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

Case 1:02-cv-00024-FMA

Document 116

Filed 11/13/2006

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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, 2006. I. INDEXATION PLAN STATUS AND DOCUMENT PRODUCTION As reported to the Court in the parties' earlier joint status reports, focus has been placed on document production and indexation issues primarily related to Jicarilla v. United States, Docket No. 2-25L. The parties agreed to set aside Pueblo of Laguna document production and indexation to focus first on completing document production and indexation for Jicarilla. This includes two significant, discrete segments of claims at issue in the context of the Jicarilla ADR. Subject to document collection with respect to these two significant, discrete segments of claims to be considered in the Jicarilla ADR, the parties intend to turn to the collection and production of documents related to the issues in this case. Plaintiff has been developing a plan for the time intensive process of collecting documents from various Pueblo repositories. Plaintiff

anticipates that retrieval, scanning, and coding of Pueblo of Laguna documents may get underway even as the parties proceed with Jicarilla production. The parties are optimistic that they will be able to work cooperatively as they have been in the Jicarilla case to resolve document production

Case 1:02-cv-00024-FMA

Document 116

Filed 11/13/2006

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and indexation issues as they arise in this case, further assisted by the protocols already established in the Jicarilla case. The parties will of course bring any unresolved issues to the attention of the Court. II. ALTERNATIVE DISPUTE RESOLUTION The parties continue to make progress in the Jicarilla ADR. At the appropriate time when the parties turn to issues in this case in ADR, the parties will benefit greatly from the experience gained in the Jicarilla ADR. The parties shall report further to the Court on these matters of indexation and production of documents on or before February 12, 2007 unless the Court orders otherwise or unless intervening events warrant an earlier report. Respectfully submitted this 13th day of November, 2006.

/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 Rodrigues by /s Donald H. Grove Robert 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 Nordhaus Law Firm, LLP 405 Dr. Martin Luther King Jr Ave NE Albuquerque, NM 87102 telephone 505-243-4275

Martin LaLonde Laura Maroldy Kenneth Stegeby U.S. Department of Justice Environment and Natural Resources Division Natural Resources Section P.O. Box 663 2

Case 1:02-cv-00024-FMA

Document 116

Filed 11/13/2006

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Of Counsel

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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