (CBG) and the Ministry of Health, Welfare and Sport (VWS).

229. Lareb works together with the CBG and supports it in its statutory task in pharmacovigilance. Lareb informs the CBG by means of signals. Where vaccines are concerned, Lareb also informs the National Institute for Public Health and the Environment (RIVM). The RIVM can then take measures, for example amending the package leaflet, tightening who may use the medicine or receive the vaccine, or taking a product off the market. Lareb thereby forms a crucial intermediate link in signalling side effects of the Covid-19 injections and in giving warnings in that context.

230. On 8 September 2020 the RIVM awarded Lareb the contract to develop a ‘Covid Information and Monitoring System’ (CIMS). Crucial in this was that in this RIVM system the side effects of the various batches of the various Covid-19 vaccines are

registered per batch number, by reference to the batch number concerned and – where consent to this was not explicitly refused – by reference to the BSN (citizen service number) of the person in question.

231. In the context of privacy legislation, a data processing agreement was concluded between the RIVM and Lareb. The purpose of this data processing agreement was to enable Lareb to retrieve from the RIVM’s CIMS system the vaccine product and the batch number by reference to the patient’s BSN. In this way Lareb supplements the data on the side effects of the Covid-19 injections in the RIVM’s CIMS system.

232. An agreement was concluded between De Jonge and Lareb under which Lareb was commissioned to register the side effects of the Covid-19 vaccines by reference to the BSN and batch number.

233. The importance of keeping a register in which the distinct batch numbers are related to the side effects reported is evident. After all, a batch number is a number assigned to a production run of medicines. If something goes wrong in the production process, it stands to reason that the whole production run (batch) with the same number is affected by the same defect.

234. Batch numbers are the means par excellence of checking whether the quality of medicines is constant and whether they are safe and effective. Without registration by batch number there can be no effective signalling of defects in quality, safety and effectiveness.

235. In view of the foregoing, there is no doubt that the RIVM and Lareb are able to provide, per batch number, an overview of the registered side effects of the Covid-19 injections.

Lareb provides no data by batch number

236. By way of a Woo request (request under the Open Government Act) of 4 August 2022, Kuipers’s Ministry was asked to make public summary lists of all batch numbers of the vaccines of Pfizer, Moderna, AstraZeneca, Janssen and Novavax. This Woo request also asked for a summary register to be made public concerning the number of side effects and deaths linked to the batch numbers of the aforementioned vaccines. By decision of 29 March 2023, Kuipers announced that VWS had put out a search request to the RIVM, Lareb and the CBG-MEB. Kuipers announced that the requested documents had not been found at these bodies. The search request had therefore produced no documents. For this reason the Woo request was not granted. As EXHIBIT 79, [claimants] submit Kuipers’s Woo decision of 29 March 2023.

237. As indicated above, Lareb has a crucial role in pharmacovigilance. According to Lareb’s website [fn 39], it carries out research regularly as an

independent organisation. According to Lareb, the aim of that research is to gain more insight into known side effects of vaccines and medicines and to recognise new side effects earlier. According to its website, Lareb also collects information on the course, risk factors, treatment and burden of side effects. All of this with the aim of increasing the safety of medicines and vaccines. It cannot be reconciled with this task in pharmacovigilance that Lareb claims to be unable to make available data on side effects by batch number.

Kant carries out a cover-up construction for the benefit of the Covid-19 project

238. The remarkable assertion by Lareb, and therefore by Kant, noted above, that no data can be provided by batch number has only one explanation: Kant is lying. This lie by Kant serves an interest other than the interest of public health. Kant’s lie is of great importance for the Covid-19 project to be able to succeed. Worldwide this lie is kept alive by persons in the same position as Kant, with the aim of making the Covid-19 project succeed.

239. Kant’s lie conceals the enormously large differences in harmful short-term effects between the various Covid-19 injection batches. Kant knows this like no other, because she is familiar with all the possibilities of the CIMS system and, as a director with independent authority, accepted on behalf of Lareb the commission from Kuipers’s Ministry to register the side effects per batch.

240. Kant will not be able to refute the claimants’ accusations that she knowingly and intentionally caused Lareb to neglect its task in the field of pharmacovigilance. The evidence for this assertion of the claimants is evident and will be presented and explained below.

Kant’s cover-up

241. Lareb, under Kant’s leadership, kept a register of the side effects of the Covid-19 injections for the benefit of the Covid-19 project, and in doing so always registered the batch number concerned.

242. Until 19 November 2022 Lareb registered the side effects and deaths reported to it not only for the RIVM but also for the international data system named ‘Vaers’. Part of Kant’s cover-up was intentionally leaving unmentioned to the Dutch population, by batch number, the side effects and deaths resulting from Covid-19 injections. As already indicated above, Kant flatly denied that these data were available.

