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