Exhibit, Doc. 15-1 — America's Frontline Doctors v. Becerra

Summary

Lee Merritt, M.D.'s declaration under 28 U.S.C. § 1746, Document 15-1 in Case 2:21-cv-00702-CLM in the U.S. District Court, N.D. of Alabama (America's Frontline Doctors v. Becerra), was filed July 19, 2021; the declarant, an orthopedic surgeon licensed in Iowa and Nebraska, says it is submitted in support of legal actions to revoke the emergency use authorization for COVID-19 injections. It sets out a sample informed-consent statement for COVID-19 vaccines that lists the risks the declarant would disclose and puts the benefit at an absolute risk reduction of approximately 1%, and is executed June 1, 2021 and followed by the declarant's curriculum vitae.

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Case 2:21-cv-00702-CLM   Document 15-1   Filed 07/19/21   Page 1 of 8
Jul-19 PM 01:01
U.S. DISTRICT COURT
N.D. OF ALABAMA

DECLARATION OF LEE MERRITT, MD
Pursuant to 28 U.S.C. § 1746, Lee Merritt, M.D. hereby declares:
I am fully competent to make this declaration and I have personal
knowledge of the facts stated in this declaration.
This declaration is submitted in support of legal actions regarding the
COVID-19 injections and to revoke the emergency use authorization for
COVID-19 injections.

I am an orthopaedic surgeon licensed in Iowa and Nebraska. I have a
practice in Nebraska.

The following is a sample of an Informed Consent that I would do for
COVID-19 vaccines:

The COVID-19 vaccines are experimental and only authorized under an
Emergency Use Authorization. This means that this particular vaccine
has not been fully studied and we cannot be certain of all of the impacts
it could have on you.

Risks of the COVID vaccination include but are not limited to: death,
failure to prevent the disease being vaccinated against, risk of
anaphylaxis, irritation at the injection site, muscle soreness, tingling in
the hand and/ or arm, bleeding from the injection site, other bleeding
that may be life-threatening such as brain hemorrhage, internal
bleeding, bleeding into the eye, gastrointestinal bleeding, neurologic
complications including paralysis that may or may not completely
resolve, focal paralysis such as Bell’s palsy, transverse myelitis,
Amyotrophic Lateral Sclerosis (Lou Gehrig’s disease), headaches,
dizziness, narcolepsy (inability to remain awake), thrombocytopenia
(lack of platelets that prevent bleeding, pancytopenia (lack of all blood
elements such as red and white blood cells, infection, miscarriage, blood
clots, etc.
Case 2:21-cv-00702-CLM   Document 15-1   Filed 07/19/21   Page 2 of 8
Additionally, problems may arise even years after vaccinations. These
issues may include “immune enhancement” in which case the
vaccination may cause increased risk of severe or fatal worsening of
COVID or other similar diseases and influenza like illnesses. Also, the
risk of infertility, birth defects, and cancer is unknown, and late onset
of neurologic disorders, autoimmune disease.

There have been reports of passage of the vaccine in breast milk that
caused fatal bleeding in a nursing baby.

The benefit of this vaccination is an overall absolute risk reduction of
negative outcomes of approximately 1% and the potential to have lesser
severity of symptoms if you do catch COVID-19 (which may still
happen).

Please sign here if you consent to this injection.

I declare under penalty of perjury under the laws of the United States

of America that the foregoing is true and correct.

June 1

Executed on , 2021.

Lee D. Merritt MD (Jun 1, 2021 13:06 CDT)

Lee Merritt, MD
Case 2:21-cv-00702-CLM   Document 15-1   Filed 07/19/21   Page 3 of 8
Declaration of Lee Merritt MD

Final Audit Report 2021-06-01
Created: 2021-06-01
By: Laurie Brander (Laurie@aflds.org)
Status: Signed
Transaction ID: CBJCHBCAABAApjoh7qqA38Bx5iIDO3PWVUQELIeQssA65

“Declaration of Lee Merritt MD" History

*) Document created by Laurie Brander (Laurie@aflds.org)
2021-06-01 - 5:38:56 PM GMT- IP address: 24.121.220.94

= Document emailed to Lee D. Merritt MD (loganpod@gmail.com) for signature
2021-06-01 - 5:39:12 PM GMT

#5 Email viewed by Lee D. Merritt MD (loganpod@gmail.com)
2021-06-01 - 6:03:29 PM GMT- IP address: 209.169.208.147

@~ Document e-signed by Lee D. Merritt MD (loganpod@gmail.com)
Signature Date: 2021-06-01 - 6:06:14 PM GMT - Time Source: server- IP address: 209.169.208.147

@ Agreement completed.
2021-06-01 - 6:06:14 PM GMT

Adobe Sign
Case 2:21-cv-00702-CLM   Document 15-1   Filed 07/19/21   Page 4 of 8
Lee D. Merritt (ne: Hieb) MD

Orthopaedic Surgery Surgery of the Spine

18111 Q Street, Omaha, NE. 68135

CURRICULUM VITAE
Mar 19, 2020

GRADUATE MEDICAL EDUCATION:

Fellowship: Louis A. Goldstein Fellow of Spinal Surgery
University of Rochester, Rochester, New York

Residency: Orthopaedics, Naval Hospital San Diego, California

Internship: Internal Medicine, National Naval Medical Center

Bethesda, Maryland, 1980-1981.

