Slovakian Mask Cultie goes after Dr. Pekova

When you don't like the Science, you cancel it with lawfare.

My Bias is Fine. Yours is Unacceptable.

files.fm/u/5hpkzsxcmm

Back in October I received this email from a Slovakian Police Investigator.

I was initially confused as I mixed up Robert Fico with Peter Kotlar but tried to convey that they should let this play out in the literature and resist the temptation to declare “mis-information” with limited data. I have a feeling my suggestions were ignored.

To clarify my above email… Those substacks were written with zero contact from either party (Peter Kotlar or Robert Fico).

I did send Peter Kotlar our work but only after colleagues suggested I forward it to him and only after it was public on Zenodo.

I did not DM Peter Kotlar on Twitter. I DM’d Robert Fico much earlier in the year trying to warn him about Dr. Fleming. No response.

So where has this lead…

The Mask Cultie above (Tomas Szalay) is ironically from the Freedom Party of Slovakia:)

He has declared that Dr. Pekova’s prior outspoken statements about the exaggerated C19 pandemic condemn her as an Expert (She’s actually correct about this).

In other words, only if you say “Vaccines Amen” 3 times and click your heels are you allowed to investigate the vaccines in Slovakia!

And a Mask nut-job is completely unbiased in casting these condemnations!

I hope Dr. Pekova prevails against this nonsense. Her data is not only important but it mirrors our data, Buckhaults’ data, and Speichers’ data. 4 Labs have all seen 4-6CT differences in qPCR of the Spike over the KAN/Ori region of the plasmid.

This is the 10-100 fold difference that confuses regulators. The mechanisms is now known and accepted for publication (in Press). The Preprint is live but doesn’t contain all of the editors and reviewers corrections. Most of these corrections are for more citations but the technical argument remains.

Yes, there are parts of Dr. Pekova’s work that I disagree with as stated in my previous substacks but those only appeared once Dr. Fleming took control of the paper and inserted “No SV40” in 3 places in the manuscript when these assays were never actually run according to their own methods. This is the process of science and inserting lawfare in the process of discovery ensures only certain conclusions will ever be reached. This is how you create vaccine hesitancy. You create Galileo events at every turn and the population learns to distrust you regardless of the details of the science. They will probably never fully understand the intricacies of qPCR but they certainly can see a rat.

Congratulations. By trying to silence critique in the name of vaccine hesitancy, you have actually accelerated vaccine hesitancy.

The Claude.ai translation of the Czech lawfare is below.

I’ll translate this Czech legal document for you. This is an official notice from the Czech Ministry of Justice regarding administrative proceedings.

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MINISTRY OF JUSTICE OF THE CZECH REPUBLIC Vyšehradská 16, 128 00 Prague 2 Department of Court Experts and Interpreters

To: MUDr. Soňa Peková, Ph.D. 5. května 23 273 08 Pchery Data Box ID: xk9uc9u

YOUR REF. NO.: DATED: OUR REF. NO.: MSP-90/2025-OSZT-SRZT/11 HANDLED BY: Mgr. Jana Kalinová TEL.: +420 221 997 111 EMAIL: oszat@msp.justice.cz (secretariat)

Prague, December 18, 2025 Number of pages: 6 Attachments: 0

Notice of Initiation of Administrative Proceedings for Misconduct Ex Officio

The Ministry of Justice, as the administrative authority competent under § 35 para. 1 of Act No. 254/2019 Coll., on Experts, Expert Offices and Expert Institutes (hereinafter “Expert Act”), for supervision of expert activities under § 46 para. 1 of Act No. 500/2004 Coll., Administrative Procedure Code (hereinafter “Administrative Code”)

hereby notifies

MUDr. Soňa Peková, Ph.D., with registered office at 5. května 23, 273 08 Pchery, ID No.: 72642874 (hereinafter “the party to the proceedings”), that it is initiating administrative proceedings with her regarding revocation of authorization to perform expert activities in the field of healthcare – branch of genetics – specialization in molecular genetics, molecular biology, molecular microbiology, because she seriously violated obligations established by Act No. 254/2019 Coll., on Experts, Expert Offices and Expert Institutes (hereinafter “Expert Act”), when at the request of MUDr. Peter Kotlár, plenipotentiary of the Government of the Slovak Republic for investigation of the management process and resource administration during the COVID-19 pandemic period, on March 16, 2025, she prepared an expert report numbered 01/03/2025 and titled “Quantitative Determination of DNA and RNA Nucleic Acid Content in Batches of Spikevax (Moderna) Vaccine and in Batches of BNT 162b2 (Pfizer) Vaccine” (hereinafter “the expert report”), in which she concluded that the presented data of the tested Spikevax (Moderna) and BNT162b2 (Pfizer) preparations are alarming and are completely sufficient for the immediate cessation of distribution and administration of these potentially health-threatening preparations, while she prepared this report despite reasonable doubts about her impartiality due to her relationship to the matter and to the person of the client MUDr. Peter Kotlár.