243. These data were, however, placed by Kant, by batch number, in the international Vaers registration system. In Vaers those data at Dutch level could only be found with knowledge of the Vaers system and the search variables and codes to be used in it. However, all Dutch data were deleted from Vaers on 18 November 2022.

244. The data as they could be found in Vaers until 19 November 2022 can be obtained via a historical database accessible online [fn 40]. The claimants therefore have at their disposal the Covid-19 batch data included in Vaers before 19 November 2022.

245. An important example of the very large differences between batches of Covid-19 injections concerns the Covid-19 Pfizer batch EM0477. This batch is of great importance because it was already administered to the Dutch population in January 2021, the start of the vaccination campaign, and immediately led to many serious reports of side effects and deaths. This batch is characterised by the fact that shortly after injection, already in February and March 2021, more than thirty persons were reported to have died. With regard to batch EM0477 more specifically, this batch led to 71 reports of side effects, of which 34 were reports of deaths. It is noted in this regard that reading the reports drawn up in connection with these reports invariably shows the ‘Regulatory authority number’ linked to the Lareb official concerned. The first letters of this reference are always ‘NL-LRB’. What is alarming here is that the side effects and deaths described in these reports almost all occurred within a few days, and the harmfulness of this batch cannot have escaped Lareb, and therefore Kant. While this batch had already led by March 2021 to more than thirty reports of deaths at Lareb, no signal came from Kant’s side that the safety of the ‘Covid-19 vaccine’ could no longer be guaranteed. As EXHIBIT 80, [claimants] submit information from the Vaers system concerning the reports of the 34 deaths from batch EM0477 reported to Lareb.

246. That the Pfizer batch EM0477 given as an example was particularly lethal compared with other batches administered in the same period in the Netherlands can easily be established, namely by comparison with other Pfizer Covid-19 batches administered to the Dutch population in the same period, such as the batches with numbers EJ7133, EJ6975 and CE6792. These other batches each have only one report of non-fatal side effects. As EXHIBIT 81, [claimants] submit a comparative overview in which the aforementioned batches administered in the Netherlands are included.

247. A comparison of international data on the Pfizer Covid-19 batch EM0477 with international data on other Covid-19 batches also shows enormous differences – more than a factor of 100 – in the number of deaths and injuries reported per batch. As EXHIBIT 82, [claimants] submit three pages of a 908-page international comparison [fn 41] between the batches.

248. That very large differences in lethality and side effects exist between Pfizer Covid-19 injection batches was proven by research carried out in Denmark under the direction of Professor Peter Riis Hansen. Professor Hansen is attached to the department of cardiology of the University of Copenhagen and attached as an expert to the European Medicines Agency (EMA). His research shows that approximately 4% of all batches are responsible for more than 70% of all reported side effects, 27% of

all serious side effects and 47% of all reported deaths after vaccination. Following this research, questions were asked in the European Parliament on 10 May 2023. As EXHIBIT 83, [claimants] submit Professor Hansen’s research, together with information about his appointment at the EMA and about the questions asked in the European Parliament about his research.

249. Despite all the facts and evidence, Kant persists in her lies. Kant’s lies serve the Covid-19 project and constitute an intentional and direct attack on the health of the Dutch people, including [claimants]. Kant states literally: ‘We can say that fear of the vaccine was unjustified’. This is a lie and a deception of unprecedented scale, and it speaks for itself that Kant is thereby acting unlawfully towards [claimants] and the entire Dutch people. As EXHIBIT 84, [claimants] submit a screenshot of an article in the AD of 20 November 2021 in which the statement quoted above appears.

250. The role of Kant in the Covid-19 deception intentionally brought about together with the other defendants cannot be overstated. As indicated above, Lareb, and therefore also Kant, is financed by the Medicines Evaluation Board (CBG) and the Ministry of Health, Welfare and Sport (VWS). Kant let herself be paid by the pharmaceutical industry and by Kuipers’s Ministry and, over a period of ten years, corrupted Lareb, so that the Covid-19 project and the Great Reset could be launched by means of the Covid-19 injection campaign. It is to this end that Kant runs Lareb.

251. As regards the almost unimaginable seriousness of Kant’s conduct, [claimants] consider it important to point out that Kant is an important participant in the Disinformation Think Tank. [claimants] have argued with reasons above, in relation to Koopmans, that it is precisely the Disinformation Think Tank that, by means of influencers recruited for that purpose, promotes the spreading of disinformation for the benefit of the Covid-19 project. It is all the more objectionable that Kant is personally involved in giving Covid-19 courses for general practitioners in which she keeps these general practitioners ignorant of what Lareb actually registered for the distinct batches, and tells the general practitioners nothing of her position in the Disinformation Think Tank. As EXHIBIT 85, [claimants] submit information concerning the aforementioned Covid-19 courses for general practitioners given by Kant.

252. Kant, with her Lareb foundation, has been an important source of information for the claimants on the safety and effectiveness of the Covid-19 injections. It was Kant who intentionally and falsely reassured the claimants by putting into a cover-up the very important signal that some Covid-19 batches are much more lethal and/or much more harmful than others. Had Kant shared this information about the large differences in reports between the distinct batches with the Dutch population – which was her task – the claimants would not have had (been able to have) a Covid-19 injection and would not have suffered damage. What has been stated with regard to Rutte concerning article 97a of the Dutch Criminal Code applies equally to Kant.

Government

253. Defendant 17, hereinafter ‘the State’, has as its primary task the protection of its citizens. The State is not permitted to transfer this task, for which it is exclusively responsible and liable, to a foreign power. This applies regardless of whether that foreign power is a foreign legal person under public law or an organisation under private law. In carrying out its primary task, the State must respect the fundamental rights and the international human rights of its citizens and actively protect its citizens to that end. This is in order to ensure that its citizens enjoy these rights in full at all times. A part of these rights that is important for this case is to be found in the ethical principles developed by the judiciary in the context of the Nuremberg trials. These principles are recorded in the Nuremberg Code 1947. The core of the Nuremberg Code 1947 forms the basis of article 7 of the International Covenant on Civil and Political Rights concluded in New York in 1966 (hereinafter ‘ICCPR’). This article reads as follows:

‘No one shall be subjected to torture or to cruel, inhuman or degrading treatment or punishment. In particular, no one shall be subjected without his free consent to medical or scientific experimentation.’

254. The State is to blame for the fact that, without freely given consent by its citizens, including [claimants], to participation in the Covid-19 experiment (Covid-19 project), a medical and scientific (behavioural) experiment was carried out on all its citizens, including [claimants], as a result of which serious damage arose for, among others, [claimants].

255. Insofar as the State might take the view that, because not every citizen has taken a Covid-19 injection, this is not a medical and scientific experiment on all its citizens, that view rests on a mistaken reading of article 7 ICCPR. After all, the data of citizens without a Covid-19 injection are also registered by the RIVM, and the experiment also had the aim of influencing citizens’ behaviour by means of torture and cruel, inhuman and degrading treatment and punishment. The Covid-19 measures imposed by the State on its citizens under the influence of the defendants in the context of the Great Reset involved torture through, among other things, having to wear face masks that make people ill and keeping a distance of at least one and a half metres from one another. The Covid-19 measures were inhuman in view of their malicious character, as has been explained at length in this summons. For all citizens these measures were inhuman and degrading, even if, under the influence of fear and deception, not everyone was aware of this. In addition, the State punished citizens who resisted the unlawful Covid-19 measures.

256. That the State unlawfully failed to protect its citizens, including [claimants], is apparent from the fact that the State involved itself with the other defendants and allowed the other defendants to corrupt the institutions that should have

protected the citizens. It was evident to the State that the other defendants had for years been working together to hollow out the power of the State so as to make the Dutch population, including [claimants], susceptible to the Covid-19: The Great Reset project. That all the defendants are connected with the private foundation the WEF, and that their actions are aimed at carrying out the Covid-19: The Great Reset project, is established in view of the State’s position of information. After all, this position of information is determined in part by defendants as its officials and subordinates. In addition, the WEF, in the person of Schwab, openly declared as early as 2017 that it was penetrating all the cabinets in the world by means of its members. As EXHIBIT 86, [claimants] submit a video concerning Schwab’s statement from 2017. The fact that the State allows the WEF, and in particular the defendants, to play their harmful role within the Dutch setting for so long results in a situation in which, to use Schwab’s words, ‘we have to prepare for a more angry world’ and ‘necessary action’ must therefore be taken. Schwab put into words, in a speech of 14 July 2020, the gloomy prospect for the future that this entails for the Dutch population, including [claimants]. [claimants] submit as EXHIBIT 87 a screenshot of Schwab’s video of 14 July 2020.

257. The extremely reprehensible and objectionable acts and omissions of the State are evidently unlawful and lead to more and more excesses under which the Dutch people, including [claimants], are suffering. The defendants are all fully responsible and liable for these excesses, because at their core they can always be traced back to the evidently unlawful Covid-19: The Great Reset project, to which the defendants give their full cooperation and for which the defendants do not shrink from misusing the institutions of the State. [claimants] give a number of examples of this.

