AFFIDAVIT OF ROBERT E. HEGGESTAD EXHIBIT D I, Robert E. Heggestad, being duly sworn, state that the following facts are true and correct: 1. On Thursday, October 25, 1984, I interviewed Mr. Manabu Fukuda during two telephone conversations. Mr. Fukuda is an interpreter in the Interpreting Branch of the Language Services Division of the United States Department of State. I informed Mr. Fukuda that I was calling on behalf of Mr. K. Tokito to confirm various facts discussed in their recent conversation and to ask further questions relating to Mr. J. Mochizuki and to the Department's policies concerning the use of escort level interpreters and conference level interpreters. 2. In our conversation, Mr. Fukuda confirmed that John T. Mochizuki was certified by the State Department as an escort level interpreter on November 1, 1977. Mr. Fukuda stated that there are no separate gradations which would show the results of certification tests for interpreters and that such tests were graded on a pass/fail basis. Mr. Fukuda further informed me that Mr. Mochizuki had been available to work for the State Department on a very limited basis and that he, therefore, had no recollection of Mr. Mochizuki's qualifications in terms of the range of capabilities for interpreters certified at the escort level. I asked whether Mr. Mochizuki had subsequently applied to be tested as a conference level interpreter. Mr. Fukuda informed me that Mr. Mochizuki had never applied to the State Department to be certified as a conference level interpreter. 3. I asked Mr. Fukuda several questions pertaining to the difference between the qualifications of interpreters Mr. who are certified for escort level interpretation and those who are certified for conference level interpretation. Fukuda informed me that although the test for escort level interpreters was not an easy test, the test for conference level interpreters was much more difficult, particularly to the extent that it required an "aptitude" for simultaneous translation. I asked Mr. Fukuda whether an escort level interpreter might be qualified to perform simultaneous translation. He stated that although an escort level interpreter would not "normally" be qualified for conference level work, it was not possible to make such a determination unless that individual was tested. Mr. Fukuda explained that escort level interpretation was used typically as part of cultural exchange programs under the sponsorship of the United States Information Agency. He stated that because an escort level interpreter travels with visiting officials, there was a certain amount of administrative work performed by the interpreter and that interpreting required more substantive interpreting than the tour guide level. 4. I asked Mr. Fukuda to describe the difference between consecutive and simultaneous translation. Mr. Fukuda explained that for consecutive translation, the interpreter takes notes, and then using such notes, repeats the statement in the second language. He explained that these notes are especially important, because the English and Japanese grammar structure are different. Thus, Mr. Fukuda noted that during simultaneous translation, where one is speaking and listening at the same time, if the interpreter does not have the aptitude for simultaneous translation, the translation can become very confused. 5. I asked Mr. Fukuda whether an escort level interpreter would normally be qualified to function effectively in an American legal proceeding. Mr. Fukuda stated that it might be possible that an escort level interpreter would be qualified for courtroom proceedings. He explained, however, that it would depend on the capabilities of the individual interpreter. Mr. Fukuda stated that the State Department would normally be aware of the level of capability of escort level interpreters which they had used but that he had no recollection of Mr. Mochizuki's qualifications. 6. I asked Mr. Fukuda whether note taking was an important factor to ensure the accuracy of consecutive interpretation. Mr. Fukuda reemphasized that for an escort level interpreter who is using consecutive translation, the taking of notes was one of the key factors in performing an accurate translation. He stated that if an escort level interpreter used consecutive translation in a legal proceeding, failure to take notes would have a very negative impact on the accuracy of the interpretation, and that without notes, or with inadequate notes, it was very likely that important facts would be omitted. Mr. Fukuda stated that the only way to ensure accuracy of the consecutive translation was to take notes at the same time and then to use those notes as the interpreter read back the statement which he had translated. Mr. Fukuda agreed that in order to ensure that consecutive translation was accurate, it was critically important that notes be taken. 7. I asked Mr. Fukuda whether there were differences in the functions performed by conference level interpreters. Mr. Fukuda explained that there were two types of conference level interpreters: (1) consecutive interpretation is used for important negotiations where translation is very deliberate. He acknowledged that the use of consecutive interpretation for conference level interpretation would He indicate that the interpreter demonstrated an exceptionally good ability to translate in important areas such as foreign affairs; (2) simultaneous interpretation is used for seminars where there are many presentation papers, with limited time available to present those papers. With respect to simultaneous interpretation used at the conference level, Mr. Fukuda explained that one conference would normally require three or four interpreters. explained that this was due to the fact that simultaneous interpretation required a great deal of energy and that simultaneous interpreters therefore tired easily. He stated that for simultaneous translation it would be better to have at least two and in most case three interpreters. Mr. Fukuda stated that for legal and complex technical matters at least two simultaneous translators would be needed for a half day period. Mr. Fukuda noted that for conferences which were very serious, the escort level interpreter would not normally be qualified. He stated that one interpreter could not perform adequately or in a full capacity for lengthy periods and that it was therefore the State Department's policy to use a simultaneous translator only for a half an hour at a time. He explained that simultaneous translation was particularly demanding, especially from Japanese to English and from English to Japanese. He noted that the Romance languages were much easier. For 8. In concluding, I asked Mr. Fukuda several questions relating to the use of consecutive reporting. consecutive interpretation, Mr. Fukuda reemphasized the importance of taking good notes. He acknowledged, however, that the ability to take good notes is not tested in the certification process for escort level interpreters. I asked whether Mr. Fukuda would expect an escort level interpreter to be familiar with the unique legal terminology used in an American Court System. He stated that it would depend on the individual's experience, and that normally if an interpreter didn't have experience in a special area, i.e. technical or legal, he would spend some time in advance researching the specific area before undertaking the interpretation job. Mr. Fukuda concluded that unless one had personal familiarity with an escort level interpreter, it would be impossible to know whether he would be competent to interpret a courtroom proceeding. DULLA Robert E. Heggestad EXHIBITE AFFIDAVIT OF ROBERT E. HEGGESTAD 1. On November 26, 1984, I interviewed by telephone, Ms. Dina Kohn ("Ms. Kohn"), the Director of the United States District Court Interpreters Office in New York. This office is part of the Federal Court system. I |