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.