GG : bmj 
■'-3078 
21. Defendants admit the allegations of paragraph 
46 of the complaint except allege that HEW's proposed 
legislation permits the Secretary of HEW to make such 
modification of the Guidelines as he deems necessary. 
22. Defendants lack knowledge or information 
sufficient to form a belief as to the truth or falsity of 
the allegations of paragraph 50 of the complaint. 
ANSWER TO PLAINTIFF'S FOURTH CLAIM 
23. Defendants answer paragraph 55 by repeating 
defendants' responses to paragraphs 1 through 37 of the 
complaint. 
24. Defendants admit the allegations contained 
in paragraphs 60 through 66, 71, 72 and 77 of the complaint. 
25. Defendants deny each and every allegation 
contained in paragraphs 67 through 70, 78 through 84 of 
the complaint. 
26. Defendants neither admit nor deny the 
allegations of paragraphs 56 through 59 of the complaint 
because those paragraphs contain only allegations 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 guide- 
lines cited by plaintiff, and cases decided thereunder for 
full statements of the applicable law. 
27. Defendants admit the allegations of paragraph 
73 of the complaint and allege that notice was published in 
the Federal Register on January 14, 1976 (41 F.R. 2105) 
stating that copies of the proposed guidelines were avail- 
able from NXH on request. 
-4- 
[B-49] 
