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COVID-19 Vaccine Mandates

Business Mask Mandate


Thank you for contacting our office, and for your interest in joining together with individuals from throughout the State of New York in challenging COVID-19 vaccine mandates that are now being handed down by, among others, employers, educational institutions, and the State of New York itself. Above you find some helpful links which will reference specific challenges to the various mandates across New York State. 

We understand that you may be calling to discuss your options if you are one of the individuals now being faced with termination or other unforeseen penalties for attempting to exercise your right to bodily autonomy, and to refuse medical treatment without full and proper approval by the United States Food and Drug Administration (the “FDA”) – the COVID-19 vaccines have only, to date, been authorized for “Emergency Use,” rendering the newfound mandates, from a legal perspective, invalid ab initio.

You may have heard that HoganWillig, PLLC is collecting information from individuals seeking to join the broad efforts to challenge these COVID-19 vaccine mandates, and you heard correctly. To that end, we are asking interested individuals to complete the below questionnaire, so that we can thoroughly organize your information and present it to the Court, in a Complaint, in a coherent/efficient manner. This information will be collected and used to determine, in part, who the appropriate Defendants will be in this lawsuit (which will, in all likelihood, be filed in Federal Court), and to further assist in our efforts to draft the documents necessary to commence the lawsuit – including Affidavits from many of you.

To provide context on HoganWillig’s background, we wanted to also explain HoganWillig’s experience in challenging arbitrary government mandates throughout the COVID-19 pandemic, and our position and ability to represent individuals throughout the State of New York in this matter.

Governor Cuomo first declared a State Disaster Emergency on March 7, 2020, via his issuance of Executive Order 202, and shortly thereafter required that all businesses throughout the State, private and public alike, reduce their workforce to only those employees essential to conduct business in-person.

However, given the nature of our firm and the business we conduct daily, we elected instead to apply to the Empire State Development Corporation for an “Essential Business Designation,” exempting our firm from Governor Cuomo’s Executive Orders, and the restrictions set forth therein. We were therefore very pleased to receive an Essential Business Designation on March 19, 2020, becoming the first law firm in the State of New York to receive this Designation, and permitting us to remain open, avoid closing our doors at any time during the COVID-19 pandemic, and retain our entire workforce.

During the course of the COVID-19 pandemic, as referenced above, our law firm has represented several businesses and individuals in challenges to Governor Cuomo’s and/or the State of New York’s arbitrary government mandates. For example, our firm represented approximately one hundred local bars and restaurants in a challenge to Governor Cuomo’s Executive Order banning indoor dining and was able to secure an Order enjoining the State of New York from enforcing that Executive Order against our bar and restaurant clients. This Order was shortly followed up by announcements from the Erie County Department of Health and Governor Cuomo’s Office, lifting the indoor dining ban across the State.

We then represented the same bars and restaurants in a challenge to Governor Cuomo’s Executive Order requiring bars and restaurants to close their doors at 10:00 p.m. and were again able to secure an Order enjoining the State from enforcing the Executive Order against our bar and restaurant clients.

We also represented barbershops and salons in their efforts to re-open amid Governor Cuomo’s Closure Orders, youth sports teams and athletes in their efforts to resume competitive gameplay despite Governor Cuomo’s and the Department of Health’s prohibitive Executive Orders and Guidance, and the parents of hundreds of local students in their bid to return to full-time, five days per week in-person instruction, which ultimately became moot as COVID-19 transmission rates began to drop early in 2021.

The above is offered not to boast of HoganWillig’s accomplishments during this pandemic, but rather, to demonstrate to individuals such as yourself the backdrop against which HoganWillig would be able to represent you in your efforts to challenge the State’s COVID-19 vaccine mandates.

We understand, of course, that you may have questions about how this matter would proceed, the timeline for filing this lawsuit and challenging the COVID-19 vaccine mandates, and about our legal fees in this matter; in this regard, once your information has been provided and collected by our office, your information will be added to a database to which we will distribute a Zoom link weekly, so we can stay in constant contact with all of you and provide answers to the questions you have in this matter.

Thank you for thinking of our firm in mounting a challenge to the COVID-19 vaccine mandate you are being faced with; we look forward to receiving your information, and to working with you in what is admittedly the difficult challenge to protect the rights afforded to you under the United States and New York State Constitutions.


STEP ONE: Fill Out Questionnaire

General Questionnaire Form


Retainer Agreement


Retainer Payment  --  Please reference client/matter number 38115/2111628 when making your one-time $500 payment.

(if you are looking to challenge the vaccine mandate at the Bills Stadium or Key Bank Center click the link below and fill out the questionnaire on that page. NOT the one above.) 

Information Regarding Highmark Stadium and Keybank Center Ticketholders Questionnaire Form

Please send us this documentation as soon as possible, as all of this information is critical in our representation of you in challenging Vaccine Mandates. Pertaining to updates on the lawsuit, the attorneys are currently in the process of drafting a complaint and we will be set to file sometime next week. So, please send back your information/payments as soon as possible. We are working around the clock to make the best legal arguments we can to be successful in court.


We are posting for you some examples of exemption requests relative to the COVID-19 vaccination.  We’ve tried to provide one for religious and one for medical reasons.  We are not endorsing either at this time but given the requests we received, we felt it was appropriate to provide some examples.  However, since we are unable to speak with everyone regarding their individual circumstances, please review them carefully and make sure that you are comfortable with the information that is included in the event you do choose to use either one.  If there is a portion or portions of the exemption request that does not apply to you or is not true, please remove that language before utilizing the document.  We hope this is helpful. 

Catholic Vaccine Exemption Template

COVID-19 Vaccine Medical Exemption Form

Sample Medical Exemption Form

We appreciate your patience through this challenging time and our law firm is doing whatever we can to help you as well as many others who have the same concerns. Should you have further questions, please do not hesitate to contact our team at  We will try our absolute best to get back to all of the emails and questions you may have. Also, we will email you once we receive any further information.

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