Examples of excesses

WEF partner Gates invests in Dutch WEF partner Heineken

258. A first example of an excess is that the State allowed WEF partner Gates to make an investment of EUR 880,000,000.00 here in the Netherlands in the brewing group Heineken. Heineken is a WEF partner which, during the pretended corona crisis in July 2021 in the Netherlands, used malicious, manipulative television advertising to induce people, especially the elderly, to have themselves inoculated with Covid-19 injections. This manipulation made use of the false pretext that freedom would belong exclusively to people inoculated with Covid-19 injections. This was translated into the WEF / Heineken credo ‘The night belongs to the vaccinated’. With this, Heineken, with the State’s consent, carried out the Covid-19: The Great Reset project. The State should have counteracted all this in order to protect its citizens, including [claimants]. It should be borne in mind here that it was precisely among the elderly, who were addressed and misled with the aforementioned credo, that many deaths and injuries as a result of the Covid-19 injections were reported. As EXHIBIT 88, [claimants] submit a screenshot of the Heineken video, together with information from the WEF website concerning Heineken and information concerning Gates’s investment in Heineken.

The State and its officials violate the provision of article 162 of the Code of Criminal Procedure, which is fundamental to a state governed by the rule of law

259. A second excess to which [claimants] draw attention is the fact that the State and its officials have not applied article 162 of the Code of Criminal Procedure. This article reads as follows:

1. Public bodies and officials who, in the exercise of their office, become aware of a serious offence (misdrijf) with the investigation of which they are not charged, are obliged to report it without delay, handing over the documents relating to the matter, to the public prosecutor or to one of his assistant prosecutors,

a. if the offence is an official offence as referred to in Title XXVIII of the Second Book of the Criminal Code, or

b. if the offence was committed by an official who in doing so breached a special official duty or made use of power, opportunity or means afforded to him by his office, or

c. if the offence involves an infringement or unlawful use of a regulation whose implementation or the supervision of compliance with which has been entrusted to them.

2. On request, they provide the public prosecutor or the assistant prosecutor designated by him with all information concerning criminal offences with the investigation of which they are not charged and which have come to their knowledge in the exercise of their office.

3. The provisions of the first and second paragraphs do not apply to an official who, by making a report or providing information, would create a danger of prosecution of himself or of someone in whose prosecution he could claim privilege from giving evidence.

4. The same obligations rest on legal persons or bodies of legal persons whose tasks and powers are described by or pursuant to the law, insofar as designated for that purpose by order in council.

5. Rules may be laid down by or pursuant to order in council in the interest of the proper implementation of this article.

6. The reporting of offences referred to in the first paragraph under c may be further restricted in consultation with the public prosecutor and in compliance with the rules referred to in the previous paragraph.

7. The recommendation for an order in council as referred to in the fourth or fifth paragraph is not made until the draft has been published in the Netherlands Government Gazette (Staatscourant) and two months have passed since the day of publication.

260. [claimants] are of the opinion that the righteous officials of integrity of the State who have knowledge of the official offences alleged in this summons are obliged to report them without delay, handing over the documents relating to the matter, to the public prosecutor or to one of his assistant prosecutors. That, to date, there has been no report under article 162 Sv. (Code of Criminal Procedure) may, in the opinion of [claimants], be called an excess.

261. [claimants] note that many well-meaning and well-informed Dutch citizens made their serious objections and concerns known to Dutch officials, but that nothing was subsequently done with this. A striking example of this is that on 4 January 2023 Mr Ton Koenderink, in the municipality of Haaksbergen, by using his right to speak, fully informed the municipal council about the oft-cited Pfizer safety report of 30 April 2021 (exhibit 40) and its implications. It is to be called particularly objectionable that, as this video shows, the State meets its own citizens with silence. A screenshot of Mr Ton Koenderink’s extremely important and striking presentation of 4 January 2023 is submitted as EXHIBIT 89.

The State, through national television, threatens unvaccinated citizens of the Netherlands with death.

262. A third and last particularly objectionable excess attributable to the State, to which [claimants] draw attention, concerns the following. During the pretended Covid-19 crisis, the State, on national television, openly threatened with death people who did not want to have Covid-19 injections. To that end the State had two gruesome video messages made through its public broadcasters NOS, NTR and VPRO, and broadcast them via the central government’s Postbus 51 television information channel. These videos give the clear message that people without a Covid-19 injection must be ruthlessly murdered. In proof of this, [claimants] submit as EXHIBIT 90 two screenshots of videos from October 2021. The message of the State contained in them is abject and infamous. On seeing these video messages, [claimants] were psychologically abused by the State.

263. Had the State complied with its duty to protect its citizens, [claimants] would not have had (been able to have) the Covid-19 injections.

Claimants, damage

264. The claimants are all Dutch citizens living in the Netherlands who placed their trust in what the defendants proclaimed and were consequently misled and, as a result, had several Covid-19 injections. All the claimants suffer damage as a result of this deception and as a result of the Covid-19 injections given to them as a consequence of this deception. The claimants’ damage is both material and non-material within the meaning of article 6:106 DCC.

