Free Status Report - District Court of Federal Claims - federal

Case 1:02-cv-00024-FMA

Document 115

Filed 08/14/2006

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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 May 16, 2006. I. INDEXATION PLAN STATUS AND DOCUMENT PRODUCTION As previously reported to the Court in the parties' last joint status report, 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 a second significant issue in the context of the Jicarilla ADR. Subject to document collection with respect to the second issue to be considered in the Jicarilla ADR, the parties intend to place greater emphasis on collecting and producing documents related to the issues in this case. Plaintiff has recently started to discuss and develop a plan for the time intensive process of collecting documents from various Pueblo repositories. Plaintiff

anticipates that it will be in a position to start collecting documents in the near future. The parties are optimistic that they will be able to work cooperatively as they have been in the Jicarilla case to

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resolve document production and indexation issues as they arise in this case. The parties will of course bring my 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 November 13, 2006 unless the Court orders otherwise or unless intervening events warrant an earlier report. Respectfully submitted this 14th day of August, 2006.

/s Alan R. Taradash by /s Thomas J. Peckham 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 Thomas J. Peckham 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 Of Counsel

Martin LaLonde Laura Maroldy Kenneth Stegeby U.S. Department of Justice Environment and Natural Resources Division Natural Resources Section P.O. Box 663 Washington, DC 20044-0663

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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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Case 1:02-cv-00024-FMA

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