Free Joint Status Report - District Court of Federal Claims - federal

Case 1:02-cv-00024-FMA

Document 125

Filed 11/13/2007

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UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ PUEBLO OF LAGUNA, ) ) Plaintiff, ) ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant. ) ____________________________________)

No. 02-24L Judge Francis M. Allegra

JOINT STATUS REPORT Plaintiff, the Pueblo of Laguna, and Defendant, the United States, (the "parties"), respectfully submit this Joint Status Report to the Court regarding the parties' progress on document production and indexation issues since their last joint status report filed on August 14, 2007. I. DOCUMENT PRODUCTION AND INDEXATION PLAN STATUS Since the last status report, the parties have continued to concentrate their efforts on document production, indexation issues, and ADR in Jicarilla v. United States, Docket No. 2-25L. The parties are pleased with their efforts to work collectively and diligently to address all document production and indexation issues in Jicarilla. As previously reported to the Court, the parties are optimistic that they will be able to utilize the lessons learned in Jicarilla to resolve any document production and indexation issues that may arise in this case. Plaintiff continues developing a plan for the retrieval of documents from various Pueblo repositories and has begun the process of conducting a preliminary analysis of the Pueblo's repositories that may contain records relevant to the case. As such, Plaintiff continues to engage in preliminary discussions with Pueblo officials about the collection of documents and will remain in communication with Defendant as the discussions progress.

Case 1:02-cv-00024-FMA

Document 125

Filed 11/13/2007

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As the parties' experts continue to focus more on the evaluation of records and analysis of the issues in the Jicarilla ADR, the parties remain optimistic that this will allow the parties to direct their efforts to addressing document production and indexation in this case. II. ALTERNATIVE DISPUTE RESOLUTION The parties are pleased with the significant progress that has been made in the Jicarilla ADR proceedings. They share a similar commitment to collectively and diligently resolve any issues that may arise in ADR in this case. The parties are optimistic that they will be able to apply what they have learned in the Jicarilla ADR proceedings to facilitate the resolution of issues in the subsequent ADR proceedings in this case. The parties shall report further to the Court on these matters of indexation and production of documents on or before February12, 2008 unless the Court orders otherwise or unless intervening events warrant an earlier report. Respectfully submitted this 13th day of November, 2007.

/s Alan R. Taradash by /s Donald H. Grove Alan R. Taradash Nordhaus Law Firm, LLP 405 Dr. Martin Luther King Jr. Ave. NE Albuquerque, NM 87102-3541 telephone: 505-243-4275 facsimile: 505-243-4464

/s Robert W. Rodrigues by /s Donald H. Grove Robert W. Rodrigues U.S. Department of Justice Environment and Natural Resources Division Natural Resources Section P.O. Box 663 Washington, DC 20044-0663 telephone: 202-305-0484 facsimile: 202-305-0506 Attorney of Record for Defendant

Attorney of Record for Plaintiff

Thomas J. Peckham Daniel I.S.J. Rey-Bear Deidre A. Lujan

Laura Maroldy E. Kenneth Stegeby U.S. Department of Justice 2

Case 1:02-cv-00024-FMA

Document 125

Filed 11/13/2007

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Nordhaus Law Firm, LLP 405 Dr. Martin Luther King Jr Ave NE Albuquerque, NM 87102 telephone 505-243-4275 Of Counsel

Environment and Natural Resources Division Natural Resources Section P.O. Box 663 Washington, DC 20044-0663

Donald H. Grove Nordhaus Law Firm, LLP Suite 801 1401 K Street NW Washington, DC 20005 telephone 202-530-1270 Of Counsel

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