265. The claimants’ material damage concerns financial loss, in particular personal injury damage. As a result of the Covid-19 injections, all the claimants were injected, without their freely given consent, with (among other things) the toxic graphene oxide. It is plausible that the Covid-19 injections, and in particular this poison forming part of those injections, cause lasting adverse health consequences in people. On this ground alone it is plausible that all the claimants suffer personal injury damage. In claimants 4, 6 and 7 the personal injury has manifested itself in the form of grievous bodily harm. In the other claimants there are currently no external physical signs of

grievous bodily harm, but there are less far-reaching complaints. This does not alter the fact that it is plausible that the Covid-19 injections have caused bodily injury in them too. As regards the latter, it may be observed that it is plausible that the claimants’ health will also suffer in the long term from these Covid-19 injections. As regards their personal injury and its plausibility, the claimants refer to the diagnoses made by medical specialists. These diagnoses are submitted as EXHIBIT 91.

266. In addition to material damage, all the claimants suffer non-material damage within the meaning of article 6:106 DCC. This damage consists of the mental harm experienced by the claimants (feelings of pain, suffering, shame, powerlessness and uncertainty about their health) as a result of the deception brought about by the claimants [sic]. The Covid-19 injections themselves, more particularly the fact that the claimants know they have been injected with them while they cannot know what exactly the consequences will be, also lead to non-material damage within the meaning of article 6:106 DCC.

267. In the context of the non-material damage it is further noted that the claimants have argued with reasons that the defendants had the intention of causing them harm. It is also noted, in connection with the provisions of article 6:106(1)(c) DCC, that claimants 2 and 3 and claimants 4 and 5 are each other’s spouses.

268. It is settled case law [fn 42] that, for referral to the follow-up proceedings for the assessment of damages (schadestaatprocedure), it is necessary and also sufficient that the existence or the possibility of damage as a result of an attributable failure or an unlawful act is plausible. The claimants are of the opinion that, with the present summons, they have amply satisfied this standard for referral to the proceedings for the assessment of damages.

Unlawful conduct by the defendants

269. The law provides in article 6:162 DCC that a person who commits an unlawful act towards another which can be attributed to him is obliged to compensate the damage that the other suffers as a consequence.

270. The following are regarded as an unlawful act: an infringement of a right, and an act or omission in breach of a statutory duty or of what is proper in society according to unwritten law, all this subject to the presence of a ground of justification.

271. In this summons the claimants have described at length the manner in which the defendants have made themselves guilty of carrying out the Covid-19: The Great Reset project and the widespread deception of citizens needed for it. The defendants have thereby evidently acted unlawfully. In this, all the types of unlawful conduct mentioned in article 6:162 DCC apply to the defendants. Below the claimants will give important examples of this, without being exhaustive.

Infringement of a right

272. As regards the infringement of the claimants’ rights, the claimants point in particular to article 7 of the International Covenant on Civil and Political Rights [fn 43], which provides:

No one shall be subjected to torture or to cruel, inhuman or degrading treatment or punishment. In particular, no one shall be subjected without his free consent to medical or scientific experimentation.

273. Through the defendants’ actions, the claimants have ended up in a situation in which they have been subjected, without their freely given consent, to an ongoing medical and scientific experiment.

Acting in breach of a statutory duty

274. Article 2 of the Criminal Code provides that Dutch criminal law applies to anyone who commits any criminal offence in the Netherlands. None of the defendants, including those who live abroad, can escape his or her statutory duty to observe the Dutch Criminal Code.

275. The significance of article 97a Sr. (Criminal Code), which concerns a serious offence against the security of the state, has already been pointed out above. This article reads as follows.

An attack undertaken with the aim of bringing the Realm wholly or partly under foreign rule or of separating part of it is punished with life imprisonment or a fixed term of imprisonment of at most thirty years or a fine of the fifth category.

276. The claimants are of the opinion that the manner in which the defendants have made themselves guilty of carrying out the Covid-19: The Great Reset project and the widespread deception of citizens needed for it must be classified as acting in breach of the statutory duty to refrain from committing criminal conduct within the meaning of this article.

277. It is further noted that the defendants’ conduct is classified as assault (mishandeling) within the meaning of article 300 of the Criminal Code. In this the defendants intentionally harmed the claimants’ health. This article reads:

1. Assault is punished with imprisonment of at most three years or a fine of the fourth category.

2. If the act results in grievous bodily harm, the offender is punished with imprisonment of at most four years or a fine of the fourth category.

3. If the act results in death, he is punished with imprisonment of at most six years or a fine of the fourth category.

4. Intentional harming of health is equated with assault.

5. An attempt to commit this serious offence is not punishable.

278. Specifically for the benefit of claimants 4, 6 and 7, who have suffered grievous bodily harm through the defendants’ actions, reference is hereby made to article 308 of the Criminal Code. This article provides as follows.

