JNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA 
FERDINAND J. MACK, JR. , 
an infant. 
Plaintiff 
77 - 0916 
v. Civil Action No. 
JOSEPH A. CALIFA NO, JR. , : 
ET AL. , 
Defendants : 
AFFIDAVIT IN SUPPORT OF MOTION JAMES. E. DAV.EY, Clerk 
FOB TEMPORARY RESTRAINING ORDER 
1. I, Ruth Hubbard, am a Ph. D. , a research associate and 
lecturer at Harvard University, and have been a Professor of 
Biology at Harvard University for 3 years. 
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 
inhabitant of the large intestine of all warm blooded animals, 
including humans. Some strains of E. coli are known to cause 
diarrhea, urinary tract infections and other diseases. In the 
experiments the DNA (i.e. , all the genetic information, including 
E I L E D 
MAY 3 1 m 
[Appendix C — 65] 
