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Paragraph

ERDA's SUGGESTED RESPONSE AND/OR COMMENTS (Continued)

103

Deny.

104

Deny.

Need for study already denied.

ERDA could do it objectively.

if it were needed,

Plaintiffs’ refusal or

Inability to concede that objectivity cannot justify
retention of "independent" study group.
105

Conclusion of law which requires

no answer.

106

Conclusion of law which requires

no answer.

107

Conclusion of law which requires

no answer.

108

Conclusion of law which requires

no answer.

109

Conclusion of law which requires

no answer.

In view of the foregoing responses to the numbered allegations of the
complaint, ERDA denies each claim alleged in paragraphs 111 through 115,
and opposes the grant of any relief sought in the prayer for relief.

We

do, of course, stick by the agreements voluntarily made in discussions in
Honolulu on November 1, 1975, and will work with DO! on resolving the
question of funding the aerial survey.

DOE ARCHIVES

Enclosure 1

GO

Select target paragraph3