Full opinion text
ORDER DENYING DEFENDANT FORD AND FIRESTONE’S MOTIONS TO DISMISS COLOMBIAN AND VENEZUELAN CASES ON GROUND OF FORUM NON CON-VENIENS BARKER, District Judge. Defendants Ford Motor Co. (“Ford”) and Bridgestone/Firestone, Inc. (Firestone) filed various motions and supplemental motions to dismiss certain personal injury and wrongful death cases on the ground of forum non conveniens. For the reasons set forth below, these motions are DENIED with respect to the cases listed in the caption above. Procedural Background Approximately 700 personal injury and wrongful death cases have been filed against Ford and/or Firestone in federal courts around the country alleging that defects in Ford Explorers and certain models of Firestone tires were responsible for the accidents causing the injuries suffered by Plaintiffs. The cases were transferred to this court by the Judicial Panel on Multidistrict Litigation, pursuant to 28 U.S.C. § 1407 on October 26, 2000. Approximately 200 of these cases were filed by Plaintiffs who were injured in accidents that occurred in foreign countries, including Colombia, Venezuela, Thailand, Panama, and Ecuador. On December 21, 2000, the first of many motions to dismiss these cases on the ground of forum non conve-niens was filed by Ford. Ford asked that, for the cases involving accidents in Venezuela, the cases be dismissed from this litigation in lieu of further proceedings in Venezuelan courts. A corresponding motion sought dismissal of the cases involving accidents occurring in Colombia in favor of trial in Colombian courts. Firestone soon followed Ford’s lead in seeking such relief. In February 2001, we granted Plaintiffs’ motion to conduct discovery on forum non conveniens issues. In re Bridgestone/Firestone, Inc. ATX, ATX II and Wilderness Tires Products Liability Litigation, 131 F.Supp.2d 1027 (S.D.Ind.2001). Because of the complexities of this doctrine and because the majority of the foreign cases originate from Colombia and Venezuela, the parties briefed, and we rule on here, only the cases listed in the caption above, all of which are Colombian or Venezuelan cases. Of course, our ruling carries implications for the remainder of the forum non conveniens motions which the parties should take into account when determining their strategies in the remaining cases. Forum Non Conveniens Analysis “[T]he central focus of the forum non conveniens inquiry is convenience.” Piper Aircraft Co. v. Reyno, 454 U.S. 235, 249, 102 S.Ct. 252, 70 L.Ed.2d 419 (1981). In other words, “a trial court may dismiss a suit over which it would normally have jurisdiction if it best serves the convenience of the parties and the ends of justice.” Kamel v. Hill-Rom Co., Inc., 108 F.3d 799, 802 (7th Cir.1997) (citations omitted). The forum non conveniens inquiry is guided by a number of considerations. First, an adequate alternative forum must be available to hear the case. Id. If this threshold criterion is satisfied, then the court must identify various private and public interest factors and balance them to determine if their weight favors dismissal. Id. at 803; see also ISI International, Inc. v. Borden Ladner Gervais, LLP, 2001 WL 1382572, at *2 (N.D.Ill. Nov.5, 2001) (“the court must balance the private interests of the litigants and the public interests of the forum to determine the superior forum”). Ford and Firestone “bear[ ] the burden of persuasion as to all elements of the forum non conveniens analysis.” Lacey v. Cessna Aircraft Co., 862 F.2d 38, 43-44 (3d Cir.1988) (Lacey I); see also Pyrenee, Ltd. v. Wocom Commodities, Ltd., 984 F.Supp. 1148, 1161 (N.D.Ill.1997) (“The defendant has the burden of demonstrating forum non conveniens.”). Adequate Alternative Forum We first determine whether there is an adequate alternative forum in which to hear these cases. Piper, 454 U.S. at 254 n. 22, 102 S.Ct. 252. Whether there is an adequate alternative forum for Plaintiffs’ claims is a “two-part inquiry: availability and adequacy.” Kamel, 108 F.3d at 802. A forum is “available” if “all parties are amenable to process and are within the forum’s jurisdiction.” Id. at 803 (citing Piper, 454 U.S. at 254 n. 22, 102 S.Ct. 252). An alternative forum is “adequate” when “the parties will not be deprived of all remedies or treated unfairly.” Id. (citing Piper, 454 U.S. at 255, 102 S.Ct. 252). Venezuelan Courts We begin by addressing whether the courts of Venezuela provide Plaintiffs allegedly injured in Venezuela an adequate alternative forum in which to bring their claims. Defendants have submitted the affidavits of two experts (Rengel and Cot-tin) who testify that “citizens and residents of Venezuela may bring suit in the Venezuelan courts to assert claims against nonresident defendants such as Ford and Firestone for conduct related in part to events occurring in Venezuela.” Rengel Aff. ¶ 9; see also Cottin Dec. ¶ 13 (“the Venezuelan courts ... have jurisdiction to address a complaint against persons who are not domiciled [or present] in Venezuela ... ”). Plaintiffs contest this assertion with the affidavits of their own experts. Tatiana B. deMaekelt, head of the private international law department at Universi-dad Central de Venezuela and Universidad Católica Andrés Bello, reaches the opposite conclusion regarding the jurisdiction of Venezuelan courts in these cases. As explained below, the testimony of Rengel and Cottin does not satisfy Defendants’ burden of establishing Venezuela as an available alternative forum. Plaintiffs’ expert, deMaekelt, explains that Article 39 of the Statute of Private International Law “provides that the first forum for bringing suit against a non-domiciliary defendant is the country where the defendant is domiciled.” DeMaekelt Aff. ¶ 3. DeMaekelt, in partial agreement with Defendants’ experts, then identifies two potentially applicable exceptions to this principle, which are set forth in Article 40 of the Statute on Private International Law. Id. at ¶ 6; see also Rengel Aff. ¶ 12. The first of these exceptions permits jurisdiction over personal injury cases with non-domiciliary defendants “where the facts are verified” in Venezuela and where a contract is executed in Venezuela. Article 40(2) (cited in Cottin Reply Aff. ¶ 6; deMaekelt Aff. ¶¶ 6, 12). According to Ford and Firestone, because the vehicles involved in the accidents at issue were purchased or leased in Venezuela, and because the accidents occurred in Venezuela, Venezuelan courts have jurisdiction over these cases as the site “where the facts were verified.” Cottin Reply Aff. ¶ 7-9. DeMaekelt calls Cottin’s conclusions into serious doubt. She opines that the language of Article 40(2) is not as clear as Defendants suggest and states that this subparagraph requires the equivalent of a “most significant contact” analysis, likely resulting in the determination that Venezuelan courts would not have jurisdiction over the cases on this basis. DeMaekelt Aff. ¶ 13. DeMaekelt adds that she is not aware of any reported cases in which a Venezuelan court accepted jurisdiction on the basis of the quoted language in Article 40(2). Cottin responds by pointing out that deMaekelt’s proposed most significant contact analysis is not codified in any Venezuelan law and that, because Venezuela has a civil law system, rather than a common law system, the lack of reported case decisions is irrelevant. Cottin Reply Aff. ¶¶ 8-9. In short, Cottin’s position is that the “literal meaning” of Article 