403569

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF HAWAII
:
c
RUST
THE
PEOPLE
OF BIKINI,
et al.,

US DOE tRchinrs

826 U.S. ATOMIC EN
ERGY
FAM

Plaintiffs,
Vs.

ROBERT C. SEAMANS, JR., et al.,
Defendants. -

Collertion_ Dos [deal Esier
Box

it, Joo

/326

Folder4*7 ikiws ~ mo ti our

NOTION FOR PRELIMINARY INJUNCTION
By this Motion Plaintifis request that this Court
grant prelininary injunctive relief pursuant to Rule 65,

F.R.C.P.

a
Factual szpport for the preliminary injunction

is found in the Verified Complaint and the afficevits which
are attached to this motion and incorporated herein bv
reference.

An incex to the affidavits, listing them by

author and subjecz matter, follows the signature page of

this motion.

BEST AVAILABLE COPY

On the basis of the facts set forth in the Verified
Complaint and in the affidavits attached, we respectfully
submit that permanent and irreparable injury is taking place
now and will concinve to take place unless this Court grants
this motion for preliminary injunction and orders preliminary
injunctive relie= 2s set forth below.

The Plainziffs hereby seek the following preliminary
injunctive relief:

DOE ARCHIVES
I.

LIMITATION OF =CCESS TO BIKINI ATOLL

The principval means of transportation within che

‘7

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