- 4 - 
As our Court of Ap ; jals observed in Calvert Cliffs' 
Coord. Com. v United States, 449 F.2d 1109 at 1115: 
" ^_T}ie Section 102 jj^TEPA]] duties are 
not inherently flexible. They must be 
complied with to the fullest extent, unless 
there is a clear conflict of statutory authority. " 
For the foregoing and such other and further reasons as 
may be urged that the orally hearing of this motion, plaintiff 
moves that a temporary restraining order in the form of that 
annexed hereto be entered by the Court. 
Respectfully submitted 
Ferdinand J. Mack 
17 West Jefferson Street 
Suite 106 
Rockville, Maryland 20850 
279-2230 
CERTIFICATE OF MAILING 
I HEREBY CERTIFY that a copy of the foregoing Supplemental 
Memorandum of Points and Authorities in Support of Motion for 
Preliminary Injunction was mailed, postage prepaid to the 
U. S. Attorney, Earl J. Silbert on the 7^ day of June, 1977 . 
[Appendix C — 90] 