40(2) establishes the Venezuelan court’s jurisdiction over the cases at issue here. Id. at ¶ 7. In his original declaration, Cottin relied on Article 53 of Venezuela’s Code of Civil Procedure for the proposition that executing a contract or “verification” of facts in Venezuela permits jurisdiction over Ford and Firestone. Cottin Dec. ¶ 13. It turns out, as all parties agree, that Article 53 was abrogated by the Statute on Private International Law. DeMaekelt Aff. ¶¶ 18-20; Cottin Reply Aff. ¶ 6 n. 1; Rengel Dep. at 113. While it is true that Article 53 of the Code of Civil Procedure and Article 40(2) of the Statute on Private International Law say much the same thing, we are understandably reluctant to put much stock in Cottin’s interpretation of the language of the latter law. See Pyrenee, 984 F.Supp. at 1164 (discounting plaintiffs expert testimony partly on basis that expert relied on earlier draft of law at issue). Our reluctance is heightened by the fact that Cottin, at his deposition, admitted that he had not reviewed the Statute on Private International Law prior to submitting his opinion on jurisdiction in the case. Cottin Dep. at 93. In short, Cottin formed his initial opinion in this case without considering the statute on which he now offers his “expert” opinion for our reliance. Hence, we find deMaek-elt’s opinion that Article 40(2) does not confer jurisdiction over Defendants to be more reliable than Cottin’s opinion to the contrary. We thus adopt the view that based on Article 40(2) Venezuelan courts are not an available forum on the basis of the presence in Venezuela of relevant contracts or “verified facts.” Ford and Firestone cite a second exception to Article 39 of the Statute of Private International Law in support of their contention that Venezuelan courts have jurisdiction over these cases. Article 40(4) of the Statute on Private International Law permits jurisdiction over a non-domiciliary when the parties submit to the jurisdiction of Venezuelan courts. Article 40(4) (cited in deMaekelt Aff. ¶¶ 8-11; Cottin Reply Aff. ¶ 6; see also Rengel Dec. ¶ 12). Cot-tin and Rengel conclude that Venezuelan courts would recognize the consent of Ford and Firestone to jurisdiction over these cases in Venezuela. Cottin Dec. ¶ 13; Rengel Dee. ¶ 12. DeMaekelt attacks these conclusions, maintaining, on the basis of Article 40(4) and Article 44 of the Statute on Private International Law, that express submission by both parties is required in order for Venezuelan courts to have jurisdiction over the actions at issue here. DeMaekelt Aff. ¶¶ 9-10. On this basis, Plaintiffs argue that, by bringing their cases in the United States, they are not expressly submitting to the jurisdiction of Venezuelan courts, and that the unilateral submission of Ford and Firestone to Venezuelan jurisdiction is insufficient to create jurisdiction. DeMaekelt Aff. ¶ 9-11; Plaintiffs’ Memo, at 18. Defendants argue: Of course, no one can force plaintiffs to refile these actions in Venezuela after they are dismissed in the United States. If plaintiffs willfully elect not to pursue their claims in Venezuela, that is their choice.... But the critical point is that if these actions are dismissed, plaintiffs can file their claims in Venezuela. And if they do, defendants have agreed not to challenge the Venezuelan court’s jurisdiction, thus satisfying Article 40 (sub-paragraph 3). Joint Reply at 17 (emphasis in original). We acknowledge the appeal of Defendants’ argument. However, two key points prevent the argument from pulling the weight Defendants place on it. First, Defendants’ argument dismisses the express language of Article 40 that requires the acquiescence of both “parties” to the jurisdiction of the court. Defendants address Article 40 as if it sets out limitations akin to personal jurisdiction over non-domiciliary defendants — limitations that they can unilaterally waive. We find, however, consistent with deMaekelt’s analysis, that Article 40 is more reasonably read to set forth the Venezuelan courts’ jurisdiction over cases involving non-domiciliary defendants — and it provides for jurisdiction over cases when both parties submit to jurisdiction. Second, unreliable experts cannot carry Defendants’ burden of persuasion. That Defendants experts are unreliable cannot be denied. As noted above, in addition to admitting that he is not a specialist in the subjects disputed here, Cottin first formed his opinion in this case on the basis of an abrogated statute. We are even less inclined to rely on the opinion of Defendants’ other expert, Rengel. Rengel’s opinion that Venezuelan courts have jurisdiction over Ford and Firestone is merely conclu-sory. Rengel Aff. ¶¶ 11-12. He does not address deMaekelt’s interpretation that Plaintiffs have not consented to jurisdiction in Venezuela, thereby rendering ineffective Ford and Firestone’s consent. Most significantly, Rengel, a partner in the law firm of Travieso Evans Arria Rengel & Paz, personally handles litigation for Ford in Venezuela. Rengel Dep. at 70-71. That Defendants bear the burden of persuasion with regard to the adequacy and availability of an alternative forum also is clear. Mercier v. Sheraton International, Inc., 935 F.2d 419, 425 (1st Cir.1991); El-Fadl v. Central Bank of Jordan, 75 F.3d 668, 677-79 (D.C.Cir.1996) (overturning grant of forum non conveniens dismissal on ground that district court failed to hold defendants to their burden of persuasion on question of whether Jordan was adequate alternative forum); Cleary v. Sterenbuch, 2001 WL 1035285, at *3 (N.D.Ill. Sept.10, 2001) (denying forum non conveniens motion because, among other reasons, defendant “fail[ed] to establish that Liechtenstein is an adequate forum”). The unreliability of their experts, in light of the burden Ford and Firestone bear, is fatal to their contention that Venezuelan courts could exercise jurisdiction over these cases. Here, Plaintiffs’ expert offers a reasonable interpretation of the key provision regarding consent to jurisdiction which Defendants fail to address with credible expert testimony. Instead, they offer conclusory opinions of discredited experts. Enough of a question is raised by deMaekelt’s opinion that Defendants, with their unreliable expert testimony, fail to meet their burden of persuasion that Venezuelan courts are an available alternative forum. El-Fadl, 75 F.3d at 679 (defendants did not meet burden of persuasion when their expert failed to address various potentially dispositive provisions of foreign law called to court’s attention by plaintiffs expert); Mercier, 935 F.2d at 425 (finding that gaps in defendant’s expert affidavit prevented defendant from carrying its burden even in light of plaintiffs failure to provide competing evidence on significant issue). While our finding that Venezuelan courts are not an available alternative forum is a sufficient basis for denying Defendants’ motion, we also address the adequacy of Venezuela as an alternative forum. See Leon v. Millon Air, Inc., 251 F.3d 1305, 1311 (11th Cir.2001) (“Availability and adequacy warrant separate consideration.”). The standard by which we judge whether Defendants have met their burden of persuasion on adequacy is not demanding. In Kamel, the Seventh Circuit opined that “[a]n alternative forum is adequate when the parties will not be deprived of all remedies or treated unfairly.” 