specific contracts and sreps to be taken.

That approval

should 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 shouid be furnished to Plaintiffs and the

persons they represent in both English and Marshallese at
the earliest possible dare, 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 Resertlenent
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 eacn Defendant Seing required to submit a
“report to the Court and Plainriffs and their counsel in both
English and Marshallese every 45 days detailing such action
as has been taken by the agency duringthe 45 day period and
requesting approval for such further steps as the agency

wishes to take. BEST AVAILABLE COPY

In the alternative, Plaintiffs request that the
Court order the several agencies to agree on a Project
Manager to be an incividual also agreeable to Plainriffs and
their counsel to assume personal administrative control of
the entire Bikini Resettlement, with a requirement that the
Project Manager discharze the reporting function to the Court,
Plaintifis and their counsel, every 45 days.

It is respectivlly submitted that onlv by the DOE ARCHIVES
affirmative injunction steps requested herein can the Bikini

Resettlement be brought into compliance with NEPA and only by

Select target paragraph3