lne7
rlsintiris
vill grevail on their claims.
The defendants have
aamizviediy fatles t: comply with an applicable federal statute
aca nave pleinl: izncred the judicially enforceable terms of the
-.
The Publis Interest -~ The public interest in this
e252 25 unquestionably on the side of the plaintiffs.
There is
no public interest in favor of delaying the return of the Bikinians,
exposing them tc sangers of excessive radiation, or locating further
us
locations.
Moreover,
the true public interest
lies in a comprehensive and profound study of the environmental
vne resettlement program before further steps
submit that based on the traditional
“7-2 relief, the Court should preliminarily
“rtnar
orefe2t
2onstruction work on the Bikini resettlement
and order immediate preparation of an environmental impact
TE
All Tefendants Are Subject To The
infjunziive Zelie? Requested By Plaintiffs
a
Feierel Agencies - NEPA provides that "all agencies of the
Faeder2ei Government
receort
on eriarcs2ls
sigrirtizanvly
shall.
.
.
(C)
include in every recommendation or
for legislation and other major Federal actions
2ife2ting the quality of the human environment, a
ilei stavetenit cy the responsible official.
.
.
."
42 U.S.C.
aan aN
2n2 TE?
~.lTiegeenoy
aiselines orovide tne following ampiification for
gopiis2ts sucon as tais one.
cone agency
directly
(1) directly sponsors
involved in an action
licenses, or permits, or
:
Seg7 14d
(2)
is
atea to