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REASONING:

Party to the proceedings

1. The party to the proceedings has had authorization to perform expert activities in the field of healthcare – branch of genetics – specialization in molecular genetics, molecular biology, molecular microbiology since December 15, 2017. She is a self-employed natural person with assigned ID No.: 72642874.

2. According to the electronic register of expert acts, she has prepared one expert report during the existence of this register (i.e., since November 2022).

Procedure of the administrative authority before initiating proceedings

Complaint

3. On April 28, 2025, the Ministry of Justice (hereinafter “the ministry” or “administrative authority”) received notification from MUDr. Tomáš Szalay, PhD., Member of the National Council of the Slovak Republic, regarding suspicion of commission of misconduct in the field of expert activities, which according to his claim the party to the proceedings may have committed by preparing expert report No. 01/03/2025, in which she assessed the content of DNA and RNA nucleic acids in vaccination preparations against COVID-19 disease, specifically in 17 batches of Spikevax (Moderna) vaccine and 7 batches of BNT 162b2 (Pfizer) vaccine. An attachment to the notification was a copy of an article from DeníkN published in the Slovak Republic dated March 17, 2025, titled “Scientist says Peková’s analysis does not prove high DNA content in mRNA vaccines, as Kotlár claims.”

4. The complainant stated in the complaint that on March 13, 2025, MUDr. Peter Kotlár, Member of the National Council of the Slovak Republic and plenipotentiary of the Government of the Slovak Republic for investigation of the management process and resource management during the COVID-19 pandemic, appeared at a press conference titled “Results of analysis of vaccine batches used against Covid-19 disease in the Slovak population” (publicly accessible at https://tv.nrsr.sk/archiv/tlacovakonferencia/9/6726) and spoke about the results of an unspecified analysis of vaccines against COVID-19 disease. Specifically, he said that according to the results of this analysis, one dose of vaccine contains an enormously high amount of DNA, which can integrate into human DNA, thereby genetically modifying the human organism. He claimed that this is not contamination of vaccines, but a purposeful enormous amount of genetic material that can transfer human nuclear DNA, and this introduction of genetic material can become stable and permanent and with sufficiently high probability can cause the development of cancer diseases. He literally said: “If it needs to be said in plain language, though not nicely: Moderna and Pfizer have made genetically modified organisms out of the vaccinated, they treated people like corn without their knowledge. The high DNA content to this extent is absolutely scandalous and the use of these preparations in our population should be immediately banned. [...] These findings are so serious that the Prosecutor General should act immediately, the scientific community should sound the alarm, and all vaccine advocates should be ashamed. Modestly but confidently said, we are one of the few countries in the world, if not the only one, that has carried out such analyses and also publishes them. Let’s do something great and rank among the examples. These components of vaccine content not guaranteed by the company could be fully used in court disputes with pharmaceutical companies, they could also serve the Supreme Audit Office and other state components for purposes of developing a procedure for refusing payment of the amount for pre-ordered vaccine quantities until 2026.”

5. The complainant pointed out that although MUDr. Peter Kotlár did not identify the author of the analysis even when asked by journalists, the party to the proceedings later claimed authorship on her Facebook profile and also in an interview published on YouTube.

6. The complainant further pointed out that in these posts, the party to the proceedings says she prepared the report to show that the vaccines are dangerous and to stop vaccination with these vaccines. The complainant believes that if she was guided by this intention when preparing the report, she was biased. Furthermore, the complainant points to her previous collaboration with MUDr. Peter Kotlár, for whom she prepared the report, and to the fact that she repeatedly publicly commented on the expert report in public space, which was contrary to her duty of confidentiality. Finally, the complainant stated that the party to the proceedings did not register the report in the register of expert acts, and questioned her authorization to prepare the report because she does not have authorization to perform expert activities in the field of pharmacy, branch of pharmaceutical control.

