GG : bmj 
7-3078 
conducted in accordance with the Recombinant DNA Research 
Guidelines and is of scientific merit, and only to the 
extent that monies are available for such funding. 
ANSWER TO PLAINTIFF'S SECOND CLAIM 
14. Defendants answer paragraph 38 by repeating 
defendants' responses to paragraphs 1 through 37 of the 
complaint. 
15. Defendants deny each and every allegation 
contained in paragraphs 39 and 40 of the complaint. 
A NSWER TO PLAINTIFF’S THIRD CLAIM 
16. Defendants answer paragraph 41 by repeating 
defendants' responses to paragraphs 1 through 40 of the 
complaint. 
17. Defendants admit the allegations contained in 
paragraphs 42 through 44 of the complaint. 
18. Defendants deny each and every allegation 
contained in paragraphs 49 and 51 through 54 of the com- 
plaint. 
19 . Defendants neither admit nor deny the 
allegations contained in paragraphs 47 and 48 of the com- 
plaint since they contain only allegations of law 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 to the cases decided 
thereunder for full statements of the applicable law. 
20. Defendants admit the allegations of paragraph 
45 of the complaint except allege that the Department of 
Health, Education and Welfare's legislative proposal did not 
incorporate all the recommendations of the Interagency 
Committee on Recombinant DNA Research. 
-3- 
[B— 48] 
