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, 
Civil 
Action No. 
77 - 0916 
E J L E D 
may 3 * te/7 
JAMES h msft Clerk 
Defendants 
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF 
MOTION FOR TEMPORARY RESTRAINING ORDER 
AND PRELIMINARY INJUNCTION 
1. This Motion does not seek to restrain activity in 
the field of gene research. It asks only that before plaintiff 
[Appendix C — 45] 
