MRNA Bioweapons Prohibition Case: Supplement to Motion for Rehearing that includes a proposed Second Amended Complaint (Exhibit A)

Dec 14, 2025

My case was Dismissed with Prejudice Friday afternoon 12/12/2025. This means I can’t amend my complaint to cure defects. Just before midnight on 12/12/2025 I filed a Motion for Rehearing.

Tonight on 12/23/ 2025 I filed a Supplement to the Motion for Rehearing that includes a proposed Second Amended Complaint (Exhibit A) to demonstrate to the Court that the defects were curable and dismissal with prejudice was premature. Screen shot and pdf below. The purpose is to have the Motion for Rehearing granted and then file the attached proposed Second Amended Complaint (Exhibit A). If the Motion for Rehearing is Denied this will help with an Appeal as it demonstrates the Dismissal with Prejudice was premature as the defects could be cured.

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The judge stated that I did not state a clear cause of action clearly and concisely and that my case was conclusory. That is why my case was dismissed. It had nothing to do with the PREP Act as the PREP Act does not apply to my case as I am not suing the manufacturers, etc., for monetary damages. In my opinion the PREP Act is not Constitutional and people suing for indemnification purposes need to vigorously argue that in their briefs. I also do not believe that the PREP Act covers bioweapons…

The Dismissal also had nothing to do with my case being in the wrong venue etc.

If I get to the hearing stage in the Trial Court, I believe I will win in State Court. I will introduce evidence, studies, affidavits, etc. My witnesses will all testify to the harm of shedding i.e. involuntary environmental exposure and state that the mRNA injections are biological and technological weapons of mass destruction. I will also subpoena Surgeon General Ladapo to testify under oath to Florida Department of Health bulletins that mRNA is not safe and a potential threat to the human genome, his public declaration that COVID/mRNA shots are poison, and harms and damages of the mRNA. The State would have no defense to this.

The issue is to get to that stage. If I had filed an Amended Complaint as clean as the proposed Second Amended Complaint in this Supplement to the Motion for Rehearing, I think I would already have a hearing scheduled. Live and learn.

As it is now, I have about a 30% chance of the Judge Granting the Motion for Rehearing as I have demonstrated that the defects are curable and it will be a coin toss on winning the Appeal if needed.

If you actually read the Emergency Motion for a Preliminary Injunction and Evidentiary Hearing, as well as the Motion for Rehearing and the Supplement to the Motion for Rehearing (screen shot below and downloadable pdf) you will see that I have legitimate due process arguments. Also, I believe that the proposed Second Amended Complaint (Exhibit A) is a good template. It is based on my novel shedding argument that the shedding or involuntary environmental exposure is coerced or forced vaccination in violation of Florida’s recent Health Freedom law. I think this is a viable legal argument. I think the proposed Second Amended Complaint (Exhibit A) is also an excellent template for those that were harmed directly by the mRNA injections.

I do think that what I just filed is a very good move legally. As I found a way to get a Proposed Amended Complaint in front of the judge when I am not allowed to amend the complaint. Like I said if I had a cleaner Amended Complaint to begin with, I think I would have the evidentiary hearing scheduled by now. So, I do see this dismissal as avoidable.

I get people telling all the time what I am doing wrong and what I should do. My response is routinely to file a case and do better than I am doing, outperform me. That seems to fall on deaf ears. That is not sarcasm. I have been encouraging people to enter the arena for a few years. I am still shocked that we do not have at least 100 cases like mine in every state from both shedding and injection victims. I attribute it to Leaned Helplessness and Diffusion of Responsibility.

Hint, I think the proposed Second Amended Complaint (Exhibit A) is a good template. Find a legal argument or create one like I just did. My case is centered on my allegation that my heart failure and triple bypass heart surgery in April of 2023 are the result of shedding or involuntary environmental exposure. I argue that continued distribution of the mRNA bioweapons is a threat of imminent harm.

Yes, I know, many believe the Courts are corrupt and there is no way to win. Well, let’s test that hypothesis and see 100 cases pop up in each state and see what happens…

If you are familiar with my recent filings and case history scroll down to view the Supplement to the Motion for Rehearing that has my proposed Second Amended Complaint (Exhibit A).

