For approximately 30 months affiant, together with his
wife and seven chiidren lived in the interior of Bikini Island
at the place marked in the aerial photograph attached hereto
with a red "x" in Janai Weto, where external gamma radiation is
between 65 and 75 microroentgens per hour.
Affiant and his family consumed well water and ate locally

available foods as well as imported foods.
Affiant and his family consumed bananas, potatoes, papayas,
pandanus, coconut, and fish, all from Bikini Island.
Dr. Conard, when he made studies at Bikini in 1974, took
urine samples from affiant and his wife, but not from any of their
children.
Aside from the urine samples, no other tests were administered to affiant or his family.
Affiant now knows that he and his family, like others

who have lived or are living at Bikini, has been Placed at risk
by exposure to radiation and that to understand the extent of exposure and, if necessary treat results of that exposure, extensive
examination will be necessary.
Affiant, as a trained and experienced Health Aide, knows
that he and his family require immediate and extensive medical
examination and possible treatment.
Dr. Conard knew, when urine samples were taken from
affiant and his wife, that they were living in the interior of
Bikini Island.
By that time

(late 1974) Dr. Conard reasonably must have

xnown of the probability of extremely high radiation risk to affiant

and his family.
Nevertheless neither Dr. Conard nor any other ERDA or
SZC shysician furnished affiant or his family with appropriate
examination or care.
Affiant has no confidence in Dr. Conard or other ERDASEC health care personnel.

Affiant believes he and his family

a
ang
others who have been placed at risk on Bikini Island should

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