Free Status Report - District Court of Federal Claims - federal

Case 1:88-cv-00508-EGB

Document 96

Filed 12/18/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

) ) Plaintiff, ) v. ) ) THE UNITED STATES, ) ) Defendant, ) _________________________________________ )

THE NAVAJO NATION,

No. 508-88L Senior Judge Eric G. Bruggink

JOINT STATUS REPORT Pursuant to the United States' October 22, 2007 Status Report and the Plaintiff's October 23, 2007 Status Report, the parties submit the following joint report. 1. In their October reports, the parties stated their intention to propose a case

management plan on or before today, December 18, 2007. 2. The parties have discussed proposals for further proceedings in this case on

several occasions. To date, however, the parties have not reached an agreement on a proposed plan. 3. On December 3, 2007, Plaintiff transmitted a proposed case management plan to

the United States. Plaintiff transmitted a revised proposed case management plan to the United States on December 6, 2007. 4. The parties discussed Plaintiff's proposal, and alternative proposals, on

December 6, 2007. 5. On December 12, 2007, the United States transmitted a revised proposed case

management plan to Plaintiff. Plaintiff is currently considering the United States' proposal.

Case 1:88-cv-00508-EGB

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6.

The parties agree that additional time is needed to fully discuss and explore the

available options. 7. The parties propose submitting a proposed case management plan in this action

on or before January 14, 2008. Dated: December 18, 2007 Respectfully submitted, BRUCE R. GREENE M. CATHERINE CONDON Greene, Meyer & McElroy, P.C. 1007 Pearl St., Ste. 220 Boulder, Colorado 80302 (303) 442-2021 (phone) (303) 444-3490 (fax) PETER J. OSETEK 412 E. Huron Street Ann Arbor, Michigan 48104 (734) 769-4500 Counsel for the NAVAJO NATION By: /s Bruce R. Greene Bruce R. Greene

WILLIAM J. SHAPIRO Trial Attorney United States Department of Justice Environment and Natural Resources Division Natural Resources Section 501 I Street, Suite 9-700 Sacramento, California 95814 (916) 930-2207 (phone) (916) 930-2210 (fax)

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Case 1:88-cv-00508-EGB

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MARK BARRON Trial Attorney United States Department of Justice Environment and Natural Resources Division Natural Resources Section 601 D Street, NW Washington, DC 20004 (202) 305- 0490 (202) 305-0506 (fax) Counsel for the UNITED STATES OF AMERICA By: /s William J. Shapiro

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