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

Case 1:02-cv-01383-MMS

Document 50-4

Filed 01/08/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS
SAMISH INDIAN NATION, a federally recognized Indian tribe, Plaintiff,

Case No. 02-1383L (Chief Judge Edward J. Damich)

v.
THE UNITED STATES OF AMERICA, Defendant.

)

1

EXHIBIT 3 TO PARTIES' JOINT STATUS REPORT

January 8,2007

Case 1:02-cv-01383-MMS

Document 50-4

Filed 01/08/2007

Page 2 of 3

LAWOFFICES

SONOSKY, CHAMBERS, SACHSE, ENDRESONPERRY, & LLP
1425 K STREET, NW, SUITE 600 WASHINGTON, DC 20005 TEL (202) 682-0240 I FAX (202) 682-0249
WWW .SONOSKY.COM

MARVIN J . SONOSKY (1909-1997) HARRY SACHSE R. CHAMBERS REIDPEYTON R. WILLIAM PERRY BENTON MILLER LLOYD DOUGM B. L. ENDRESON DoK+LaJ. Q!?.~oI'J MYRA M. MUNSON (AK)* ANNE D. NOTO MARYJ . PAVEL DAVIDC. MIELKE JAMES E. GLAZE GARY BROWNELL F. (NM)* COLIN C. ~ P S O N JAMES T. MEGGESTO DOUGM W. WOLF

December 15,2006

MARISSA FLANNERY K. (AK)* MELANIEB. OSBORNE (AK)' VANESSAL. RAY-HODGE WILLIAM STEPHENS F. ADDIE C.ROLMCK JENNIFER J . THOMAS (CA)* Y A ~ B I ? ! EE. ?.?CP.S.K (m:* CAROLE HOLLEY ~ i ( ) * A. (
OF COUNSEL
ARTHUR LAZARUS, JR.

By Email - Original by Mail

ROGER DUBROCK W. (AK)* KAYE. WEN GOUWENS (AK)' MATTHEWS. JAPPE RICHARD D. M O N W (AK)* AARON S C H(AK)' M. ~

Devon Lehman McCune, Trial Attorney U.S. Department of Justice Environment & Natural Resources Division Natural Resources Section 1961 Stout Street, 8" Floor Denver, CO 80294 Re: Samish Indian Nation v. United States, No. 02-1 383 (Fed. C1.) Dear Ms. McCune: On November 15, we discussed with you our proposal that the parties undertake to try and resolve discovery disputes informally by scheduling times when we could meet with you and the appropriate government officials to talk about our discovery requests. We further proposed that, in the interests of facilitating resolution of these issues, we focus on only TPA and IHS funding, and defer matters relating to all other programs. At that time, you expressed a willingness to explore this and said you would confer with your clients. A month has now passed and we have not heard from you - other than your email of December 8 reporting only that you have been having discussions with your clients and hoped to have more information for us this week. This week has come and gone with no further response fiom you. Given the Court's order, if we are going to make any progress towards resolving our disputes on the discovery, the Government needs to act. Is the Government willing to schedule meetings or conference calls at
84648.1
.. ... , .
..
,

Case 1:02-cv-01383-MMS

Document 50-4

Filed 01/08/2007

Page 3 of 3

Devon Lehman McCune, Trial Attorney December 15,2006 Page 2 which we can talk with you and appropriate Government officials about our discovery requests regarding TPA and IHS h d i n g ? If so, the Government needs to advise us as soon as possible of the names of the officials who would be available for such discussions, as well as possible dates when these discussions or meetings might occur. Sincerely,

William R. Perry Anne D . Noto cc: Craig Dorsay, Esq.