7. On July 29, 2025, the complainant supplemented his submission and sent the ministry a link to an article titled “Quantitative Analysis of Nucleic Acid Content in Spikevax (Moderna) and BNT 162b2 (Pfizer) COVID-19 Vaccine Lots,” published on May 13, 2025, in HSO Journal of Angiology and Vascular Surgery, which contentwise copies the analysis presented at the press conference. Co-authors of the article are listed as the party to the proceedings with MUDr. Peter Kotlár and Dr. Richard M. Fleming, PhD. (see: https://www.heraldopenaccess.us/openaccess/quantitative-analysis-of-nucleic-acid-content-in-spikevax-moderna-and-bnt162b2-pfizer-covid-19-vaccine-lots).

8. The complainant further stated that MUDr. Peter Kotlár appeared on May 23, 2025, at another press conference, where in response to a journalist’s question about how much the analysis he refers to cost, he stated zero EUR (https://tv.nrsr.sk/archiv/tlacovakonferencia/9/6860).

Provision of explanation

9. The ministry, by letter dated July 28, 2025, summoned the party to the proceedings to provide an explanation under § 137 of the Administrative Code. It ordered the party to the proceedings to respond to the claims stated in the complaint, especially to state whether she prepared an expert report in which she analyzed batches of vaccines used against Covid-19 disease, which is mentioned in the notification. At the same time, she was summoned to clarify, in case an expert report was prepared, for what reason she did not register the report in the electronic register of expert reports. Finally, she was summoned to submit the report to the ministry if she had prepared it.

10. On July 29, 2025 and July 30, 2025, the ministry received a statement from the party to the proceedings. She stated that on March 16, 2025, she prepared a report titled “Quantitative determination of DNA and RNA nucleic acid content in 17 batches of Spikevax (Moderna) vaccine and 7 batches of BNT162b2 (Pfizer) vaccine,” which she registered only in her expert diary under internal designation No. 01/03/2025. She did not realize that the transitional period under Act No. 254/2019 Coll., on Experts, Expert Offices and Expert Institutes (Expert Act) had ended, and that she had an obligation to register in the electronic register. Therefore, she fulfilled this obligation only after receiving the summons from the administrative authority. Regarding the facts stated in the complaint, she stated that they are based on personal feelings and opinions of their authors. In the attachments she sent:

• Copy of expert report No. 01/03/2025 dated March 16, 2025, in Czech language, 41 pages in scope; on the last page by the party’s name there is no signature or imprint of a round seal;

• Copy of expert report No. 01/03/2025 dated March 16, 2025, in English language, 41 pages in scope; on the last page by the party’s name there is no signature or imprint of a round seal;

• Annex 1 of the expert report – letter dated March 3, 2025, from the Office of the Government of the Slovak Republic signed by MUDr. Peter Kotlár addressed to TILIA LABORATORIES s.r.o., 5. května 44, 273 08 Pchery, containing a request for quantitative analysis of liposomal preparations;

• Annex 2 of the expert report (in English) - study titled “Sequencing of bivalent Moderna and Pfizer mRNA vaccines reveals nanogram to microgram quantities of expression vector dsDNA per dose,” Kevin McKernan, Yvonne Helbert, Liam T. Kane, Stephen McLaughlin, Medicinal Genomics, 100 Cummings Center, Suite 406-L, Beverly Mass, 01915, the party to the proceedings is not listed as an author (23 pages in scope);

• Annex 3 of the expert report – list of tested Spikevax (Moderna) and BNT162b1 (Pfizer) batches and data measured using multiplex quantitative Real-Time PCR;

• Annex 4 of the expert report (in English) – study titled “RT-PCR Test Targeting the Conserved 5’-UTR of SARS-CoV-2 Overcomes Shortcomings of the First WHO-Recommended RT-PCR Test,” authors Ulrike Kämmerer, PhD, Sona Pekova, PhD, Rainer J. Klement, PhD, Rogier Louwen, PhD, Pieter Borger, PhD, Klaus Steger, PhD,” published April 4, 2023, in International Journal of Vaccine Theory, Practice, and Research;

• Annex 5 of the expert report (in English) – article titled “Clinical features of Omicron variant infection in 445 patients with coronavirus 19 disease,” authors Lihong Yang, Jianfeng Zhong, Weihong Wang, Feng Zhou, Zhaowei Tong, Yifeng Zheng, Xing Chen, published in 2023 in ANN SAUDI MED 2023 at www.annsaudimed.net;

