Emergency Regulations Limiting Medical Exemptions to Vaccination May Become PERMANENT!


Dangerous Democrat Vaccine “catch up” Schedule Continues to Sicken Children

October 6, 2019 — When shady laws get passed state agencies start actin’ shady. The New York State Department of Health (NYS DOH) is no exception to this rule. We just found out the “emergency” regulations implemented by NYS DOH to limit medical exemptions to vaccination may become permanent in November! There are two sections to the below report:

FIRST – we are publishing an ACTION ALERT from New York Alliance for Vaccine Rights that was written by Attorney Elizabeth Brehm asking everyone to write letters, emails and make phone calls to the NYS DOH. Brehm reminds us mothers in California got arrested fighting for their children. A letter and a phone call is the ***least*** we can all do.

SECOND we are publishing a more extensive post from attorney Elizabeth Brehm as well. Brehm is one of the three lawyers fighting against the repeal of the religious exemption to vaccination in multiple New York jurisdictions. She spoke to Jonathan Karmel, a lawyer at NYS DOH regarding how NYS DOH is implementing the dangerous Democrat vaccine “catch up” schedule that is making children sick and got some pretty interesting, and even shocking information. She was told the emergency regulations limiting approval of medical exemptions can easily be extended or made permanent. Brehm was able to record the second half of the phone conversation that you can listen to for yourself.



PLEASE ACT!!! IMMEDIATELY SUBMIT YOUR COMMENTS, VIEWS AND ARGUMENTS regarding the emergency regulations issued in mid-August by DOH regarding School Immunization Requirements (religious and medical exemptions).

See page 28:

The State Register plays a central role in New York’s rule making process. It contains newly proposed amendments to state agency rules and provides interested parties an opportunity to comment on actions before an agency adopts each rule (Exec. Law, Art. 6-A). These emergency regs will expire in November and cannot be made permanent until they respond to public comments.


Katherine Ceroalo, DOH, Bureau of Program Counsel, Reg. Affairs Unit,
Room 2438, ESP Tower Building, Albany, NY 12237, (518) 473-7488;

Public comment will be received until: 60 days after publication of the September 4, 2019 Notice.

Please emphasize (1) that this rule/law removing the religious exemption has detrimentally affected our 26,000 healthy children, infringed on our religious beliefs, wherein we must keep our bodies pure according to God (among other things); (2) has caused significant irreparable harm to our 26,000 healthy children and thousands of families! (3) The absolute lack of ANY emergency which would justify these being put in place in the first instance and/or continued after Nov 13, 2019; (4) the incorrect and stricter interpretation of the law as the ACIP does NOT demand immediate next doses in the series; (5) the horrid and draconian nature of the medical exemption requirements; (6) the definition of “attend” for school purposes. You are free to add anything else about these regulations that you feel but – please – they are worth reading carefully and understanding the implications of them so that you can speak up against them. You heard the DOH attorney on my call, they will simply “renew” these under the guise of a fake emergency and they will make them permanent unless we make all hell break loose before then.

Reminder: mothers in California got arrested – you can write and send an email. It’s not asking too much. We are all tired, we are all busy, we are all overwhelmed. But we all have no choice. Please take action now! Keep on, warriors!

#2 – Post from Attorney Elizabeth Brehm

The update below is mostly about the implementation of the dangerous Democrat vaccine “catch up” schedule that is making children sick. Brehm argues to NYS DOH that schools are implementing this law/rule in a dangerous fashion and she asks for NYS DOH to restate their guidelines to schools. Effectively the lawyer says – “You’re right! but…no.” Her post is below in all italics, followed by a link to the actual audio of the second half of her phone call with attorney Jonathan Karmel from NYS DOH.

(first published in a private Facebook group, republished here with permission)


*Infuriating update on conversations with DOH regarding the enforcement if ACIP minimum intervals and not allowing through June 30th to be caught up*

After close to two weeks of calling DOH multiple times per day and being bounced around, I finally reached an attorney there today by the name of Jonathan Karmel – 518-408-5450 (Please note a Craig sometimes answers the phones who is very polite so please use your kindness up on him when asking for Jonathan).

We had about a 12-13 minute conversation before I could start recording, but the last 8 minutes of our call is at the link below.

After finally allowing me to speak without interrupting me, I was able to explain that the ACIP schedule only identifies minimum ages and minimum intervals for vaccines in a series and NOT maximum intervals. So if children have their first in series, and have presented proof of appointments, and will be caught up as of June 30, 2020, then they are in full compliance of the law. However, DOH has interpreted ACIP to mandate those minimum intervals (plus 14 days after which the child will be kicked out).

He patronized me with comments like “well, do you think you are the first person with this issue” and “well at least you are intelligent and clearly have done your research and know what you are talking about” assuming I was calling only as a parent on behalf of my child.

He also said I “have identified a real issue” that is “completely valid” but…sorry. This is what the DOH has decided.

He said DOH does “not have an army out to enforce this law” and schools that are making a good faith effort to comply are not “the targets” here – so if they have first in series and an appointment later in the year on record, those are not the schools that they are going after. I said that is ZERO help for you to tell me that when the DOH regs and guidances call for strict enforcement and schools are walking on eggshells in fear and therefore kicking out kids out.

We discussed the emergency regs (which I will make a separate post about but EVERY SINGLE PERSON HERE MUST submit a public comment – will explain more).

That is about when the recording begins. Buckle up for this idiocy. You will hear his direct supervisor’s name and number here – let’s feel free to give both Jonathan Karmel and Richard Thomas a call about this specific issue and tell them to change their guidances to the schools.