IN THE UNITED STATES DISTRICT c o m ~ ; - -. \,Y@ 1 i ftf 8: 2 I 
FOR THE DISTRICT OF COLUMBIA 
ELOUISE PEPION COBELL, et al., CLERK 
Plaintiffs, 
V. 
1 
1 
1 
) 
1 
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GALE A. NORTON, Secretary of the ) 
Interior, et al., 
Defendants. 1 
1 
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-' I 'i I-. + ~ ~ E F . : - ~ ~ ~ ~ - ~ ~ T T I N G T ~ ~ ~ i 
Case No. I:96CVO1285 
(Judge Lamberth) 
INTERIOR DEFENDANTS' OFFICE OF THE INSPECTOR GENERAL'S 
SUBMISSIONS IN COMPLIANCE WITH PRELIMINARY INJUNCTION 
By order dated July 28, 2003, the Court ordered the Department of Interior immediately 
to disconnect from the Internet all of its information technology systems, except for (I) systems 
whose continued connection to the Internet 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 Internet, if the Department of Interior further certifies that 
those systems are either secure or do not house or access "individual Indian trust data," as dcfined 
by the preliminary injunction. 
In compliance with the Court's order, the Department of Interior submits the attached 
certification of the Department of Interior's Office of Inspector General. 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. SCHFFER 
Deputy Assistant Attorney General 
J. CHRISTOPHER KOHN 
D.C. Bar No. 261495 
Deputy Director 
JOHN T. STEMPLEWICZ 
Senior Trial Counsel 
GLENN D. G1LLETl 
JOHN WARSHAWSKY 
Trial Attorneys 
Commercial 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 14-9163 
Dated: August 11,2003 
2 CERTIFICATE OF SERVICE 
I dcclare under penalty of perjury that, on August 1 1, 2003 I served the foregoing Interior 
Defendants' Ofice of the Inspector Generals Submissions in Compliance with the Preliminary 
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 Ordcr of April 17,2003) 
Black feet 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