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IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 
1 
ELOUISE PEPION COBELL &., 1 
) No. 1:96CVO1285 
Plaintiffs, 1 (Special Master-Monitor Kicffer) 
V. 1 
) 
GALE A. NORTON, Secretary of ) 
the Interior, gt al., ) 
) 
Defendants. 1 
INTERIOR DEFENDANTS’ OPPOSITION TO PLAINTIFFS’ MOTION 
FOR ORDER (1) REOULRING DEFENDANTS TO BEAR THE COST OF 
RESPONDING TO INTERIOR DEFENDANTS’ FEBRUARY 21,2003 
DISCOVERY AND (2) TO GRANT PLAINTIFFS AN ENLARGEMENT OF TIME 
Interior Defendants respecthlly submit the following opposition to Plaintiffs’ Motion for 
Order Requiring Defendants to Bear the Cost Responding to Interior Defendants’ February 2 1, 
2003 Request for Production of Documents and Set of Interrogatories, And To Grant Plaintiffs an 
Enlargement of Time Within Which to Respond Thereto (“Motion for Protective Order”). The 
Motion for Protective Order should be denied. 
INTRODUCTION 
On February 21, 2003, Interior Defendants served on Plaintiffs a set of nineteen 
interrogatories (“Interrogatories”) and twenty-six requests for the production of documents 
(“Document Requests”). See Interrogatories, attached as Exhibit 1; Document Requests, 
attached as Exhibit 2. Seven Interrogatories and twenty Document Requests are directly related 
to Plaintiffs’ Plan for Deterniining Accurate Balances in the Individual Indian Trust (“Plaintiffs’ 
Trust Compensation Plan”), filed by Plaintiffs on January 6, 2003, and the subject, in part, of the 
upcoming Phase 1.5 trial. Interrogatories, Nos. I, 3-8; Document Requests, Nos. 1-19, 22. This is the background image for an Adobe Acrobat Capture page with image plus hidden text.  
Three Document Requests are indirectly related to Plaintiffs’ Trust Compensation Plan.’ See 
Document Requests, Nos. 23-25. Ten Interrogatories and two Document Requests are directly 
related to Plaintiffs’ Compliance Action Plan Together With Applicable Trust Standards 
(Plaintiffs’ Trust Management Plan), filed by Plaintiffs on January 6, 2003, and the subject, in 
part, of the upcoming Phase 1.5trial. See Interrogatories, Nos. 2, 10-18; Document Requests, 
Nos. 20-21. Two Interrogatories and one Document Request are related to information Plaintiffs 
may possess regarding Interior’s Historical Accounting Plan, filed on January 6,2003. See 
Interrogatories,Nos. 9, 19; Document Request No. 26. 
Plaintiffs’ answers to the Interrogatories and responses to the Document Requests were 
due on March 24, 2003. Fed. R. Civ. P. 33, 34. On that date, Plaintiffs filed the Motion for 
Protective Order. Plaintiffs label all of the Interrogatories and Document Requests as “expert 
discovery” (Motion for Protective Order at 1 ) and seek to have Defendants pay tens of thousands 
of dollars and wait untold days (seePlaintiffs’ Proposed Order at 2) before Plaintiffs will respond 
to any of the Interrogatories or Document Requests. Plaintiffs also allege that to answer the 
Interrogatories and produce responsive documents would be unduly burdensome, and they seek a 
blanket protective order freeing themselves from ever responding to any of the Interrogatories or 
Document Requests (seeMotion for Protective Order at 4-5). Plaintiffs also claim that 
unspecified information responsive to Interior Defendants’ discovery may be privileged attorneywork 
product and conclude, somehow, that this means Interior Defendants should not be 
u These three document requests seek information in Plaintiffs’ possession regarding the 
revenue that Plaintiffs believe the LIM trust should havc earned, actually did earn, and was 
disbursed to Plaintiffs. These three types of revenue-based infomation are central to Plaintiffs’ 
Trust Compensation Plan. 
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permitted to have any discovery (Motion for Protective Order at 6-8).2 Alternatively, if the Court 
does not foreclose Interior Defendants’ discovery, Plaintiffs ask for an “indefinite” enlargement 
of time in which to respond (Plaintiffs’ Proposed Order at 2). 
ARGUMENT 
In civil litigation, parties may obtain discovery “regarding any matter, not privileged, that 
is relevant to the claim or defense of any party.” Fed. R. Civ. P. 26(b)( 1). It is a fundamental 
principle of litigation in federal courts that a party is entitled to relevant discovery. “Mutual 
knowledge of all the relevant facts gathered by both parties is essential to proper litigation.” 
Hickman v. Tavlor, 329 U.S. 495, 507 (1947). A protective order may only be issued where the 
movant demonstrates “good cause.” Fed. R. Civ. P. 26(c). “To establish ‘good cause’ a rnovant 
must articulate a real and specific harm, and not just ‘stereotyped and conclusory statements.”’ 
P.H.E., Inc. v. Department of Justice, 139 F.R.D. 249,252 (D.D.C. 1991) (citation omitted). 
On January 6,2003, Plaintiffs submitted plans that they have asked the Court to adopt at 
the conclusion of the Phase 1.5 trial. To block all discovery into Plaintiffs’ plans would not only 
be “unfair” (Motion for Protective Order at 7); it would be anathema to the federal litigation 
system. Plaintiffs’ have not met their heavy burden of showing “good cause.” Their Motion for 
Protective Order should be denied. 
Y Plaintiffs also argue that all information and documents requested by Interior Defendants 
are protected by a novel “voluntarily submitted” privilege (seeMotion for Protective Order at 6- 
7). This fanciful privilege apparently applies whenever Plaintiffs voluntarily submit something 
to the Court for trial, but do not want Defendants to know anything about it. 
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I. THE INTERROGATORIES AND DOCUMENT REQUESTS ARE NOT 
“EXPERT DISCOVERY” 
The centerpiece of Plaintiffs’ Motion for Protective Order is their claim that Interior 
Defendants’ Interrogatories and Document Requests are “expert discovery” and therefore either 
should not be had or should only be had if Defendants pay some undefined sum.3 See Motion for 
Protective Order at 1-3, 6-10. As discussed above, the overwhelming majority of the requested 
discovery is directly related to the plans that Plaintiffs filed on January 6, 2003, and have asked 
the Court to adopt. In order to address those plans at the upcoming trial, Interior Defendants are 
entitled to discovery about the plans. Interior Defendants’ discovery fits squarely within the 
scope of Rule 26(b)(1). 
