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

Case 1:02-cv-01383-MMS

Document 46

Filed 11/20/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

SAMISH INDIAN NATION, a federally recognized Indian tribe, Plaintiff, v. THE UNITED STATES OF AMERICA, Defendant.

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

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Parties' Joint Status Report

Pursuant to this Court's Order of July 21,2006 as amended by the Order of September 18, the parties respectfully submit this joint status report.

In accord with the Court's Order of July 21, Plaintiff served its discovery request on Defendant on July 26, 2006. This included requests for admission, interrogatories and requests for production of documents. On October 19 and November 1, Defendant served its responses to those discovery requests.

Defendant's responses include a series of objections to Plaintiffs discovery. Plaintiff has proposed to Defendant that the parties undertake to try and resolve those discovery disputes informally, and Defendant has expressed a willingness to explore this.

Case 1:02-cv-01383-MMS

Document 46

Filed 11/20/2006

Page 2 of 2

The parties propose that they be allowed a period of 60 days to try to resolve the discovery disputes, and submit to the Court on or before January 19,2007, a report on the progress of that effort. Dated: November 20,2006 Respectfully submitted,

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Craig J. ~ d r s gEsq. ~, Attorney at Law 1 S.W. Columbia, Suite 440 Portland, Oregon 97258 Telephone: (503) 790-9060 Facsimile: (503) 790-9068

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United States Department d Juhtice f Natural Resources Section b y A.*C 1uom 1961 Stout Street, SthFloor DL3 a~.ttb(/1& Denver CO 80294 Telephone: (303) 844- 1487 Facsimile: (303) 844- 1350

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Counsel of Record for Plaintiff Samish Indian Nation

Counsel of Record for Defendant

Of Counsel to the Samish Indian Nation: William R. Perry, Esq. Anne D. Noto, Esq. Sonosky, Chambers, Sachse, Endreson & Perry, LLP 1425 K Street, N.W. Suite 600 Washington, D.C. 20005 Telephone: (202) 682-0240 Facsimile: (202) 682-0249