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Declaration Of Suzann Burk

Date
2018-06-24

Summary

A declaration of Suzann Burk, Director of the Division of Disclosure and Oversight Management at the FDA's Center for Biologics Evaluation and Research, filed December 17, 2021 as Document 40 in America's Frontline Doctors, et al. v. United States of America, et al., Civil Action No. 2:21-CV-702-CLM, in the U.S. District Court for the Northern District of Alabama. It is submitted in support of Defendants' Motion to Dismiss Plaintiffs' Amended Complaint and in opposition to Plaintiffs' Motion for a Preliminary Injunction. The declaration lists attached Exhibits 1–22: fact sheets, letters of authorization and emergency use authorization review memoranda for the Pfizer-BioNTech, Moderna and Janssen COVID-19 vaccines. It certifies that each listed document was the current version and publicly available on FDA's website as of November 5, 2021, and is made under 28 U.S.C. § 1746.

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          Case 2:21-cv-00702-CLM Document 40 Filed 12/17/21 Page 1 of 5                 FILED
                                                                               2021 Dec-17 PM 01:27
                                                                               U.S. DISTRICT COURT
                                                                                   N.D. OF ALABAMA


                 IN THE UNITED STATES DISTRICT COURT
               FOR THE NORTHERN DISTRICT OF ALABAMA
                          SOUTHERN DIVISION


     AMERICA’S FRONTLINE
     DOCTORS, et al.,

                  Plaintiffs,
                                                  CIVIL ACTION NO.
     v.                                           2:21-CV-702-CLM

     UNITED STATES OF AMERICA, et
     al.,

                  Defendants.


                     DECLARATION OF SUZANN BURK
      I, Suzann Burk, declare as follows:
      1.      I am the Director of the Division of Disclosure and Oversight
Management (“DDOM”), Office of Communication Outreach and Development,
Center for Biologics Evaluation and Research (“CBER”), United States Food and
Drug Administration (“FDA”), in Silver Spring, Maryland.
      2.      As the Director of DDOM, I have overall responsibility for the
disclosure of documents officially maintained by CBER, the center in FDA that
regulates biologic products such as blood, vaccines, gene therapy, and human cells,
tissues, and cellular and tissue-based products. I have been the Director of DDOM
since June 24, 2018. Prior to that date, I was the Team Lead of the Electronic
Disclosure Team in DDOM for approximately nine and one-half years. Prior to that,
I was a member of the Congressional and Oversight Branch in DDOM for two years

                                        1
        Case 2:21-cv-00702-CLM Document 40 Filed 12/17/21 Page 2 of 5




and a member of the Access Litigation and Freedom of Information Branch in
DDOM for four years.
      3.    In my capacity as Director of DDOM I have access to official CBER
documents. I am responsible for disclosing documents in litigation on behalf of
CBER.
      4.    I submit this declaration in support of Defendants’ Motion to Dismiss
Plaintiffs’ Amended Complaint and in opposition to Plaintiffs’ Motion for a
Preliminary Injunction. The statements made in this declaration are based on my
personal knowledge and official records available to me in my official capacity.
      5.    Attached hereto are        copies   of   the following documents:


Exhibit      Vaccine      Document                                 Date
             Manufacturer
Exhibit 1    Pfizer-      Fact Sheet for Recipients and            Oct. 29, 2021
             BioNTech     Caregivers 12 years of age and
                          older
Exhibit 2    Pfizer-      Fact Sheet for Recipients and            Oct. 29, 2021
             BioNTech     Caregivers 5–11 years of age
Exhibit 3    Pfizer-      Fact Sheet for Healthcare                Oct. 29, 2021
             BioNTech     Providers Administering Vaccine
                          (Vaccination Providers), 12 years
                          of age and older, purple cap
Exhibit 4    Pfizer-      Fact Sheet for Healthcare                Oct. 29, 2021
             BioNTech     Providers Administering Vaccine
                          (Vaccination Providers), 12 years
                          of age and older, gray cap
Exhibit 5    Pfizer-      Fact Sheet for Healthcare                Oct. 29, 2021
             BioNTech     Providers Administering Vaccine
                          (Vaccination Providers), 5–11
                          years of age, orange cap


