- 9 - 
12. Plaintiff adopts as his own, and by reference incorporates, 
as grounds for the relief sought, the objections of the Attorney General 
of the State of New York to the Draft Environmental Impact Statement, 
as set forth in Appendix K 80-110 of the Environmental Impact Statement. 
13. Until the defendants comply with their stipulation that the 
Risk Assessment Studies will not go forward until there is an environmental 
impact statement — one addressed to those experiments — this Court should 
continue the stay in effect, or alternatively preliminarily enjoin those 
experiments . 
17 West Jefferson Street 
Suite 106 
Rockville, Maryland 20850 
Attorney for Plaintiff 
Ferdinand j. mack 
ATTORNEY AT LAW 
SUITE 106 
OLD TOWN CENTER 
17 WEST JEFFERSON 8T. 
ROCKVILLE MARYLAND 
80860 
CERTIFICATE OF SERVICE 
I hereby certify that the foregoing Supplemental Memorandum of 
Points and Authorities in Support of Motion for Preliminary Injunction 
and in Opposition to Vacation of Stay and the annexed affidavits of 
Dr. Stuart Newman and Dr. John C. Cobb were personally served upon 
the U.S. Attorney for the District of Columbia this 12th day of January, 
1978. 
[Appendix C — 133] 
301 270-2030 