Plaintiffs seem to have a fundamental misunderstanding about the nature of expert 
testimony. Any expert hired by Plaintiffs to testify at the upcoming trial will presumably discuss 
the plans filed by Plaintiffs and give an opinion about the plans, or certain parts of the plans. 
That Interior Defendants are not seeking discovery about those expert opinions through the 
Document Requests and Interrogatories should be self-evident, as this discovery was propounded 
a week before Plaintiffs identified any experts. Interior Defendants have separately conducted 
discovery, including depositions and document requests, directed toward the opinions of 
Plaintiffs’ experts. In the Document Requests and Interrogatories, Interior Defendants seek 
discovery about the plans themselves, as prepared and submitted by Plaintiffs. The discovery is 
The down payment just to determine how much they will charge for this discovery, 
according to Plaintiffs, is $10,000. Plaintiffs’ Proposed Order at 2. 
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aimed directly at Plaintiffs, not at any expert hired by plaintiff^.^ This is not expert discovery 
and Plaintiffs’ conclusory allegations do not transform it into expert dis~overy.~ 
The cost-shifting provisions in Rule 26(b)(4)(C) only apply to discovery sought from an 
expert. Because this discovery is not sought from any expert, these provisions have no 
application here. 
Plaintiffs have not met their burden of showing that the Document Requests and 
Interrogatories are expert discovery and cannot demonstrate the requisite good cause for a 
blanket protective order foreclosing all discovery into Plaintiffs’ plans unless Defendants agree to 
11. THE INTERROGATORIES AND DOCUMENT REQUESTS DO NOT IMPOSE 
UNDUE BURDEN ON PLAINTIFFS 
Plaintiffs also seek to avoid responding to any of Interior Defendants’ discovery on the 
grounds that it would be unduly burdensome. See Motion for Protective Order at 4-5.The only 
support for this claim of undue burden is the Fasold Affidavit. 
As indicated by Plaintiffs (Motion for Protective Order at 4), when evaluating a claim of 
undue burden a court will consider “relevance, the need of the party for the documents, the 
breadth of the document request, the time period covered by it, the particularity with which the 
documents are described and the burden imposed.” Alexander v. FBI, 186 F.R.D. 2 1,34 (D.D.C. 
4 It is curious to note that of the six retained experts identified by Plaintiffs, none has 
issued a report or an opinion about Plaintiffs’ Trust Management Plan. It is inconceivable how 
Plaintiffs could claim that any of these experts would be involved in responding to the ten 
Interrogatories and two Document Requests related to that plan. 
I! Plaintiffs cannot turn non-expert fact discovery into expert discovery simply by assigning 
some, or all, of their experts to assist them in responding to the discovery. 
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1998). The burden of proving that a search for information would be unduly burdensome is on 
the moving party. See, e.g., Linder v. Calero-Portocarrero, 180 F.R.D. 168, 172 (D.D.C. 1998). 
Unfortunately, Plaintiffs omit any discussion of the first five Alexander factors in their 
Motion for Protective Order. As discussed above, because the discovery is related to the plans 
which will be the subject of the upcoming trial, the relevance of this discovery, and Interior 
Defendants’ corresponding need for it, are beyond dispute. 
In addition, as even a cursory review of the Document Requests makes clear, the 
requested discovery is tightly focused on the plans and described with particularity. Interior 
Defendants do not ask for all documents related to a particular subject, but only seek those 
documents that were relied upon by Plaintiffs in crafting the various elements of their plans, and 
which actually contain information which made its way into the plans. See, e-g., Document 
Requests, Nos. 1-21. Perhaps in an effort to make Interior Defendants’ Document Requests seem 
broader than they actually are, Plaintiffs misleadingly truncate one of the few requests even 
mentioned in the Motion for Protective Order. Plaintiffs quote the first part of Document 
Request No. 4 (Motion for Protective Order at 5 ) , but tellingly omit the remainder of the request, 
which narrows considerably the range of responsive documents. 
The only Alexander factor discussed by Plaintiffs is their assertion that responding to the 
requested discovery would cause some burden for Plaintiffs, and their agents, if they were to 
comply. Plaintiffs choose to give no estimate as to their burden for anyone other than the experts 
who they claim would be assigned to respond to these requests. Mr. Fasold, purporting to speak 
for himself, and for an unidentified cadre of experts who are working under his direction (Fasold 
Affidavit at 7 3 ) , estimates that it will take over 500 hours to “identify, search for, and collect’’ 
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the requested documents. Fasold Affidavit at 7 6 . 
Five hundred hours seems like a grossly excessive amount of time given the limited 
nature of the requests. Plaintiffs do not bother to break down the estimated burden for each 
request and therefore it is unclear whether some requests might be more quickly responded to 
than others. 
Even if the Fasold estimate proves to be accurate, however, Plaintiffs have not 
demonstrated that this shows undue burden. Because the agents who would be conducting this 
search remain nameless -with the exception of Mr. Fasold -it is unclear whether the burden 
would be widely dispersed. For example, if fifty people work on the production then it would 
only take each person ten hours. If the burden is shared equally by the six testifying experts 
designated by Plaintiffs this would require only slightly over eighty hours for each expert and his 
assistants. 
At most, Mr. Fasold’s affidavit shows that it might inconvenience Plaintiffs to respond to 
Interior Defendants’ Document Requests and Interrogatories. “Inconvenience,” however, is not 
synonymous with “undue burden.” 
An individual operating a small business, for example, or a corporation operated by a sole 
shareholder, may suffer, in like circumstances, more inconvenience than the movant with 
its thousands of employees. But this inconvenience . . . is part of the price we pay to 
secure the effective administration of justice and the enforcement of our laws. 
InreRadio Cow. ofAm., 13 F.R.D. 167,172 (S.D.N.Y. 1952). 
Plaintiffs have brought this action against Defendants and they have submitted plans to 
the Court that fomi part of the Phase 1.5 trial. Some inconvenience in responding to discovery 
directed at those plans is a necessary consequence of this litigation and does not equate to undue 
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burden. 
