Declaration of Natasha DiCicco — Together Employees v. Mass General Brigham Incorporated (D. Mass.)

Summary

The Declaration of Natasha DiCicco, filed November 1, 2021 as Exhibit 1, Document 32-1, in Together Employees v. Mass General Brigham Incorporated, Civil Action No. 1:21-cv-11686-FDS, in the U.S. District Court for the District of Massachusetts. The declarant, one of the named plaintiffs, makes the statement under 28 U.S.C. § 1746 and states she is an MGB employee on unpaid leave. The declaration states that she sought a religious accommodation to MGB's COVID-19 vaccination policy and describes the religious beliefs she gives as the basis for the request, citing Bible passages. It states that MGB denied the accommodation before speaking with her or allowing her to submit supporting documentation. The filing runs 18 pages.

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Case 1:21-cv-11686-FDS Document 32-1 Filed 11/01/21 Page 1 of 18




           EXHIBIT 1
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                     UNITED STATES DISTRICT COURT
                      DISTRICT OF MASSACHUSETTS

__________________________________________
TOGETHER EMPLOYEES, by                     )
individual representatives,                )
ROBERTA LANCIONE                           )
JOYCE MILLER, MARIA DIFRONZO,              )
MICHAEL SACCOCCIO,                         )
ELIZABETH BIGGER,                          )
NATASHA DICICCO,                           )
NICHOLAS ARNO and                          )        CIVIL ACTION NO.
RUBEN ALMEIDA,                             )        1:21-cv-11686-FDS
Plaintiffs                                 )
                                           )
v.                                         )
                                           )
MASS GENERAL BRIGHAM                       )
INCORPORATED                               )
Defendant                                  )

                   DECLARATION OF NATASHA DICICCO

In accordance with 28 U.S.C. § 1746, I Natasha DiCicco, declare under the penalty

of perjury of the laws of the United States of America, and state upon personal

knowledge that:

1.    I am an adult of sound mind, and make this statement voluntarily, based

upon my own personal knowledge, education, facts or data, and experience, and

under the penalty of perjury of the laws of the United States of America.
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2.    I am an employee of defendant, Mass General Brigham Incorporated

(“MGB”), currently on unpaid leave and subject to be terminated on November

5, 2021.

3.    I sought a religious accommodation to MGB’s vaccination policy, notifying

them that I had sincerely held religious beliefs that precluded me from taking

the COVID-19 vaccines.

4.    I have been a practicing Christian for my entire life, baptized as an infant

and growing up in a Christian home.

5.    I am currently a member of the Saint Joseph Parish in Wakefield,

Massachusetts. This is a Catholic church.

6.    My Christian beliefs come from my personal relationship with Jesus

Christ, and not specifically the Catholic church as a whole, or even my specific

parish.

7.    The role that church plays in my life is that the Christian church is the

body of Christ (Col. 1:18 – “And he is the head of the body, the church; he is the

beginning and the firstborn from among the dead, so that in everything he

might have the supremacy.”) and is where I go to receive teachings on the word

of God from our priest and fellowship with other Christian believers.

8.    My faith is not limited to the simple act of going to church on Sundays; I

read the Bible and pray continually (1 Thess. 5:17 – “pray continually”).

9.    By reading the Scriptures and praying, God communicates His will to me

through the Holy Spirit.
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10.      This is what many Christians refer to as their personal relationship with

Jesus. My personal relationship with Jesus is one of the most important aspects

of practicing my faith. (John 15:15 “No longer do I call you servants, for the

servant does not know what his master is doing; but I have called you friends,

for all that I have heard from my Father I have made known to you.”)

11.      In referring to “God,” the “Holy Spirit” or “Jesus,” I am referring to God

the Father, God the Son and God the Holy Spirit, or the Trinity. For more of an

explanation, I have provided a helpful resource with a video:

https://www.gotquestions.org/Trinity-Bible.html.

12.      In my life I seek to live out God’s will, as He has communicated to me.

(Rom. 8:14 “For all who are being led by the Spirit of God, these are sons of

God.”)

13.      During the pandemic, throughout 2020, I prayed continually. While the

vaccines were available, I sought counseling from my Priest and prayed and read

the Bible to obtain God’s will as to whether I should take not only the COVID-19

vaccines, but any vaccines.

14.      It was the COVID-19 vaccines that caused me to pray on vaccination in

general and seek guidance from the Lord.

15.      First, Exodus 20:13 states “thou shall not murder.” I am strongly opposed

to abortion. This opposition is not a personal opposition, but one rooted in my

religious beliefs through prayer and reading the Bible. (Psalm 139:13 “You

formed my inward parts; you knitted me together in my mother’s womb.”) Thus,
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I believe from reading those (and other Scriptures), praying on the subject and

receiving teaching on the subject from my Priest.

16.    Therefore, I believe life is sacred, from conception, and that it would be a

sin if I were to partake in any way whatsoever with the act of abortion.

17.    To take vaccines that were either produced or manufactured using,

developed with, or tested on aborted fetal tissue would be a sin and I cannot

violated my conscience by partaking in such an act.

18.    Praying about the COVID vaccines led me to look into what I was taking,

and I learned of the vaccines’ connection to the practice of abortion, namely that

the Johnson & Johnson vaccines used fetal cell cultures to produce and

manufacture the vaccine and that both Pfizer and Moderna used fetal cells for

proof of concept for their vaccines1.

19.    For me to partake in this would be a serious and sinful act and would

greatly harm my personal relationship with Jesus.

20.    For me to disobey the Holy Spirit is the same a disobeying God, and that

would also be a sin. (John 14:15 “If you love me, you will keep my

commandments.”)

21.    In addition, by praying about these vaccines, God began to communicate

with me regarding the ingredients themselves and the concept caring for myself

in a way that I could honor Him with my body. (1 Cor. 6:19-20 “Do you not know



1 https://www.health.nd.gov/sites/www/files/documents/COVID%20Vaccine%20Page/COVID-

19_Vaccine_Fetal_Cell_Handout.pdf
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that your body is a temple of the Holy Spirit, who is in you, whom you have

received from God? You are not your own; you were bought at a price. Therefore

honor God with your body”).

22.    This includes prayerfully considering what medicines I do and do not

take and seeking guidance from God regarding those medical decisions.

23.    In Matthew 9:20-22, a woman who had a bleeding disease that doctors

and modern medicine at that time could not heal came to Jesus having faith

that if she could just touch His cloak, that He could heal her. He did heal her,

stating that it was her faith that had healed her.

24.    I stated to MGB that I sought counseling from my Priest regarding these

exact issues.

25.    I was more than willing to discuss these beliefs with MGB.

26.    I was more than willing to discuss what accommodation would allow me

to practice my religion while at the same time ensure the safety of myself and

others while at work.

27.    MGB sent me emails from a standard account and did not identify who

was reviewing my accommodation request.

28.    MGB denied my accommodation before even speaking with me or

allowing me to submit supporting documentation (I emailed documents after being

denied, which I have included with this Declaration).

29.    MGB used, as one of its reasons for denial, that I was not seeking an

exemption from the flu vaccine policy, however my application submitted asked

for an exemption from the flu vaccine policy.
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