UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA 
FERDINAND J. MACK, JR. 
An Infant 
Plaintiff 
Civil Action 77-0916 
v 
FILED 
DEC- g $77 
JOSEPH A. CALIFANO, JR. et al. 
Defendants 
JAMES F. DAVEY, Clerk 
RESPONSE OF PLAINTIFF TO DEFENDANTS' MOTION FOR VACATION OF STAY 
Ferdinand J. Mack, Jr. , an infant, plaintiff, for answer to the request 
contained in the defendants' "Notice of Filing" that the stay of this Court 
entered herein July 18, 1977, be vacated by the Court, respectfully 
represents to the Court as follows: 
# 
1. This is an action having as its primary purpose the prohibition 
of experiments termed "risk assessment studies" which defendants seek 
to conduct at Ft. Detrick, Maryland. The experiments are technically 
entitled "Proposed Experiments on the Biological Properties of Polyoma 
Recombinant DNA Cloned in Bacterial Cells" (Complaint, page 4). 
2. On July 18, 1977, at the request of the defendants, a stay 
was entered into in the form of a stipulation which was signed by counsel 
for plaintiff and defendants, and approved by the Court. That stipulation 
provided in pertinent part: 
FERDINAND J. MACE 
ATTORNEY AT LAW 
OLD TOWN C EN T ER 
17 WEST JEFYERSOX ST. 
ROCKVILLE MARYLAND 
"Defendants shall give to counsel for 
plaintiff thirty (30) days notice of any 
experiment to be conducted at Ft. Detrick, 
Maryland, on the biological properties of 
polyoma recombinant DNA cloned in bacterial 
cells, and no such experiments shall be 
conducted at Ft. Detrick prior to the finalization 
of an environmental impact statement. " 
SOI 276-2230 
[Appendix C — 97] 