Plaintiffs complain that the timing of responding to the discovery is especially 
inconvenient in that it is “a little over a month prior to trial” (Motion for Protective Order at 5). 
But Plaintiffs have only themselves to blame. Interior Defendants sent out this discovery on 
February 2 1,2003. If Plaintiffs had been diligent and timely responded to the discovery it would 
have been produced during the period which the Court set (with the agreement of Plaintiffs) for 
fact discovery in this case. Complaints now about how responding to discovery will interfere 
with their trial preparation plans (Motion for Protective Order at 5 ) do not establish undue 
burden. If anyone’s trial preparation plans are being interfered with by Plaintiffs’ tardy 
compliance with discovery obligations, it is Defendants’. 
111. NO PRIVILEGED INFORMATION HAS BEEN IDENTIFIED BY PLAINTIFFS 
Plaintiffs also seek a blanket protective order to prevent all discovery regarding their 
plans because certain information or documents might be protected attorney work-product. 
Motion for Protective Order at 6. Plaintiffs provide no support whatsoever for this claim. They 
do not identify a single piece of responsive information or a single responsive document for 
which they wish to assert the attorney work-product privilege. 
If Plaintiffs desire to prevent the production of certain responsive documents on the 
grounds that they may contain information to which a claim of attorney work-product privilege is 
asserted, the proper approach is to include the particular document on a privilege log. Plaintiffs 
cannot obtain a blanket protective order blocking production of &lresponsive documents merely 
because they might theoretically claim privilege with respect to a few. 
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In short, Plaintiffs have not demonstrated the requisite “good cause” for a protective 
order; Plaintiffs have only demonstrated bad faith. 
IV. PLAINTIFFS’ MOTION FOR ENLARGEMENT OF TIME SHOULD BE DENlED 
If the Court agrees with Interior Defendants that Plaintiffs have not met their burden of 
demonstrating good cause in support of their Motion for a Protective Order, Plaintiffs ask the 
Court for an “indefinite enlargement of time” within which to respond to the lnterrogatories and 
Document Requests. Plaintiffs’ Proposed Order at 2. The sheer audacity of this request is truly 
shocking. 
If the Court denies Plaintiffs’ request for a protective order this necessarily means that 
Plaintiffs have not demonstrated any good cause for not responding to Defendants’ discovery. 
Under those circumstances, Plaintiffs should immediately answer the Interrogatories and produce 
the requested documents. Interior Defendants’ ability to respond to Plaintiffs’ plans at trial 
already has been substantially prejudiced. Any further delay in responding to the discovery, 
much less the “indefinite” delay requested by Plaintiffs, would be unconscionable. Plaintiffs’ 
request for an enlargement should be denied. 
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CONCLUSION 
For these reasons, Plaintiffs’ Motion for a Protective Order should be denied. 
Dated: April 7,2003 Respectfully submitted, 
ROBERT D. McCALLUM, JR. 
Acting Associate Attorney General 
STUART E. SCHIFFER 
Deputy Assistant Attorney General 
J. CHRlSTOPHER KOHN 
W Deputy Director 
D.C. Bar No. 261495 
JOHN T. STEMPLEWICZ 
Senior Trial Attorney 
PHLLLP M. SELIGMAN 
Commercial Litigation Branch 
Civil Division 
P.O. Box 875 
Ben Franklin Station 
Washington, D.C. 20044-0875 
(202) 514-7194 
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IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 
ELOUISE PEPION COBELL, @ 4, 1 
) 
Plaintiffs, )
1 
V. ) Case No. 1:96CV01285 
) (Judge Lamberth) 
GALE NORTON, Secretary of the Interior, al., ) 
) 
Defendants. ) 
ORDER 
This matter comes before the Court on Plaintiffs’ Motion For Order Requiring 
Defendants to Bear the Cost Responding to Interior Defendants’ Request for Production of 
Documents, Dated February 21, 2003 And To Interior Defendants’ Set of Interrogatories, Dated 
February 2 1, 2003 And To Grant Plaintiffs An Enlargement of Time Within Which To Respond 
Thereto (“Motion for Protective Order”). Upon consideration of the Motion for Protective Order, 
the responses thereto, and the record in this case, it is hereby 
ORDERED that Plaintiffs’ Motion for a Protective Order is DENIED. 
ORDERED that Plaintiffs’ Motion for an enlargement of time is DENIED. 
SO ORDERED. 
Date: 
ROYCE C. LAMBERTH 
United States District Judge This is the background image for an Adobe Acrobat Capture page with image plus hidden text.  
cc: 
Sandra P. Spooner 
John T. Stemplewicz 
Commercial Litigation Branch 
Civil Division 
P.O. Box 875 
Ben Franklin Station 
Washington, D.C. 20044-0875 
(202) 5 14-7194 
Dennis M Gingold, Esq. 
Mark Brown, Esq. 
1275 Pennsylvania Avenue, N.W. 
Ninth Floor 
Washington, D.C. 20004 
202-318-2372 
Keith Harper, Esq. 
Native American Rights Fund 
1712 N Street, NW 
Washington, D.C. 20036-2976 
202-822-0068 
Elliott Levitas, Esq. 
1100 Peachtree Street, Suite 2800 
Atlanta, GA 30309-4530 This is the background image for an Adobe Acrobat Capture page with image plus hidden text.  
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, &al., 
Defendants. 
) 
) 
) 
) 
)
1 
1 
1 
) 
No.1:96CVO1285 
(Judge Lamberth) 
INTERIOR DEFENDANTS’ SET OF 
INTERROGATORIES, DATED FEBRUARY 21,2003 
Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, the Secretary of the 
Interior and the Assistant Secretary- Indian Affairs (‘‘Interior Defendants”), hereby request that 
Plaintiffs’ class representatives answer in writing and under oath the following interrogatories 
within 30 days. 
