<< COB0000001 >>
N THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
	ELOUISE PEPION COBELL et al,	)
		)
	Plaintiffs,	)
		)
	v.	)	Case No. 1:96CV01285
)	(Special Master Alan Balaran)
GALE A. NORTON, Secretary of the Interior, ~ ~L)
		)
	Defendants.	)
DEFENDANTS' REPLY IN SUPPORT
OF MOTION TO COMPEL APPEARANCE AND
TESTIMONY OF PLAINTIFF ELOUISE COBELL AT DEPOSITION
	The Secretary of the Interior and the Assistant Secretary - Indian Affairs ("Interior
Defendants") state the following as their Reply to Plaintiffs' Opposition ("Plaintiffs' Opposition")
to Defendants' Motion to Compel Appearance and Testimony of Plainti ff Elouise Cobell at
Deposition.
	Plaintiffs' Opposition contains no new arguments, but merely incorporates by reference
Plaint ifs' Motion for Protective Order Seeking: (1) Stay of Plaint ifs' Obligation to Respond to
Interior Defendants' Request for the Production of Documents, Dated June 5, 2002; (2) Stay of
Threatened Depositions of the Five Named Plaintiffs; and (3) Stay of Rule 11 Motion With
Respect to Court-Ordered Attorney~s Fees (the "Motion to Stay"), which Plaintiffs filed on or
about July 5, 2002, and Plaintiffs further incorporate by reference their July 24, 2002, reply in
support of that Motion to Stay.
	Accordingly, as their reply to Plaintiffs' Opposition, Interior Defendants hereby
<< COB0000002 >>
incorporate by reference their opposition to the Plaintiffs' Motion to Stay, which Interior
Defendants filed on July 16, 2002.
RespectfUly submitted,
ROBERT D. McCALLIJM
Assistant Attorney General
STUART E. SCHIFFER
Deputy Assistant Attorney General
J.	CHRISTOPHER KOHN
Director
Deputy Director
JOHN T. STEMPLEWJCZ
Senior Trial Attorney
DAVID J. GOTTESMAN
Trial Attorney
Commercial Litigation Branch
Civil Division
P.O.Box 875
Ben Franklin Station
Washington, D.C. 20044-0875
(202) 514-7194
Dated:	September 10, 2002
-2-
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CERTIFICATE OF SERVICE
	I declare under penalty of perjury that, on September 10, 2002 I served the foregoing
Defendants 'Reply in Support of Motion to Compel Appearance and Testimony of Plaint if
Elouise Cobell at Deposition by facsimile upon:
Keith Harper, Esq.	Dennis M Gingold, Esq.
Native American Rights Fund	Mark Kester Brown, Esq.
1712 N Street, N.W.	1275 Pennsylvania Avenue, N.W.
Washington, D.C. 20036-2976	Ninth Floor
(202) 822-0068	Washington, D.C. 20004
	(202) 318-2372
and byU.S. Mail upon:
Elliott Levitas, Esq.
1100 Peachtree Street, Suite 2800
Atlanta, GA 30309-4530
Copy by Facsimile and U.S. Mail upon:
Alan L. Balaran, Esq.
Special Master
1717 Pennsylvania Avenue, N.W.
12th Floor
Washington, D.C. 20006
(202) 986-8477
Joseph S. Kieffer, III
Court Monitor
420 7th Street, N.W.
Apartment 705
Washington, D.C. 20004
Kevin P. Kingston