Motion for Leave to File Amicus Brief (Kerr) — Norris v. Stanley

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9 FILED S KZ
October 5. 2021 2:02 PM
U.S. DISTRICT COURT

Case : 21-cv-00756 WESTERN DISTRICT OF, MICHIGAN
mq_ Scanned pl S/2]

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF MICHIGAN

JEANNA NORRIS,
on behalf of herself and all others similarly situated
Plaintiffs,

V.

PRESIDENT SAMUEL L. STANLEY, JR.
in his official capacity as President of Michigan State University; DIANNE BYRUM, in her official
capacity as Chair of the Board of Trustees, DAN KELLY, in his official capacity as Vice Chair of the
Board of Trustees; and RENEE JEFFERSON, PAT O’KEEFE, BRIANNA T. SCOTT, KELLY TEBAY,
and REMA VASSAR in their official capacities as Members of the Board of Trustees
Defendants.

EXPEDITED CONSIDERATION REQUESTED

MOTION FOR LEAVE TO FILE AMICUS BRIEF, AMICUS BRIEF FOR ROBERT KERR AS
AMICUS CURIAE IN SUPPORT OF PLAINTIFF.

To the Honorable Paul L. Maloney, United States District Judge, Western District of Michigan.

Robert C. Kerr

714 Sawyer Rd.

Lansing, Mi 48911

(517) 449-7246
kerr.ingham@yahoo.com
Amicus Curiae (Pro se)

TABLE OF CONTENTS
MOTION FOR LEAVE TO FILE AMICUS BRIEF .............ssssessssssssesssessesseseessoesensens 1
ARGUMENTS ......cccssscssssscsecsscatacssscsecssenssscssossscasecsnsecsecsseeseesceessecsssseecsssenssessesensees sees 4
I, What are the relative risks and rewards of a vaccine mandate for

previously infected individuals?..............ccccscssecssesscsssscceeseeeso ese 4

IT. Timeliness of consideration:.................csseccceecsssssecsecessuescseeaceeesosens 6
VARIED OBSERVATIONS AND QUESTIONG...............0:ceeeceeeeeecececseeececenens 7
Early Detection Program timeliness................:scessssseseereeeeereeeeesesnensecs 7
Ability to continue long-term testing.................cscsssseeceeeesenceeeeereeeseeeons 8

Post infection, ongoing antibody testing................... cc eceseeeceeeeeecteeeeecees 8
9

CONCLUSION .........ssssssssssossscessssscesssssccersessccssssereatenseasensessccasssesssessscesteaescsseessasenstanes
Case : 21-cv-00756

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF MICHIGAN

JEANNA NORRIS,
on behalf of herself and all others similarly situated
Plaintiffs,

Vv.

PRESIDENT SAMUEL L. STANLEY, JR.
in his official capacity as President of Michigan State University; DIANNE BYRUM, in her official
capacity as Chair of the Board of Trustees, DAN KELLY, in his official capacity as Vice Chair of the
Board of Trustees; and RENEE JEFFERSON, PAT O’KEEFE, BRIANNA T. SCOTT, KELLY TEBAY,
and REMA VASSAR in their official capacities as Members of the Board of Trustees
Defendants.

EXPEDITED CONSIDERATION REQUESTED

MOTION FOR LEAVE TO FILE AMICUS BRIEF

Robert Kerr, an employee of Michigan State University, and an individual who would likely fall under
the requested class per the Plaintiffs class action request, and on behalf of the many individuals
similarly situated, respectfully move for leave of Court to file the accompanying amicus brief in
support of Plaintiffs motion for injunctive relief, and consideration of their claim of unnecessary harm.

While the Defendant has chosen to keep the Plaintiff on remote work status, and the assignment of
remote work has left the court questioning the ripeness of the case before it, Myself and many other
similarly situated employees, are left, trying to make long-term decisions on our gainful employment,
absent critical, and needed information.

Respectfully submitted on this 5th day of October, 2021,

Robert ah bo Za f-— a

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