DOJ: Cobell v. Norton, et al. Case No. 1:96CV01285 (D.D.C.)

Civil Division

U.S. Department of Justice

Cobell v. Norton, et al.

Case No. 1:96CV01285 (D.D.C.)

April, 2003 Filings

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**Cobell Case Documents**
Date and Summary	Full Title
April 30, 2003 Government files for leave to file supplemental authority in connection with motion to strike pleading requesting personal sanctions against Government employees and their personal counsel	Interior Defendants' Motion for Leave to File Supplemental Authority in Support of Interior Defendants' Motion to Strike Plaintiffs' Request for Personal Sanctions in Plaintiffs' Comments to the January 27,2003 Corrected Report and Recommendation of the Special Master (Mar. 4,2003) PDF OCR
April 30, 2003 Government seeks to limit testimony of witness to rebuttal testimony due to fact that plaintiffs concealed their true plan for use of his testimony and expressly misrepresented his role in the case	Motion for Reconsideration of Interior Defendants' Motion In Limine to Exclude Expert Testimony of Paul Homan as Other than a Rebuttal Witness PDF OCR
April 29, 2003 Government notes numerous deficiencies in Plaintiffs' "unilateral" Pretrial Statement	Defendants' Objections to the Pretrial Statement Submissions of Plaintiffs PDF OCR
April 28, 2003 Interior moves to disqualify Plaintiffs' expert witness who worked for Cobell Special Master, in light of appearance of impropriety, and to disqualify Dennis Gingold as that expert's counsel based on conflict of interest	Interior Defendants' Motion to Disqualify Joseph Christie as Expert Witness for Plaintiffs and to Disqualify Dennis Gingold as Counsel for Joseph Christie PDF OCR
April 28, 2003 Government seeks to bar testimony of high-ranking Treasury officials, whose testimony would be tangential to Phase 1.5 issues, in light of Plaintiffs' failure to show required extraordinary circumstances	Defendants' Motion In Limine to Preclude the Testimony of General Counsel Aufhauser and Fiscal Assistant Secretary Hammond at the Phase 1.5 Trial PDF OCR
April 28, 2003 Interior seeks to exclude from evidence Special Master's unfinished report that is based, in part, on secretly acquired information	Interior Defendants' Motion In Limine to Exclude Interim Report of the Special Master Regarding the Filing of Interior's Eighth Quarterly Report and All Evidence Related to the Special Master's Incomplete Investigation PDF OCR
April 28, 2003 Interior seeks to prevent Plaintiffs from calling Associate White House Counsel, who could provide no information relevant to Phase 1.5 issues, as witness at trial	Interior Defendants' Motion In Limine to Preclude the Testimony of Kyle Sampson PDF OCR
April 28, 2003 Interior seeks to exclude Plaintiffs' rebuttal witness from testifying in areas in which he is not qualified	Interior Defendants' Motion In Limine as to Plaintiffs' Proffered Expert "Rebuttal" Testimony and Opinions PDF OCR
April 25, 2003 Interior requests expedited hearings in connection with additional motions having to do with upcoming trial	Department of the Interior's Response To the Second Investigative Report of the Special Master Regarding the Office of Trust Records PDF OCR
April 25, 2003 Government rebuts Plaintiffs' argument that Interior's motion for summary judgment with respect to its Historical Accounting plan is legally defective	Defendants' Reply in Support of Motion for Partial Summary Judgment That Interior's Historical Accounting Plan Comports With Their Obligation to Perform an Accounting PDF OCR
April 25, 2003 Interior points out that its Trust Management plan complies with all relevant legal requirements, while Plaintiffs' plan does not	Defendants' Reply in Support of Motion for Partial Summary Judgment That Interior's Trust Management Plan Comports with Their Obligation to Perform an Accounting PDF OCR
April 25, 2003 Interior reiterates its motion for summary judgment on basis of statute of limitations in light of Plaintiffs failure to show that there exists any genuine issue of material fact that Plaintiffs knew or should have known of their claims prior to October 1, 1984	Defendants' Notice of Filing of Redacted Version of Reply in Support of Motion for Partial Summary Judgment Regarding Statute of Limitations and Laches PDF OCR
