wd

based on a-:Ziant's personal knowledge, number not more than three
families and 20 total persons, agree to assume all liability for
any and all future health care, shelter and nutritional needs
of such persons because any present willingness to return of
such persc~s has been abetted by the statements of representatives
of ERDA.
3.

waither affiant nor most of the People of Bikini can

read or uncarstand English.

Nevertheless the Bikini People are

well-educated and virtually all adults read Marshallese.
7.

Unless defendants are required to supply information

to plaintizis and the persons they represent in Marshallese, they
will be unzdle to participate meaningfully in decisions relating
to their Pasettlement and they will necessarily be permanently and
izrevarabl:; injured thereby.

8.

-2fendants have spent hundreds of thousands, if not

millions, cf dollars toward the Bikini Resettlement without any
attempt whacever to comply with the National Environmental Protec~
tion Act anid have, in the process disseminated misinformation and
lies and wzsted countless sums of money.

Unless they are enjoined

from further agency spending and contract spending on the Bikini
Resettlemen: except with Court approval, further illegal conduct
and irreparable injury is inevitable.
9.

Communication with the Bikini People by representatives

of ERDA has created a decade of heartbreak without any productive
value whatever.

Information communicated by ERDA representatives

on technic: matters has frequently been simplistic lies or halftruths cal-::lated to serve the interests of ERDA or its predecessor,

tne United szates Atomic Energy Commission, not the Bikini People.
Izreparab.

aarm has already been caused by this type of communica-

tion and =-_:ss it is enjoined except for such communication as
has speciz: =: court approval or consent by plaintiffs, further
irreparabls Aarm will be inevitable.
13.

v-less defendants are immediately ordered to commence

Dr2paration

2f a Draft Environmental

30521bb

Impact Statement in both

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:

Select target paragraph3