UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA
Washington DC 20001
V. Case No. 09-0117 (RMU)
January 16, 2009
The plaintiff alleges as its complaint as follows:
1. The plaintiff brings suit against the defendants alleging violations of
the due process clause and equal protection of the Fourteenth
Amendment to the United States Constitution and 42 U.S.C. §1983.
2. This court has federal question jurisdiction pursuant to 28 U.S.C. §
3. Venue is appropriate in the District Court for the District of Columbia of
Washington pursuant to 28 U.S.C. §1391(e).
4. The plaintiff, NDABA, is a citizen of Washington District of Columbia
whose principal resident is in the District of Columbia.
5. Ndaba is a United States citizen, who is opposed to U.S. government
supporting, providing, endorsing and using the experimental HPV vaccine
in Washington DC public school system on female children’s on the
grounds that the children were deprived of their right to life and not
afforded the procedural due process of law and equal protection of law of
the Fourteenth Amendment and, therefore deprived of their U.S.
6. Ndaba’s purpose is to protect life, which is a fundamental right under
the 14th Amendment, Section 1 of the U.S. Constitution, and any
abridgment of those rights must pass strict scrutiny of due process of law
and the equal protection of the law by representing and to advocating on
behalf of his opposition to federal support of HPV vaccine shots in District
of Columbia public school system in Washington.