u
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a
uw

Oo

cr
b-

2
el
m
be

s Gliticult,
Jaluit,

gular access to Kili under the best conditions

being by Field Trio Shiv from Majuro,

a trio of at least

scheduling which is,

fourdays'

at best,

duration,

via

on a basis of

erratic.

For example, at the present time, two of Plaintiffs’
most important witnesses for the hearing on the Motion for
Preliminary Injunction, Lore Kessibuki, the Magistrate of
the Bikini Council and Tomaki Juda, one of the named
tg

laintiffs,

live on Kili Island.

Winter surf conditions

will commence in November and continue through April or May.
it is necessary that the

Motion for Preliminary

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unction be heard at the earliest possible date in order

hat these two ‘vvitnesses can return to Majuro to take the

ty

tl
‘J
wu

Wy

hus,

ield Trip Ship to Kili before surf conditions become such

that they would be unable to return to their present homes
anc to their families for a veriod of six months.
Communication between Kili and the Marshalls
District Office of MLSC at Majuro is solely by radio telephone,
@ situation which obtains for all attorney client communication
between counsel for Plaintiffs at Majuro and all of the Bikini
Peoole exceot for those who live on Majuro.
The radio telephone communications are on open

né

nu

yu

circuits, making confidential communication between counsel
clients imoractical.
Voice communication between Majuro and either Saipan
sr elsewhere in the world is difficult to impossible and,
in any event,

zion.

cannot be

raliec upon as

a means ef communica-

Cables ars transmitted over open circuits,

again making

confidential communication among counsel for Plaintiffs
imoractical excest by means of regular mail.

Select target paragraph3