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’ RESPONSE TO PLAINTIFFS' FIRST MOTION FOR EXPEDITED 
EXCLUSION OF CERTAIN CLASS MEMBERS FROM THE PRIOR NOTICE 
REQUIREMENT OF THE SEPTEMBER 29, 2004 ORDER 
Defendants have no objection to the relief requested in Plaintiffs' First Motion for 
Expedited Exclusion of Certain Class Members from the Prior Notice Requirement of the 
September 29, 2004 Order.1 Indeed, Defendants opposed Plaintiffs' request that class members 
be prevented from selling their land and continue to take the position that class members should 
not be required to await a notice from the Court or action by Plaintiffs' counsel before they can 
do so. 
Respectfully submitted, Dated: October 15, 2004 
ROBERT D. McCALLUM, JR. 
Associate Attorney General 
PETER D. KEISLER 
Assistant Attorney General 
STUART E. SCHIFFER 
Deputy Assistant Attorney General 
1Plaintiffs' counsel incorrectly state in footnote 1 of their motion that they "has met and 
conferred with counsel for defendants who states that defendants will oppose the relief sought 
herein." In fact, Defendants' counsel never stated that they would oppose this motion.
J. CHRISTOPHER KOHN 
Director 
/s/ Sandra P. Spooner 
SANDRA P. SPOONER 
D.C. Bar No. 261495 
Deputy Director 
JOHN T. STEMPLEWICZ 
Senior Trial Counsel 
Commercial Litigation Branch 
Civil Division 
P.O. Box 875 
Ben Franklin Station 
Washington, D.C. 20044-0875 
(202) 514-7194
CERTIFICATE OF SERVICE 
I hereby certify that, on October 15, 2004 the foregoing Defendants' Response to 
Plaintiffs' First Motion for Expedited Exclusion of Certain Class Members from the Prior Notice 
Requirement of the September 29, 2004 Order 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