EXAMINATION & MORATORIUM ON
FURTHER VACCINATION OF
MINOR CHILDREN
Hon. L. Grant
Respondent Janet Burton ("Mother"), by and
through counsel undersigned, pursuant to ARS 25-403, 405 & 408 and Rule 65, ARCP,
again moves the Court to issue a temporary restraining order prohibiting further
vaccination of the minor children, Gwyneth and Greyson Hutchinson, as said children have
indicated adverse reactions to the vaccinations administered May 12, 2004 until said
children can be thoroughly examined pursuant to the recommendation made October 6, 2004 by
Stuart Z. Lanson, M.D. MD(H), FACS, FAAP.M. FAAOA. FAAOO, FAAFPRS. Sr. Lanson's
opinions on the children, respectively, are attached hereto as Exhibit A and are
incorporated by reference as though fully set forth herein, as is Mother's Motion for
Emergency TRO, filed on or about July 7, 2004, upon which the Court has yet to rule.
Dr. Lanson states that neither child should be subjected to further vaccinations at this
time, especially multiple vaccinations as was previously administered.
Counsel undersigned shared this information with
Father's attorney the afternoon of October 7, 2004. Father's counsel informed the
undersigned that he would share the information with his client but that Father would not
agree to a moratorium as the children require vaccinations to be in school. Mother,
of course, disagrees with such position, thus, the instant motion. As of this
morning Father's position has not changed, thus, the instant motion. Accordingly, as
the children and/or Mother may suffer immediate irreparable harm if this matter is not
acted on expeditiously, this Court should proceed without notice of the opposing party to
be heard in opposition.
WHEREFORE, respondent, Janet Burton, again asks this
Court to issue a temporary restraining order prohibiting further vaccination of the minor
children, Gwyneth and Greyson Hutchinson, until said children can be thoroughly examined
by the physician(s) recommended by Dr. Lanson and mandating moratorium on further
vaccination of the children as set forth above, order Father to reimburse Mother's
attorney fees and costs incurred herein and enter such other and further relief as the
Court deems just and proper under the circumstances.
RESPECTFULLY SUBMITTED this 8 day of
Oct, 2004
Wallace R. Nichols Esq.
Attorney for Respondent
Copy of the foregoing caused to be faxed and served
this 8 day of Oct, 2004
