-nZ UALS action pursuant to Rule 23 of the Federal
teecure, on behalf of ourselves and all others
similariy situated,
including all living persons who were Presidents
TD Sfiini Atoll srior to the 1946 evacuation and all living
hesiennants
cr such cersons.*
The members of the class on behalf
22 Vnoim we Dring this action are so numerous as to make it impractical
to tring tnem all before the Court.
There are common questions of
2 Ta2t, and cur claims are typical of the claims of the
35.
cn
We will adequately and fairly protect the interests of
2128s.
cefendants have acted,
and refused to act, on grounds
generally arciicadle to the entire class, thereby making appropriate
Tingl
aeclearsatory and injunctive relief with respect to the class
2s 2
wnole
SETenca2ncs
3.
DeFendent Robert C.
Seamans, Jr., is Administrator of the
vnivei States Energy Zesearch and Development Administration (ERDA),
whien, as of January 19, 1975, assumed all functions of the United
Sozv2s Atomic Energy Commission relevant herein.
As Administrator of
Goon information and relief, he is a resident of Washington, D.C.
5.
Defendant william J.
Stanley is Director of the Pacific
ery OFPice of the United States Energy Research and
Develioment Administretion.
As Director of the Pacific Area
tine members o27 our Bikini community were absent from Bikini
<tvLl 25 the time of the 1946 evacuation for reasons of employment,
tinizelization, or education.
ZT? te within vne class.
We consider them and their descendants