slands; it may be necessary or desirable for ourt to tax2 testimony and receive other evidence in tne Marshall Islands in order to avoid transportation of mumercus witnesses to Honolulu and it may be necessary or Sesirable for evidence to be taken in Washington D.C., the iocation of many exvert witnesses and agency officials of tne Defendant Acencies. COOPESATION AMONG COUNSEL AND COURT Obviously, the maximum possible cooperation among counsel and court will be required for this litigation to be nancled expeditiously. PlaintifZs' counsel will make every cossible efforc co be cooperative with the Court and with all ther counsel at all times in order to avoid difficulties .nicn would otherwise ensue. FIRST DRE-TRIAL CONFERENCE It is respectfully submitted a preliminary pre-trial tonziezrence shoulz be neld at the earliest possible date, either immediately oreceding or immediately following the Hearing on PlaintiZis' Motion for Preliminary Injunction, in order to address the sotential oroblems of this litigation and agree 9en preliminary ground rules for handling them at the earliest Respectfully submitted, GEORGE M. ALLEN ficronesian Legal Services Corporation “larsnalls Office P. 9. Box 376 Maiuro, Marshall Islands 969690 Telephone: 227 Cable Address: ‘!icrolex DANIEL H. MACMEEKIN THEODORE R. MITCHELL EDWARD C. KING ANN =. ALLEN con't.