• Annex 6 of the expert report (in English) – study titled “Worse Than the Disease? Reviewing Some Possible Unintended Consequences of the mRNA Vaccines Against COVID-19,” Stephanie Seneff and Greg Nigh, Computer Science and Artificial Intelligence Laboratory, MIT, Cambridge, MA 02139, USA, Naturopathic Oncology, Immersion Health, Portland, OR 97214, USA, published May 10, 2021, in International Journal of Vaccine Theory, Practice, and Research;

• Annex 7 (in English) – document titled “Quantitative Multiplex Real-Time PCR analysis of Moderna (Spikevax) and Pfizer (BNT162b2) vaccines,” Soňa Peková, TILIA LABORATORIES s.r.o., March 8, 2025.

Established factual state

11. From publicly available sources it follows that the party to the proceedings has expressed views since the beginning of the COVID-19 pandemic on the origin of the COVID-19 virus and held a negative attitude toward vaccination with vaccines against COVID-19. Below are some of her statements:

• In February 2021, in an interview for Reflex magazine, she stated that she does not regret her statement that the COVID-19 virus would disappear by Christmas 2020, because according to her research, the original wave of the pandemic was caused by a virus that has already disappeared, and subsequent waves originate from mutations that do not derive from the original virus and she doesn’t know where they come from (see https://www.reflex.cz/clanek/rozhovory/105325/sona-pekova-radi-tu-jine-kmeny-viru-ten-jarni-jak-jsem-tehdy-rikala-vymizel.html).

• In June 2021, on the YouTube channel Czechfreepress CFP!, she stated that side effects of COVID-19 vaccines are being concealed because, among other things, a “giant” form for reporting them is too complicated for doctors to fill out. At the same time she stated: “[...] for people to get vaccinated against some laboratory scams, that seems completely absurd to me” (see

• On April 6, 2022, in an interview published on Free Radio for Free People, operated by the company Free Radio, z.s., in the program “Studio Beta – Soňa Peková with additional information about covid,” she expressed a negative attitude toward vaccination with vaccines against the virus causing COVID-19 disease. She expressed the conviction that opinions other than officially presented opinions are ignored by responsible institutions, which she disagrees with, and is convinced that the people “who are currently orchestrating this here will one day probably be swept away” (see https://svobodne-radio.com/2022-04-06-studio-beta-sona-pekova-s-dalsimi-informacemi-o-covidu/).

12. On March 13, 2025, MUDr. Peter Kotlár, plenipotentiary of the Government of the Slovak Republic for investigation of the management process and resource administration during the COVID-19 pandemic period, Member of the National Council of the Slovak Republic, presented at a press conference the results of analysis of Moderna (Spikevax) and Pfizer (BNT162b2) vaccines used against Covid-19 disease in the Slovak Republic. The presented conclusion of this analysis was that all assessed batches of Spikevax (Moderna) and BNT162b2 (Pfizer) vaccines used for vaccination against COVID-19 disease contain excessive amounts of DNA, as a result of which the human organism becomes a genetically modified organism, and therefore their use should be immediately banned. He did not identify the author of the analysis (see https://www.nrsr.sk/web/Default.aspx?sid=video&VideoId=3026).

13. Later, the party to the proceedings stated on her Facebook profile: “[...] I provided the data for MUDr. Peter Kotlár’s presentation, it was produced by our laboratory TILIA LABORATORIES s.r.o., and you can find this presentation in full scope here, also in the form of individual images in the annex https://www.10letters.org/CzechResearch.pdf. And I am now writing a complete report in full detail of all measured data in the form of an Expert Report for the Prosecutor General’s Office of the Slovak Republic, because I am a Court Expert in the field of Molecular Biology, Molecular Genetics, Molecular Microbiology. But I want to very strongly repeat once again my position on the matter. I performed the ‘Analysis’ of Spikevax (Moderna) and BNT162b2 (Pfizer) vaccines so that this alarming data would enable immediate cessation of use of these experimental and potentially dangerous preparations.”

