lne7

rlsintiris

vill grevail on their claims.

The defendants have

aamizviediy fatles t: comply with an applicable federal statute
aca nave pleinl: izncred the judicially enforceable terms of the

-.

The Publis Interest -~ The public interest in this

e252 25 unquestionably on the side of the plaintiffs.

There is

no public interest in favor of delaying the return of the Bikinians,
exposing them tc sangers of excessive radiation, or locating further
us

locations.

Moreover,

the true public interest

lies in a comprehensive and profound study of the environmental

vne resettlement program before further steps

submit that based on the traditional

“7-2 relief, the Court should preliminarily
“rtnar
orefe2t

2onstruction work on the Bikini resettlement

and order immediate preparation of an environmental impact

TE
All Tefendants Are Subject To The
infjunziive Zelie? Requested By Plaintiffs

a

Feierel Agencies - NEPA provides that "all agencies of the

Faeder2ei Government
receort

on eriarcs2ls

sigrirtizanvly

shall.

.

.

(C)

include in every recommendation or

for legislation and other major Federal actions

2ife2ting the quality of the human environment, a

ilei stavetenit cy the responsible official.

.

.

."

42 U.S.C.

aan aN
2n2 TE?
~.lTiegeenoy

aiselines orovide tne following ampiification for
gopiis2ts sucon as tais one.
cone agency
directly

(1) directly sponsors

involved in an action

licenses, or permits, or
:

Seg7 14d

(2)

is

atea to

Select target paragraph3