APPIDAVIT TRUST TERRITORY OF THE PACIFIC ISLANDS ) ) ‘IARSHALL ISLANDS DISTRICT ) ) ) ) ss 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. . 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~ 5052109 | PRIVACY ACT MATERIAL REMOVED