UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA 
FERDINAND J. MACK, JR. , : 
an infant, 
Plaintiff : 
77 - 0916 
v. : Civil Action No. 
JOSEPH A. CALIFANO, JR., 
ET AL. , 
Defendants 
FILED 
MAY 3 1 19/7 
JAMES L PAVflr, Clerk 
AFFIDAVIT IN SUPPORT OF MOTION 
FOR TEMPORARY RESTRAINING ORDER 
1. I, Stephen Havas, am a physician, an Assistant in Medicine 
at Massachusetts General Hospital, an Instructor in Medicine at 
Harvard Medical School, and Board Certified in Internal Medicine. 
2. I have read and am familiar with a document entitled 
Proposed Experiments on the Biological Properties of Polyoma 
Recombinant DNA Cloned in Bacterial Cells, by Martin and Rowe 
(the "Protocol"), for the conduct of experiments in Building 550 
at Ft. Detrick, Maryland. 
3. These experiments involve the use of polyoma virus, 
which is known to cause cancer in mice and other rodents. The 
experiments also employ the bacterium, _E. coli, which lives on 
land and in water all over the earth, and in particular is a common 
[Appendix C — 59] 
