3 
organism which has been similarly cleaved. The splicing can be, 
sealed with another enzyme called DNA ligase, and the composite 
DNA can then be inserted into a host organism where the foreign 
genetic information may be expressed and reproduced. 
7. Using recombinant DNA techniques, genetic 
information from any living organism can be implanted into 
bacteria. Also, genetic information from lower organisms such 
as viruses can be inserted into and expressed in higher 
organisms. This rapid exchange of genetic information across 
wide species barriers, as can occur in recombinant DNA research, 
is rare in nature and limited by reproductive barriers. 
8 . The recombinant DNA technique is a powerful new 
scientific tool which, while providing speed and convenience in 
the conduct of genetic research, permits hitherto impossible 
genetic manipulations with little control over the outcome of 
these manipulations. It is now possible artifically to 
manipulate the course of evolution within a short period of 
time using a technique different and far more extensive than that 
of traditional breeding techniques. Recombinant DNA research 
raises unprecedented hazards to humans and the environment 
compounded by the inability to predict the outcome of the 
research, and the ability of a dangerous organism to replicate, 
maintain and establish itself in the ecosphere. 
9. Escherichia coli (E^ coli ) , the host organism 
most widely used in recombinant DNA research, is a ubiquitous 
organism which resides in the human gut, in all warm blooded 
species, economically important and otherwise, in water supplies, 
and other places. It has pathogenic, or disease causing 
capabilities. E^ coli is frequently associated with upper 
urinary tract infections in humans. It is capable of trans- 
ferring the foreign DNA implanted in it to other microorganisms, 
which could result in the formation of a novel pathogen. 
10. Defendant, Nutter, acting at the instructions of 
defendants Califano and Frederickson, and using Federal funds 
provided by defendant Califano, is causing Building 550 at Ft. 
Detrick, to be renovated, and defendants are presently in the 
[Appendix C — 37] 
