IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA 
FERDINAND J. MACE 
ATTORNEY AT LAW 
SUITE ioe 
OLD TOWN CENTER 
17 WEST JEFFERSON ST. 
ROCKVILLE. MARYLAND 
ROMO 
FERDINAND J. MACK, JR. 
an infant 
Plaintiff 
v 
JOSEPH A. CALIFANO, JR. et al 
Defendants 
Civil Action No. 77-0916 
/ 
FILED 
FEB" 6 1278 
JAMES F. DAVEY, Cierk 
SUPPLEMENTAL MEMORANDUM OF PLAINTIFF 
This memorandum is directed to the two matters that counsel for 
plaintiff requested additional time to address. 
First is the representation of counsel for the intervenor, made in 
open court, that the Risk Assessment Studies, the subject of this action, 
have already been run in Europe "with no adverse consequences. " The 
Government has furnished counsel for plaintiff with that portion of the 
transcript of proceeding upon which counsel for the intervenor claims 
he based that representation to the court. At no point in the transcript 
is the statement of counsel for the intervenor that there have been 
"no adverse consequences" confirmed. It is, as counsel for the 
intervenor advised counsel for plaintiff following the last court hearing, 
true only that no one has heard one way or the other as to whether there 
have been any adverse consequences from the European Risk Assessment 
Studies . 
The second matter as to which counsel for plaintiff wished to address 
the court was the question of whether the particular organisms which 
were to be utilized in the Risk Assessment Studies were in fact considered 
301 279-2230 
[Appendix C — 185 ] 
