UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA 
FERDINAND J. MACK, JR., 
an infant, 
Plaintiff 
v. 
JOSEPH A. CALIFANO, JR. 
ET AL. , 
Defendants 
AFFIDAVIT IN SUPPORT OF MOTION 
FOR TEMPORARY RESTRAINING ORDER 
1. I, Stuart Newman, Ph.D. , am an Assistant Professor 
of Biological Sciences at the State University of New York 
at Albany, and have held this position for the past two 
years. 
2 . I have read and am familiar with a document en- 
titled Proposed Experiments on the Biological Properties 
of Polyoma Recombinant DNA Cloned in Bacteria Cells, by 
M. A. Martin and W.P. Rowe (the "Protocol") , for the conduct 
of experiments in Building 550 at Ft. Detrick, Maryland. 
3. It is proposed by the investigators to manufacture 
novel organisms in which bacteria (E- coli ) closely related 
to a strain known to colonize the human digestive, urinary, 
and respiratory tracts will carry and reproduce the genetic 
information of a virus (polyoma) known to cause cancer in 
certain species of mammal. These bacteria and their resi- 
dent plasmids or bacteriophages containing the cancer 
virus genes will then be introduced by various routes into 
mice and mouse tissue culture cells. Finally, evidence of 
productive virus infection in the animals or cells will 
be assayed. 
[Appendix C — 227] 
Civil Action No 