DEFINITIONS 
In these interrogatories, the following definitions will apply: 
A. “Document”or “documents” means any written or graphic matter of any kind or 
nature, however produced, reproduced, or recorded, whether handwritten, typed, drawn, 
sketched, printed, computer-generated,microfiched, microfilmed, or recorded by any physical, 
mechanical, electronic or electrical means whatever, whether produced, reproduced, or stored on 
paper, cards, disc, tape, film, electronic facsimile, computer storage, or any other media, whether 
an original, master, or duplicate including without limitation, books, records, papers, film, 
videotape, sound recordings, pamphlets, brochures, circulars, advertisements, specifications, 
Exhibit 1 
Interior Defs’ Opposition to 
Pltfs’ Motion for Order This is the background image for an Adobe Acrobat Capture page with image plus hidden text.  
blueprints, maps, telegrams, notes, notebooks, work sheets, electronic mail transmissions, 
reports, diaries, or items similar to any of the foregoing. "Document" or "documents" shall 
further collectively include the original, duplicate original, and any or all copies or reproductions 
of the original document, to the extent that any or all copies are different in any way from the 
original document, whether by interlineation, receipt stamps, notation, indication of copies sent 
or received, or otherwise. 
B. Words used in the singular shall be construed to include the plural, and vice versa. 
Words used with reference to a person of the male gender shall also be construed to refer to a 
person of the female gender, and vice versa. 
"Identify" or "identity" shall have the following meanings: 
When used in reference to an organization, the response shall state the full name 
and present or last known address of the corporation, partnership, f m or other 
entity. 
When used in reference to an individual, the response shall state his or her full 
name, present or last known address, present or last known business affiliation 
and job description, any past or present affiliation with you, the manner in which 
he relates to any of the issues or facts in this litigation, and the source and extent 
of his or her knowledge about any of these facts or issues. If you do not know the 
present address or present employer of any such person, please so indicate and 
state his last known address and last known employer. 
When used in reference to a document, the response shall state the type of 
document (e.g., memorandum, letter, note, contract), its date, author(s), 
addressee(s) (if any), synopsis of content, and present location. In lieu of 
providing this information, you may attach a copy of the document to your 
answers. 
When used in reference to a source of information, the response shall identify 
each individual providing infomation. The response shall also state whether the 
information has been reduced to writing or other tangible form. If so, this writing 
or other record shall be identified in the manner described in subparagraph(3) 
above. 
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D. "Describe" or "state" means the following: Describe fully by reference to 
underlying facts rather than ultimate facts or conclusions of law or facts, and 
particularize as to: 
the identity of each person involved in each such event, including, but not 
limited to persons employed by you and those persons purporting to act for 
YOU; 
the specific acts of each person participating in each such event; 
the date and time of each such event; 
the address and location of each such event; and, 
the identity of each person present during each such event. 
E. Documents to be identified or facts to be stated are described as those which 
"relate to" any entity, a person, an action, a document, or an event. The term "relate to" means to 
name, to refer to either directly or indirectly, to comment upon, analyze, review, report on, form 
the basis of, be considered in the preparation of, result from, be in any way connected with, 
emanate from, or have any logical relation to the entity, person, document, event, or action. 
F. "Person" or "individual"means any natural person, corporation, partnership, other 
business association or entity recognized by taw, and the employees or independent contractors 
thereof, and any domestic or foreign government body, commission, board, agency, branch, 
department, component or element thereof. 
G. "And" as well as "or" shall be construed in either the disjunctive or conjunctive 
form as necessary to bring within the scope of the interrogatoryany information which may 
otherwise be Construed outside its scope. 
13. "You" or "your" means any of the Plaintiffs who are designated as class 
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representatives in this lawsuit, and any agent of theirs. 
I. “Communication”means any transmission of words or thoughts by a person or 
between or among two or more persons, including but not limited to spoken words, discussions, 
conferences, conversations, negotiations, agreements, understandings, interviews, inquiries, 
promises, correspondence,statements, whether oral or written, and whether transmitted in person 
or by electronic or other means, including but limited to radio, telphonic, fax, email or other 
means. 
J. “Plaintiffs’ Trust Compensation Plan” means the paper entitled “Plaintiffs’ Plan 
for Determining Accurate Balances in the Individual Indian Trust,” filed by Plaintiffs on January 
6,2003. 
K. “Plaintiffs’ Trust Management Plan” means the paper entitled “Plaintiffs’ 
Compliance Action Plan Together with Applicable Trust Standards,” filed by Plaintiffs on 
January 6,2003. 
L. “Allottec” has the meaning that Plaintiffs’ ascribed to it when used in Plaintiffs’ 
Trust Compensation Plan. 
INSTRUCTIONS 
A. In answering these interrogatories,furnish all information, however obtained, 
including hearsay, that is available to you, including information known by or in the possession 
of yourself, your employees, subcontractors, experts, agents, attorneys, or appearing in your 
documents, not merely information within the personal knowledge of the individual(s) executing 
the answers to interrogatories. 
B. If you cannot answer the following interrogatories in full after exercising due 
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diligence to secure the information, so state, and answer to the extent possible. Specify your 
inability to answer the remainder, and state whatever information or knowledge you have 
concerning the unanswered portion. 
C. Where exact statistical or numerical information, including dates, or times, cannot 
be furnished, estimated or approximate information is to be supplied. Where an estimation or 
approximation is supplied, it should be so indicated, and an explanation provided as to the basis 
upon which the estimate or approximationwas made. State in detail the reason(s) why exact 
statistical or numerical information cannot be furnished. 
D. If you object to or otherwise decline to answer any portion of an interrogatory, 
please provide all infomation called for by that portion of the interrogatoryto which you do not 
object or to which you do not decline to answer. If you state an objection to an interrogatoryon 
the ground that it is too broad (k,asks for infomation outside the scope of Rule 26), provide 
the information that you contend would be within the scope of Rule 26. If you object to an 
interrogatory on the ground that to provide an answer would constitute an undue burden, provide 
all requested information that can be supplied without undertaking an undue burden. For those 
portions of an interrogatoryto which you object or otherwise decline to answer, state the reason 
for such objection or declination. 
INTERROGATORIES 
INTERROGATORY NO. 1: Identify all persons who provided information to Plaintiffs that 
was included in Plaintiffs’ Trust Compensation Plan and, for each person so identified, give a 
summary of the information that was provided by that person and included in Plaintiffs’ Trust 
Compensation Plan. 
INTERROGATORY NO. 2: Identify all persons who provided information to Plaintiffs that 
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was included in Plaintiffs’ Trust Management Plan and, for each person so identified, give a 
summary of the information that was provided by that person and included in Plaintiffs’ Trust 
Management Plan. 
