UNITED STATES DISTRICT COUNT 
SOUTHERN DISTRICT OF NEW YORK 
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FRIENDS. OF THE EARTH, INC., 
Plaintiff, 
- against - 
JOSEPH A. CALIFANO, JR., individually 
and as SECRETARY OF THE DEPARTMENT OF 
HEALTH, EDUCATION, AND WELFARE , JAMES 
F. DICKSON III, M.D., individually 
and as ASSISTANT SECRETARY FOR HEALTH 
OF THE DEPARTMENT OF HEALTH, EDUCATION, 
AND WELFARE, DR. DONALD S. FREDRICKSON, 
individually and as DIRECTOR OF THE 
NATIONAL INSTITUTES OF HEALTH, and 
THE NATIONAL INSTITUTES OF HEALTH, 
Defendants . 
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VERIFIED COMPLAINT FOR DECLARATORY 
JUDGMENT AND INJUNCTION 
Plaintiffs, as and for their complaint, by their attorney 
named below, allege as follows: 
1. This action is brought against the above-named defen- 
dants for their failure to comply with the requirements of the 
National Environmental Policy Act of 1969 (NEPA), P.L. 91-190, 
83 Stat. 852, 42 U.S.C. §4321 et sen . , as amended by P.L. 94-83, 
89 Stat. 424; the requirements of the Administrative Procedure 
Act (APA), 5 U.S.C. 0551 et sec . (original version at P.L. 79-404, 
60 Stat. 237); and numerous other lav/s and regulations (a) with 
respect to the funding of recombinant DNA research and its pro- 
found environmental impacts and consequences, (b) with respect to 
the Recombinant DNA Research Guidelines promulgated by the defend- 
ants to regulate the recombinant DNA research program, and (c) 
with respect to the proposals for legislation regulating recom- 
binant DNA activities. 
Plaintiff seeks, i ntcr alia . a declaration from the Court: 
A. That the actions of the defendants in connection with 
the recombinant DI!\ research program, including the actions and 
dctonninali ons 
(1) to conduct recombinant DNA research; 
k?IC 
Civil Action 
No. 
7 7 d ' (O. c?c?e2S~ 
