1601 N. Tucson Blvd. Suite 9
Tucson, AZ 85716-3450
Phone: (800) 635-1196
Hotline: (800) 419-4777
Association of American Physicians and Surgeons, Inc.
A Voice for Private Physicians Since 1943
Omnia pro aegroto


I, Dawn Richardson, hereby declare under penalty of perjury that the following is true and correct to the best of my knowledge, information, and belief:

1. I am a patient residing in the State of Texas. I frequently seek medical care for my 2 children and myself. I am also President of Parents Requesting Open Vaccine Education (P.R.O.V.E.), a Texas-based non-profit association focusing on medical issues. I lobby the government frequently on medical issues. This effort has included my leading significant coordinated lobbying against proposed legislation and rules that would authorize the release and collection of confidential medical records without the expressed written informed consent of the patient or parent/guardian in the case of a child.

2. My communications with our health care providers have already been chilled by the Privacy Rule, which authorizes mandatory and permissive disclosure of my and my children's personal medical records to government officials without my consent. What I say to my and my children's physician or other health care providers and the details of my and my children's health history or treatment that is recorded in our medical files can now be reviewed by an unlimited number of officials without a warrant and can also be used for unconsented research on us. This deters me from seeking medical care in some situations and from being frank in talking with my health care providers.

3. My access to medical care and treatment for myself and my children is substantially reduced under the Privacy Rule. Now that government has access to patient records, physicians have already expressed to me and members of PROVE that they will no longer care for children who have not been fully vaccinated in compliance with all government vaccine recommendations and mandates because they fear penalty.

4. I have been directly harmed by this mandatory and permissive government access. I cannot have straightforward discussions with my physicians about my vaccination choices and other health care decisions for my family. Government access to my lawful elections to accept or decline vaccines or screening tests causes injury to my personal, professional and political reputation. Disclosures to government of my medical records harms my ability to petition government about vaccine and other medical issues. I also can no longer obtain medical care for myself or my children with the assurance that our records won't be released into a government database without my permission to persons I do not know, for purposes I cannot predict, which may be contrary to my and my children's best interests. Government access to the medical history of my children and myself also harms my effectiveness and my reputation in my community.

5. In my involvement with P.R.O.V.E., I have personally become involved in cases where the parent has been threatened to have their children removed from their homes by child protective government employees based on the lawful decisions of parents to decline certain controversial vaccines. I was even personally confronted by a lawyer from our state health department relaying that there were people in the department who felt that my decision to let my children contract chickenpox naturally and not give them the chicken pox vaccine constituted child abuse. The Privacy Rule discourages patients, including myself, from providing medical history to physicians that can be used against them in this and other ways.

6. I am also harmed by the restriction of the Privacy Rule on my own access to my own medical records. It directly and immediately injures me by obstructing my ability to obtain prompt second opinions or leave the health network altogether. My market choice is thereby restricted with respect to the decisions most important to me: protecting the health of my family.

7. I am competent to testify to the matters stated herein.

Executed this day of January 8, 2002 in the County of Travis, State of Texas: