ERDA's SUGGESTED RESPONSE AND/OR COMMENTS

Paragraph

Deny present existence of NEPA obligations, consistently

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with the position expressed at the informal conference with

the Court on November 1.

ERDA defers to the Department of

the Interior (DO1) with respect to obligations under the
Trusteeship Agreement.

ERDA denies NEPA obligations, but admits jurisdiction and
venue.
Deny, for lack of knowledge.

3
4, 5, 6

The complaint has no paragraphs 4, 5, and 6.

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US DOE ARCH TS

Ubjection should probably be made to maintenance of the suit

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Our practical concern is that the

in fact, run counter to the true desires of

some off the Bikinians.
Admit.

Admit.

We note, however, that there appears to be no basis

for naming Stanley as a defendant.

He has no responsibility

for Bikini-related activities, except to provide logistic
support as directed.

See also our response to Interrogatory

No. 1, previously furnished.

ERDA defers to Department of Defense (DOD) (though we note

the obvious, that Schlesinger is no longer Secretary).
WW, 12, 13, 14

ERDA defers to DOI.

63
Enclosure \

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