1. A person through whose fault another person sustains grievous bodily harm, or such bodily harm as results in temporary illness or inability to carry out his official or professional activities, is punished with imprisonment of at most one year or a fine of the fourth category.

2. If the fault consists of recklessness, he is punished with imprisonment of at most two years or a fine of the fourth category.

279. Specifically with regard to the State and its officials, it is repeated that the claimants point to a flagrant violation of article 162 of the Code of Criminal Procedure, which places officials under a statutory obligation – in short – to report official offences.

280. Finally, the claimants point here to the defendants’ obligation to comply with the statutory obligations under the International Crimes Act. Article 3 of this Act makes genocide a criminal offence. This article reads as follows.

1. A person who, with the intent to destroy, in whole or in part, a national, ethnic or religious group, or a group belonging to a particular race, as such:

a. kills members of the group;

b. causes serious bodily or mental harm to members of the group;

c. deliberately inflicts on the group conditions of life aimed at its physical destruction in whole or in part;

d. imposes measures intended to prevent births within the group; or

e. forcibly transfers children of the group to another group,

is punished, as guilty of genocide, with life imprisonment or a fixed term of imprisonment of at most thirty years or a fine of the sixth category.

2. Conspiracy to commit genocide and incitement to genocide that takes place in public, orally or in writing or by image, are punished in the same way as the attempt.

281. The claimants wish your court, in its inquiry into the truth, also to examine whether genocide has been committed against the claimants on grounds b and c of this article. The claimants consider that, in view of the facts and circumstances they have put forward fully and truthfully in this summons, this is plausible.

Acting in breach of what is proper in society according to unwritten law.

282. In this summons the claimants have set out, with regard to each of the defendants, what function they fulfil in society. In doing so, the defendants have been categorised in groups according to the social position they (mainly) occupy.

283. For government officials, the standard applies in particular of serving the citizen, including [claimants], with integrity, so that trust in the government cannot be betrayed. Defendants 1 to 10 have grossly violated this trust by carrying out the Covid-19: The Great Reset project and the widespread deception of citizens needed for it. Insofar as this conduct is not prohibited by law and codes of conduct, this conduct is contrary to what is proper in society according to unwritten law.

284. For the pharmaceutical industry, its right to exist depends on the trust that citizens can place in the safety and effectiveness of medicines which the citizen may assume have been properly tested. On the basis of this given, and the fact that medicines intervene in people’s health, the pharmaceutical industry has the duty to deal with great care with the health interests of citizens in safe, effective and well-tested medicines. The conduct of the pharmaceutical industry must be directed first and foremost at not betraying the citizen’s trust. Through the pharmaceutical industry’s cooperation in carrying out the Covid-19: The Great Reset project and the widespread deception of citizens needed for it, the pharmaceutical industry has grossly violated this trust. Insofar as this conduct is not prohibited by law and codes of conduct, this conduct is contrary to what is proper in society according to unwritten law.

285. As regards the mass media, they ought to inform the public in a careful, reliable, independent, pluriform and objective manner. In this connection the mass media ought to check carefully the information they give to the public. In doing so, the mass media should leave room for different opinions and facilitate a balanced debate. In this summons it has been set out that the mass media engage in censorship and in this way cooperate in carrying out the Covid-19: The Great Reset project and the widespread deception needed for it. Insofar as this conduct is not prohibited by law and codes of conduct, this conduct is contrary to what is proper in society according to unwritten law.

286. For (officials at) non-governmental organisations, they pride themselves on the idea that, without profit motive, they want to support people and governments in their mission to bring mankind and its living environment to full flourishing. In this they present themselves as benefactors who want to support this mission. This way of presenting themselves creates in the public the legitimate expectation that these organisations and their officials will not act in their own interest.

In view of this, the unwritten standard applies to these organisations and their officials that they may not harm the interests of people and their living environment. In this summons it has been described at length that defendants Sijbesma and Gates cooperate in carrying out the Covid-19: The Great Reset project and the widespread deception needed for it. This project is harmful to the health of people and their living environment. Insofar as this conduct is not prohibited by law, this conduct is contrary to what is proper in society according to unwritten law.

287. For semi-government bodies, the State and the citizen must be able to rely on the government tasks entrusted to them at the expense of the Dutch people, including [claimants], being carried out with integrity and care. Kant has grossly violated this trust by carrying out the Covid-19: The Great Reset project and the widespread deception of citizens needed for it. Insofar as this conduct is not prohibited by law and codes of conduct, this conduct is contrary to what is proper in society according to unwritten law.

288. For the State, as already indicated above, its primary task is the protection of its citizens. It is incompatible with this that the State facilitates and permits the Covid-19: The Great Reset project to be carried out and the widespread deception of citizens needed for it to take place in the Netherlands. Insofar as this conduct is not prohibited by law and codes of conduct, this conduct is contrary to what is proper in society according to unwritten law.

