GG : bmj 
7-3078 
4. Defendants lack knowledge or information 
sufficient to form a belief as to the truth or falsity of 
the allegations contained in paragraph 3 of the complaint. 
5. Defendants admit the allegations of paragraph 
4 of the complaint except allege that Dr. James F. Dickson 
was Acting Assistant Secretary for Health at the time the 
complaint was filed and is now Deputy Assistant Secretary 
for Health. 
6. Defendants admit the allegations of paragraph 
8 of the complaint except lack knowledge or information 
sufficient to form a belief as to truth or falsity of the 
the allegation that the rapid exchange of genetic informa- 
tion across wide species barriers, as can occur in 
recombinant DNA research, is rare in nature and limited by 
reproductive barriers. 
7. Defendants deny the allegation of paragraph 9 
of the complaint except admit that the recombinant DNA 
technique is a powerful new scientific tool in the conduct 
of genetic research. 
8. Defendants deny the allegations of paragraph 
10 of the complaint except admit that Escherichia coll (E. 
Coli) K-12 is a host organism frequently used in recombinant 
DNA research. 
9. Defendants deny the allegations of paragraph 
11 of the complaint, except admit that it has been suggested 
by members of the scientific community that recombinant DNA 
research may yield, among other benefits, increased knowledge 
of basic biological processes, an increased understanding of 
some diseases, improved food production, synthesis of 
proteins such as insulin and other substances of medical or 
industrial application, and cures for certain forms of 
cancer. 
- 2 - 
[B-46] 
