JURISDICTION AND VENUE
2,
The Court has jurisdiction of this action under the
national Environmental Policy Act,
42 U.S.C.
§§4321 et seg.;
the
Trusteeshio Agreement for the Former Japanese Mandated Islands,
ol Scat.
3301, T.I.A.S. No.
and 28 U.S.C.
§2201.
1665; 28 U.S.C.
§1331;
28 U.S.C.
§1361;
The matter in controversy exceeds the value
or ten thousand dollars,
exclusive of interest and costs.
is properly laid in in this district under 28 U.S.C.
Venue
§1391.
PARTIES
3.
All of us,
the Plaintiffs,
evritory of the Pacific Islands
are citizens of the Trust
(also known as Micronesia)
are residents of the Marshall Islands District.
furthermore,
and
All of us,
were residents of Bikini Atoll at the time of that
atoll's evacuation in 1946 prior to Operation Crossroads, the first
of the American atomic tests in the Pacific, or are direct descendants
of such residents.
a.
Plaintiff Bikini Council is the governing body of the
Bikini community.
Membership in the Council is determined in
accordance with our custom and tradition.
b.
Plaintiff Lore Kessibuki is a citizen of the Trust
Territory of the Pacific Islands, a member of the Bikini community,
Oo
fu
nd
is Magistrate of our community.
executive official of our community.
born on Bikini Atoll,
As such,
he is the highest
Plaintiff Kessibuki was
in the Marshall Islands,
in 1910.
He was
a residenc of Bikini Atoll until his relocation therefrom in 1946
prior to the Operation Crossroads nuclear tests.
on Kili Island in the Marshall Islands.
He now lives