14. On March 16, 2025, the party to the proceedings stated on her Facebook profile: “Dear friends, done, an expert report of 159 pages of text and annexes, with maximum detail regarding analytical procedure, results and evaluation of data concerning Spikevax (Moderna) and BNT162b2(Pfizer) preparations was handed over to MUDr. Peter Kotlár – today electronically, tomorrow also in original official printed form with the round stamp of a court expert. The reason why we are both doing this is to stop the widespread use of experimental preparations that have not been thoroughly tested and appear to have adverse health consequences.”

15. On March 21, 2025, on her Facebook profile she stated: “[...] I would like to inform you that the data concerning the content of Spikevax (Moderna) and BNT62b2 preparations, which were handed over a few days ago in the form of a forensic expert report to the Government of the Slovak Republic, were also sent today to the editorial office of the New England Journal of Medicine (NEJM): Quantitative Analysis of Nucleic Acid Content in Spikevax (Moderna) and BNT162b2(Pfizer) COVID-19 Vaccine Lots (Prof. Richard M. Fleming, Dr. Peter Kotlar, Dr. Sona Pekova). I am attaching the Cover Letter. This data will be useful also for colleagues from abroad who are trying to settle C19 discrepancies in their countries, because in recent years censorship and propaganda have proliferated so much in ‘science’ that it was almost impossible to publish data outside the strangely preferred and only possible direction of thinking. So hopefully the ice will finally break and in science a pluralistic and politically independent space for work and meaningful discussion will open again.”

16. On the same day, an interview was published on the YouTube channel

12. in which the party to the proceedings, in response to the moderator’s question about what motives led her to prepare the analysis, or subsequently the expert report, stated: “[...] I want the distribution and use of these preparations to be stopped, ceased [...]. So this was supposed to lead, or is supposed to lead to this, and that’s why I did it, so that this would immediately stop, so that it would stop being distributed, offered to people and so that it would be properly examined or actually at all, so that it wouldn’t be used further, because this is a potentially dangerous thing. (...) So what we did with Peter Kotlár, and we both see it the same way, that we want this to end and the only way to end it is to show clearly the data that the preparations are simply dangerous [...].”

13. In the above-mentioned interview, in response to further questions from the moderator, the party to the proceedings stated: “[...] So the data that the Prosecutor General received, and this is complete data, on the basis of which that very brief summary was then created, [...] Well, and what will happen next with it will be seen, but there is still in process Doctor Fleming from Houston, Texas, he is actually one of our trio who worked on it and is now actually working on publishing it [...].” From the context of the interview, it follows that the “trio” means MUDr. Peková, MUDr. Fleming and MUDr. Kotlár.

14. On May 13, 2025, an article titled “Quantitative Analysis of Nucleic Acid Content in Spikevax (Moderna) and BNT162b2 (Pfizer) COVID-19 Vaccine Lots” was published in HSOA Journal of Angiology, with co-authors listed as MUDr. Soňa Peková, Ph.D., representative of the expert report client MUDr. Peter Kotlár and MUDr. Richard M Fleming, Ph.D. The content of the article corresponds to the content of the analysis presented at MUDr. Peter Kotlár’s press conference. A link to the article can be found at https://www.heraldopenaccess.us/openaccess/quantitative-analysis-of-nucleic-acid-content-in-spikevax-moderna-and-bnt162b2-pfizer-covid-19-vaccine-lots.

15. On May 23, 2025, MUDr. Peter Kotlár stated at a press conference that he paid zero EUR for the analysis/expert report (see https://tv.nrsr.sk/archiv/tlacovakonferencia/9/6860, from 25:17 minutes).

16. On July 29, 2025, the party to the proceedings registered the expert report in the electronically maintained register, stating March 3, 2025, as the date of assignment and March 16, 2025, as the date of preparation.

17. It can be summarized that in the period from March 3, 2025, to May 13, 2025, three documents were created whose content overlaps and whose author or co-author is the party to the proceedings:

18. Analysis “Results of analysis of vaccine batches used against Covid-19 disease in the Slovak population” presented at the press conference on March 13, 2025, to whose authorship the party to the proceedings admitted and which is in English at the link https://www.10letters.org/CzechResearch.pdf. Here the analysis is called “Quantitative Multiplex Real-Time PCR analysis of Moderna (Spikevax) and Pfizer (BNT162b2) vaccines.”

19. Co-authored article “Quantitative Analysis of Nucleic Acid Content in Spikevax (Moderna) and BNT162b2 (Pfizer) COVID-19 Vaccine Lots” published on May 13, 2025, in HSOA Journal of Angiology.