108 F.3d at 803. The absence of strict liability does not render a foreign court inadequate. Piper, 454 U.S. at 255, 102 S.Ct. 252. Also, adequacy is satisfied if the relevant type of case is “cognizable in theory” even in the absence of reference to any actual cases of the type. Macedo v. Boeing Co., 693 F.2d 683, 688 (7th Cir.1982). Hence, Plaintiffs’ contention that “[n]ot one Venezuela case has ever imposed product liability on a defendant who is not in possession or control of the instrument causing injury” is of no avail. Plaintiffs’ Memo, at 20 (citing Rodner Aff. ¶ 12). Plaintiffs also do not succeed on the basis of their expert opinion that “Venezuelan jurisprudence has not yet developed a defined set of substantive rules to govern traditional products liability for defectively designed or manufactured consumer products.” Rodner Aff. ¶ 12. Defendants point to Article 1.185 of the Venezuelan Civil Code as evidence that Plaintiffs’ claims are at least cognizable in theory. Cottin Dec. ¶¶ 16-17. According to Cottin, this law establishes that those causing harm to another through negligence or causing intentional harm to another are obligated to compensate the injured party. Id. Of course, for the reasons explained earlier, Cottin’s expertise in this area is questionable. However, Defendants meet their burden of persuasion by relying on a prior publication authored by Rodner, Plaintiffs’ expert, that contradicts the opinion he submits here. In the late 1970’s, Rodner interpreted Article 1.185 of the Civil Code to establish a cause of action in product liability: James O. Rodner, Manufacturer’s Liability in Venezuelan Law and Angel Rojo’s Monograph, Journal of the School of Law, Universidad Católica Andrés Bello, at 10 (1976-77). Thus, it appears that Plaintiffs would “not be deprived of all remedies or treated unfairly” if their cases could be brought in Venezuelan courts. However, because we find Defendants failed to meet their burden of persuasion that Venezuelan courts have jurisdiction over the cases, we must conclude that there is not an adequate alternative forum for these actions. Liability in tort is consecrated in Article 1.185 of the Civil Code_If the damage caused to the victim comes from a manufacturing defect, the manufacturing defect is due to the fault of the manufacturer, and (sic [then?]) the manufacturer must indemnify the victim for all damage, foreseen and even unforeseen, including pain and suffering .... Colombian Courts We next consider whether the Colombian court system provides an adequate alternative forum for the cases brought by Plaintiffs who are citizens and residents of Colombia. Unlike their argument against the Venezuelan courts, Plaintiffs essentially concede that all parties are amenable to process for these action in the courts of Colombia. Plaintiffs’ Resp. at 20-21. Hence, we find that Colombia is available as an alternative forum. Kamel, 108 F.3d at 802 (citing Piper, 454 U.S. at 255, 102 S.Ct. 252). With regard to adequacy, Plaintiffs raise two arguments in response to Defendants’ attempts to demonstrate that these cases can be brought in Colombia. Citing the political instability and the pervasive influence of guerrilla violence in Colombia, they maintain that Colombian courts cannot provide an adequate alternative forum. Plaintiffs’ Resp. at 20-21. As explained fully in the next section of this entry, we feel that this argument is best addressed as part of the balancing of public and private factors in favor of one forum over another. See, e.g., Guidi v. Inter-Continental Hotels Corp., 224 F.3d 142, 145-48 (2d Cir.2000) (plaintiffs’ safety concerns should be considered as part of the weighing of conveniences); Iragorri v. Interna tional Elevator, Inc., 203 F.3d 8, 13 (1st Cir.2000) (opining that some safety concerns might better relate to balancing of interests) (Iragorri I ). Therefore, we address only the second of the Plaintiffs’ arguments against the adequacy of Colombian courts. Plaintiffs contend that there is no established body of law governing consumer products liability in Colombian jurisprudence. Plaintiffs’ Resp. at 21. Hernán Fabio Lopez Blanco, Plaintiffs’ expert, opines that there is no substantive case law in the area of defective products and that there is an absence of rules and standards to guide Colombian courts if faced with a product liability case. Lopez Blan-co Aff. ¶4.1. Specifically, Lopez Blanco maintains that Law 3466 of 1982, a consumer statute, is incomplete. Id. ¶4.3. According to him, the statute provides for fines, recalls, and sales prohibitions but fails to develop the manner in which recovery for injuries suffered by consumers for damages can be obtained in court. Id. Defendants counter with the declaration of one of their experts, Juan Ignacio Gam-boa Uribe. Gamboa calls our attention to a number of “Verbal Proceedings” brought before civil circuit judges against Ford Motor of Venezuela. Gamboa Reply Dec. ¶ 2. He also sets forth the procedures involved in Verbal Proceedings, as established in Title XXIII of the Colombian Civil Procedure Code. Id. ¶ 3(c). It is certainly the case that these procedures differ from those in the district courts of the United States, but such differences do not render the courts of Colombia inadequate. PT United Can Co. Ltd. v. Crown Cork & Seal Co., Inc., 138 F.3d 65, 73 (2d Cir.1998) (“A forum is not inadequate even if the foreign justice system differs from that of the United States.”); Gschwind v. Cessna Aircraft Co., 161 F.3d 602, 607 (10th Cir.1998) (“[PJrocedural differences between forums do not bar a forum non conveniens dismissal in the absence of a 'complete denial of due process.’ ”). As noted earlier, the standard of adequacy is low. It is enough that the parties not be “deprived of all remedies or treated unfairly” and that the relevant type of case be “cognizable in theory.” Kamel, 108 F.3d at 803; Macedo, 693 F.2d at 688. Here, Defendants meet their burden of persuasion on the question of adequacy. Gamboa’s declarations establish that Co-lumbian courts have procedures and substantive law capable of providing a remedy in product liability cases. Balancing the Interests Once a district court determines whether an adequate alternative forum exists, then it is charged with balancing the private and public interest factors relevant to the choice of forum. Kamel, 108 F.3d at 803; Piper, 454 U.S. at 254-55, 102 S.Ct. 252. Private factors are usually analyzed separately from public factors. E.g., Kamel, 108 F.3d at 804 (determining district court adequately balanced private factors before reviewing district court’s balancing of public factors). Defendants continue to bear the burden of persuasion as to this element of the forum non conveniens analysis. Lacey I, 862 F.2d at 43-44. Certain considerations carry more weight than others in the determination of whether Ford and Firestone have met their burden. Defendants must provide enough information to enable the court to balance the parties’ interests. Piper, 454 U.S. at 258, 102 S.Ct. 252. At least “some idea of the type of evidence available” to establish key elements of the case must be provided to the court. Macedo, 693 F.2d at 689. For instance, some of the private interests to be considered include “the relative ease of access to sources of proof’ and the availability of witnesses. Gilbert, 330 U.S. at 508, 67 S.Ct. 839. To balance these interests, the court needs information permitting it to “scrutinize the substance of the dispute between the parties to evaluate what proof is required, and determine whether the pieces of evidence cited by the parties are crucial, or even relevant, to the plaintiffs cause of action and to any potential defenses to the action.” Van Cauwenberghe v. Biard, 486 U.S. 517, 528, 108 S.Ct. 1945, 100 L.Ed.2d 517 (1988). Both parties submitted voluminous evidence in support of their respective positions on the forum non conveniens motions. Another important consideration is the degree to which the balance of private and public interests must tip in order to warrant forum non conveniens dismissal. In Kamel, the Seventh Circuit formulated the issue in the following manner: “when a trial in the chosen forum would result in vexation and oppression to the defendant which would far outweigh the plaintiffs convenience or when the chosen forum would generate administrative and legal entanglements for the trial court,” then dismissal is appropriate. 