independent an free from inappropriate influence as required by 
Section 5 of the Federal Advisory Committee Act and is constituted 
contrary to lav/. 
M. Enjoining and restraining defendants from convening 
meetings of the above Advisory Committee as long as its member- 
ship is improperly constituted. 
N. Declaring that all previous recommendations and certi- 
fications made by the above Advisory Committee are ultra vires 
and invalid. 
O. Declaring that defendants are required by Section 301 
of the Public Health Service Act to obtain the recommendation of 
the National Advisory Health Council and the National Cancer 
Advisory Board prior to adopting any means for carrying out the 
recombinant DNA research program. 
P. Declaring that the defendants' failure to obtain the 
recommendations of the National Advisory Health Council and the 
National Cancer Advisory Board with respect to items (1) 
through (6) in "A" above, was and is contrary to law. 
Q. Granting such interlocutory relief to plaintiff, 
pending final judgment in this action, as may be necessary to 
prevent irreparable injury pending final judgment herein ; 
R. Granting plaintiff reasonable attorneys' fees and 
the costs and disbursements of this action; and 
S. Granting to plaintiff such other and further relief 
as to the Court seems just. 
Dated: New York, New York 
May 6, 1977 
Friends of the Earth, Inc. 
72 Jane Street 
New York, Mew York 10014 
212-675-5911 
212-666-8146 
RICHARD M. 1IARTZMAN 
attorney for plaintiff 
39 
[B-41] 
