ERDA's SUGGESTED RESPONSE AND/OR COMMENTS
Paragraph
Deny present existence of NEPA obligations, consistently
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with the position expressed at the informal conference with
the Court on November 1.
ERDA defers to the Department of
the Interior (DO1) with respect to obligations under the
Trusteeship Agreement.
ERDA denies NEPA obligations, but admits jurisdiction and
venue.
Deny, for lack of knowledge.
3
4, 5, 6
The complaint has no paragraphs 4, 5, and 6.
P
US DOE ARCH TS
Ubjection should probably be made to maintenance of the suit
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Our practical concern is that the
in fact, run counter to the true desires of
some off the Bikinians.
Admit.
Admit.
We note, however, that there appears to be no basis
for naming Stanley as a defendant.
He has no responsibility
for Bikini-related activities, except to provide logistic
support as directed.
See also our response to Interrogatory
No. 1, previously furnished.
ERDA defers to Department of Defense (DOD) (though we note
the obvious, that Schlesinger is no longer Secretary).
WW, 12, 13, 14
ERDA defers to DOI.
63
Enclosure \