INTERROGATORY NO. 3: Describe how Plaintiffs’ Trust Compensation Plan would account 
for instances where mineral rights on Indian reservation land are not owned pro rata by the tribe, 
the individual allottee, and other non-Indian entities. 
INTERROGATORY NO. 4: Describe how Plaintiffs’ Trust Compensation Plan would account 
for instances where mineral rights are owned by the tribe even though an allottee may own the 
surface rights for the land where the production well is located. 
INTERROGATORY NO. 5: Identify how Plaintiffs “determined that the most appropriate 
index to compute interest on the monies generated fiom Allotted Lands was the long term 
corporate bond index” (Plaintiffs’ Trust Compensation Plan at 51). 
INTERROGATORY NO. 6: Identify (a) why Plaintiffs “believe that qualified experts can be 
retained” to identify “the members of the class in the Cobell lawsuit” (Plaintiffs’ Trust 
Compensation Plan at 52); and (b) precisely how such experts would conduct “such a search” 
(Id.). 
INTERROGATORY NO. 7: Identify precisely how Plaintiffs propose to make “the proper 
determinations of amounts to be credited to individual accounts” under Plaintiffs’ Trust 
Compensation Plan (Plaintiffs’ Trust Compensation Plan at 53). 
INTERROGATORY NO. 8: Define the meaning that Plaintiffs ascribe to the term “allotted 
land percentages,” as used (frequently) in Plaintiffs’ Trust Compensation Plan. 
INTERROGATORY NO. 9: For each named plaintiff addressed in the Revised Interim Final 
Report of Joseph R. Rosenbaum, dated November 19,2001, please state whether you agree with 
the results compiled. If you do not, please state in detail each and every instance in which you 
disagree and identify all documents which support your contention. 
INTERROGATORY NO. 10: Describe any changes in existing statutes that would be 
necessary to implement and cany out the Plaintiffs’Trust Management Plan. 
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INTERROGATORYNO. 11: Describe any changes in funding of trust-related activities in 
current or future fiscal years that would be necessary to implement and carry out the Plaintiffs' 
Trust Management Plan. 
INTERROGATORY NO. 12: Describe the "divergent interests of individual Indian trust 
beneficiaries and tribal leaders" that "require the complete separation of trust administration" 
(Plaintiffs' Trust Management Plan at 42). 
INTERROGATORY NO. 13: Describe the effect that implementation of the Plaintiffs' Trust 
Management Plan would have on Indian tribes that are currently perfoming trust-related 
activities that affect individual Indian beneficiaries. 
INTERROGATORY NO. 14: Describe the basis for Plaintiffs' "belie[fl" that it is possible to 
comply with "the ordinary, applicable Indian preference policy of the Department of Interior" 
(Plaintiffs' Trust Management Plan at 33 n.43) while implementing and carrying out the 
Plaintiffs' Trust Management Plan, including but not limited to removing conflicted personnel 
(idat 33), "appoint[ing] new and independent trust administration management" (id.at 33-36, 
38), and "segregat[ing]administration of ITMtrust records fiom tribal and other DO1 records" 
(id.at 42). 
INTERROGATORY NO. 15: For each of the titled positions identified in the Plaintiffs' Trust 
Management Plan (seegenerally id.at 33-40), describe how each position would fit into the 
organizational structure of the Department of the Interior and, if applicable, how each position 
would fit into the organizational structure of an entity other than the Department of Interior. 
INTERROGATORY NO. 16: Describe who would be in charge of trust reform if the Plaintiffs' 
Trust Management Plan were implemented as written. 
INTERROGATORY NO. 17: Describe how the Trust Manager would "segregate 
administration of IIMtrust records fioni tribal and other DO1 records" and achieve the "complete 
separation of trust administration" (Plaintiffs' Trust Management Plan at 42-43). 
INTERROGATORY NO. 18: For each action required to be taken or completed within a 
certain number of days, as identified in the Plaintiffs' Trust Management Plan (seegenerally 
at 33-47), describe the basis for asserting that each particular action can be taken or completed 
within the prescribed number of days. 
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INTERROGATORYNO.19: Describe the complete basis for the statement in Plaintiffs' 
Response to Defendants' Historical Accounting Plan for Individual Indian Money Accounts at 26 
(filed January 31,2003) that "the vast majority of trust records necessary to support a complete 
and accurate historical accounting either do not exist or have been destroyed by the trusteedelegates.
" 
Dated: February 2 I, 2003 Respecthlly submitted, 
ROBERT D. McCALLUM, JR. 
Assistant Attorney General 
STUART E. SCHIFFER 
Deputy Assistant Attorney General 
J. CHRISTOPHER KOHN 
Deputy Kector 
D.C. Bar No. 261495 
JOHN T. STEMPLEWICZ 
Senior Trial Attorney 
PHLLLLP M. SELIGMAN 
Commercial Litigation Branch 
Civil Division 
P.O. Box 875 
Ben Franklin Station 
Washington, D.C. 20044-0875 
(202) 514-7194 This is the background image for an Adobe Acrobat Capture page with image plus hidden text.  
CERTIFICATE OF SERVICE 
I declare under penalty of perjury that, on February 21,2003 I served the foregoing Interior 
Defendants ’Set of Interrogatories, Dated February 21, 2003 by hand upon: 
Keith Harper, Esq. 
Native American Rights Fund 
1712N Street, N.W. 
Washington, D.C. 20036-2976 
(202) 822-0068 
By US. Mail upon: 
Elliott Levitas, Esq. 
1100 Peachtree Street, Suite 2800 
Atlanta, GA 30309-4530 
By hand upon: 
Alan L. Balaran, Esq. 
Special Master 
1717 Pennsylvania Avenue, N. W. 
13th Floor 
Washington, D.C. 20006 
(202) 986-8477 
Joseph S. Kieffer, ILl 
Special Master Monitor 
420 7* Street, N.W. 
Apartment 705 
Washington, D.C. 20004 
(202) 478-1958 
Dennis M Gingold, Esq. 
Mark Kester Brown, Esq. 
1275 Pennsylvania Avenue, N.W. 
Ninth Floor 
Washington, D.C. 20004 
(202) 318-2372 
Jay St. John1 This is the background image for an Adobe Acrobat Capture page with image plus hidden text.  
IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 
ELOUISE PEPION COBELL, & al., 
Plaintiffs, 
1 
v. ) Case No. 1:96CVO1285 
) (Judge Lamberth) 
GALE A. NORTON, Secretary of the Interior, a &) 
) 
Defendants. 
INTERIOR DEFENDANTS’ REQUEST FOR PRODUCTION 
OF DOCUMENTS. DATED FEBRUARY 21,2003 
Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, the Secretaty.of the 
Interior and the Assistant Secretary- Indian Affairs (“Lnterior Defendants”) hereby request that 
Plaintiffs’ class representatives produce the documents requested herein for inspection and 
copying within thirty days after service, at the offices of the Department of Justice, 1100 L Street, 
N.W., Washington, DC 20005, or at such other place and time as the parties may agree, in 
accordance with the following definitions and instructions. Any written objections to this request 
for production shall be served within thirty days aRer service. 
DEFINITIONS 
In these document requests, the following definitions will apply: 
A. “Document“or “documents” means any written or graphic matter of any kind or 
nature, however produced, reproduced, or recorded, whether handwritten, typed, drawn, 
sketched, printed, computer-generated, microfiched, microfilmed, or recorded by any physical, 
mechanical, electronic or electrical means whatever, whether produced, reproduced, or stored on 
paper, cards, disc, tape, film, electronic facsimile, computer storage, or any other media, whether 
Exhibit 2 
Interior Defs’ Opposition to 
Pltfs‘Motion for Order This is the background image for an Adobe Acrobat Capture page with image plus hidden text.  
an original, master, or duplicate includingwithout limitation, books, records, papers, film, 
videotape, sound recordings, pamphlets, brochures, circulars, advertisements, specifications, 
blueprints, maps, telegrams, notes, notebooks, work sheets, electronic mail transmissions, 
reports, diaries, or items similar to any of the foregoing. "Document" or "documents"shalI 
further collectively include the original, duplicate original, and any or all copies or reproductions 
of the original document, to the extent that any or all copies are different in any way from the 
original document, whether by interlineation, receipt stamps, notation, indication of copies sent 
or received, or otherwise. 
B. Words used in the singular shall be construed to include the plural, and vice versa. 
Words used with reference to a person of the male gender shall also be construed to refer to a 
person of the female gender, and vice versa. 
"Identitjr"or "identity" shall have the following meanings: 
When used in reference to an organization, the response shall state the full name 
and present or last known address of the corporation, partnership, firm or other 
entity. 
When used in reference to an individual, the response shall state his or her full 
name, present or last known address, present or last known business affiliation 
and job description, any past or present affiliation with you, the manner in which 
he relates to any of the issues or facts in this litigation, and the source and extent 
of his or her knowledge about any of these facts or issues. If you do not know the 
present address or present employer of any such person, please so indicate and 
state his last known address and last known employer. 
When used in reference to a document, the response shall state the type of 
document (e.g., memorandum, letter, note, contract), its date, author(s), 
addressee(s) (if any), synopsis of content, and present location. In lieu of 
providing this information, you may attach a copy of the document to your 
answers. 
When used in reference to a source of information, the response shall identify 
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each individual providing information. The response shall also state whether the 
information has been reduced to writing or other tangible form. If so, this writing 
or other record shall be identified in the manner described in subparagraph (3) 
above. 
D. "Describe" or "state" means the following: Describe fully by reference to 
underlying facts rather than ultimate facts or conclusions of law or facts, and 
particularize as to: 
(I) the identity of each person involved in each such event, including, but not 
limited to persons employed by you and those persons purporting to act for 
YOU; 
(2) the specific acts of each person participating in each such event; 
(3) the date and time of each such event; 
(4) the address and location of each such event; and, 
( 5 ) the identity of each person present during each such event. 
E. Documents to be identified or facts to be stated are described as those which 
"relate to" any entity, a person, an action, a document, or an event. The term "relate to" means to 
name, to refer to either directly or indirectly, to comment upon, analyze, review, report on, form 
the basis of, be considered in the preparation of, result from, be in any way connected with, 
emanate horn, or have any logical relation to the entity, person, document, event, or action. 
F. "Person" or "individual" means any natural person, corporation, partnership, other 
business association or entity recognized by law, and the employees or independent contractors 
thereof, and any domestic or foreign government body, commission, board, agency, branch, 
department, component or element thereof. 
G. "And" as well as "or" shall be construed in either the disjunctive or conjunctive 
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form as necessary to bring within the scope of the document request any information which may 
otherwise be construed outside its scope. 
H. ”You”or “your“means any of the Plaintiffs who are designated as class 
representatives in this lawsuit, and any agent of theirs. 
I. “Communication” means any transmission of words or thoughts by a person or 
between or among two or more persons, including but not limited to spoken words, discussions, 
conferences, conversations, negotiations, agreements, understandings, interviews, inquiries, 
promises, correspondence, statements, whether oral or written, and whether transmitted in person 
or by electronic or other means, including but limited to radio, telphonic, fax, email or other 
means. 
J. “Plaintiffs’ Trust Compensation Plan” means the paper entitled “Plaintiffs’ Plan 
for Determining Accurate Balances in the Individual Indian Trust,” filed by Plaintiffs on January 
6,2003. 
K. “Plaintiffs’ Trust Management Plan” means the paper entitled ““Plaintiffs’ 
Compliance Action Plan Together with Applicable Trust Standards,” filed by Plaintiffs on 
January 6,2003. 
L. “Allotted Lands” has the meaning that Plaintiffs’ ascribed to it when used in 
Plaintiffs’ Trust Compensation Plan. 
M. “Allotted royalties” has the meaning that Plaintiffs’ ascribed to it when used in 
Plaintiffs’ Trust Compensation Plan. 
N. “Allotted revenue” has the meaning that Plaintiffs’ ascribed to it when used in 
Plaintiffs’ Trust Compensation Plan. 
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INSTRUCTIONS 
A. If you contend that you are entitled to withhold &om production a requested 
document, or any part thereof, on the basis of attorney/client privilege, the work product doctrine, 
or other grounds, you are to provide a list with the following information: 
Principals. The name and title of the author(s), sender(s), addressee(s), and 
recipient(s). 
Date. The date the document was originated. 
Publications. The date and title of each person to whom the contents of the 
document has been communicated (by copy, exhibition, reading, summarization, 
or otherwise). 