108 F.3d at 802. Interpretations of this language differ. Defendants maintain that they need show merely that the public and private factors “point towards” trial in Venezuela and Colombia. Joint Reply at 16. Plaintiffs argue that Defendants should be held to a higher standard such that the relevant interests must “clearly point towards” trial in the alternative forum. Plaintiffs’ Resp. at 9. The crux of the disagreement is the degree of deference to which Plaintiffs are entitled in their choice of forum. In Piper, the Supreme Court determined that “there is ordinarily a strong presumption in favor of the plaintiffs choice of forum, which may be overcome only when the private and public factors clearly point towards trial in the alternative forum.” 454 U.S. at 255, 102 S.Ct. 252 (emphasis added). However, the Court limited the force of this presumption in a situation relevant here. The Piper court held that “the presumption applies with less force when the plaintiff [is] foreign.” Id. The distinction is justified, in the Supreme Court’s view, because the focus of the forum non conveniens inquiry is convenience and “[w]hen the home forum [of the plaintiff] has been chosen, it is reasonable to assume that this choice is convenient.” Id. at 255-56, 102 S.Ct. 252. Presuming convenience is less reasonable when the plaintiff chooses a foreign forum. Id. at 256, 102 S.Ct. 252. On the basis of certain treaty obligations, the Colombian and Venezuelan Plaintiffs before us maintain that they are entitled to a presumption of convenience equal to that of resident or citizen plaintiffs. Plaintiffs’ Resp. at 14. The United States and Venezuela signed a Treaty of Peace, Friendship, Navigation and Commerce on January 20, 1836. 8 Stat. 466, 1836 WL 3643. Article 13 of the treaty provides that the courts of both countries shall be “open and free” to the other’s citizens “on the same terms which are usual and customary with the natives or citizens of the country in which they may be ....” A similar treaty was signed between the United States and Colombia (then New Granada) on December 12, 1846. Article 13, Treaty of Peace, Amity, Navigation and Commerce, 9 State. 881, 1846 WL 6378. Plaintiffs’ reasoning is persuasive. Indeed, in reference to the treaty with Venezuela, one court took Plaintiffs’ position, determining that “no discount may be imposed on the [Venezuelan] plaintiffs initial choice of a [United States] forum solely because [the plaintiff] is a foreign corporation.” Blanco, 997 F.2d at 981. In opposition, Defendants maintain that the U.S. treaties with Venezuela and Colombia are not relevant to the forum non conveniens question and that they need only show that the balance of public and private factors simply “point towards” trial in the foreign forums. Joint Reply at 15-16. They contend that Blanco and eases reaching similar holdings are directly counter to Piper and Kamel, the controlling precedents in this jurisdiction. However, no treaties were mentioned, let alone considered and rejected, in Piper and Kamel. Rather than adopting wholesale either Defendants’ or Plaintiffs’ approach, we will use the more nuanced approach suggested by Iragorri II and other precedents: expatriate U.S. nationals and treaty nationals residing in their home countries are entitled to the same deference on their choice of forum, with the consideration that suing in a United States forum while residing in a foreign country is less likely to be convenient. This formulation accommodates a number of conflicting values, including protecting U.S. courts from a glut of foreign cases while continuing to respect our treaty obligations. See Piper, 454 U.S. at 252, 102 S.Ct. 252 (acknowledging concern about any decisions which would make American courts even more attractive to foreign plaintiffs, especially considering that American courts are already crowded); Alcoa Steamship Co., Inc. v. M/V Nordic Regent, 654 F.2d 147, 153 (2d Cir.1980) (noting that treaty obligations are paramount under the Constitution); Iragorri II, 274 F.3d at 69 n. 2 (Department of Justice opined that “nationals of the other party to the treaty are entitled to access to U.S. courts on terms no less favorable than those enjoyed by U.S. nationals in like situations.”) (emphasis added). It also follows the widely recognized principle that not even U.S. citizenship is a talisman against forum non conveniens dismissal. Piper, 454 U.S. at 256 n. 23, 102 S.Ct. 252 (“A citizen’s forum choice should not be given dispositive weight .... ”); see also Kamel, 108 F.3d at 804 (certain situations merit discount of plaintiffs American citizenship). And, ultimately, it captures the main point of our analysis — convenience. Hence, we conclude that Plaintiffs here are entitled to the same deference as U.S. citizens in similar situations, with the understanding that suing in a United States court is sometimes, although not always, less likely to be convenient when the shared situation is residence in a foreign country. See Doe v. Hyland Therapeutics Division, 807 F.Supp. 1117, 1123 n. 9 (S.D.N.Y.1992) (“Moreover, circumstances may indicate that the chosen forum, though foreign, is still more convenient to the plaintiff than the home forum.”). Hence, the balance of private and public interest factors must do more than merely “point towards” further proceedings in Venezuela and Colombia. Private Interest Factors — Colombia Keeping in mind the degree of deference properly accorded Plaintiffs, we examine the private interest factors having an impact on the choice of forum. All of the Colombian cases were filed in the Southern District of Florida and likely would be remanded there for trial. For this reason, the forum to which we compare the Colombian courts is the district court in southern Florida. Important considerations concerning the private interests of the litigants include “the relative ease of access to sources of proof; availability of compulsory process for attendance of unwilling, and the cost of obtaining attendance of willing, witnesses; possibility of view of premises, if view would be appropriate to the action; and all other practical problems that make trial of a case easy, expeditious and inexpensive [including] questions as to the enforcibility [sic] of a judgment if one is obtained.” Gulf Oil Corp. v. Gilbert, 330 U.S. 501, 508, 67 S.Ct. 839, 91 L.Ed. 1055 (1947). We look first at ease of access to sources of proof, including documents and witness testimony, as they are often considered together. See, e.g., Roynat v. Richmond