Establishment of liability, conditio sine qua non

289. It has consistently been set out in this summons that, without the unlawful conduct of the defendants, committed both separately and jointly, the claimants would not have had a Covid-19 injection, and their damage would therefore not have occurred.

290. In view of the group liability to be asserted below, the conditio sine qua non link is not a requirement for the claims of [claimants] to be awarded.

Attribution of the damage to the defendants

291. The unlawful acts with which the defendants are charged can be attributed to them because they are due to their fault and to causes for which they are accountable by law and according to generally accepted views. After all, the defendants have all actively cooperated in carrying out the Covid-19: The Great Reset project and the widespread deception of citizens needed for it, including [claimants].

Group liability

292. Article 6:166 DCC provides that if one of a number of persons belonging to a group unlawfully causes damage, and the risk of thus causing damage should have restrained these persons from their conduct as a group, they are jointly and severally liable if this conduct can be attributed to them.

293. In this summons the claimants have pointed out to your court the group connection between all the defendants. The introduction to this summons includes an image concerning the partners of Gavi. This summons has stated and argued at length how the defendants, who all belong to the circle of these partners, actively cooperated in carrying out the Covid-19: The Great Reset project and the widespread deception of citizens needed for it, including [claimants]. Each of the defendants should have refrained from his or her unlawful conduct in the context of this project, because it increased the risk of thus causing damage (through taking a Covid-19 injection).

Defence of the defendants and its refutation

294. The claimants are not aware of any legally relevant defence by the defendants against the claimants’ claims, which is why the claimants cannot address and refute any such defence of the defendants in this summons.

Offer of proof

295. Insofar as the burden of proof rests on the claimants under article 150 DCCP, the claimants offer to prove all their assertions by all means permitted by law. In particular, the claimants offer proof by the hearing of witnesses and expert witnesses. In this connection the following persons can be heard under oath.

the claimants and the defendants

the doctors who, as appears from exhibit 91, made a diagnosis in the claimants

Member of the European Parliament Cristian Terheș

Jurisdiction of the District Court of the Northern Netherlands, Leeuwarden location

296. Article 107 DCCP provides that if a court has jurisdiction with regard to one of the defendants jointly involved in the proceedings, that court also has jurisdiction with regard to the other defendants, provided there is such a connection between the claims against the various defendants that reasons of efficiency justify a joint hearing.

297. Defendant Hofstra lives in Goutum, municipality of Leeuwarden, and your court therefore has jurisdiction under article 99 DCCP to hear the claims against Hofstra. Because between the claims

against the various defendants – who have acted as a group – there is such a connection that reasons of efficiency justify a joint hearing, your court has jurisdiction under article 107 with regard to all the defendants to hear and decide the claims brought against them by the claimants.

Petitum

WHEREFORE

May it please the court, by judgment:

(1) to declare that the defendants, as a group and each individually, have acted unlawfully towards the claimants by intentionally misleading them in an unlawful manner and thereby inducing them to have Covid-19 injections of which the defendants knew, or at least ought to have known, that these injections were not safe and effective;

(2) to order the defendants, jointly and severally, on the understanding that payment by one releases the others, to compensate the claimants for their damage, to be assessed in follow-up proceedings for the assessment of damages and settled in accordance with the law, provisionally enforceable;

(3) to order the defendants to pay the costs of these proceedings by means of an order for costs to be pronounced for that purpose by your court, provisionally enforceable.

The costs of this writ are:

deed € 106.73 + information costs € 0.59 + VAT € 22.54 = total € 129.86

The costs of this writ have been increased by VAT because the applicant cannot offset it.

I declare that the additional costs are necessary to carry out this official act properly and that the bailiff has no direct or indirect interest in the business or third party that charged these costs.

(tgv.) Bailiff

[fn 1] https://www.who.int/europe/health-topics/vaccines-and-immunization#tab=tab_1

[fn 2] https://www.gavi.org/our-alliance

[fn 3] The GGD is administratively part of the Fryslân Safety Region (Veiligheidsregio Fryslân).

[fn 4] This advice goes to the Ministry of VWS (Ministry of Health, Welfare and Sport) via the Administrative Coordination Consultation (BAO). The BAO tests the substantive advice for administrative feasibility and practicability and ultimately determines the control policy.

[fn 5] As will be set out further below, Van Dissel, too, knew that the Covid-19 vaccinations were never tested for preventing transmission of the supposed virus.

[fn 6] https://decorrespondent.nl/11128/de-wereld-is-voorgoed-veranderd-door-corona-denkt-viroloog-marion-koopmans/e0013376-fee5-045c-3dab-ee24387670fa

[fn 7] Mr Schwab, who is one of the founders of the project ‘Covid-19 The Great Reset’, will be discussed further in this summons.

