13 
they are removed. Additionally, all waste materials from 
the entire facility (including sewage) are sterilized before 
discard as a redundant safety measure. Therefore, before any 
harm could ensue, the recombinant DNA molecules would nave to 
escape the physical containment measures (an extremely unlikely 
possibility) and the vector-host system would have to multiply 
or secondarily transmit the DNA in nature (an almost incon- 
ceivable possibility; see EK2 specifications) and then cause 
some untoward event which the whole, intact virus has never 
been shown capable of inducing. 
Accordingly, plaintiff's attack upon the safety of 
the experiment to be performed at Fort Detrick is premised 
upon the totally false assumption that the host organism to 
be utilized can readily survive outside the laboratory, and 
is able to "live in people." Plaintiff further assumes that 
some dangerous organism may escape from the rigid physical 
containment required. Since both assumptions are false, 
plaintiff has failed to show that he or the environment will 
be irreparably injured by this experiment. 
III. Further Delay In The Experiment Will 
Deprive Scientists Of Important 
Information Concerning Recombinant 
DNA Molecules. 
As explained in the Nutter Affidavit, the experiment 
is designed to provide important and much needed information 
on the possibilities of recombinant DNA technology. Further 
delay in obtaining this knowledge will leave an unnecessary 
gap in scientific understanding of recombinant DNA technological 
possibilities . 
[Appendix C — 121] 
