> mail requires substantial periods of time
ase ilaturo is served by air on an every-other-day basis,
mn a Ilignt eastbound three days a week and a flight

“estoounG three cays a week.

There is no plane on Sunday.

LANGUAGE PROBLEMS
“nile some of the named Plaintiffs and persons they

qt

uw

oO

represent are bi-lingual,

in both English and Marshallese,

of the members of the Bikini community read and write

Marshallese only.
None of the counsel for Plaintiffs is, at this
nmi,

able to sseak or read Marshallese.

lead counsel,

George M. Allen,

is presently learning the Marshallese language.

AopOintment of one or more official translators will
necessary for handling of court proceedings where witnesses
must testily in Marshallese.
Additionally,

some expert testimony may come from

“sLtnessas whose only language or primary language is Japanese.
subject matter of this litigation involve nuclear testing
its consecuences.

A related field of expertise is radiation

expert and to which they have contributed a substantial body
sclentiftilc research and literature.

There may be need for

translation from English to Japanese and vice versa as well as
om English to Marshallese and vice versa.
PROCEZDINGS OUTSIDE THE DISTRICT
Tnere mav be necessity or desirability for some
ceedings,

including both discovery and taking of evidence,

taxe clace outside the District of Hawaii.

For example,

may be necessarv or desirable for the Court to view and

napect the orospective living places of the Plaintiffs in

Select target paragraph3