external gamma radiation, for substantial periods of time.
As shown by his affidavit,

and

his family are anong those who have been exposed to high
radiation on Bikini Island over substantial time.

Meanwhile,

for reasons nade clear in his affidavit, he and others
sinilarly situated, have experienced a total loss of confidence in health care monitoring offered first by AEC and
now by ERDA, under the direction of Dr. Robert Conard.

Dr.

Conard is a nenber of the staff of the Brookhaven National
Laboratory at Upton, L.I., New York.

Brookhaven was formerly

an AEC institution and is now associated with AEC's successor
agency, ERDA.

.

Clearly

and others similarly

situated are entitled to immediate examination of the type
praved for in the Verified Complaint.
'

that whatever Dr.

It is equally clear

Conard's credentials may be,

and others similarly situated have no confidence in his
concern for their wellbeing.

In order. that the Bikini

"People may have confidence in the results of whatever evaluation
is made of those who have been placed at risk, the evaluation
Gust be made by scientific personnel independent of either
AEC or ERDA as to whose selection the People of Bikini have
had some meaningful role. BEST AVAILABLE COPY
This Court should order that scientific evaluation
of the type prayed for in the Verified Complaint be made
immediately available to

and his family and

all of the persons who now reside on Bikini Island and to all
other persons who have been on Bikini Island for substantial
DOE ARCHIVES

PRIVACY ACT MATERIAL REMOVED
2t

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