AFFIDAVIT OF LTC. THERESA LONG M.D. IN SUPPORT OF A MOTION FOR A PRELIMINARY INJUNCTION ORDER
by Patrick Byrne
Sept. 24, 2021
I, Lieutenant Colonel Theresa Long, MD, MPH, FS being duly sworn, depose and state as follows:
1. I make this affidavit, as a whistle blower under the Military Whistleblower Protection Act, Title 10 U.S.C. § 1034, in support of the above referenced MOTION as expert testimony in support thereof.
2. The expert opinions expressed here are my own and arrived at from my persons, professional and educational experiences taken in context, where appropriate, by scientific data, publications, treatises, opinions, documents, reports and other information relevant to the subject matter and are not necessarily those of the Army or Department of Defense.
Experience & Credentials
3. I am competent to testify to the facts and matters set forth herein. A true and accurate copy of my curriculum vitae is attached hereto as Exhibit A.
4. After receiving a bachelor’s degree from the University of Texas Austin, completed my medical degree from the University of Texas Health Science Center at Houston Medical School in 2008. I served as a Field Surgeon for ten years and went on to complete a residency in Aerospace and Occupational Medicine at the United States Army School of Aviation Medicine, Fort Rucker, AL. I hold a Master’s in Public Health, and I have been trained by the Combat Readiness Center at Ft. Rucker as an Aviation Safety Officer. Additionally, I have trained in the Medical Management of Chemical and Biological Causalities at Fort Detrick and USAMIIRD.
5. I am board certified in flight Aerospace Medicine and board eligible in Occupational Medicine.
6. I am currently serving as the Brigade Surgeon for the 1st Aviation Brigade Ft. Rucker, Alabama and am responsible for certifying the health, mental and physical ability, and readiness for all nearly 4,000 individuals on flight status on this post.
7. My appended curriculum vitae further demonstrates my academic and scientific achievements by me over the past thirteen years.
8. Prior to the outset of the pandemic, I received specialized military training from Infectious Disease doctors from the Army, Navy and Air Force on emerging infectious disease threats, FEMA training, Emergency preparedness training, Medical effects of Ionizing Radiation, OSHA, Aerospace Toxicology, Epidemiology, Biostatistics, medical research and disaster planning. More recently I have functioned as a medical and scientific advisor to an Aviation training Brigade seeking to identify risk mitigation strategies, and bio statistical analysis of SARS- Cov-2 (“Covid 19”) infections in both vaccinated and unvaccinated Soldiers. In so doing, I have identified, diagnosed and treated Covid 19 pathogenic infections. I have observed vaccine adverse events following the administration of EUA vaccines, and followed the success of Soldiers who obtained various Covid 19 therapies outside the military. The majority of the service members within the DOD population are young and in good physical condition. Military aviators are a subset of the military population that has to meet the most stringent medical standards to be on flight status. The population of student pilots I take care of are primarily in their 20s-30s, males and in excellent physical condition. The risk of serious illness or death in this population from SARs-CoV-2 is minimal, with a survival rate of 99.997%.
9. In observing, studying and analyzing all the available data, information, samples, experiences, histories and results of these treatments and inoculations provided, I have formulated a professional opinion, which requires me to report those findings to superiors in the chain of command and colleagues in the military. I have done so with mixed results in terms of acceptance, rejection and threats of punishment for so sharing.
10. The application of risk management is critical to the safety and success in both medicine and aviation. Aerospace Medicine is a specialty devoted to safety of flight by the aeromedical dispositioning and treatment of flight crew members, as accomplished by the consistent and careful application of risk mitigation and management strategies. ATP 5-19, 1-3. Risk Management (RM)1 outlines a disciplined approach to express a risk level in terms readily understood at all echelons.
adminpubs.tradoc.army.mil/regulations/TR385-2withChange1.docx
Case 1:21-cv-02228-RM-STV Document 17 Filed 09/24/21 USDC Colorado Page 7 of 269
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