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Paragraph
ERDA's SUGGESTED RESPONSE AND/OR COMMENTS (Continued)
103
Deny.
104
Deny.
Need for study already denied.
ERDA could do it objectively.
if it were needed,
Plaintiffs’ refusal or
Inability to concede that objectivity cannot justify
retention of "independent" study group.
105
Conclusion of law which requires
no answer.
106
Conclusion of law which requires
no answer.
107
Conclusion of law which requires
no answer.
108
Conclusion of law which requires
no answer.
109
Conclusion of law which requires
no answer.
In view of the foregoing responses to the numbered allegations of the
complaint, ERDA denies each claim alleged in paragraphs 111 through 115,
and opposes the grant of any relief sought in the prayer for relief.
We
do, of course, stick by the agreements voluntarily made in discussions in
Honolulu on November 1, 1975, and will work with DO! on resolving the
question of funding the aerial survey.
DOE ARCHIVES
Enclosure 1
GO