er

ing on Plaintiffs!

Motion for

resent special and unique problems
the definition of "Complex Litigation"
Federal Practice.

That is so because this

a2 need for certification of a class as a
action, because it will involve a possible need
for a Multi-bDis< r ict Panel during the later phases of discovery
and because oros
slams

of communication and logistics among

autornevs and Da endants spread over ten time zones from Saipan
to Washington wi

1 7

undoubtedly necessitate special procedures

fox nandling of notices and hearings.

TA

oric

-

the li sigation is Environmental Impact of the vost

-

war IIT

a
one
OfSs

the

ohn

moc iaar testing program of the United States,
er

”
techn

1Q

a

the subject

y

matter of

Finally,

ically most sophisticated series of

a POINTMENT OF LEAD COUNSEL

Piaint izis hereby advise the Court that they have
by Moore's Federal Practice, upon lead

agreec as sugess

3

counsel Zor all

nases of the litigation.

une Micronesian Legal Services Corporation
Gifice,

George M. Allen of
(MLSC)

Marshalls

appointed lead counsel for Plaintiffs ‘for

is neres

all shases of ii
sucgested that if Defendants can agree upon

It is

acDointment of $s ither lead counsel, representing all agencies
or,

at

least,

tne vert

liason counsel,

such a step will faci-

Liiite whe hand. ing of communications and logistics.
MULTI-ETISTRICT CROBLEMS
Counse .

of

tat

wnat other i:

for Plaintifiis are not aware,
watt

at this time,

on may presently be pending elsewhere

Select target paragraph3