Descriptions. A description of the nature and subject matter of the document. 
Privilege. A statement of the privilege and the basis upon which it is asserted. 
Paws. The number of pages in the document. 
Custodian. The present custodian of the document. 
Notwithstanding a claim that a document is privileged, any document so withheld must 
be produced with the portion claimed to be protected excised. 
B. You are requested to produce all documents in your possession, custody or controi 
in their original file folders and to identify the file from which each document came. All 
documents produced are to be clearly organized and labeled to correspond to each Request or as 
they are kept by you in the usual course of business, provided that you identi@ the individual file 
in which they were maintained. 
C. If you object to or otherwise decline to produce any documents responsive to a 
document request, please provide all documents called for by that portion of the document 
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request to which you do not object or to which you do not decline to produce. If you object to a 
document request on the ground that it is too broad (i.c., that it calls both for documents which 
are within the scope of Rule 26 and documents which are not), provide the documents that you 
contend are within the scope of Rule 26. If you object to a document request on the ground that 
to provide the requested documents would constitute an undue burden, provide all requested 
documents that can be supplied without undertaking an undue burden. For those portions of a 
production request to which you object or otherwise decline to produce, state the reason for such 
objection or declination. 
D. You are required to furnish all documents in your possession, custody or control, 
including those documents not merely in your custody but also those in the possession of your 
attorneys, agents, or other persons under your control. 
E. If any document requested was formerly in your possession, custody, or control 
and has been lost or destroyed, you are requested to submit in lieu of each such document a 
written statement that: (i) describes in detail the nature of the document and its contents; 
(ii) identifies the person who prepared or authorized the document and, if applicable, the person 
to whom the document was sent; (iii) specifies the date upon which the document was prepared 
or transmitted or both; and, (iv) specifies, ifpossible, the date upon which the document was 
destroyed, and, if destroyed, the conditions of or reasons for such destruction and the persons 
requesting and performing the destruction. 
F. Some specified requests for documents may be subsumed in the scope of other 
requests for documents. Documents responsive to requests so subsumed may be produced in 
response to the request with the broader scope. 
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G. In producing the requested documents, you do not need to produce any documents 
that were included as exhibits to Plaintiffs’ Trust Compensation Plan or Plaintiffs’ Trust 
Management PIan. 
DOCUMENTS REOUESTED 
REOUEST NO. 1: All documents relied upon by Plaintiffs in drafting Plaintiffs’ Trust 
Compensation Plan that contain information that was included in Plaintiffs’ Trust Compensation 
Plan. 
REOUEST NO. 2: All documents relied upon by Plaintiffs in drafting Plaintiffs’ Trust 
Compensation Plan that support Plaintiffs’ contention that “even the Interior defendants have 
admitted that the historical accounting that the United States government owes to individual 
Indian trust beneficiaries is impossible” (Plaintiffs’ Trust Compensation Plan at 7). 
REOUEST NO. 3: All documents relied upon by Plaintiffs in drafting Plaintiffs’ Trust 
Compensation Plan that support Plaintiffs’ contention that “routinely BIA agency 
superintendents and field personnel have used Trust funds as slush funds” (Plaintiffs’ Trust 
Compensation Plan at 11). 
REQUEST NO. 4: All documents relied upon by Plaintiffs in drafting the “Oil and Gas” 
portion of Plaintiffs’ Trust Compensation Plan that contain information related to Plaintiffs’ plan 
to compute total revenues from reservations with Allotted Lands by “estimating historical 
production volumes and applying historical price estimates”(Plaintiffs’ Trust Compensation Plan 
at 42). 
REQUEST NO. 5: All documents relied upon by Plaintiffs in drafting the “Oil and Gas‘’ 
portion of Plaintiffs’ Trust Compensation Plan that contain information related to Plaintiffs’ plan 
to compute total royalties “by applying historical royalty rates to total revenues” (Plaintiffs’ Trust 
Compensation Plan at 42). 
REOUEST NO. 6: All documents relied upon by Plaintiffs in drafting the “Oil and Gas” 
portion of Plaintiffs’ Trust Compensation Plan that contain information related to Plaintiffs’ plan 
to compute allotted royalties “by applying historical Allotted Land percentages to total royalties’’ 
(Plaintiffs’ Trust Compensation Plan at 42). 
REQUEST NO. 7: All documents relied upon by Plaintiffs in drafting the “Hard Rock 
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Minerals” portion of Plaintiffs’ Trust Compensation Plan that contain information related to 
Plaintiffs’ plan to compute total revenues from reservations with Allotted Lands by “estimating 
historical Hard Rock production and applying historical price estimates” (Plaintiffs’ Trust 
Compensation Plan at 46). 
REOUEST NO. 8: All documents relied upon by Plaintiffs in drafting the “Hard Rock 
Minerals” portion of Plaintiffs’ Trust Compensation Plan that contain information related to 
Plaintiffs’ plan to compute total royalties “by applying historical royalty rates to total revenues” 
(Plaintiffs’ Trust Compensation Plan at 46). 
REOUEST NO. 9: All documents relied upon by Plaintiffs in drafting the “Hard Rock 
Minerals” portion of Plaintiffs’ Trust Compensation Plan that contain information related to 
Plaintiffs’ plan to compute allotted royalties “by applying historical Allotted Land percentages to 
total royalties” (Plaintiffs’ Trust Compensation Plan at 46). 
REOUEST NO. 10: All documents relied upon by Plaintiffs in drafting the “Land Leases” 
portion of Plaintiffs’ Trust Compensation Plan that contain information related to Plaintiffs’ plan 
to estimate “total revenue by land use type (agricultural, grazing, business, and other)” 
(Plaintiffs’ Trust Compensation Plan at 48). 
REOUEST NO. 11: All documents relied upon by Plaintiffs in drafting the “Land Leases” 
portion of Plaintiffs’ Trust Compensation Plan that contain information related to Plaintiffs’ plan 
to estimate allotted revenue “by applying average Allotted Land percentages to estimated total 
revenues” (Plaintiffs’ Trust Compensation Plan at 48). 
REOUEST NO. 12: All documents relied upon by Plaintiffs in drafting the “Land Sales” 
portion of Plaintiffs’ Trust Compensation Plan that contain information related to Plaintiffs’ plan 
to compute “total revenue (value of Allotted Lands sold)” (Plaintiffs’ Trust Compensation Plan 
at 49). 
