Declaration of Adriana Pinto — Children's Health Defense v. Rutgers (D.N.J., 2021-08-30)

Summary

A Declaration of Plaintiff Adriana Pinto under 28 U.S.C. 1746, Document 10-4, stamped Filed 08/30/21, in Children's Health Defense, Inc., Peter Cordi, Raelynne Miller, Kayla Mateo, Adriana Pinto, Jake Bothe, and Does 1-13 v. Rutgers, The State University of New Jersey, et al., Case No. 3:21-cv-15333 (ZNQ-TJB), in the U.S. District Court for the District of New Jersey. Pinto states that she is a Rutgers senior who needs one more class to graduate, has refused COVID-19 vaccines, and enrolled in a fully remote class to use Rutgers' remote-study exemption. She says Rutgers blocked her NetID account on or about August 26, 2021 for non-compliance with its vaccine policy, which would keep her from attending the first day of class on September 1, 2021. Exhibits A and B are referenced but carry no text.

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Record facts

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Julio C. Gomez, Esq. 
GOMEZ LLC ATTORNEY AT LAW 
1451 Cooper Road 
Scotch Plains, NJ 07076 
Tel 908.789.1080 
Fax 908.789.1081 
Attorney for Plaintiffs 
 
UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF NEW JERSEY 
CHILDREN’S HEALTH DEFENSE, INC., 
PETER CORDI, RAELYNNE MILLER, 
KAYLA MATEO, ADRIANA PINTO, 
JAKE BOTHE, AND DOES 1-13, 
 
 
Plaintiffs, 
Case No. 3:21-cv-15333 
(ZNQ-TJB) 
 
-against- 
 
 
 
RUTGERS, THE STATE UNIVERSITY 
OF NEW JERSEY, BOARD OF 
GOVERNORS, RUTGERS SCHOOL OF 
BIOMEDICAL AND HEALTH 
SCIENCES, CHANCELLOR BRIAN L. 
STROM, PRESIDENT JONATHAN 
HOLLOWAY, in their official capacities. 
 
DECLARATION 
OF PLAINTIFF 
Defendants 
 
 
DECLARATION OF PLAINTIFF ADRIANA PINTO 
Pursuant to 28 U.S.C. § 1746, I, ADRIANA PINTO, of full age certify as 
follows: 
1. 
I am 22 years old and a lifetime member of Plaintiff Children’s Health 
Case 3:21-cv-15333-ZNQ-TJB   Document 10-4   Filed 08/30/21   Page 1 of 4 PageID: 141

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Defense, Inc., a 501(c)(3) non-profit. 
2. 
I am also a senior at Rutgers University, majoring in psychology with 
a minor in education.  I need to take one more class to complete the coursework 
towards my degree and qualify for graduation. 
3. 
After researching COVID-19 vaccines, I decided not to take them 
because I believe they would alter my body’s natural immunity artificially with 
unknown and untested chemical substances and technologies that have not been 
proven to be safe or effective long-term. 
4. 
I have struggled with my health as a young adult, and must adhere to 
strict requirements to stay healthy and I do not want to undertake any unknown risk 
to my health from COVID-19 vaccines.  Therefore, in the exercise of my right to 
informed consent, I have refused treatment with COVID-19 vaccines. 
5. 
I understand that Rutgers’ COVID-19 vaccine policy requires all 
students returning for the Fall 2021 semester to be vaccinated for COVID-19; 
however, I also understand that Rutgers’ policy exempts certain students from its 
requirements: (1) students who request and receive a medical exemption; (2) 
students who request and receive a religious exemption; and (3) students whose 
entire course of study is fully remote. 
6. 
I did not request a medical exemption or a religious exemption to 
Rutgers’ policy; instead, I availed myself of the third exemption and enrolled in a 
Case 3:21-cv-15333-ZNQ-TJB   Document 10-4   Filed 08/30/21   Page 2 of 4 PageID: 142

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course of study that is fully remote this semester. 
7. 
On or about August 3, 2021, I registered for the last class I need to take, 
Quantitative Methods; the class is being offered remotely on Tuesdays, Wednesdays 
and Thursdays.  Students are required to attend this class virtually via Zoom. 
8. 
I elected to take this class remotely to avoid appearing on campus and 
thus protect myself and others from any infection or transmission of SARS-CoV-2. 
9. 
On or about August 26, 2021, Rutgers blocked access to my Rutgers 
NetID.rutgers.edu account with an “Action Required” notice, stating that I was not 
compliant with the Rutgers COVID-19 vaccine mandate.  A true and correct copy 
of that notice is attached as Exhibit A; a true and correct copy of an email received 
from Rutgers regarding this matter is attached as Exhibit B.  Unless I upload 
evidence of COVID-19 vaccination I cannot access my account.  The block on my 
account prevents me from accessing any Rutgers online service, including my 
email, my class schedule, and my degree requirements.  As a result of the block on 
my account, I cannot access a program called “SAKAI” which is needed to log into 
Zoom and attend my class. 
10. 
If the block on my account is not lifted, I will not be able to attend 
class on the first day of the semester, Wednesday, September 1, 2021. 
 
 
Case 3:21-cv-15333-ZNQ-TJB   Document 10-4   Filed 08/30/21   Page 3 of 4 PageID: 143

Case 3:21-cv-15333-ZNQ-TJB   Document 10-4   Filed 08/30/21   Page 4 of 4 PageID: 144

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