I j 8: 2 1 IN THE UNITED STATES DISTRICT C O T - 
FOR THE DISTRICT OF COLUMBIA L - 
ELOUISE PEPJON COBELL, et al., 
Plaintiffs, 
V. 
1 
1 
1 
) 
) 
1 
Case No. 1 :96CVO 1285 
(Judge Lamberth) 
GALE A. NORTON, Secretary of the 
Interior, et al., 
) 
1 
) 
) Defendants. 
INTERIOR DEFENDANTS' SUBMISSIONS IN COMPLIANCE 
WITH PRELIMINARY INJUNCTION 
By order dated July 28, 2003, the Court ordered the Department of Interior immediately 
to disconnect from the Jntemet all of its information technology systems, except for (1) systems 
whose continued connection to the Jntcrnet are certified to be necessary to protect against fires 
and other threats to life or property, and (2) systems that the Special Master has previously 
authorized to be reconnected to the Jntemet, if the Department of Interior further certifies that 
those systems are either secure or do not house or access "individual Indian trust data," as defined 
by the preliminary injunction. 
In cornpliarice with the Court's order, the Department of Interior submits the attached 
certifications. This compliance should not be understood to reflect agreement with the Court's 
reasoning. As we explained in opposing entry of the preliminary injunction, the record contains 
no evidence that could warrant entry of any injunction, much less an order requiring the 
Department of the Interior to disconnect from the Internet. The Court does not have a general 
power to supervise the security of the Interior Department's information technology systems. To 
the extent that the Court has any authority in this area, its review is limited to determining whether the Department's security measures are "SO defective that they would necessarily delay 
rather than accelerate the ultimate provision of an adequate accounting." Cobell v. Norton, 240 
F.3d 1081, 11 10 (D.C. Cir. 2001). The government thus reserves the right to challenge the 
Court's preliminary injunction ruling on appeal. 
Respectfully submitted, 
ROBERT D. McCALLUM, JR. 
Associate Attorney General 
PETER D. KEISLER 
Assistant Attorney General 
STUART E. SCHIFFER 
Deputy Assistant Attorney General 
J. CHRISTOPHER KOHN 
Director 
W D.C. Bar No. 261495 
Deputy Director 
JOIHN T. STEMPLEWICZ 
Senior Trial Counsel 
GLENN D. GLLETT 
JOHN WARSHAWSKY 
Trial Attorneys 
Conimercial Litigation Branch 
Civil Division 
P.O. Box 875 
Ben Franklin Station 
Washington, D.C. 20044-0875 
Telephone: (202) 5 14-7 194 
Facsimile: (202) 5 14-9 163 
Dated: August 11, 2003 
2 CERTIFICATE OF SERVICE 
I declare under penalty of perjury that, on August 1 1, 2003 I served the foregoing Interior 
Defendants' Submissions in Compliance with the Prelimiizaiy Injunction by Prepaid First Class 
Mail upon: 
Keith Harper, Esq. 
Native American Rights Fund 
1712 N Street, N.W. 
Washington, D.C. 20036-2976 
Elliott Levitas, Esq 
1100 Peachtree Street, Suite 2800 
Atlanta, GA 30309-4530 
Earl Old Person (Pro se) (Per the Court's Order of April 17, 2003) 
Blackfeet Tribe 
P.O. Box 850 
Browning, MT 5941 7 
Dennis M Gingold, Esq. 
Mark Kester Brown, Esq. 
607 - 14th Street, NW 
Box 6 
Washington, D.C. 20005