‘the taking of those steps can further irreparable injury to the

People of Bikini be prevented.
Some of the damage which has been done can never
be repaired.

Some people have been exposed to radiation,

needlessly, with probable adverse impact to their health
which cannot be remedied.

However, by this Court's use of

its broad equity power and its power to enforce the provisions
of NEPA, the Bikini Resettlement can be brought under control
and coordinated so that the People of Bikini can have the benefit
of rights protected under NEPA and so they can begin to
participate in planning for their futu

DATED:

Honolulu, Hawaii, ©/
s

O44,“7(ans

Respectfully subnitted,

GEORGE M. ALLEN
Micronesian Legal Services Corporat
Marshalls Office
P. O. Box 376
Majuro, Marshall Islands 96960
Telephone:
227

Cable Address:

py
BEST AVAILASLE co

Microlex

DANIEL H. MACHEEKIN

_ THEODORE R. MITCHELL
EDWARD C. KING
ANN E. ALLEN

Micronesian Legal Services Corporat
Central Office
P. O. Box 826
Saipan, Mariana Islands ¢6950
Telephone:
6228/6471/6472
Cable Address: MNicrolex
c

JONATHAN M. WEISGALL

a

POE

Covington & Burlingeos
888 - 16th Street, N. W.
Washington, D. C.
20006
Telephone:
202-452-6218
Telex:
89-593
Cable Address:
Covling

-16i

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