GG : braj 
7-307S 
28. Defendants deny the allegations of paragraphs 
74, 75 and 76 of the complaint except admit that the Guide- 
lines were published at page 27902 of 41 Federal Register on 
July 7, 1976 to which the Court is respectfully referred for 
a complete and accurate statement of the contents thereof. 
29. Defendants deny the allegations of paragraph 
82 of the complaint except admit that defendants have 
implemented and continue to apply the Recombinant DNA 
Research Guidelines as though they have full force and 
effect . 
ANSWER TO PLAINTIFF'S FIFTH CLAIM 
30. Defendants answer paragraph 85 by repeating 
defendants' responses to paragraphs 1 through 40 and 55 
through 84 of the complaint. 
31. Defendants deny each and every allegation in 
paragraphs 86 and 87 of the complaint. 
ANSWER TO PLAINTIFF'S SIXTH CLAIM 
32. Defendants answer paragraph 88 by repeating 
defendants' responses to paragraphs 1 through 40 and 55 
through 87 of the complaint. 
33. Defendants admit the allegations contained in 
paragraphs 89 and 90 of the complaint. 
34. Defendants deny each and every allegation 
contained in paragraphs 92 through 99 of the complaint. 
35 . Defendants deny each and every allegation 
contained in paragraph 91 of the complaint; and allege that 
pursuant to EEW Reorganization Plan No. 3 all functions of 
the Surgeon General were transferred to the Secretary of 
HEW, that certain of the aforementioned f mictions were 
delegated to the Assistant Secretary for Health, and that 
certain functions were in turn redelegated to the Director , 
UTH 
-5- 
[B-50] 