On 12/12/2025 I filed a Motion for Rehearing.

Current case in the Trial Court was dismissed on 12/12/2025.

On 12/11/2025 I filed an Emergency Motion for a Preliminary Injunction and a 3.5 Hour Evidentiary Hearing.

If you are familiar with my recent filings and case history, you can scroll down to the screen shot of my motion below.

On December 8, 2025, I filed a Motion for Expedited Ruling on Pending Motion for a Status Conference..
On December 6, 2025, I filed a Notice for Supplement exhibit ‘U’ which was a study showing high mortality after 3 years with an ejection fraction below 20%. This was to buttress irreparable harm argument.
On December 4, 2025, I filed a Notice of Supplemental Exhibit S - Shedding Study. I also introduced a new legal argument that the shedding or environmental exposure constitutes forced or coerced MRNA in violation of Florida’s recent health freedom law prohibiting that.
On December 4, 2025, I motioned for a status hearing regarding setting up a date for an evidentiary hearing.
On December 1, 2025, I filed Notice of Issuance of Appellate Mandate and a Renewed Request for an Expedited Evidentiary Hearing
On November 20, 2025, I filed a motion for a preliminary injunction and an evidentiary hearing in my case seeking to prohibit mRNA injections and products because they are biological and technological weapons of mass destruction. I am requesting a 3.5 hour evidentiary hearing and asking to be allowed 6 witnesses.
At Appellate Court I had a procedural win on November 12, 2025, and my case is back in the Trial Court.
I then filed an Amended Complaint with the Trial Court later that night on 11/12/2025.
On 11/19/2025 and 11/20/2025 I served Governor DeSantis and Attorney General Uthmeier each with a Summons along with the Amended Complaint and the Initial Complaint.

I am arguing in my case that my congestive heart failure and triple bypass heart surgery in April of 2023 were the result of shedding. I argue that mRNA nanoparticle injections are biological and technological weapons of mass destruction and are a public health risk. I invoke the Florida Civil Rights act and the Basic Rights in the Florida Constitution. In particular, the right to life. I also invoke Florida’s Informed Consent Law and Florida’s Health Freedom Law prohibiting coerced MRNA, which I argue shedding or involuntary environmental exposure is. If you are not familiar with my case, you can read my Amended Complaint and then the initial complaint below if you want to get granular.

To RECAP if you are not familiar with my prior case history.

I filed my initial Complaint on December 1, 2024 seeking an injunction to prohibit the distribution of mRNA injections in Florida because they violate Fla. Stat. 790.166 Weapons of Mass destruction. I also sought Declaratory Judgements from the Court. The case was dismissed prematurely and I appealed. Case is currently in FL 1DCA.
Article with the Amended Initial Appellate Brief can be found here.
Article with the Initial Complaint can be found here.
On November 12, 2025 1DCA dismissed appeal sending case back to Trial Court or now.
On November 2nd I filed an affidavit with echocardiogram showing ejection fraction decline from 35-40% to15-20%.
On October 23, 2025. Study Showing Decreased Lifespan with Each Injection Filed in Florida Case Seeking to prohibit MRNA injections because they are Biological and Technological Weapons of Mass Destruction
On Oct. 9, 2025, I filed the Alliance of Indigenous Nations Tribunal ORDER stating MRNA injections are a Biological and Technological Weapon of Mass Destruction as a Supplemental Authority.
On 9-5-2025 Filed Surgeon General Ladapo statement in his official capacity that COVID MRNA injections are ‘poison’
On 8-30-2025 Peer Reviewed Paper stating virus and vaccine violate Biological Weapons Convention as Supplemental Authority
On 8-18-2025 HHS Statement as Supplemental Authority
8/12/2025 Notice of Supplemental Authority - Japanese Research
On 7/22/2025 Surgeon General Ladapo’s research as a Supplemental Authority.
On 5-30 Court ORDER Denied my Motion for Oral Argument
3/30/2025 Supplemental Authority Highlighting Major Procedural Error.

Dr. Joseph Sansone is a psychotherapist opposed to psychopathic authoritarianism.

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