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UNITED STATES
ENERGY RESEARCH AND DEVELOPMENT ADMINISTRATION
WASHINGTON, D.C. 20545
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December 2, 1975
ot. US DOE ARCHIVES
326 U.S. ATOMIC ENERGY
Honorable Peter R. Taft
RG_.——s—sCOMMISSION
Land and Natural Resources Division
Collection Dos
Assistant Attorney General
ATTN: Floyd L. France, Chief,
' General Litigation Section
U. S. Department of Justice
Washington, D. C. 20530
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Folder #
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Dear Mr. Taft:
THE PEOPLE OF BIKINI, ET AL. V. SEAMANS, ET AL., Civil No. 75-348,
U.S.D.C., D. Hawaii (Fle: 90-1-4-1204) — ~C.
This ts in response to your October 20, 1975 request for a complete
litigation report on this action insofar as the activities of the
Energy Research and Development Administration (ERDA) are concerned.
The principal thrust of this report is to provide information which
may be used in the preparation of an answer to the amended complaint.
We understand that the answer is to be filed on December 12, 1975.
We are not including, at this time, any affidavit for use in opposing
‘the request for preliminary injunction (to be heard January 30, 1976)
because of the likelihood that plaintiffs may again change the exact
nature of their demand for relief. We will, of course, provide
appropriate affidavits in advance of the January 30 hearing.
Department of the Interior and ERDA staff members are currently
working on a joint presentation to be made to the Office of Manaaerent
and Budget regarding the question of funding for the proposed serial
radiological survey.
this matter.
We will keep you informed of the status of
”
Enclosure 1 to this letter is a paragraph-by-paragraph statement of
ERDA's position in response to the amended complaint.
Where another
defendant agency has a more direct concern, we have deferred to the
views of that agency, even though we may have no reason to doubt the
accuracy of the allegation.
Similarly, we have recommended denial
of several of the plaintiffs' allegations for lack of knowledse or
Information sufficient to form a belief as to the truth of the
allegation, even though we have no reason to doubt that the particular
allegations may be generally accurate.
Wherever we are aware of
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