20. Expert report dated March 16, 2025, whose declared purpose was: Quantitative determination of DNA and RNA nucleic acid content in batches of Spikevax (Moderna) vaccine and in batches of BNT 162b2 (Pfizer) vaccine.

21. The analysis has a total of 13 pages. On the title page is a heading in English, author Sona Pekova, MD, PhD., TILIA LABORATORIES s.r.o., Laboratory for molecular diagnostics, Pchery, Czech Republic, 08.03.2025. The main part of the analysis consists of 8 graphs and 1 table. The summary on the final page contains interpretation of results, according to which both assessed vaccines contain high amounts of DNA cassettes for S protein expression, in amounts comparable to mRNA. This conclusion was presented and interpreted by MUDr. Peter Kotlár at the press conference.

22. The expert report is dated March 16, 2025. The graphs and table used are identical to the tables and graphs used in the analysis. The graphs and table are contained in the expert report in chapters 2.1.1. and 2.1.2. on pages 27 to 33. The core of the expert report is the analysis, however, the expert report is more comprehensive, which corresponds to what the party to the proceedings stated on her Facebook profile, namely that she is writing a complete report in full detail of all measured data in the form of an expert report. The conclusions of both documents, i.e., the analysis and the expert report, are identical: The amount of DNA in the assessed vaccines is high, and therefore the vaccines are dangerous and should not be used.

23. The report includes six annexes. Of these, 4 are scientific articles, another annex is a table of measured values, and the last annex (marked as No. 1 in the report) consists of a copy of MUDr. Peter Kotlár’s letter dated March 3, 2025. Peter Kotlár was the client. However, in the mentioned letter, he does not request preparation of an expert report, but rather preparation of a quantitative analysis of preparations. The letter is then not addressed to the party to the proceedings, but to the company Tilia Laboratories, s.r.o. The letter does not request preparation of an expert report nor does it pose any questions.

24. Finally, from the register of expert reports maintained by the ministry, it was confirmed that the party to the proceedings registered expert report No. 01/03/2025 dated March 16, 2025, in the register on July 29, 2025, under item number 060703/2025.

Preliminary legal assessment

26. One of the basic obligations of an expert is to perform activities impartially (cf. § 1 para. 3 of the Expert Act). The purpose of an expert report is to create a credible basis for decision-making, typically by public authorities. If it cannot be relied upon that the conclusions of an expert report are unbiased, then the report not only lacks purpose but can even endanger the public interest in fair decision-making by administrative authorities.

27. There is general agreement that a person who has a relationship to the matter being decided will be more or less, consciously or unconsciously, biased, which will influence their judgment and the conclusions resulting from it. Even if, despite this obstacle, they managed to maintain impartiality, their conclusions will be questioned precisely because of their relationship to the matter. Therefore, even if the report were impartial, it will quite understandably raise doubts. Therefore, certain relationships establish bias by law, which is an obstacle to that person acting in the matter.

28. In the Expert Act, bias is regulated in § 18 para. 1, according to which an expert must not perform an expert act if there can be reasonable doubt about their impartiality due to their relationship to the matter and the client. Commentary on this provision states that exclusion of an expert serves as the main means of ensuring protection of the expert’s impartiality, which together with expertise belongs to the basic attributes of expert activities ensuring provision of an objective expert opinion on a factual question in proceedings or on another expert factual problem significant for legal action. (DÖRFL, Luboš. § 18 [Exclusion]. In: DÖRFL, Luboš, KRYSL, Alexandr, LEHKÁ, Markéta, VISINGER, Radek. Act on Experts, Expert Offices and Expert Institutes. 1st edition. Prague: C. H. Beck, 2021, p. 168, marg. No. 33.).

29. The prohibition on performing an expert act applies both to cases where the expert is appointed to perform an expert act by a public authority and to acts performed by the expert based on a contract. In assessing the bias of experts, similar criteria are used as in assessing the bias of judges. Reasons that may lead to exclusion of an expert from an expert task due to bias may be factual reasons, for relationship to the matter for which the expert report is being prepared, or personal reasons, for relationship to persons associated with preparation of the expert report. Relationship to the matter is then understood as the expert’s personal interest in the outcome of the proceedings.

