Civil Division

U.S. Department of Justice

Cobell v. Norton, et al.

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

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October, 2003 Filings

The Department of Justice has previously filed the following documents on behalf of the United States and the Departments of the Interior and Treasury. Click here for additional archives.

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Cobell Case Documents
Date and Summary Full Title

October 30, 2003
Government opposes plaintiffs' motion that fails to comply with rules of the Court and which is based on misrepresentation of the record of the case

Defendants' Opposition to Plaintiffs' Consolidated Motion to Compel Production of Documents and Request for Sanctions Pursuant to Rule 37


PDF      OCR

October 29, 2003
Government appeals District Court's structural injunction

Notice of Appeal


PDF     OCR

October 29, 2003
Interior opposes plaintiffs' request for unbounded enlargement of time that would allow the pursuit of legally unnecessary discovery of government officials

Interior Defendants' Memorandum in Opposition to Plaintiffs' Motion for Enlargement Regarding Interior Defendants' Motion for Reimbursement of "Improper" Special Master Fees


PDF     OCR

October 29, 2003
Government seeks to prohibit unauthorized discovery that is unrelated to any future proceeding

Defendants' Motion for a Protective Order Regarding Plaintiffs' Request for Production of MMS Audit Documents and Plaintiffs' Notices of Deposition of Deborah Gibbs Tschudy and Lonnie J. Kimball with Requests for Production of Documents


PDF     OCR

October 24, 2003
Government objects to blatant overcharges and unsubstantiated expenses in plaintiffs' request for reimbursement of their experts' deposition fees

Defendants' Opposition to Plaintiffs' Motion for a Protective Order Requiring Defendants to Pay Plaintiffs' Expert Deposition Fees and Expenses


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October 23, 2003
Government objects to plaintiffs' request for fees that is defective in that it is untimely filed, fails to state the amount of fees sought and does not show, or even allege, that the plaintiffs are entitled to fees under the applicable statute

Defendants' Opposition to Plaintiffs' Request for an Award of Attorney's Fees and Expenses Pursuant to the Equal Access to Justice Act


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October 22, 2003
Interior opposes plaintiffs' motion for more time to seek costs for which they offer no explanation of entitlement

Interior Defendants' Memorandum in Opposition to Plaintiffs' Motion for Enlargement of Time to Submit Bill of Costs


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October 17, 2003
Interior replies to plaintiffs' third objectionable pleading filed neither in accordance with the rules of the Court nor with the permission of the Court

Reply Brief in Support of Interior Defendants' Motion to Strike "Plaintiffs' Notice of Supplemental Authority in Support of Comments Feed by Plaintiffs on August 27, 2003 and September 10, 2003 Regarding this Court's Preliminary Injunction" or, in the Alternative, Interior Defendants' Response Thereto


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October 17, 2003
Interior opposes plaintiffs' motion that ignores general and specific objections previously raised by the government

Interior Defendants' Opposition to Plaintiffs' Motion to Compel Anson Baker's Deposition and the Production of Documents Related Thereto


PDF     OCR

October 16, 2003
Interior objects to Special Master report based on innuendo rather than evidence and which fails to support an inference that records are not being properly maintained

Interior Defendants' Response and Objection to the Site Visit Report of the Special Master to the Dallas, Texas Office of the Minerals Revenue Management Division of the Department of The Interior's Minerals Management Service


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October 14, 2003
Interior opposes motion that would deprive government of advance notice of Special Master site visits and opportunity to accompany him on those visits

Interior Defendants' Opposition to Plaintiffs' Consolidated Motion for a Temporary Restraining Order and Preliminary Injunction


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October 14, 2003
Interior opposes plaintiffs' position that they have discovery rights that exceed the limits established by the Federal Rules of Civil Procedure

Interior Defendants' Reply in Support of Motion for a Protective Order Regarding Plaintiffs' Notice of Deposition of Anson Baker And Request for Production of Documents


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October 06, 2003
Interior replies to plaintiffs' claim that the Court of Appeals decision in Cobell is irrelevant, noting that the Court of Appeals agreed with arguments that the District Court deemed frivolous and used as the basis for its sanctions ruling

Interior Defendants' Reply Memorandum in Further Support of Their Motion for Leave to Supplement Their Motion for Reconsideration of the March 5, 2003 Memorandum and Order Insofar as it Imposed Sanctions on Interior Defendants and Their Counsel


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October 03, 2003
Interior seeks reimbursement of fees paid to Special Master for work performed beyond the scope of his appointment and for other improperly billed charges

Interior Defendants' Motion for Reimbursement of Improper Special Master Fees


PDF     OCR

October 03, 2003
Government replies to plaintiffs' attempt to take discovery of litigation counsel in abrogation of Federal Rules of Civil Procedure

Reply Memorandum in Support of the Motion of the United States for a Protective Order and to Quash the Subpoenas Issued to Government Trial Attorneys Petrie, Quinn and Spooner


PDF      OCR

October 03, 2003
Interior rebuts plaintiffs' attempt to manipulate civil discovery rules

Interior Defendants' Reply in Support of Their Motion for Protective Order and Motion to Quash Plaintiffs' Notice of Deposition and Request for Production of Documents Directed to Non-party Michael Carr and Defendants and Opposition to Plaintiffs' Motion to Compel Michael Carr's Deposition and the Production of Documents Related Thereto


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October 02, 2003
Government seeks to quash subpoenas served on government counsel noting that plaintiffs have not made requisite showing necessary to depose opposing counsel, the information sought is available elsewhere and, in any event, discovery is not authorized at this time

Defendants' Reply in Support of Their Motion to Strike Plaintiffs' "Comments," Filed August 27, 2003 and in Opposition to Plaintiffs' Request for the Court to Consider Sanctions Sua Sponte for Filing a Frivolous Motion


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