                                         2
      Case 2:21-cv-00702-CLM Document 40 Filed 12/17/21 Page 3 of 5




Exhibit 6   Pfizer-       Letter of Authorization from      Oct. 29, 2021
            BioNTech      Jacqueline A. O'Shaughnessy,      (revised)
                          Acting Chief Scientist, FDA, to
                          Pfizer Inc.
Exhibit 7   Pfizer-       COVID-19 Vaccine Emergency        Dec. 11, 2020
            BioNTech      Use Authorization Review
                          Memorandum
Exhibit 8   Pfizer-       COVID-19 Vaccine EUA              May 10, 2021
            BioNTech      Amendment Review
                          Memorandum
Exhibit 9   Pfizer-       COVID-19 Vaccine EUA              Aug. 12, 2021
            BioNTech      Amendment Review
                          Memorandum
Exhibit 10 Pfizer-        COVID-19 Vaccine EUA              Sept. 24, 2021
           BioNTech       Amendment Review
                          Memorandum
Exhibit 11 Pfizer-        COVID-19 Vaccine EUA              Oct. 20, 2021
           BioNTech       Amendment Review
                          Memorandum
Exhibit 12 Moderna        Fact Sheet for Recipients and     Oct. 20, 2021
                          Caregivers                        (revised)
Exhibit 13 Moderna        Fact Sheet for Healthcare         Oct. 20, 2021
                          Providers Administering Vaccine   (revised)
                          (Vaccination Providers)
Exhibit 14 Moderna        Letter of Authorization from      Oct. 20, 2021
                          Jacqueline A. O'Shaughnessy,      (reissued)
                          Acting Chief Scientist, FDA, to
                          ModernaTX, Inc.
Exhibit 15 Moderna        COVID-19 Vaccine Emergency        Dec. 18, 2020
                          Use Authorization Review
                          Memorandum
Exhibit 16 Moderna        COVID-19 Vaccine EUA              Aug. 12, 2021
                          Amendment Review
                          Memorandum
Exhibit 17 Moderna        COVID-19 Vaccine EUA              Oct. 20, 2021
                          Amendment Review
                          Memorandum
Exhibit 18 Janssen        Fact Sheet for Recipients and     Oct. 20, 2021
                          Caregivers                        (revised)

                                   3
          Case 2:21-cv-00702-CLM Document 40 Filed 12/17/21 Page 4 of 5




 Exhibit 19 Janssen             Fact Sheet for Healthcare            Oct. 20, 2021
                                Providers Administering Vaccine      (revised)
                                (Vaccination Providers)
 Exhibit 20 Janssen             Letter of Authorization from         Oct. 20, 2021
                                Jacqueline A. O'Shaughnessy,         (reissued)
                                Acting Chief Scientist, FDA, to
                                Janssen Biotech, Inc.
 Exhibit 21 Janssen             COVID-19 Vaccine Emergency           Feb. 27, 2021
                                Use Authorization Review
                                Memorandum
 Exhibit 22 Janssen             COVID-19 Vaccine EUA                 Oct. 20, 2021
                                Amendment Review
                                Memorandum

      6.      I certify that each document listed in Paragraph 5 was the current
effective version as of November 5, 2021, and was publicly available on FDA’s
website, https://www.fda.gov, as of that date.
      7.      I declare under penalty of perjury that the foregoing Exhibits 1–22 and
the facts contained in this declaration are true and correct pursuant to 28 U.S.C.
§ 1746.




                                          4
       Case 2:21-cv-00702-CLM Document 40 Filed 12/17/21 Page 5 of 5




                                                    Digitally signed by Suzann H. Burk -S
                                  Suzann H. Burk -  DN: c=US, o=U.S. Government, ou=HHS,
                                                    ou=FDA, ou=People, cn=Suzann H. Burk -S,

                                  S________________________________
                                                    0.9.2342.19200300.100.1.1=1300129983
                                                    Date: 2021.12.16 13:11:10 -05'00'


                                  SUZANN BURK
                                  Division Director
                                  Office of Communication,
                                  Division of Disclosure and Oversight
                                  Management, Outreach and Development
                                  Center for Biologics Evaluation and Research
                                  Food and Drug Administration
                                  U.S. Department of Health and Human
                                  Services

Executed on December ____,
                      16   2021




                                     5


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