3 
lines, i. e., high and low life, apples and oranges, humans and 
other primates, etc.. Recombinant DNA research is expected to 
change all this. 
4. This scientific tool is expected to make it possible, 
for example, to take genes from cattle with certain desirable 
traits and combine them with the genes of other cattle, and to 
produce in a single generation cattle having the traits of both. 
As in the proposed experiments at Ft. Detrick, barriers between 
living organisms in nature that could never combine in re- 
production are skirted by the laboratory mixing of genes of 
the two. The Ft. Detrick experiments will involve an attempt 
to combine genes from viruses that are known to cause cancer in 
mice (polyoma) with a microorganism that is known to be pathogenic 
in man (E. coli ) , and which lives in the intestines of man and 
all other warm blooded animals. (Protocol, Exhibit No. 1) 
In nature such a combination could not occur. These new 
organisms are to be created in laboratories as secure as can 
be made, as indeed they must; for if they were to be released 
into the environment, the organisms, which are alive and will 
continue to grow, may cause disease and maladies never before 
experienced by man, and may take a generation or more to make 
themselves known. Little can be added to the potential hazards 
to plaintiff, (and all who live) as described in the three (3) 
affidavits filed in support of this Motion. While no one, 
including the defendants, can predict with certainty what will 
happen if the organisms are released into the environment, 
widespread death and disease are distinct possibilities. 
[Appendix C — 47] 
