8 
plaintiff, the environment in which he lives, and his fellow 
residents of Frederick County, Maryland, if not the entire United 
States, will suffer permanent and irreparable injury for which 
there is no adequate remedy at law. 
WHEREFORE, plaintiff demands: 
1. That this Court enter a judgment declaring that 
the actions of defendants taken in connection with the experiments 
in Recombinant DNA Research to be performed at Ft. Detrick, 
Maryland, are unlawful; 
2. That the defendants be enjoined preliminary and 
permanently, from conducting experiments at Ft. Detrick, Maryland, 
on the Biological Properties of Polyoma Recombinant DNA Cloned 
in Bacterial Cells; 
3. That the defendants be enjoined, preliminary and 
permanently, from entering into or permitting performance of 
contracts for the construction or renovation of facilities to 
be used for the conduct of Recombinant DNA Research at Ft. Detrick, 
Maryland; 
4. That the defendants be enjoined, preliminary and 
permanently, from constructing or renovating facilities at Ft. 
Detrick, Maryland to be used for the conduct of Recombinant DNA 
Research. 
5. That this Court enter a judgment declaring that 
the defendants are required by ll02(2)(C) of NEPA to prepare 
and circulate for comment a final environmental impact statement 
[Appendix C — 42] 