Medical Degree: University of Rochester School of Medicine and Dentistry
Rochester, New York 1976-1980.

ADDITIONAL GRADUATE MEDICAL EDUCATION
Fellowship: American Academy of Anti-Aging Medicine, completed 2005
UNDERGRADUATE EDUCATION:
Grinnell College, Grinnell, Iowa. 1969-1973
University of Iowa, Iowa City, lowa. 1975-1976
AWARDS/OTHER ACCOMPLISHMENTS:
Alpha Omega Honor Medical Society, 1980.
American Medical Women’s Association Award for Academic Achievement, 1980.
National Honor Society 1969 |

APPOINTMENTS:
Case 2:21-cv-00702-CLM   Document 15-1   Filed 07/19/21   Page 5 of 8
President, Association of American Physicians and Surgeons 2010-2011
Chairman of Credentialing, Yuma Regional Medical Center 2005- 2007
Chief of Staff, Yuma Regional Medical Center, 2001-2003.

Chief of Surgery, Yuma Regional Medical Center, 1998-1999.
Spine-Tech Faculty Consultant, 1997-1998.

Consultant, Naval Studies Board, 1995-1999.

Executive Appointment to Naval Research Advisory Committee, 1993-1995,

PRACTICE EXPERIENCE:
Orthopaedic Trauma Coverage, various hospitals via Locum Tenens, 2016-2018

Private Practice, Anti-Aging Medicine, Esthetics, Outpatient Orthopaedics, Enlighten
Omaha, NE. 2016- Present

Orthopaedic and Spinal Surgeon, Burgess Hospital
Center, Onawa, Iowa, July 2015 - 2021

Orthopaedic and Spinal Surgeon, Stewart Memorial Hospital, Lake City, Iowa, 15 June
2009 to 15 November 2014

Private Practice, Spinal Surgery and Trauma, Yuma Regional Medical Center, Yuma,
Arizona, 1995 to 2009

Prince Georges Orthopaedic Associates, Clinton, Maryland, Southern Maryland Hospital
Center. private group practice, Orthopaedic and Spinal Surgeon, 1992-1993.

Orthopaedic Surgeon, Naval Hospital Cherry Point, North Carolina, 1991-1992 (DOD
civilian contract). General practice with emphasis on spinal disorders and sports medicine.

(Active Duty USN) Orthopaedic Surgeon, Naval Hospital Camp Lejeune, North Carolina,

(Active Duty USN ) General Practice. General Medical Office with United States Navy
Quantico, Virginia (Department Head) 1982-1983. Iwakuni, Japan (Department Head)

BIBLIOGRAPHY:
Case 2:21-cv-00702-CLM   Document 15-1   Filed 07/19/21   Page 6 of 8
Reports of Bleeding and Thrombocytopenia Reported to VAERS after Moderna and
COVID-19 Vaccinations, Dec 15, 2020, to Mar 12, 2021, Merritt L, Journal AAPS, Vol.
26, No.2, Summer 2021, p 51-54.

“Wrong Site Surgery”, L. Hieb, Letter to the Editor, Orthopaedics, Vol 26, No. 2, Feb
2003, pg. 124.

Interbody Fusion in the Elderly, Chapter 21, Advances in Spinal Fusion-Molecular
Science, Biomechanics and Clinical Management, L. Hieb, Marcel Dekker, Inc. Nov 2003,
pg. 293-312.

“Spontaneous Posteroperative Cerebrospinal Fluid Leaks Following Application of Anti-
Adhesion Barrier Gel. Case Report and Review of the Literature.” Hieb, Stevens. Spine,
April 2001, pg. 748-751.

“Tri Care From the Inside and Out”, L. Hieb, Naval Institute Proceedings, Nov 2000, pg.

Naval Expeditionary Logistics, Enabling Operational Maneuvers from the Sea. Panel
report, Naval Studies Board, (Member) Committee on Naval Expeditionary Logistics,

“Telemedicine, Applying and Misapplying a Concept.” L. Hieb. Naval Institute
Proceedings, January 1997, pg. 74-75.

