GG : bin j 
7-3078 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
x 
FRIENDS OF THE EARTH, INC., : 
Plaintiff, : 
-v- : ANSWER 
JOSEPH A. CALIFANO , JR., individually : 77 Civ. 2225 (VLB) 
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. : 
FREDERICKSON , individually and as 
Director of the National Institutes of : 
Health, and THE NATIONAL INSTITUES OF 
HEALTH, : 
Defendants. : 
x 
Defendants, by their attorney Robert B. Fiske, 
Jr. , United States Attorney for the Southern District of New 
York answer the complaint herein as follows: 
ANSWER TO PLAINTIFF'S FIRST CLAIM 
1. Defendants admit the allegations contained in 
paragraphs 5 through 7, 15 and 17 through 23 of the complaint. 
2. Deny each and every allegation contained in 
paragraphs 2, 12, 13 and 34 through 37 of the complaint. 
3. Defendants neither admit nor deny the allega- 
tions of paragraphs 1 and 24 through 32 of the complaint, 
because these paragraphs recite conclusions of law rather 
than allegations of fact, to which no responsive pleading is 
required. Defendants respectfully refer the Court to the 
text of the statutes , regulations and guidelines cited by 
plaintiff, and cases decided thereunder for full statements 
of the applicable law. 
[B-45] 
