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Zeder,

Interior,
in

the

Autnorizty
$2laly

Prom the

and

chain

by
of

other persons,
command of the

exercised by him as

Government

of the

including
Department

of the

High Commissioner is

United States

and

is

derived

an exercise

t2 Uns authority of the United States in the Trust Territory.

Defendant

vonnston officially resides on Saipan, in the Mariana Islands, part
or tne Trust Territory.
2“.

Defendant Oscar DeBrum is District Administrator of the

varsnall Islands District of the Trust Territory of the Pacific
Tslanas.

As District Administrator, defendant DeBrum is the principal

executive officiel in the government of the Marshall Islands district.
Derentent DeBrum was appointed to his position by the High Commissioner,
23

sucject to the supervision and direction of, and control by, the
QO

mmissioner,

cmmissioner.

and serves at the pleasure of the High

Defendant DeBrum is a citizen of the Trust

Territory and a resident of Majuro Atoll in the Marshall Islands
District of the Trust Territory.
15.
Scazves.

Defendant Gerald R.

Ford is the President of the United

As President, defendant Ford is successor to former

President Lyndon B. Johnson, who ordered the commencement of the
Bikini resettlement program.

Defendant Ford is the only federal

oPlicial with executive authority over all government agencies
tnvolved in the Bikini resettlement program.

In addition, defendant

Ford has constitutional responsibility for the faithful execution
of tne laws and treaties of the United States, including the
Trusteeshin Agreement for the Former Japanese Mandated Islands.

mssident Ford cfficially resides in Washington, D.C.

STATEMENT OF THE CASE

16,
Ttlenis,

Bikini Atoll is located in the Ralik Chain of the Marshall
norch of the Equator, in the west-central part of the

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