stecifiec contracts and steps to be taken.

That approval

snould be withheld until the Defendants are able to show, on

a step-by-step basis, that further steps will bring them
into compliance with NEPA, leading with all due deliberate
speed to completion of Draft Environmental Impact Statement
(DEIS), which DEIS should be furnished to Plaintiffs and the

persons they represent in both English and Marshallese at
the earliest possible date, and, in any event, no later than

one year after the date of entry of the preliminary injunction.

X.

FURTHER MONITORING OF THE RESETTLEMENT BY THE COURT
In order to insure that the Bikini Resettlement

does not again stall out into its present posture, Plaintiffs

request that the Court affirmatively require that the Defendants submit all further activity to regular monitoring by

the Court, with each Defendant being required to submit a
report to the Court and Plaintiffs and their counsel in both

English and Marshallese every 45 days detailing such action
as has been taken by the agency during the 45 day period and
requesting approval for such further steps as the agency
wishes to take.
In the alternative, Plaintiffs request that the
Court order the several agencies to agree on a Project

Nanager to be an individual also agreeable to Plaintiffs and
their counsel to assume personal administrative control of
cne entire Bikini Resettlement, with a requirement that the
“vosect Manager cischarge the reporting function to the Court,
7_3intiiis and their counsel,

every 45 days.

It is ressectfully submitted that only By the
ailirmative injunction steps requested herein can the Bikini
Resettlement be brought into compliance with NEPA and only by

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