Transp. Corp., 772 F.Supp. 417, 422 (S.D.Ind.1991). Defendants attempt to tilt this factor in their favor through their willingness to accommodate the participation of foreign Plaintiffs in pretrial proceedings in the MDL and to make available any evidence produced through coordinated discovery. Ford Memo. (Colombian Cases) at 12 n. 8; Joint Reply at 21-22. There are problems with this seemingly generous offer. Most importantly, certain types of discovery conducted here may not be usable in a Colombian proceeding. Lopez Blanco opines that expert testimony developed abroad must be presented again before the Colombian judge with an opportunity for contradiction of the evidence. Lopez Blanco Aff. ¶ 5.5. It also appears that answers to interrogatories and requests for admission would be of no use in a Colombian trial. Lopez Blanco Aff. ¶5.5 (written testimony permitted only from diplomatic agents and their dependents). Finally, use of deposition testimony is problematic, at best. Parties can request ratification before a Colombian judge of oral testimony given abroad. Id. Ratification entails travel to Colombia by the witness and testimony through an interpreter, if necessary, regarding the earlier testimony. Id. The opinions of Gamboa and Lopez Blanco permit the conclusion that documents (unlike deposition testimony and expert reports) obtained in the MDL could be presented in a Colombian proceeding. We nonetheless conclude that Defendants’ offer to make discovery available to foreign Plaintiffs does not establish that there will be meaningful ease of access to the evidence collected in the consolidated proceedings before us. Of course, there is other evidence that will be important to the Colombian cases, some of which is more readily available in Colombia. The question before us concerns the relative importance of evidence available in the possible forums. See, e.g., Reid-Walen v. Hansen, 933 F.2d 1390, 1396 (8th Cir.1991) (“[T]he district court must examine the materiality and importance of the anticipated witnesses’ testimony and then determine their accessibility and convenience to the forum.”). We look at the theories the parties may seek to prove at trial to determine the importance and availability of possible evidence. E.g., Macedo, 693 F.2d at 688-89 (determining location of damage evidence and then considering where liability evidence most accessible). Liability, for instance, will be a major source of contention at the trials of these cases. Of course, in all cases, Plaintiffs must prove that the vehicles and/or tires were defective and the proximate cause of injuries. In some cases, Ford and Firestone may contest liability on the grounds that vehicle maintenance or repair deficiencies were at fault in the accidents. See Esworthy Aff. ¶ 9 (Supp.App. K). While some records and testimony concerning vehicle and tire service history have already been produced, additional records are likely to be in Colombia. See, e.g., Supp.App. B., Box 117, Document # 17171. This argument does not persuade us that relatively significant portions of material evidence are available only in the alternative forum. Cf. Piper, 454 U.S. at 257, 102 S.Ct. 252 (discussing location of “large proportion” of relevant evidence). Many of the service providers for the Rodriguez and Escobar/Iragorri vehicles and tires are Ford dealerships, raising the possibility that Ford has access to this information through its business channels. Most importantly, Ford and Firestone make no allegations specific to any of these Colombian cases that improper service conditions played a role in the accidents. Cf. Lacey v. Cessna Aircraft Co., 932 F.2d 170, 182 (3d Cir.1991) (Lacey II) (commending district court for finding support for both plaintiffs products liability claim and defendants’ assertions of pilot error and negligent maintenance before proceeding to examine where necessary proof was located). Even if they did, we are not certain that evidence from Colombian service stations, for instance, would tip the scale in favor of a Colombian forum. It is likely that expert testimony about the increased risk of accidents resulting from improper service conditions would be crucial and would come from the United States. See Lopez Blanco Aff. ¶4.2 n. 2 (“[In Atomundial v. BF Goodrich-Icollan-tas, a case brought in Colombia,] it became necessary to dispense with expert testimony because there was no one in the country, other than parts technicians, qualified to discuss the quality, specifications and durability of tires ....”). Instead, Plaintiffs make a convincing case that much of the evidence regarding liability is in the United States. The vehicles in both the Rodriguez cases and the Escobar/Iragorri cases were manufactured in the United States, as were the tires in the Rodriguez cases. Because of their American manufacture, most of the documents and witnesses related to the design, testing, and accident rates of these products are in this country. As noted before, while the relevant documents could be transported to Colombia without much inconvenience, crucial expert reports and deposition testimony probably could not be made available in Colombian courts, demonstrating that the bulk of relevant liability evidence is more accessible in the United States. Evidence on “actual damages” and “moral damages” also will be important to these cases. Damages evidence, consisting of medical and employment records, tax returns, testimony from medical providers, and the like, originate in Colombia, although some of these documents already have been produced here in the United States. See, e.g., Supp.App. B, Box 117, Document # 17195. We do not find that the importance of the evidence remaining in Colombia outweighs that of the evidence relating to liability, most of which is in the United States. This conclusion is especially clear if we address these cases individually, rather than en masse. In each case, the amount of evidence related to that particular Plaintiffs injuries, for instance, likely will be less than the amount of evidence needed to determine whether the tires and/or the Explorer were defective. In sum, ease of access to proof weighs in favor of retaining jurisdiction in the United States. Defendants also fail to show that considerations of compulsory process and the cost of transporting witnesses favor trial in the alternative forum. Defendants point out that no American court will be able to compel testimony of non-party witnesses in Colombia, such as accident witnesses or witnesses providing medical treatment to Plaintiffs. Ford Memo. (Colombia) at 13-14. Of course, the inability to present evidence necessary to the parties’ positions presents a serious inconvenience to trying the cases in the United States. However, letters rogatory, while a potentially cumbersome process, may be used to secure video depositions of Colombian witnesses unwilling to provide testimony in a U.S. trial. See DiRienzo v. Philip Services Corp., 232 F.3d 49, 66-67 (2d Cir.2000) (error to fail to consider ability to obtain witness testimony through letters rogato-ry). Moreover, as we explained above, deposition testimony from U.S. liability witnesses might not be admitted in Colombian proceedings. In such situations, Colombian courts will be unable to exercise compulsory jurisdiction over such witnesses if they are unwilling to travel to Colombia. In Reidr-Walen, the Eighth Circuit found this factor to be a draw, opining that “[i]f the suit is brought in the U.S., the parties will not have compulsory process over Jamaican witnesses. By the same token, if the suit is brought in Jamaica, the parties will lack compulsory process over American witnesses.” 