IV. AS AIJD FOR PLAINTIFF'S SECOND CLAIM 
3lJ. Plaintiff repeats and realleges each and every 
allegation set forth in Paragraphs 1 through 37 vdtli the same 
effect as though herein fully set forth. 
39» In taking the actions of 
(i) developing and pursuing the recombinant DNA 
research program; 
(ii) funding research projects and construction 
and/or renovation of facilities for the 
purpose of conducting recombinant DNA research; 
(iii) promulgating the Recombinant DNA Research 
Guidelines ; 
defendants have not, to the fullest extent possible, executed 
and administered the policies, regulations and public laws with 
the execution and administration of which they are charged, in 
accordance with the policies set forth in NEPA, and the said 
actions are, accordingly, arbitrary. 
40. Plaintiff has no adequate remedy at law. 
19 
ana 
[B-21] 
