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ELOUISE PEPION COBELL, et al., ) 
Plaintiffs,   
   v. 
GALE A. NORTON, Secretary of  
the Interior, et al.,          
 Defendants.                 
DEFENDANTS. RESPONSE TO PLAINTIFFS. MOTION TO UNSEAL DOCUMENTS 
IN ACCORDANCE WITH THE APRIL 22, 2005 PROTECTIVE ORDER 
Defendants do not oppose Plaintiffs. Motion to Unseal Documents in Accordance with 
the April 22, 2005 Protective Order (.Plaintiffs. Motion).1  As Plaintiffs. Motion states, they 
attempted to meet and confer with Defendants. counsel prior to filing the motion, but were 
unsuccessful.  Plaintiffs. Motion at 1, n.1.  As a result, Defendants did not have an opportunity to 
indicate whether they would oppose the motion prior to Plaintiffs. filing it.  Having since 
reviewed Plaintiffs. motion and the documents they seek to unseal, Defendants do not oppose 
Plaintiffs. Motion. 
    
1  The documents Plaintiffs move to have unsealed are Bates Nos. DOI_IT0015376-80, 
DOI_IT0004571, DOI_IT0004623, and DOI_IT0004630. 
IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 
No. 1:96CV01285 (RCL) 
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Respectfully submitted, Dated: May 25, 2005 
ROBERT D. McCALLUM 
Associate Attorney General 
PETER D. KEISLER 
Assistant Attorney General 
STUART E. SCHIFFER 
Deputy Assistant Attorney General 
   
 /s/ Timothy E. Curley 
________________________________________ 
J. CHRISTOPHER KOHN (D.C. Bar No. 212357) 
Director 
JOHN T. STEMPLEWICZ 
Senior Trial Attorney 
TIMOTHY E. CURLEY (D.C. Bar No. 470450) 
Commercial Litigation Branch 
Civil Division 
P.O. Box 875, Ben Franklin Station 
Washington, D.C. 20044-0875 
Telephone:  (202) 514-7450  
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CERTIFICATE OF SERVICE 
I hereby certify that, on May 26, 2005 the foregoing Defendants. Response to Plaintiffs. 
Motion to Unseal Documents in Accordance with the April 22, 2005 Protective 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