COMPLAINT
The Plaintiffs, by their counsel van der Veen, Hartshorn, Levin & Lindheim, through Bruce L. Castor, Jr. are seeking damages against State actors for committing acts, under color of law, which deprived Plaintiffs of rights secured by the First and Fourteenth Amendments to the United States Constitution, the laws of the United States, and the Civil Services Reform Act of 1978; arising out of Defendants’ engaging in constitutional violations that stemming out of the COVID-19 Mandate issued Office of Personnel Management following an executive order from Joseph R. Biden, President of the United States.