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than meet it in a forthright fashion. One wonders if the stipulation was 
entered into by the Government in good faith, or was simply a device 
to avoid an inevitable order to prepare an environmental impact statement. 
10. Defendants predicate their opposition to a preliminary 
injunction in large part upon a claim that plaintiff has not shown that 
he has met the traditional criteria for determination of granting preliminary 
injunctive relief. Those are (1) the probability of plaintiff's success on 
the merits; (2) irreparable harm to the plaintiffs pendente life ; (3) the 
balance of hardships between the parties; and (4) where appropriate, as 
here, ‘he public interest. Virginia Petroleum Jobbers Association v F.P.C. , 
259 F 2d 921, 925 (D.C. Cir. 1958). 
However, when a federal statute has been violated, the 
rule has been that a court need not inquire into the traditional requirements 
for equitable relief. United States v City and County of San Francisco, 
310 U.S. 16, S.Ct. 749 (1940) (Court affirmed injunction of action 
in violation v_ ;deral "Raker" Act); 'Atchison, Topeka and Santa Fe 
Railway Co. v Callaway, 382 F. Supp. 610, 623 (D.D.C. 1974) 
(NEPA violation); Lathan v Volpe, 455 F 2d 1111, 1116, (9th Cir. 1971) 
(NEPA violation); Community Nutrition Institute v Butz, 420 F. Supp. 
751 (D.D.C. 1976) (Court enjoined regulation promulgated in violation 
of the Administrative Procedure Act and the Federal Meat Inspection Act) . 
11 . Even though the traditional criteria for equitable relief 
need not be established in this case because of its very nature, 
nevertheless, plaintiff has established the irreparable injury that is 
required. In Jones v District of Columbia Redevelopment Land Agency, 
499 F 2d 502, 512 (D.C. Circuit 1974), the Court stated: 
e 
[Appendix C — 131] 
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