252 



.us by • the status quo. 



La harm in the f'oim of marine mammal 

 injury ty will i without this Court's intcr- 



i. Upon consideration of the i of this casu, Peti- 

 ts Likely to succi ■ ■■' . 



The Court is thoroughly knowledgeable as to all that has 

 ■i from the inception of this lawsuit in 1974 to the 

 of these one. In light of this 



i y, a procedural history of this litigation has been 

 : • .ill, and a discussion of the Marine Mammal Protection 

 Act is included only as it relates to substantive objections. 



Petitioner further moves that the Court schedule an 

 immediate hearing on the Motion to provide for oral argument and 

 quest ioni ng. 



Respectfully submitted, 



Bernard Fensterwald, Jr. 

 Fensterwald & Associates 

 2101 L Street, N.W. 

 Suite 203 



Washington, D.C. 20037 

 (202) 785-1636 



Attorney for Petitioner 



Dated: March 2, 1977 