[fn 8] The basic rules are still in force and read: (1) stay at home if you have symptoms and get tested; (2) keep 1.5 metres away from others; (3) wash your hands often and cough and sneeze into your elbow; (4) work from home as much as possible; (5) avoid crowds: leave if it is busy; (6) travel outside rush hour as much as possible; (7) wear a face mask in public indoor spaces.

[fn 9] Addition by the litigation lawyer

[fn 10] http://reparti.free.fr/schwab2020.pdf

[fn 11] Frank Ruesink MBA / Founder of Liefdevol Rebelleren (Loving Rebellion), Freedom Speaker & System Changer https://www.linkedin.com/in/frankruesink/?originalSubdomain=nl

[fn 12] Underlined by the litigation lawyer

[fn 13] Gommers is also registered as inventor of a ventilation system (ADVS) for which patents were applied for in the United States at the United States Patent and Trademark Office (USPTO) on 30 September 2016. In the meantime a patent has been granted in this connection under number 10773045. Further, an application for a patent on this invention is still pending under number 20180093063. The rights under the patent with number 10773045 have been transferred to Kirura Holding B.V.

[fn 14] [claimants] dispute that the defendants, including Gommers, were actually injected with a Covid-19 injection fluid.

[fn 15] Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters, Aarhus, 25-06-1998

[fn 16] https://wetten.overheid.nl/BWBV0001700/2005-03-29

[fn 17] This can be compared with the EMA, EU/EEA Heads of Medicines Agencies and the European Medicines Agency (EMA).

[fn 18] https://www.pfizer.com/news/announcements/open-letter-pfizer-chairman-and-ceo-albert-bourla

[fn 19] This report has number 090177e196ea and is dated 30 April 2021

[fn 20] According to Pfizer, this brand name is composed of parts of the words Covid-19, community, immunity, and mRNA.

[fn 21] Variants of this motto have been used in all languages worldwide.

[fn 22] The name Moderna derives from a contraction of the words ‘Mode’ and ‘RNA’.

[fn 23] This patent has a publication date of 15 January 2021, but until mid-June 2021 it could not be found, using the usual search terms including the patent number, with the search engine offered on the internet by WEF partner Google, which the great majority of the world population uses.

[fn 24] Shown in bold and underlined by the litigation lawyer.

[fn 25] https://over.nos.nl/organisatie/taken-en-missie/

[fn 26] Until 1 September 2022 Van Cann worked as deputy editor-in-chief alongside Mr Gelauff, who was editor-in-chief until that date. Gelauff subsequently retired and, as far as [claimants] have been able to ascertain, is no longer active as a journalist.

[fn 27] The versions of the package leaflets of the Pfizer vaccine Comirnaty drawn up at different times state, up to and including the version of November 2022, under E: ‘Specific obligations to be fulfilled after the granting of a conditional marketing authorisation.’ At that point the planned end date of the experiment, namely August 2024, was stated.

[fn 28] The complete Agenda 21 has been placed on the USB stick.

[fn 29] The complete Agenda 2030 has been placed on the USB stick.

[fn 30] https://databank.worldbank.org/

[fn 31] United Nations Conference on Trade and Development (UNCTAD), and in consultation with organisations such as the International Trade Centre, the United Nations Statistics Division (UNSD) and the World Trade Organization (WTO)

[fn 32] The complete patent has been placed on the USB stick.

[fn 33] https://www.gatesfoundation.org/

[fn 34] Cladistics or cladism is a method of analysis used in biosystematics to determine the presumed evolutionary relationships between organisms. The word ‘Clade’ is derived from it.

[fn 35] https://centerforhealthsecurity.org/who-we-are-at-the-center-for-health-security-0

[fn 36] The video material of this exhibit has been placed on the USB stick.

[fn 37] Shown in bold and underlined by the litigation lawyer

[fn 38] Dr Fauci was the director of this organisation from 1984 up to and including 2002.

[fn 39] https://www.lareb.nl/

[fn 40] https://www.medalerts.org/vaersdb/findfield.php In the search system of this database, the data entered into Vaers by Lareb staff can be found in the so-called expert mode. To do so, the DC Split Type NLPFIZER, NLMODERNATX or NLJNJFOC must be entered under the ‘Demographics’ tab.

[fn 41] The complete overview can be downloaded via https://knollfrank.github.io/HowBadisMyBatch/batchCodes.html

[fn 42] T.F.E. Tjong Tjin Tai, De schadestaatprocedure, no. 401, referring to, among others, HR 30 June 2006, ECLI:NL:HR:2006:AX6246, RvdW 2006, 681, para. 3.5.2 and HR 23 September 1988, ECLI:NL:HR:1988:AD5713, NJ 1989, 743 and S.D. Lindenbergh, GS Schadevergoeding, art. 6:97 BW, note 5.6.

[fn 43] New York, 16-12-1966