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Health Freedom Defense Fund – FAQ’s Regarding Donations for U.S. Freedom Flyers Vaccine Mandate Litigation

By January 16, 2024January 17th, 2024No Comments

UPDATE January 16, 2024

After months of stalling, game playing and evading service, Josh Yoder and other associated parties finally appeared in court in response to the Declaratory Judgement Action (DJA) on August 22, 2023. On September 19, 2023 they filed a counterclaim stating gross inversions of the truth and asserting baseless legal theories.  HFDF has thus since filed a motion to dismiss the counterclaim for sound and meritorious legal reasons. We are currently waiting for the court to rule on this pending motion and then to proceed ahead with next steps in HFDF’s DJA litigation.

Instead of participating properly in the legal process, Yoder and associates continue to share false information online in an attempt to defame HFDF and its leadership. These actions are not consistent with an individual seeking a fair and just resolution.

HFDF and its leadership will continue to act with integrity and will comply with legal decisions regarding the appropriate disbursement of donor funds. We look forward to the day that the truth of this matter is finally revealed in court.


This information is provided to help donors and others understand the nature of Health Freedom Defense Fund’s (HFDF) efforts regarding funds raised for the U.S. Freedom Flyers vaccine mandate litigation. The following numbered sections, styled as “claim” and “TRUTH” for each topic, address specific topics fully refuting allegations raised by Josh Yoder, particularly to clarify relevant information especially for concerned supporters of HFDF’s mission. Yoder claims rights to the funds arising from his prior involvement with the U.S. Freedom Flyers vaccine mandate litigation. Yoder has asserted the following claims through social media podcasts and other communications in which Yoder has spread defamatory statements and outright lies, miscast what has actually happened, misstated applicable law regarding charitable assets, and otherwise has sought to deliberately damage HFDF’s reputation and to discredit HFDF’s founder and president, Leslie Manookian.

First, by way of background: On June 20, 2023, HFDF filed a “declaratory judgment” action to determine the proper disposition and expenditure of charitable funds received by HFDF for the U.S. Freedom Flyers litigation. A declaratory judgment is a court-issued judgment that defines and outlines the rights and obligations of each party in a contract at the early stages of a controversy. This judgment is legally binding but does not require action or award damages. It helps to resolve disputes and prevent lawsuits. HFDF seeks to operate and proceed with utmost integrity and submit to the Court’s jurisdiction and direction regarding proper use and disposition of the Funds, consistent with all applicable law and proper stewardship of charitable resources. HFDF seeks the court’s guidance as the proper legal avenue to resolve the dispute. HFDF has only ever spent the funds in question on litigation costs, as communicated to donors, and will not disburse funds for any other purpose or use without a court’s guidance.

The named defendants in the lawsuit are named solely to allow them to participate in this case.  Defendant US Freedom Flyers is an unincorporated group that has numbered as much as 30,000 individuals. Another “US Freedom Flyers” defendant is a Texas nonprofit corporation, which apparently a few people from the unincorporated group formed later. Josh Yoder is one of the named individual defendants, again named so that he can raise a claim in the litigation if he so chooses. As HFDF is based in Idaho, HFDF’s bank accounts are in Idaho, HFDF’s business is conducted out of Idaho, and the state Attorney General has oversight over charitable assets in the state, HFDF named the Idaho AG’s office as an “interested party,” based on the applicability of the Idaho Uniform Prudent Management of Institutional Funds Act (sometimes known as “UPMIFA”) and the A.G. office’s related power over these charitable assets.

The funds at issue cannot simply be returned to the donors. For one thing, money is fungible by nature; extensive funds have already been spent on the U.S. Freedom Flyers litigation challenging the Biden administration’s Covid-19 vaccine mandate for federal contractors and subcontractors. How would HFDF know which funds could be returned and to whom? Additionally, the donors have given the funds as tax-deductible contributions to a Section 501(c)(3) public charity, with resulting tax benefits. They cannot claim the contributions back now. The legally correct path forward, as the Idaho A.G.’s office has informed HFDF in response to its own self-initiated inquiry, is to proceed with a declaratory judgment action in order to obtain a court’s guidance. 

Yoder claims that he will likewise use the funds for health freedom purposes. But the original USFF group is unincorporated, has lacked proper oversight, lacks the required public charity status, and the U.S. Freedom Flyers litigation is now concluded. Yoder claims further that his newly incorporated Texas nonprofit corporation deserves the funds. However, as noted, legally, the funds must be allocated to the stated purpose, which is health freedom litigation and this new entity’s stated purposes are more generally “charitable, educational, religious, or scientific purposes.” 

