ra

external gamma rediation, for substantial periods of time.
As shown by his affidavit,

and

his family are among those who have been exposed to high

radiation on Bikini Island over substantial time.

Meanwhile,

for reasons made clear in his affidavit, he and others

.. ——

wr

similarly situated, have experienced a total loss of confidence in health care monitoring offered first by AEC and
now by ERDA, under the direction of Dr. Robert Conard.

Dr.

Conard is a member of the staff of the Brookhaven National
Laboratory at Upton, L.I., New York.

Brookhaven was formerly

an AEC institution and is now associated with AEC's successor
agency,

ERDA.

Clearly

a

and others similarly

situated are entitled to immediate examination of the type
prayed for in the Verified Complaint.

It is equally clear

that whatever Dr. Conard's credentials may be,
and others similarly situated have no confidence in his

concern for their wellbeing.

In order that the Bikini

People may have confidence in the results of whatever evaluation
is made of those who have been placed at risk,

the evaluation

must be made by scientific personnel independent of either

4=C or ERDA as to whose selection the People of Bikini have
had some meaningful role.
This Court should order that scientific evaluation
of the type oraved for in the Verified Complaint be made
immediately available to

and his family and

ail of the persons who now reside on Bikini Island and to all
cog

th‘gx.

persons wno have been on Bikini Island for substantial

5052016

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PRIVACY ACT iircRiat SMC 2

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