the taking of those steps can further irreparable injury to the People of Bikini be prevented. Some of the damage which has been done can never be repaired. Some people have been exposed to radiation, needlessly, with probable adverse impact to their health which cannot be remedied. However, by this Court's use of its broad equity power and its power to enforce the provisions of NEPA, the Bikini Resettlement can be brought under control and coordinated so that the People of Bikini can have the benefit of rights protected under NEPA and so they can begin to participate in planning for their futu DATED: Honolulu, Hawaii, Respectfully submitted, GEORGE M. ALLEN Micronesian Legal Services Corporatio Marshalls Office P. O. Box 376 Majuro, Marshall Islands Telephone: 227 Cable Address: 96960 Microlex DANIEL H. MACMEEKIN THEODORE R. MITCHELL EDWARD C. KING ANN E. ALLEN Micronesian Legal Services Corporatic Central Office P. O. Box 826 Saipan, Mariana Islands 96950 Telephone: 6228/6471/6472 Cable Address: Microlex JONATHAN M. WEISGALL Covington & Burling 888 - 16th Street, N. W. Washington, D. C. 20006 Telephone: 202-452-6218 Telex: 89-593 Cable Address: Covling -16- 9232080