April 25, 2003 Interior requests expedited hearings in connection with motions having to do with upcoming trial	Interior Defendants' Motion for Expedited Consideration of Certain Pre-Trial Motions PDF OCR
April 21, 2003 Interior urges exclusion of expert testimony by unqualified witness on reliability and relevance of methodologies used in Plaintiffs' plan	Interior Defendants' Motion In Limine as to Plaintiffs' Proffered Expert Testimony and Report Regarding the Reliability and Relevance of Methodologies Employed in Plaintiffs' Plan PDF OCR
April 18, 2003 Interior asks Court to withdraw sanctions imposed in earlier Order, noting that Plaintiffs' misstatements of fact and fundamental errors of law do not address applicable rule upon which Court based it decision	Interior Defendants' Reply Brief in Further Support of Their Motion for Reconsideration of the Court's March 11, 2003 Memorandum and Order Insofar as it Granted Plaintiffs' Motion for Sanctions PDF OCR
April 18, 2003 Interior seeks to bar testimony of plaintiffs' expert who relies on untested, unchallenged, undefined and unreliable methodologies	Interior Defendants' Motion In Limine to Exclude Plaintiffs' Plan for Determining Accurate Balances in the Individual Indian Trust and All Evidence Offered in Support PDF OCR
April 18, 2003 Interior seeks to exclude Plaintiffs' plan since it is a plan for calculating damages, rather than performing an accounting and is, therefore, irrelevant to the Phase 1.5 trial	Interior Defendants' Motion In Limine with Regard to Expert Testimony and Report in Support of Plaintiffs' Plan For Determining Accurate Balances in the Individual Indian Trust PDF OCR
April 17, 2003 Government opposes Plaintiffs' request for yet more time to specify claims against government officials and attorneys some thirteen months after having been ordered to do so by Court	Opposition of the United States to Plaintiffs' Motion For Enlargement of Time to File Bills of Particulars with Respect to Plaintiffs' Motion for Order To Show Cause Filed October 19, 2001 PDF OCR
April 14, 2003 Government seeks reconsideration of Court Orders in light of recent legislation limiting annual compensation of Special Master and Special-Master Monitor	Defendants' Consolidated Reply in Support of (1) Motion for Reconsideration of March 5, 2003 Order Directing Payment to Special Master Alan L. Balaran; and (2) Motion for Reconsideration of March 5, 2003 Order Directing Payment to Special Master-monitor Joseph S. Kieffer, III PDF OCR
April 14, 2003 Government urges Court to grant it permission to contact Earl Old Person, who was removed as class representative at Plaintiffs' request	Defendants' Reply in Support of (1) Motion for Expedited Consideration; and (2) Motion for Clarification that Defendants and Their Attorneys Are Permitted to Contact Plaintiff Earl Old Person or, in the Alternative, for Permission to Do So PDF OCR
April 14, 2003 Interior seeks to depose plaintiffs' "expert witness" regarding his work for Cobell Special Master, or in the alternative, to bar his testimony at Phase 1.5 trial	Interior Defendants' Opposition to Plaintiffs' and Joe Christie's Motion for a Protective Order, Motion to Compel Discovery from Joe Christie, And Request for Expedited Consideration PDF OCR
April 07, 2003 Government notes its appeal of Order effecting its work-product privilege	Amended Notice of Appeal PDF OCR
April 07, 2003 Government opposes Plaintiffs' attempt to thwart or delay discovery regarding their Phase 1.5 Plans, and their attempt to shift cost to the Government, by labelling it "expert discovery"	Interior Defendants' Opposition to Plaintiffs' Motion For Order (1) Requiring Defendants to Bear the Cost of Responding to Interior Defendants' February 21,2003 Discovery and (2) to Grant Plaintiffs an Enlargement of Time PDF OCR
April 07, 2003 Interior seeks adoption, in part, and rejection, in part, of Special Master-Monitor's Report and Recommendation	Interior Defendants' Response and Objections to Report and Recommendation of the Special Master-Monitor on Defendants' Deliberative Process Privilege Claims Over Phase 1.5 Trial Deposition Testimony PDF OCR

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