HFDF has a demonstrated track record of successful vaccine mandate litigation. HFDF is expressly asking the court’s guidance requiring proper disposition of the funds, including potentially using them in furtherance of its mission, with the Idaho AG’s legally proper involvement. In contrast, Yoder is deliberately seeking to smear HFDF’s and Manookian’s long-standing, impeccable reputation and is making baseless, false allegations against them. While this statement does not address every single lie told by Josh Yoder, the following “claims” and “TRUTHS” sets the record straight on the most significant.


1.         Josh Yoder’s claim: HFDF filed the lawsuit for the purpose of wrongfully keeping USFF’s funds.

TRUTH: The funds were legally donated to HFDF for express purposes of paying for Covid mandate litigation expenses. It is HFDF’s fiduciary and ethical duty to protect donors and properly distribute funds for the stated mission. HFDF is seeking legal guidance to ensure funds are properly handled, consistent with applicable laws specific to charitable funds. HFDF will happily comply with whatever the judge decides.  No funds can legally be given back to donors at this point, and the law on such prohibition is absolutely clear. 

2.         Josh Yoder’s claim: Manookian has taken $80,000 of donor funds.

TRUTH: Manookian has ALWAYS served as a volunteer for HFDF.  She has NEVER taken or been paid a penny from HFDF for herself. She has donated over 10,000 hours of time to HFDF since its founding in 2020 and contributed thousands of dollars of her own funds. All the work she does, she does for free, because she cares about helping people in need. She left millions of dollars on the table when she retired from Wall Street to commit her life to creating a positive impact on the world. She has donated tens of thousands of hours of her time in the past 20 years to research, produce, and share her documentary on vaccines, The Greater Good, and to the cause of health freedom. She has often paid for her own plane tickets, hotels, and travel to testify, speak, and educate others in support of health freedom. In addition, never in Manookian’s entire career has she ever been accused of ANY wrongdoing or had a single black mark on her record.

3.         Josh Yoder’s claim: HFDF improperly filed the lawsuit in Idaho because Manookian and HFDF are part of the deep state.

TRUTH: HFDF’s bank accounts are in Idaho, and therefore the declaratory judgment action regarding charitable assets is entirely proper to be filed in Idaho.  Additionally, Manookian resides in Idaho and has resided in Idaho nearly her entire life. While HFDF was incorporated in Wyoming, HFDF has always been operated from Idaho, Idaho is therefore the proper jurisdiction for the lawsuit. Lastly, the state AG has authority over charitable assets in the state and is the proper official to consult.

4.         Josh Yoder’s claim: George Wentz is HFDF’s lead lawyer.

TRUTH: George Wentz has not been HFDF’s lead lawyer since early 2022. Aside from a completely unrelated business matter, Manookian has not spoken to him since March of 2022 and had only spoken with him sporadically for many months prior to that phone call.

5.         Josh Yoder’s claim: Manookian was taking a 10% “cut” of funds.

TRUTH: Like most non-profits, HFDF charges an administrative fee to cover operational costs. HFDF must pay for the donor interface (nearly 4% off the top of online donations), for its bookkeepers, accountants, website, software and IT, staff, PR, etc. and all the work done to support its clients. HFDF coordinated the entire USFF lawsuit – creating a questionnaire to survey the 30,000 members to identify plaintiffs, reviewing the survey answers, doing all plaintiff intake, identifying good plaintiffs, reviewing plaintiff declarations, communicating with the plaintiffs, etc. HFDF handled over 12,000 donations. HFDF supports big legal actions involving hundreds to thousands of individuals and could not support them without charging a fee. But Manookian does not and has not taken a dime personally.

6.         Josh Yoder’s claim: Manookian and HFDF are refusing to refund donor funds.

TRUTH: Manookian and HFDF are bound by federal and state law which dictates what can and can’t be done with charitable assets. The Idaho Attorney General has responsibility for and oversight of charitable funds located in his state. Manookian and HFDF properly sought the instruction of the Idaho AG in this matter, as required by law. The Idaho AG instructed HFDF to file a declaratory judgment action with the Idaho State Court in order to receive the court’s guidance on proper disposition of the funds. As the funds were subject to a gift restriction for litigation costs only, it would be illegal for HFDF to refund any of the funds – as a tiny minority of donors have requested. Manookian and HFDF will not break the law, no matter how much Josh Yoder and his allies attempt to smear her and the nonprofit she founded.

