IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 
____________________________________
) 
ELOUISE PEPION COBELL, et al., ) 
Plaintiffs, 
v. 
GALE A. NORTON, Secretary of 
the Interior, et al., 
) 
) 
)
)
)
)
) No. 1:96CV01285 
(Judge Lamberth) 
Defendants. 
)
) 
DEFENDANTS’ SECOND SUBMISSION IN COMPLIANCE 
WITH MAY 28, 2004 MEMORANDUM AND ORDER 
REGARDING HISTORICAL STATEMENTS OF ACCOUNT 
In accordance with the Court's Memorandum and Order dated May 28, 2004, 
Defendants hereby submit a sample of the supplemental notice to be mailed to the Individual 
Indian Money account holders who received historical statements of account in October 2002.1 
The sample notice is attached as Exhibit 1. 
Respectfully submitted, Dated: August 18, 2004 
ROBERT D. McCALLUM, JR. 
Associate Attorney General 
PETER D. KEISLER 
Assistant Attorney General 
STUART E. SCHIFFER 
Deputy Assistant Attorney General 
J. CHRISTOPHER KOHN 
Director 
1/ As required by the Court, the sample document is redacted to remove all personally identifying 
information regarding the recipient. See Memorandum and Order at 5 n.3 (May 28, 2004).
/s/ Cynthia L. Alexander 
SANDRA P. SPOONER 
D.C. Bar No. 261495 
Deputy Director 
JOHN T. STEMPLEWICZ 
Senior Trial Counsel 
CYNTHIA L. ALEXANDER 
Trial Attorney 
Commercial Litigation Branch 
Civil Division 
P.O. Box 875 
Ben Franklin Station 
Washington, D.C. 20044-0875 
(202) 514-7194 
2
CERTIFICATE OF SERVICE 
I hereby certify that, on August 18, 2004 the foregoing Defendants' Second Submission in 
Compliance with May 28, 2004 Memorandum and Order Regarding Historical Statements of 
Account was served by Electronic Case Filing, and on the following who is not registered for 
Electronic Case Filing, by facsimile: 
Earl Old Person (Pro se) 
Blackfeet Tribe 
P.O. Box 850 
Browning, MT 59417 
Fax (406) 338-7530 
/s/ Kevin P. Kingston 
Kevin P. Kingston
United States Department of the Interior 
OFFICE OF HISTORICAL TRUST ACCOUNTING 
1801 Pennsylvania Avenue, NW, Suite 500 
Washinaton. DC 20240 
Dear Parent(s) or Guardian: 
Phone (202) 327-5300 
Fax (202) 327-5375 
[Date] 
Re: Individual Indian Money Account #- 
Please be aware that many Individual Indian Money account holders are members of a class action 
lawsuit, Cobell v. Norton, No. 1:96CV01285 (D.D.C.) (Judge Lamberth). In October 2002 the above 
referenced account holder received a Historical Statement of Account, along with a cover letter notifymg 
the account holder of the action they should take if they wanted to challenge the accuracy of that 
statement. Nothing in that notice should be interpreted as eliminating any rights that the account holder 
may have if they are a class member in that litigation. If the account holder is a class member and fails to 
challenge this Historical Statement of Account they do not lose any rights that they have as a class 
member. For further information you may contact the lawyers for the class members: Dennis M. 
Gingold, Esq., 607 14' Street, N.W., 9" Floor, Washington, DC 20005, phone: (202) 824-1448, fax: 
(202) 3 18-2372, email: dennismrrincrold@,aol.com, or Keith Harper, Esq., Native American Rights Fund, 
1712 N Street, N.W., Washington, DC 20036-2976, phone: (202) 785-4166, fax: (202) 822-0068, email: 
harper@,narf.org. You may also access further information at the plaintiffs' website, 
www,indiantrust.com. 
Very truly yours, 
Bert T. Edwards, Executive Director 
EXHIBIT 1 
Defendants' Second Submission in Compliance 
with May 28,2004 Memorandum and Order 
Regarding Historical Statements of Account