933 F.2d at 1397. Likewise, considerations of the cost of transporting willing witnesses are a wash. In the absence of a clear picture of how many witnesses important to each case are in the United States as compared to the number in Colombia, this factor does not tilt in either direction. Furthermore, it does not seem likely that it would be more costly to travel from the United States to Colombia for trial and home again than it would be to travel from Colombia to the United States for trial and home again. View of the accident scene is possible only if the trial is held in Colombia. Ford and Firestone maintain that the driving conditions to which the vehicles and tires were subjected, rather than a design defect, caused the accidents at issue in these cases. Joint Reply at 25. In such situations, a view of the premises is appropriate, and this factor weighs in favor of the alternative forum. Danser v. Firestone Tire & Rubber Co., 86 F.R.D. 120, 123 (S.D.N.Y.1980) (view of accident scene may be helpful in resolving whether tire rupture caused accident or occurred because of accident, as alleged by defendant); see also Cooper/T. Smith, 1997 WL 465290, at *5 (view of barge relevant when accident allegedly caused by conditions on barge). We next examine “all other practical problems that make trial of a case easy, expeditious and inexpensive.” A host of considerations fall under this rubric, and while not all of them suggest that trial in Colombia would be inconvenient, the sum of them favors retaining these cases for trial in the United States. One frequent consideration, enforceability of judgment, is neutral. See Gilbert, 330 U.S. at 508, 67 S.Ct. 839 (trial in foreign jurisdiction less convenient if there are questions as to whether a judgment obtained there could be enforced). Defendants “explicitly consent that any dismissal be conditioned upon their agreement to satisfy any final judgment entered by the courts of Venezuela or Colombia in favor of the plaintiffs.” Joint Reply at 26. This consent alleviates the concern about satisfying a final judgment because such conditions often are attached to dismissal on the basis of forum non conveniens. Gschwind, 161 F.3d at 607 (approving district court’s dismissal of case on condition that defendants consent to have action reinstated if foreign court refuses jurisdiction); Roynat, 772 F.Supp. at 423 (dismissing case with condition that defendant consent to jurisdiction of foreign court and not raise any statute of limitations defense available under foreign law). Because any judgment rendered in a U.S. forum also could be easily enforced, Defendants’ concession equalizes the two forum choices with respect to this issue. Among the private interests factors, courts also must consider the inability to implead potential third-party defendants. Piper, 454 U.S. at 259, 102 S.Ct. 252. In the Rodriguez cases and the Escobar/Ira-gorri cases, Defendants list as potential third-party defendants a number of service stations and dealerships which allegedly performed maintenance on the tires or vehicles and Bridgestone/Firestone Venezo-lana which manufactured the tires at issue in the Escobar cases. Supp.App. A (entries # 116 — # 120 (citing Answers to Forum Non Conveniens Interrogatories)). They also list the drivers of vehicles involved in the .accidents as third-party defendants in the cases in which the driver is not also a plaintiff. Id. Finally, included as possible third-party defendants, according to Ford and Firestone, are the dealerships, individuals, and/or retail tire establishments that sold the tires and vehicles at issue in these cases. Defendants argue that these third parties are not subject to the jurisdiction of United States courts and are potentially responsible for the accidents allegedly injuring Plaintiffs. Joint Reply at 27. They maintain that Colombia is a more convenient forum because it would permit them to implead these third parties. This factor favors dismissal. See Piper, 454 U.S. at 259, 102 S.Ct. 252 (resolving all claims in one trial more convenient than finding liability in United States and suing for indemnity or contribution in foreign forum). Also worthy of consideration is the expense and inconvenience of translation. Macedo, 693 F.2d at 690; see also Blanco, 997 F.2d at 982. Regardless of where the cases are tried, some evidence will be presented in translation. On the one hand, English translations of medical testimony, service records, and the like would be required for proceedings in the Southern District of Florida. On the other hand, Colombian courts would require Spanish translations of documents and testimony concerning defect. Lopez Blanco Aff. ¶ 5.5 (citing Colombian Code of Civil Procedure, Art. 260). In this situation, the burden on the parties if the trial is held in Colombia cannot be ignored. Hull 753 Corp. v. Elbe Flugzeugwerke GmbH, 58 F.Supp.2d 925, 929 (N.D.Ill.1999). Indeed, the best course is to weigh the amount of evidence that must be translated if the trial remains in the U.S. forum against the amount of evidence to be translated if the trial is held in a foreign forum. See Prevision Integral de Servicios Funerarios, S.A. v. Kraft, 94 F.Supp.2d 771, 779 (W.D.Tx.2000) (noting that, despite defendants’ contentions, only one key document would require translation if court retained jurisdiction, a factor weighing against forum non conveniens motion). As expected, both parties argue that the burden of translation is lightest for their respective preferred forums. Plaintiffs make the more persuasive argument. Millions of documents in English concerning liability have been produced by Ford and Firestone into the document depositories for this MDL. As Defendants correctly contend, at the time of the briefing on forum non conveniens, only about 2,000 of these documents had been marked as deposition exhibits, and at a trial, it is likely that even fewer documents would be introduced into evidence. Even with this discounted number of English-language liability documents, we find, nevertheless, that the translation burden of trying these cases in the Southern District of Florida is less than if the cases were tried in Colombia. First, translating even “several hundred” liability documents, as Defendants estimate, would be no small task. Second, most liability documents from Ford Motor de Venezuela and Bridgestone/Firestone Venezolana were originally authored in English or have already been translated from Spanish to English, and liability witnesses were deposed in English, via translation. See Quinlan Aff., MDL Docket No. 1394. For those cases in which Ford and Firestone plan to defend by pointing to poor driving of other parties, the accident report has already been translated into English. Plaintiffs/Firestone Stips. ¶ 10. While Plaintiffs’ prior medical histories probably are primarily in Spanish, records of subsequent treatment are in both English and Spanish. Id. ¶ 11. Of course, depending on Defendants’ strategy, the testimony of accident witnesses and maintenance records must be translated into English for a U.S. trial, but, for each case, the amount of such evidence will be considerably less than the amount of evidence needed to prove defect and damages, the vast majority of which is in English. As part of the balancing of conveniences, we also factor in physical threats to litigants and witnesses arising from the current volatile political situation in Colombia. In Iragorri II, the Second Circuit instructed the lower court that plaintiffs’ fears for their safety in Cali, if warranted, were “highly relevant to the balancing inquiry.” 