IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 
__________________________________________ 
ELOUISE PEPION COBELL, et al., ) 
Plaintiffs, 
v. Case No. 1:96CV01285 
(Judge Lamberth) 
) 
) 
) 
) 
) 
GALE A. NORTON, Secretary of the Interior, et al., ) 
) 
Defendants. )
) 
__________________________________________ ) 
DEFENDANTS' MOTION FOR ENLARGEMENT OF TIME WITH REGARD 
TO PARAGRAPH B.2 OF THE MARCH 15, 2004 PRELIMINARY INJUNCTION 
Pursuant to Rule 7(b) of the Federal Rules of Civil Procedure and Local Civil Rule 7, 
Defendants respectfully move this Court for an enlargement of four days, until March 26, 2004, 
for Defendants to file the declaration required by paragraph B.2 of the Court's Preliminary 
Injunction dated March 15, 2004, with respect to Information Technology Systems operated by 
the Bureau of Reclamation. Pursuant to Local Civil Rule 7(m), counsel for the Defendants called 
Plaintiffs' counsel, Messrs. Gingold and Harper, on the evening of March 22, 2004, regarding this 
motion. Neither of Plaintiffs' counsel answered his telephone when Defendants called, and as of 
the filing of this motion, neither had returned Defendants' counsel's voicemails regarding this 
motion.
Upon receipt of the Court's Preliminary Injunction, Defendants undertook to comply with 
the requirements of paragraph B.2. Pursuant to this paragraph, Defendants have been directed to 
file declarations with respect to Information Technology Systems "essential for the protection 
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against fires or other threats to life or property." Preliminary Injunction ¶ 2 (Mar. 15, 2004). As 
of the close-of-business on March 22, 2004, however, the Bureau of Reclamation has not been 
able to compile a list specifying each and every Information Technology Systems that will 
remain connected to the Internet. The Bureau of Reclamation expects to be able to complete 
requirements of paragraph B.2. of the Preliminary Injunction by March 26, 2004. 
For the foregoing reasons, Defendants respectfully request that this Court grant 
Defendants' Motion for Enlargement of Time with Regard to Paragraph B.2 of the March 15, 
2004 Preliminary Injunction. 
March 22, 2004 
Respectfully submitted, 
ROBERT McCALLUM, JR. 
Associate Attorney General 
PETER D. KEISLER 
Assistant Attorney General 
STUART E. SCHIFFER 
Deputy Assistant Attorney General 
J. CHRISTOPHER KOHN 
Director 
/s/ Sandra P. Spooner 
SANDRA P. SPOONER (D.C. Bar No. 261495) 
Deputy Director 
JOHN T. STEMPLEWICZ 
Senior Trial Attorney 
GLENN D. GILLETT 
JOHN WARSHAWSKY (D.C. Bar No. 417170) 
Trial Attorney 
Commercial Litigation Branch 
Civil Division 
P.O. Box 875, Ben Franklin Station 
Washington, D.C. 20044-0875 
Telephone: (202) 514-7194 
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CERTIFICATE OF SERVICE 
I hereby certify that, on March 22, 2004 the foregoing Defendants' Motion for 
Enlargement of Time with Regard to Paragraph B.2 of the March 15, 2004 Preliminary 
Injunction 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
IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 
__________________________________________ 
ELOUISE PEPION COBELL, et al., ) 
Plaintiffs, 
v. Case No. 1:96CV01285 
(Judge Lamberth) 
) 
) 
) 
) 
) 
GALE A. NORTON, Secretary of the Interior, et al., ) 
Defendants. 
) 
) 
__________________________________________ ) 
ORDER 
This matter comes before the Court on Defendants' Motion for Enlargement of Time with 
Regard to Paragraph B.2 of the March 15, 2004 Preliminary Injunction. After considering that 
motion, plaintiffs' reply, if any, and the record of the case, it is hereby 
ORDERED that the motion for enlargement should be, and hereby is, GRANTED, and it 
is 
FURTHER ORDERED that Defendants' declaration with regard to the Bureau of 
Reclamation, to be filed pursuant to paragraph B.2 of the March 15, 2004 Preliminary Injunction 
shall be filed no later than March 26, 2004. 
SO ORDERED this ___ day of ______________, 2004. 
ROYCE C. LAMBERTH 
United States District Judge
cc: 
Sandra P. Spooner 
John T. Stemplewicz 
Commercial Litigation Branch 
Civil Division 
P.O. Box 875 
Ben Franklin Station 
Washington, D.C. 20044-0875 
Fax (202) 514-9163 
Dennis M Gingold, Esq. 
Mark Brown, Esq. 
607 - 14th Street, NW, Box 6 
Washington, D.C. 20005 
Fax (202) 318-2372 
Keith Harper, Esq. 
Richard A. Guest, Esq. 
Native American Rights Fund 
1712 N Street, NW 
Washington, D.C. 20036-2976 
Fax (202) 822-0068 
Elliott Levitas, Esq. 
1100 Peachtree Street, Suite 2800 
Atlanta, GA 30309-4530 
Earl Old Person (Pro se) 
Blackfeet Tribe 
P.O. Box 850 
Browning, MT 59417 
(406) 338-7530 
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