Technology for the United States Navy and Marine Corps 2000-2035, Becoming a 21°
Century Force, Vol 4 Human Resources”, Panel on Human Resources, Naval Studies
Board, 1997.

Acute Bilateral Tibial Compartment Syndrome, Report of a Case and Review of the
Literature. L. Hieb, Alexander. Clinical orthopaedics and related research, March 1987,
pg. 190-193.

PRESENTATIONS/UNPUBLISHED PAPERS:

“Healos Collagen Matrix and Lumbar Interbody Fusion Cages: A 2-year Outcome Study.”
Macenski, Hieb, Lim, McAfee, Poster Presentation, Meeting of the Americas II, New
York, NY, 2002.

“Safety of Interbody Fusion in the Elderly.” Hieb, Stevens, Macenski, 2001. Presented
at the North American Spine Society Annual Meeting, Nov 2001.

“Healos Mineralized Collagen Matrix Combined with Lumbar Interbody Fusion Cages.”
Poster Presentation, Congress of Neurologic Surgeons, 51*t Annual Meeting, San Diego,
Case 2:21-cv-00702-CLM   Document 15-1   Filed 07/19/21   Page 7 of 8
California 2001.

Computerized Tomography in the Evaluation of Cervical and Lumbar Spinal Fractures-
Does it Make a Difference? Hieb, Chan, Devanny, Knight, Doerschuk. ASIA 1992.
AAOS 1993.

Influence of Pedicle Fixation on Postoperative Pain. Knight, Hieb. Poster presentation at
the Scoliosis Research Society/North American Spine Society Pedicle Fixation Workshop,
May 1991. Sacral Pedicle Fixation for Short Segment Spinal Fusion. Ibid.

Neurofibromatosis: Post Laminectomy Kyphosis of the Cervical Spine with Anterior Cord
Syndrome. Case Report and Literature Review. Knight, Hieb. American Spinal Injury
Association, 1991. Also presented SRS 1991.

Intersegmental Fixation with Lugue Plating for Degenerative Lumbar Disc Disease.
Knight, Montgomery, Hieb, Wujciak. Fifth International Conference on Lumbar Fusion
and Stabilization, Osaka, Japan, 1991.

Open Door Laminoplasty for Multilevel Cervical Spondylosis. Knight, Hieb. Videotape
American Academy of Orthopaedic Surgeons. 58'" Annual Meeting. 1991.

Laminoplasty for Treatment of Multilevel Cervical Stenosis. Knight, Hieb. ASIA 1991.

Complex Fracture of the Proximal Sacrum. Case Report and Presentation of a Method for
Fixation. Poster presentation. Hieb, Knight. ASIA 1990.

Pedicle Screw Fixation-Effects on Lumbar Lordosis and the Incidence of Aberrant Screw
Placement: Assessment of Early Results. Knight, Chan, Devanny, Jackman, Montgomery,
Hieb. SRS/NASS Advanced Course on Pedicular Fixation, 1990.

Pilon Fractures of the Ankle, Review of the Literature and the Experience at Naval Hospital
San Diego. Resident research paper presented to the Departments of Orthopaedic Surgery
of the Naval Hospital San Diego, and the University of California, San Diego, 1985.

Computerized Tomography versus Myelography in the Diagnosis of Lumbar Disc Disease.
Resident research paper presented to the Department of Orthopaedics and Radiology,
Naval Hospital Oakland, California, 1984.

RESEARCH PROJECTS:
Pain amelioration from Stem Cells/ Peptide Therapy, Current
Stabilization of the Lumbar Spine in the Elderly Patients, 1999-2001

Restoration of Lordosis following Anterior Cervical Fusion using BAK Cylindrical Cages,
Case 2:21-cv-00702-CLM   Document 15-1   Filed 07/19/21   Page 8 of 8
Effect of Anterior Discectomy and Bone Grafting on the Geometry of the Cervical Neural
Foramina. Strong Memorial Hospital, Rochester, New York, 1990.

Real Time Physiology of Gas Transport in Humans Utilizing Parotid Secretion. Navy
Undersea Medical Research Institute, 1978.

Electron Microscopy of Solid Tumors. University of Rochester, Department of Histology,

CERTIFICATION AND LICENSURE:
Recertification, NBPAS through April 30, 2021
Recertification, American Board of Orthopaedic Surgery, 2000, 2010
Board Certified, Orthopaedic Surgery, 1989.
Diplomat, National Board of Medical Examiners, 1981.
Current State Licensure:
Iowa 2000
Nebraska 2001
SCHOLARSHIPS:

United States Medicine Health Professions Scholarship, 1976-1980.

Cancer Institute Summer Fellowship, University of Rochester, 1981.


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