Read the full 104 page First Amended Complaint .pdf file HERE.

Before the General Medical Council London, United Kingdom In the Matter of:

Dr. Richard Charles Horton (#2927877) Dr. David Maxwell Salisbury (#1413890)

Docket No: _______ Dr. Arie Jeremy Zuckerman (#0870254) Dr. Michael Stuart Pegg (#1560424) Dr. Michael Llewellyn Rutter (#0639943)

FIRST AMENDED COMPLAINT (Breach of duty of honesty and candor; False Testimony; Misuse of Professional Position, Failure to Disclose Conflicting Interest, False Expert Testimony)

The autism and vaccine safety organizations (Organizations) in the United States and the United Kingdom listed below call upon the General Medical Council (GMC) to investigate the conduct of Drs. Richard Horton, Arie Zuckerman, Michael Pegg, and David Salisbury in the Fitness To Practice (FTP) hearing against Drs. AndrewWakefield, Professor John Walker-Smith, and Professor Simon Murch. As set forth more fully below, Drs. Horton, Zuckerman, Pegg, and Salisbury breached their duty of candor to GMC and violated Good Medical Practice (GMP) guidelines by giving false and misleading testimony during the investigation and at the FTP hearing. Drs. Horton, Zuckerman, and Salisbury abused their professional positions ofresponsibility and trust by attempting to censor research critical of vaccine safety and interferewith relations between lawyers and scientists. Dr. Salisbury gave misleading testimony regarding the safety of the MMR vaccine and concealed information material to its safety from the public.

These actions have harmed, and will continue to harm, children by chilling and reducing funding for research into causes of and treatments for autism, and clinical care...