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4. I asked Mr. Leeth whether his previous comment that Mr. Mochizuki, Mr. Kamiyama's interpreter, was not only uncertified, but unqualified as well, was based on his reading of recent letters sent by Mr. Kamiyama to United States Congressmen or whether it was based on other information which he had obtained independent of that letter. Mr. Leeth stated that the basis for his understanding was a conversation with Dina Kohn, the Director of Interpreter Services for the United States District Court for the Southern District of New York. He noted that during the trial, when the issue of the adequacy of the interpretation was raised, the Director of Interpreter Services for the Court was given the responsibility of reviewing the tapes to determine the adequacy of the translation. Based on that review, Mr. Leeth was told that it was their conclusion that the interpretation was inadequate. He noted that he had been told that the Court had dismissed some of the perjury allegations in the indictment. He also noted that the translator who was retained to review the original interpretation was a highly qualified graduate of New York University. He pointed out that this translator was significantly more qualified than Mr. Mochizuki.

5. I explained to Mr. Leeth that in a recent conversation with his staff, I had asked whether there was a correlation between the certification of interpreters under the Court Interpreters Act and the certification of interpreters by the State Department for escort level and conference level interpretion. Mr. Leeth pointed out that the State Department does not have a certification program. He stated that the State Department hires interpreters based

on a test, not on a certification. He explained that the Court Interpreters Act, however, required a complete


6. With respect to the different levels of interpretation at the State Department, Mr. Leeth explained that between the two levels, escort and conference, the difference in ability and competency was "miles apart." He explained that the Court Interpreters Act certification test would be most comparable to the conference level test and that the requirements for use of interpreters in the Federal courts were far and above those used for escort level interpreters at the State Department.

7. I asked Mr. Leeth to explain the difference

between consecutive interpretation and simultaneous

interpretation. I informed Mr. Leeth that I had been told that consecutive translation, to the extent that the interpreter used notes, was characterized by various people I had spoken with as being more accurate than simultaneous interpretation. I noted that to the extent that consecutive

interpretation involved a summary, even if in fact it were more accurate, it would not be appropriate for use in a courtroom where the exact words of the witness were important. Mr. Leeth responded that consecutive interpretation, when done properly, should not be a summary. He explained that the notes taken during consecutive interpretation were intended to ensure an interpretation which was as complete and accurate as a simultaneous interpretation. With respect to my statement that I had been informed that simultaneous interpretation was not as accurate as consecutive interpretation, Mr. Leeth explained that when properly done, simultaneous translation should be "a virtual mirror" of what was said by the other person.

8. Mr. Leeth informed me that for both consecutive and simultaneous interpretation, the real issue was the degree of competency. He pointed out that with respect to courtroom proceedings, where attorneys use questioning either to obscure or to clarify issues, every nuance of the testimony being translated and being heard by the court or the jury was critically important. He noted that a correct translation was especially important in view of the fact that the judge and jury needed to hear the exact words of the witness in order to make a judgement on credibility. He explained that because of the importance of interpretation in courtroom proceedings, his office required that interpreters used for courtroom proceedir ys be certified for both consecutive and simultaneous interpretation.

9. In conclusion, Mr. Leeth pointed out that when an interpreter has been requested for use in court for a language which has not been certified under the Court Interpreters Act, such as German, if a decision is made to obtain an interpreter through the State Department, the employees of the Administrative Office who are responsible for retaining the court interpreter are told specifically not to ask for escort level interpreters, but to ask only for conference level interpreters.

Sworn To Before Me
This 7 Day Of
December, 1984

Reland Hibowgored
Notary Public

My Commission Expires:
My Commission Expires January 1, 1989



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

nce between the qualifications of interpreters


who are certified for escort level interpretation and those who are certified for conference level interpretation. Mr. 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

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