UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA 
FERDINAND J. MACK, JR., 
an infant 
Route 2 
Frederick, Maryland 21701 
BY AND THROUGH HIS MOTHER 
AND NEXT FRIEND, 
MILDRED A. MACK, 
Route 2 
Frederick, Maryland 21701, 
Plaintiff 
v. 
JOSEPH A. CALIFANO, JR., 
Secretary, 
United States Department of 
Health, Education and Welfare 
330 Independence Avenue, S.W. 
Washington , D . C . , 
and 
DR. DONALD S. FREDERICKSON 
Director 
National Institutes of Health 
9000 Rockville Pike 
Bethesda, Maryland, 
and 
JOHN E. NUTTER, 
Special Assistant to the 
Deputy Director 
Department of Allergy and 
Infectious Diseases 
National Institutes of Health 
9000 Rockville Pike 
Bethesda, Maryland, 
Defendants 
77- 09ic; 
Civil Action No. 
FILED 
MAY 3 1 WT 
JAMES L om t Clerk 
COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF 
1. Plaintiff is an infant, a citizen of the United 
States, and a resident of Frederick County, Maryland. Defendants 
are the Secretary, and employees, of the United States Department 
of Health, Education and Welfare, a branch of the Executive 
Department of the United States Government and are sued in their 
official capacities. Jurisdiction is founded upon 28 U.S.C. 
Il331 (Federal Question), 28 U.S.C. §2201-2202 (Declaratory 
[Appendix C — 35] 
