-nZ UALS action pursuant to Rule 23 of the Federal teecure, on behalf of ourselves and all others similariy situated, including all living persons who were Presidents TD Sfiini Atoll srior to the 1946 evacuation and all living hesiennants cr such cersons.* The members of the class on behalf 22 Vnoim we Dring this action are so numerous as to make it impractical to tring tnem all before the Court. There are common questions of 2 Ta2t, and cur claims are typical of the claims of the 35. cn We will adequately and fairly protect the interests of 2128s. cefendants have acted, and refused to act, on grounds generally arciicadle to the entire class, thereby making appropriate Tingl aeclearsatory and injunctive relief with respect to the class 2s 2 wnole SETenca2ncs 3. DeFendent Robert C. Seamans, Jr., is Administrator of the vnivei States Energy Zesearch and Development Administration (ERDA), whien, as of January 19, 1975, assumed all functions of the United Sozv2s Atomic Energy Commission relevant herein. As Administrator of Goon information and relief, he is a resident of Washington, D.C. 5. Defendant william J. Stanley is Director of the Pacific ery OFPice of the United States Energy Research and Develioment Administretion. As Director of the Pacific Area tine members o27 our Bikini community were absent from Bikini <tvLl 25 the time of the 1946 evacuation for reasons of employment, tinizelization, or education. ZT? te within vne class. We consider them and their descendants