274 F.3d at 75; see also Guidi, 224 F.3d at 147 (attacks on tourists in Egypt should be considered in the balancing of conveniences). We find that Plaintiffs’ concerns are warranted. As recently as February 20, 2002 the Colombian government called off peace talks with Fuerzas Armadas Revolucionarias de Colombia (FARC). U.S. Dep’t of State Public Announcement on Colombia, 2/2/02. Since the collapse of peace talks, “[t]he security situation in Colombia has worsened.” Id. Two government officials, Senator Jorge Eduardo Gechem Turbay and Senator Ingrid Betancourt, also a presidential candidate, were kidnapped in late February. Juan Forero, Colombian Rebels Hijack a Plane and Kidnap a Senator, N.Y. Times, Feb. 21, 2002, at Al; Juan Forero, Colombian Rebels Sabotage Peace Hopes, N.Y. Times, Feb. 25, 2002 at Al. Bombing and sabotage attacks on infrastructure have interrupted electricity, water, and phone services in a number of cities and towns across six provinces. Juan Forero, Colombian Rebels Step Up Pace and Intensity of Attacks, N.Y. Times, Mar. 4, 2002 at Al. For the purposes of our inquiry, of particular interest is the fact that, in the recent past, judicial officers have been the targets of guerilla violence. Amnesty International Report 1998: Colombia (1998) at http://www.amnesty.org.ailib.aire-port/ar98/amr23.htm. Defendants argue that a similar argument was rejected in Iragorri I. Joint Reply at 19-20 (citing Iragorri I, 203 F.3d at 13). However, two important distinctions separate Iragorri I from the situation we consider here. First, Iragorri I was decided well over two years ago. Since then, the situation in Colombia appears to have worsened. It was only one month ago that President Pastrana called off talks with FARC and that violence in the region increased. Considering recent developments in the alternative forum is in keeping with the crux of the forum non conveniens inquiry — convenience. Cf Aguinda v. Texaco, Inc., 2000 WL 122143, at *1-2, 2000 U.S. Dist. LEXIS 745, at *4-8 (S.D.N.Y.2000) (requesting additional briefing on adequacy of alternative forum in light of military coup in Equador, the proposed alternative forum). Second, in Iragorri I, the First Circuit held that it was not an abuse of discretion to find that Colombia was an adequate alternative forum despite political instability and violence. 203 F.3d at 14. Rather than finding that Colombia is not an adequate alternative forum on this basis, we conclude only that these problems make trial there less convenient. In Guidi, the plaintiffs were a shooting victim and the widows of two other shooting victims attacked by an Egyptian gunmen at the Semiramis Inter-Continental Hotel in Cairo. 224 F.3d at 143-44. The Second Circuit held that the plaintiffs’ fears of litigating in a country where foreigners have been the target of hostile attacks were an important reason for keeping the case in the chosen forum of New York, especially where the plaintiffs themselves had suffered the effects of one such attack already. Id. at 147. Likewise, in Iragorri II, the Second Circuit held that the district court must at least consider in the balancing of conveniences the plaintiffs’ safety fears and the possibility that witnesses may be unwilling to travel to Colombia due to political unrest. 274 F.3d at 75. Following this lead, we find that the political instability and violence in Colombia, especially in light of the worsening situation since the collapse of peace talks, is a factor weighing in favor of retaining jurisdiction over these cases in U.S. courts. We find that the balancing of the private interest factors weighs in favor of retaining jurisdiction in the United States. While certain factors favor dismissal, we conclude that these factors are not as weighty as those factors favoring retention of jurisdiction over the cases. For instance, the possibility of viewing the premises if the trials are in Colombia is not a strong factor in Defendants’ favor. Their argument that a view of the accident scene is necessary boils down to the supposition that it “would be difficult for an American to imagine” conditions like “[hjigh-speed driving over road conditions with steep shoulders with sharp drop-offs.” Joint Reply at 25. Ford and Firestone underestimate both their lawyers’ rhetorical capabilities and the typical American juror’s ability to understand and even to imagine. Other courts deciding forum non conve-niens motions have found that this factor carries little weight when other media are available. See, e.g. Reid-Walen, 933 F.2d at 1398 (boating accident scene could be established “through aerial photographs and other demonstrative evidence or testimony”); Massaquoi v. Virgin Atlantic Airways, 945 F.Supp. 58, 62 (S.D.N.Y.1996) (pictures or videotape adequate to show emergency airplane exit slide involved in flight attendant training exercise resulting in physical injury). The ability to implead third parties also does not carry the day for Defendants. Most importantly, Ford and Firestone do not provide any evidence specific to the Rodriguez and Escobar/Iragorri cases to support their general allegation that the tires and vehicles were improperly serviced, that the drivers involved in the accidents were negligent, or that the sellers of the vehicles and tires engaged in any actionable activity. While we are not to entangle ourselves in the merits of the underlying dispute at this stage of the proceedings, more than general allegations are needed to support Defendants’ claim that third parties were responsible for Plaintiffs’ injuries. See Lacey II, 932 F.2d at 182 (approving of lower court’s finding that evidence supported defendants’ third party liability argument only after lower court examined defendants’ affidavits in support of contention). We summarize our analysis above: certain factors come out as a wash — witness availability and enforceability of judgment. Two factors favor trial in Colombia — possibility of view of the premises and ability to implead third parties. However, three more crucial factors indicate that trial in the United States is more convenient— access to proof, the expense and burden of translation, and the political instability and threats of violence in Colombia. In balancing these factors, we regard the latter as particularly weighty, given the facts before us. Thus, the private interests factors dictate that Defendants’ motion should be denied. Public Interest Factors — Colombia Next we consider the public interest factors. The public interest factors focus on the administrative difficulties flowing from court congestion; the local interest in having localized controversies decided at home; the interest in having the trial of a diversity case in a forum that is at home with the law that must govern the action; the avoidance of unnecessary problems in conflict of laws, or in the application of foreign law; and the unfairness of burdening citizens in an unrelated forum with jury duty. Piper, 454 U.S. at 241 n. 6, 102 S.Ct. 252 (citing Gilbert, 330 U.S. at 509, 67 S.Ct. 