Regarding bias for relationship to the matter

30. In the case under review, the party to the proceedings in her public appearances before preparing the report declared a rejecting attitude toward vaccination against COVID-19 disease. She repeatedly stated that vaccines have harmful effects and people should not be vaccinated against COVID-19 disease. The accused at the time of preparing the report was not neutral regarding vaccination against COVID-19 disease, on the contrary, she held and publicly expressed a rejecting attitude toward vaccination. She had a negative relationship to the matter she was assessing, i.e., vaccination preparations. Precisely this negative attitude represents a relationship to the matter within the meaning of § 18 para. 1 of the Expert Act. Because at the time of preparing the expert report there were reasonable doubts about the expert’s impartiality due to her relationship to vaccination and vaccines against COVID-19 disease, she had an obligation to refuse preparation of the expert report.

31. In this context, it is necessary to point out that according to the established factual state, the party to the proceedings was not asked to prepare the report but prepared it on her own initiative. From the request delivered to the party to the proceedings, it follows that although MUDr. Peter Kotlár requested from TILIA LABORATORIES s.r.o. a quantitative analysis of ribosomal preparations, the party to the proceedings, beyond the scope of this request, used the expert seal to transform the analysis (apparently performed by TILIA LABORATORIES s.r.o.) into an expert report, thereby giving this analysis greater weight. Her intention, according to her own words, was for alarming data to enable immediate cessation of use of these experimental and potentially dangerous preparations.

32. Completely in line with this rhetoric, she states in the conclusion of the expert report that the presented data of Spikevax (Moderna) and BNT162b2 (Pfizer) preparations are alarming and are completely sufficient for the immediate cessation of distribution and administration of these potentially health-threatening preparations.

33. The fact that the party to the proceedings did not request either expert fees or reimbursement of costs also raises doubts about the motives that led her to prepare the expert report.

34. It is an indisputable right of the party to the proceedings to perform analyses within her expertise, write scientific articles, and freely express her opinions. If the party to the proceedings is convinced that vaccines against COVID-19 disease are harmful, she can publish and disseminate the conclusions of her analyses in the manner customary in scientific circles. However, it is inadmissible for her to present her opinions and analyses in the form of an expert report, as was the case here.

Regarding bias for relationship to person

35. From the established factual state, it is further evident that there was a relationship between the party to the proceedings and MUDr. Peter Kotlár, who ordered an analysis from TILIA LABORATORIES s.r.o., from which later became an expert report. Together they created and published the article “Quantitative determination of DNA and RNA nucleic acid content in batches of Spikevax (Moderna) vaccine and in batches of BNT 162b2 (Pfizer) vaccine.” Although their joint article was published only after the issuance of the expert report, their collaboration on creating the article and on its publication must have been ongoing before the preparation of the expert report.

36. It can be summarized that the party to the proceedings in the assessed case created a completely unclear situation in which it is not evident for what purpose the expert report was created and who participated in its creation. Although the client requested an analysis, the accused created an expert report for him, for which she did not request expert fees or reimbursement of costs and which she did not register in the diary. In the report, she stated that the purpose for its preparation was: Quantitative determination of DNA and RNA nucleic acid content in batches of Spikevax (Moderna) vaccine and in batches of BNT 162b2 (Pfizer) vaccine. This declared “purpose” (which is actually the subject) is the title of the article published on May 13, 2025, in HSOA Journal of Angiology (Quantitative Analysis of Nucleic Acid Content in Spikevax (Moderna) and BNT162b2 (Pfizer) COVID-19 Vaccine Lots), whose authors are, besides the party to the proceedings, also MUDr. Peter Kotlár and MUDr. Richard M Fleming, Ph.D. From public statements of the party to the proceedings on her Facebook profile, as well as from statements by MUDr. Peter Kotlár, it follows that the actual purpose for preparing the expert report was an attempt to stop vaccination with the mentioned substances, and the report was to be handed over to the Prosecutor General of the Slovak Republic. The content of the report overlaps with the analysis and also with the article, whose authors are the party to the proceedings together with MUDr. Peter Kotlár and MUDr. Richard M Fleming, Ph.D.

