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PERDIN ANX> J. MACK 
ATTORNEY AT LAW 
SUITE 10« 
OLD TOWN CENTER 
17 WEST JEFFERSON ST. 
ROCKVILLE. MARYLAND 
COKBO 
"Defendants have not prepared a separate 
statement for the experiment at Ft. Detrick, .... 
the EIS which we have filed with the Court fully 
assesses the environmental impact of all 
recombinant DNA research conducted in 
accordance with the NIH Guidelines, and 
individual statements for each experiment 
are unnecessary and would be duplicative. " 
(Defendants' Memorandum in Opposition to 
Plaintiff's Motion for Preliminary Injunction, 
P. 5) 
4. Throughout the Government's opposition, perhaps 
unintentionally, runs the thread that to grant plaintiff the relief sought 
in this case would create havoc, because the ruling would be applicable 
to all DNA experiments. For example: 
"[T]here is absolutely no need for the 
preparation of a separate environmental 
impact statement for each and every 
recombinant DNA experiment which is 
conducted." (Defendants' Memo p. 2) 
"[l]ndividual statements for each experiment 
are unnecessary and would be duplicative." 
(Defendants' Memop. 5) 
”[T]here is no need whatsoever for NIH to 
engage in the useless analysis of individual 
factors in each geographic location where an 
experiment is conducted." (Defendants' Memo 
P. 10) 
This action is not directed at "each and every recombinant DNA 
experiment " which is conducted. Plaintiff's attack is only upon the 
Risk Assessment Studies, the purpose of which is to determine if a 
"real hazard"exists in DNA research; it is concerned only with the Risk 
Assessment Studies at Ft. Detrick. 
5. In arguing that the Risk Assessment Studies are covered by 
the environmental impact statement for the guidelines, it would appear 
that the defendants are attempting to hoist themselves up by their own 
301 270-2230 
[Appendix C — 126] 
