APPIDAVIT
TRUST TERRITORY OF THE
PACIFIC ISLANDS

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‘IARSHALL ISLANDS DISTRICT

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being duly sworn, states:
1.

As shown by the Verified Complaint, the United States

Energy Research and Development Administration (ERDA) has stated

return to Bixini Atoll, is, under certain extreme conditions,
acceptable Zor the People of Bikini.

2.

Neans of transportation, consisting of field trip ships

or the Trust Territory, are presently available and in operation
by which People of Bikini, or others, such as Contract workers,

might in fact travel to and live at Bikini Atoll.
3.

Notwithstanding ERDA's preliminary 1975 radiation find-

ings and recommendation, a completa radiological survey may show
all or part of Bikini Atoll, particularly Bikini Island, to be
unsafe or unacceptably risky for long-term or permanent habitation on any practical basis, in which case any persons who move
there may have to be again relocated, as may, in fact the persons

pe

oresently residing on Bikini Island.

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Uniess this Court enjoins defendants from permitting

movement of ctarsons to Bikini Atoll, permanent and irreparable
Zamage to t..-3e persons and to the Bikini People as a whole will
result.
3.

2 itwithstanding this request for Preliminary Tnjunctio:

certain persons, particularly elderly people, may wish to return
to Bikini.

‘fF after explanation of the risks associated with

sucn return they continue to wish to do so, they should be per~

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