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Question
Stretch
Jerrel,
MoFo complaint. They did not bring in Deseret Victims.
III. CLASS ACTION ALLEGATIONS
A. Class Definition
174. The proposed Plaintiff class for purposes of all claims includes all veterans who
were involved in the Human Test Series (hereinafter the “Proposed Class Members”). The
proposed class does not include participants in Project 112/SHAD (“Shipboard and Hazard
Defense), a separate program directed by the U.S. Army Deseret Test Center. Project 112/SHAD
was conducted on ships and land to test the vulnerability of ships to chemical and biological
attacks, and, with respect to tests on land, to determine how biological and chemical weapons
would be affected by climate. Although members of the military were exposed to hazardous
biological and chemical substances during Project 112/SHAD, the principal purpose of the
program was not to test the effects of biological and chemical weapons upon human subjects, as
were the veterans involved in the Human Test Series.
Case4:09-cv-00037-CW Document180 Filed11/18/10 Page59 of 76
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