IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA 
FERDINAND J. MACK, JR. 
an infant 
Plaintiff 
v 
JOSEPH A. CALIFANO, JR. et al 
Defendants 
JAMES F. DAVEY, Clerk 
SUPPLEMENTAL AFFIDAVIT OF STUART NEWMAN IN SUPPORT 
OF MOTION FORA PRELIMINARY INJUNCTION 
Stuart Newman, being first duly sworn, states as follows: 
I have read and am familiar with the document entitled IMUA-18, 
and the Statement of Understanding and Agreement dated May 23, 1977. 
The opinions expressed by me in my previous affidavit in this case are 
Civil Action No. 7J^d916 
' F I L E D 
FEB -6 1978 
unchanged. My criticism of the experiment remains that if the organisms 
involved in the experiment escape into the environment there would be no 
barrier between the organisms and the persons living in the populated area 
where the experiments are to take place. 
Stuart Newman 
FERDINAND J. MACK 
ATTORNEY AT LAW 
SUITE 106 
OI-D TOWN CENTER 
17 WEST JEFFERSON ST. 
ROCKVILLE MARYLAND 
301 27t>-£230 
STATE OF NEW YORK 
COUNTY OF 
) 
) ss 
) 
I hereby certify that before me, a notary public in and for the State 
and County aforesaid, personally appeared Stuart Newman who acknowledged 
the foregoing Supplemental Affidavit to be his voluntary act and deed. 
WITNESS my hand and notarial seal this S Acf day of , 1978. 
Notary Public 
My Commission expires 
3 -2 c - IS 
M/ t 
SHAP.VN DESROCHES 
5;^tc of New York 
i.i A County 
~i March 30, 
,,.27 
[Appendix C — 217] 
