To: Sanofi Pasteur; Zuellig Pharma Corporation; Respective Directors and Officers

From: Ramil R. Pestilos; Liza M. Makilan

Date: May 27, 2018

Re: Death of Anjielica M. Pestilos

The Department of Health, under the leadership of then Secretary Janette L. Garin, deliberately exposed
the lives of more or less 833,000 children aged 9-14 to danger in its anti-dengue mass vaccination
program which costed the government 3.5 Billion Pesos. DOH, Secretary Garin and other government
officials administering a drug, which was still undergoing clinical trial, with no proven safety and efficacy.
The program recklessly implemented the life-threatening drug with gross disregard for human lives and
ta the expense of innocent and unsuspecting children, mostly from poor and downtrodden families. The
mass vaccination program violated medical protocol and implemented it without the appropriate
screening process thru available diagnostic tests and informed consent.

Anjielica M. Pestilos, a healthy ten year old girl who had no history of any serious illness including
Dengue paid the ultimate price. As will be established, Dengvaxia is a lethal combination of yellow fever
virus, and dengue virus. The inoculation/injection of this vaccine which contains these two viruses, to
Anjielica, given her pre-existing Systemic Lupus Erythematosus and the consequent viscerotropic-like
disease, is what precipitated her death.

ISSUE

Whether the respondent are liable for Anjielica M. Pestilos death and whether the plaintiffs are entitled
to damages for the negligence of the respondent to follow medical protocol.

ARGUMENTS

1. Dengvaxia is a deadly combination of yellow fever virus, and dengue virus

2. The yellow fever virus in Dengvaxia causes viscerotropic desease, which in turn, causes multiple
organ failure and death in at least 60% of cases.
3. The danger of administering Dengvaxia to seronegatives (those who have no previous history of
dengue) is of critical concern, and is not unknown to Sanofi, even during the development stage
of Dengvaxia.
4. The clinical trial of Dengvaxia is still in progress, and is supposed to end in November 2017 and
2018.
5. Dengvaxia was sold to the Philippines for mass administration, for the staggering amount of 3.5
Billion Pesos, while Dengvaxia was still in clinical trial stage, and despite the critical safety
concern on the vaccine.
6. Sanofi, Zuellig and their respective officials caused the death of Anjielica Pestilos.
7. On November 29, 2017 Sanofi admitted the danger posed by Dengvaxia.
8. The DOH recognized the danger of Dengvaxia.

DISCUSSION