37. Given the nature, seriousness, and impact of the party’s actions on the general public, the ministry considers initiation of proceedings for revocation of authorization to perform expert activities as the only purposeful and at the same time proportional measure. The party’s actions had a society-wide impact; the expert report she prepared was addressed by the Slovak Academy of Sciences (hereinafter “SAV”), which on August 21, 2025, issued a statement in which it stated that based on a commission from the Ministry of Health of the Slovak Republic for the Biomedical Center SAV, v.v.i., and in cooperation with the State Institute for Drug Control, it performed an analysis of the composition of mRNA vaccines against COVID-19 disease. Regarding the expert report of the party to the proceedings, it stated: [...] “the publicized announcements and work containing claims about high amounts of DNA, on the basis of which the SAV analysis was also performed, are based on technically incorrect procedures and/or poorly interpreted results. Such announcements are erroneous and misleading. Together with unfounded and nonsensical claims about vaccination threats, they represent a dangerous source of manipulation with public fear, which seriously threatens the health of individuals as well as public health.”

38. As stated in the above statement, the work of the party to the proceedings, covered by expert authorization, represents a dangerous source of manipulation with public fear, and consequently threatens not only the health of individuals but public opinion in general. It is not in the public interest for expert activities to be performed in this manner.

39. Given the initiation of proceedings for revocation of authorization to perform expert activities due to bias, the ministry considers it superfluous to address other failures of the expert that she may have committed in connection with preparation of the expert report.

40. Given the above, the ministry initiated proceedings for revocation of authorization to perform expert activities under § 46 para. 1 of the Administrative Code in connection with § 14 para. 1 letter e) of the Expert Act.

INSTRUCTION:

According to § 80 para. 2 of the Misdemeanor Act, the party to the proceedings has the right to request an oral hearing if it is necessary for asserting their rights. The administrative authority is not bound by the party’s proposal to order an oral hearing and will order an oral hearing if it is necessary for establishing the facts or for asserting the rights of the party in the proceedings.

According to § 33 para. 1 of Act No. 500/2004 Coll., Administrative Procedure Code (hereinafter “A.P.C.”), a party may choose a representative. Authorization for representation is proven by written power of attorney. Power of attorney can also be granted verbally on record. In the same matter, a party can have only one representative at the same time.

According to § 36 para. 1 of the A.P.C., unless the law provides otherwise, parties are entitled to propose evidence and make other proposals throughout the proceedings, until the decision is issued; the administrative authority may declare by resolution by when parties may make their proposals.

According to § 36 para. 2 of the A.P.C., parties have the right to express their position in the proceedings. If they so request, the administrative authority shall provide them with information about the proceedings, unless the law provides otherwise.

According to § 36 para. 3 of the A.P.C., unless the law provides otherwise, parties must be given the opportunity to comment on the basis for the decision before issuing the decision in the matter; this does not apply to the applicant if their application is fully granted, and to a party who has waived the right to comment on the basis for the decision.

According to § 36 para. 4 of the Administrative Procedure Code, a party has the right during dealings with the administrative authority to consultations with a person who, according to the Civil Code, can assist them as a supporter in decision-making; if there are several such persons, the party shall choose one of them. If during the proceedings the party’s supporter objects in their own name to the invalidity of a legal act made by the supported party, the administrative authority shall take this objection into account in the proceedings.

According to § 38 para. 1 and para. 2 of the A.P.C., parties and their representatives have the right to inspect the file, even in the case that the decision in the matter is already legally effective. If the party is not represented, the party’s supporter may also inspect the file together with the party. The administrative authority will allow other persons to inspect the file if they prove a legal interest or other serious reason and this will not violate the right of any of the parties, or other affected persons, or the public interest.

According to § 14 para. 2 of the A.P.C., a party to proceedings may object to the bias of an official person as soon as they learn about it. A record has been made in the file about who is the authorized official person in the given matter, and the administrative authority will inform the party about this upon request.

Inspection of the file is possible by prior arrangement on working days in the building of the Ministry of Justice (Legerova 49, Prague 2) during office hours from 9:00 to 14:30. Due to ensuring better coordination, we ask you to communicate the date of inspection to the e-mail address: oszt@msp.justice.cz.

The Ministry summons the expert that if she wishes, in accordance with § 36 para. 2 of Act No. 500/2004 Coll., Administrative Procedure Code, to exercise her right to express her position on the initiated proceedings, especially to state all facts testifying in her favor, she should do so within 15 days from delivery of this notification.

Mgr. Radomír Čujan, LL.M. Director of the Department of Court Experts and Interpreters

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This is a formal administrative proceeding initiated against Dr. Peková for allegedly violating expert conduct rules by preparing a biased expert report on COVID-19 vaccines, specifically regarding her impartiality due to her pre-existing negative views on COVID vaccines and her relationship with the person who requested the analysis.