839). First, we examine the respective local interests in these cases. Ford and Firestone argue that only the interests of Colombia are implicated in these actions. Joint Reply at 31. The accidents occurred on the roads and highways of Colombia, and the impact of medical treatment and economic loss is felt only in Colombia. Id. Certainly, Colombia has an interest in protecting the lives and health of those who use its highways and an interest in determining the extent of damages payable to those injured in these accidents. See Leon, 251 F.3d at 1315. Contrary to Defendants’ assertions, however, the United States has some interest in the resolution of these cases. A few courts recite the maxim that “[t]he defendant’s home forum always has a strong interest in providing a forum for redress of injuries caused by its citizens.” Reid-Walen, 933 F.2d at 1400. Kamel suggests that this maxim has less weight where, as here, Defendants are American corporations with extensive foreign business dealings, 108 F.3d at 804, but the U.S. interest in this case extends beyond the general notion that our corporations can be held accountable in United States courts for injuries caused to foreign nationals. Plaintiffs present evidence that Ford and Firestone’s early warning of alleged serious problems with their products stemmed from reports of unusually high accident rates in South America and other foreign markets. E.g., DaSilva Dep. at 112-116 (in October of 1998, Ford Venezuela began receiving reports of tire failures that were conveyed, within months, to Ford and Firestone officials in the United States). American interest in Ford and Firestone’s investigations of these accidents has been high, on the theory that had the public and the relevant government agencies known of the problems sooner, fewer deaths and serious injuries would have occurred on U.S. highways. In fact, this topic was the subject of congressional committee hearings in the fall of 2000. See, e.g., Prepared Statement of Dr. Sue Bailey, Administrator, National Highway Traffic Safety Administration to the Joint Hearing of the Subcommittee on Telecommunications, Trade & Consumer Protection and the Subcommittee on Oversight & Investigations, attached as App. 1 to Defs.’ Memo, in Opp. to Class Pis.’ Mot. for Prelim. Inj. Both Colombia and the United States have legitimate interest in these cases such that this factor does not weigh heavily in favor of Defendants’ position on forum non conveniens. Defendants argue that the need to apply Colombian law in these cases strongly counsels in favor of dismissal. Ford Memo. (Colombian Cases) at 16. According to Ford and Firestone, granting the forum non conveniens motions would solve two related problems mentioned in Piper. First, the Southern District of Florida, the federal court from where these Colombian cases originated and where they will be tried absent forum non conveniens dismissal, is not familiar with the law of Colombia. See Bhatnagar, 52 F.3d at 1226 n. 5 (“[Cjourts should prefer to have cases adjudicated in the forum familiar with the law to be applied, instead of taking it upon themselves to become educated about foreign law”). Second, Defendants argue that dismissing these cases would “avoid[ ] unnecessary problems in conflict of laws, or in the application of foreign law.” See Piper, 454 U.S. at 241 n. 6, 102 S.Ct. 252 (citing Gilbert, 880 U.S. at 509, 67 S.Ct. 839). This factor is not as clearly in Defendants’ favor as it might appear to be at first blush. Ford and Firestone do not argue that foreign law applies to all issues in the cases. Instead, Defendants contend that Colombia supplies the substantive law applicable to the issues of liability and compensatory damages. Joint Reply at 35. According to Defendants, under Florida’s choice of law rules, the law of Michigan applies with respect to punitive damages claims against Ford. Memo, in Supp. of Def. Ford’s Mot. to Strike Pis.’ Req. for Punitive Damages or, in the Alternative, for Part. Summary Judgment in Favor of Ford on Pis.’ Req. for Punitive Damages at 3-4. This concession reduces the potential for problems in conflict of laws or in the application of foreign law. By Defendants’ reasoning, on some issues, at least, the parties and the Florida court will not face the burden of translating, interpreting, and applying the law of Colombia. We look next at the administrative difficulties likely to arise if these cases are not dismissed. Five cases involve Colombian Plaintiffs. Defendant Ford expresses great concern that the burden of coordinating and arranging discovery and deciding motions in these cases “would threaten to grind the entire pretrial process to a halt, harming Colombian and American parties alike.” Ford Memo (Colombian Cases) at 20. While we acknowledge that coordinating the multidistrict litigation in the Firestone cases is no small task for the Court, we are not so overwhelmed that five cases out of the now pending 700 would constitute the proverbial straw. See, e.g. Peregrine, 89 F.3d at 47 (courts have much discretion in determining whether they can accommodate additional cases); McLellan, 26 F.Supp.2d 947 (acknowledging its very large docket but exercising its discretion to decide that case would not interfere with court’s other business). The burden of trial, as opposed to pretrial proceedings, does not fall on our court, making us slightly less comfortable with determining that these cases can be accommodated. As Defendants point out, the Southern District of Florida is a busy court. Joint Reply at 31 (citing 2000 State of the Court, Southern District of Florida, at 7). However, because of the demands made upon it due in part to “its geographic locations as a gateway to the Caribbean and South America,” the Southern District of Florida “has been a historical leader in case processing innovations.” 2000 State of the Court, Southern District of Florida, at 7. Indeed, the Southern District of Florida seems uniquely positioned among United States courts to meet the challenges presented by these cases. See id. (court staff includes “linguists, who provide interpreter services in a wide variety of languages”). Moreover, as noted earlier, there is local interest in the cases which justifies the commitment of judicial resources to their resolution. See Piper, 454 U.S. at 261, 102 S.Ct. 252. On the whole, the balance of public factors does not compel the dismissal of these cases on the ground of forum non conve-niens. While we cannot ignore Colombia’s interest in the safety of its citizens, neither can we ignore the U.S. interest in these cases as evidenced by Congressional testimony about the notice Ford and Firestone received on the alleged defects through the accidents in South America. See In re Air Crash Off Long Island New York, on July 17, 1996, 65 F.Supp.2d 207, 217 (S.D.N.Y.1999) (congressional hearings and investigations by administrative agencies suggest sufficient public interest to justify imposition of jury duty). The need “to delve into the tenets of an unfamiliar legal system” for the issues of liability and compensatory damages is “justifiably [a] concern[]” to district courts. Kamel, 108 F.3d at 805. However, “we must guard against an excessive reluctance to undertake the task of deciding foreign law, a chore federal courts must often perform.” Manu International, S.A. v. Avon Products, Inc., 641 F.2d 62, 68. We have no doubt that our court and the Southern District of Florid