7.         Josh Yoder’s claim: Manookian and HFDF have absconded with half a million dollars of donor money.

TRUTH: Manookian and HFDF refused Josh Yoder’s demands to break the law and instead protected donors from Josh Yoder’s repeated attempts to misuse the funds. Manookian and HFDF continually sought to protect donors from misuse of funds. Not a single penny of the donor funds in question has EVER been spent on anything other than litigation costs, as required by law and contract.

8.         Josh Yoder’s claim: Manookian and HFDF were acting as an agent, holding USFF’s money.

TRUTH: HFDF was not acting as an agent to USFF. USFF came to HFDF requesting legal help in fighting the Biden administration’s Covid vaccine mandates, access to HFDF’s accomplished legal team, help with raising funds for the litigation, and myriad types of support of the litigation requiring dozens and dozens of hours from the HFDF team. All funds raised were for HFDF, as properly donated tax-deductible contributions – to HFDF, a Section 501(c)(3) public charity.  The funds raised were for the express purpose of litigation fighting against Covid vaccine mandates, and such efforts can continue through HFDF.  When Josh Yoder created the TX-based USFF in September of 2022, he requested funds from HFDF. But that entity has no legal right whatsoever to the funds, and Yoder’s individual involvement does not give him any such rights.

9.         Josh Yoder’s claim: HFDF does not really want to sue him; otherwise HFDF would have already served him with the legal papers.

TRUTH: After two months of evading service and game-playing, Josh Yoder and US Freedom Flyers, and associated parties finally filed a response in the case on August 22, 2023. For clarity, Yoder and the others are not being sued to obtain anything from them; rather, they have been named in the declaratory judgment action so that they may make a claim to the funds. HFDF welcomes this development, as HFDF has always sought court guidance as to the proper handling of the funds. HFDF looks forward to the court’s instructions and will happily abide by whatever the court decides.

10.       Josh Yoder’s claim: USFF was a nonprofit all along.

TRUTH: HFDF was never told of any intention for USFF (the unincorporated group) to become a 501c3 nonprofit until spring of 2022. Josh Yoder requested that HFDF disburse funds for the purpose of creating a 501c3.  HFDF refused the request, as it would be a violation of law and representations made to donors. Naming Yoder’s Texas corporation similarly as “US Freedom Flyers” appears to be an effort to confuse donors and the public, but using a similar name does not give rise to any legal rights. 

11.       Josh Yoder’s claim: Josh Yoder was in charge of when and whom HFDF paid for legal costs.

TRUTH: For the main litigation filed against the Biden administration, invoices came directly to HFDF, and HFDF paid them directly. Josh Yoder had no responsibility to review or authorize payment of invoices.

12.       Josh Yoder’s claim: USFF was dissatisfied with HFDF’s performance.

TRUTH: US Freedom Flyers was a varying group of thousands of people.  With respect to Yoder, only after Manookian and HFDF refused his repeated attempts to misuse funds did he become dissatisfied. It was not until September 1, 2022, that HFDF was made aware of this in a hostile demand letter from his attorney.

13.       Josh Yoder’s claim: HFDF filed the lawsuit in response to the USFF TX board’s vote on May 22, 2023 asking HFDF to return funds to donors and in order to block funds from being refunded to donors.

TRUTH: HFDF sought the instruction of the Idaho Attorney General through an official filing on May 15, 2023, with full and detailed disclosure of all relevant information, demonstrating transparency and integrity. Upon further communications with the Idaho Attorney General’s office and upon its instruction, HFDF filed the lawsuit with the Idaho State Court on June 20, 2023. HFDF first learned of the USFF TX board vote in an email from its attorney on June 23, 2023.

14.       Josh Yoder’s claim:  He is pursuing appropriate avenues for relief by demanding the funds and/or stirring donors to request refunds and by threatening HFDF and Manookian.

TRUTH: Yoder has resorted to false and sensational claims on social media singularly designed to smear the reputation of HFDF and its founder. But no amount of lies, smears, harassment or threats will change the fact that HFDF has followed the law and protected donor funds from misuse.

Manookian and HFDF look forward to the Court reviewing the evidence and issuing its judgment so that this issue may be resolved lawfully.