REQUEST NO. 13: All documents relied upon by Plaintiffs in drafting the “Land Sales” 
portion of Plaintiffs’ Trust Compensation Plan that contain information related to Plaintiffs’ plan 
to apply “an adjustment factor to account for an understatement in the data” (Plaintiffs’ Trust 
Compensation Plan at 49). 
REOUEST NO. 14: All documents relied upon by Plaintiffs in drafting the “Land Sales” 
portion of Plaintiffs’ Trust Compensation Plan that contain information related to Plaintiffs’ plan 
to estimate “total allotted acres” (Plaintiffs’Trust Compensation Plan at 49). 
REQUEST NO. 15: All documents relied upon by Plaintiffs in drafting the “Land Sales” 
portion of Plaintiffs’ Trust Compensation Plan that contain information related to Plaintiffs’ plan 
to estimate “allotted acres sold based on the percent of allotted acres sold historically” (Plaintiffs’ 
Trust Compensation Plan at 49). 
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REQUEST NO. 16: All documents relied upon by Plaintiffs in drafting the “Land Sales” 
portion of Plaintiffs’ Trust Compensation Plan that contain information related to Plaintiffs’ pIan 
to estimate “the price per acre for Allotted Land Sales” (Plaintiffs’Trust Compensation Plan at 
49). 
REOUEST NO. 17: All documents relied upon by Plaintiffs in drafting the “Land Sales” 
portion of Plaintiffs’ Trust Compensation Plan that contain information related to Plaintiffs’ plan 
to estimate “revenues from Allotted Land sales as allotted acres sold times price per acre” 
(Plaintiffs’ Trust Compensation Plan at 49). 
REOUEST NO. 18: All documents relied upon by Plaintiffs in drafting Plaintiffs’ Trust 
Compensation Plan that contain information related to Plaintiffs’ determination“that the most 
appropriate index to compute interest on the monies generated from Allotted Lands was the long 
term corporate bond index” (Plaintiffs’ Trust Compensation Plan at 5 1). 
REQUEST NO. 19: All documents provided to Plaintiffs by the persons identified in response 
to InterrogatoryNo. 1 of Interior Defendants’ Set of Interrogatories, Dated February 21,2003, 
which contain information that was included in Plaintiffs’ Trust Compensation Plan. 
REQUEST NO. 20: All documents relied upon by Plaintiffs in drafting Plaintiffs’ Trust 
Management Plan that contain information that was included in Plaintiffs’ Trust Management 
Plan. 
REQUEST NO. 21: All documents provided to Plaintiffs by the persons identified in response 
to InterrogatoryNo. 2 of Interior Defendants’ Set of Interrogatories, Dated February 21,2003, 
which contain information that was included in Plaintiffs’ Trust Management Plan. 
REOUEST NO. 22: All of the “over 100books, reports, studies and periodicals” (Plaintiffs’ 
Trust Compensation Plan at 41) that were relied upon by Plaintiffs in creating their “database of 
Allotted Lands”(Id.). 
REQUEST NO. 23: All documents generated by PriceWaterhouseCoopers, or any other expert 
retained by Plaintiffs or their counsel, which are in the possession, custody, or control of 
Plaintiffs or their counsel, that show the amount of revenue that IIM lands held in trust by the 
Department of the Interior should have earned during the Department of the Interior‘s 
administration. 
REQUEST NO. 24: All documents generated by PriceWaterhouseCoopers, or any other expert 
retained by Plaintiffs or their counsel, which are in the possession, custody, or control of 
Plaintiffs or their counsel, that refer or relate to the amount of revenue that the Department of the 
Interior has collected as a result of its administration of IIM trust assets. 
REQUEST NO. 25: All documents generated by PriceWaterhouseCoopers, or any other expert 
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retained by Plaintiffs or their counsel, which are in the possession, custody, or control of 
Plaintiffs or their counsel, that refer or relate to the amount of revenue that the Department of the 
Interior has disbursed to individual Indian account holders as a result of the Department of the 
Interior's administration of IIMtrust assets. 
REOUEST NO. 26: All documents identified in response to Interrogatory No. 9 of Interior 
Defendants' Set of Interrogatories,Dated February 21,2003. 
February 2 1,2003 Respectfully submitted, 
ROBERT D. McCALLUM, JR. 
Assistant Attorney General 
STUART E. SCHIFFER 
Deputy Assistant Attorney General 
J. CHRISTOPHER KOHN 
JOHN T. STEMPLEWICZ 
Senior Trial Attorney 
PHILLIP M. SELIGMAN 
Commercial Litigation Branch 
Civil Division 
P.O. Box 875 
Ben Franklin Station 
Washington, D.C. 20044-0875 
(202) 514-7194 
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CERTIFICATE OF SERVICE 
I declare under penalty of perjury that, on February 2 1,2003 I served the foregoingInterior 
Defendants 'Requestfor Production OfDocuments, Dated February 22.2003 by hand upon: 
Keith Harper, Esq. 
Native American Rights Fund 
1712N Street, N.W. 
Washington, D.C. 20036-2976 
(202) 822-0068 
By U.S. Mail upon: 
Elliott Levitas, Esq. 
1100 Peachtree Street, Suite 2800 
Atlanta, GA 30309-4530 
By hand upon: 
Alan L. Balaran, Esq. 
Special Master 
1717 Pennsylvania Avenue, N.W. 
13th Floor 
Washington, D.C. 20006 
(202) 986-8477 
Joseph S. Kieffer, 
Special Master Monitor 
420 7" Street, N.W. 
Apartment 705 
Washington, D.C. 20004 
(202) 478-1958 
Dennis M Gingold, Esq. 
Mark Kester Brown, Esq. 
1275 Pennsylvania Avenue, N.W. 
Ninth Floor 
Washington, D.C. 20004 
(202) 318-2372 This is the background image for an Adobe Acrobat Capture page with image plus hidden text.  
CERTIFICATE OF SERVICE 
I declare under penalty of perjury that, on April 7,2003 I served the Foregoing Interior 
Defendants' Opposition to Plaintgs 'Motion For Order (1) Requiring Defendants to Bear the 
Cost of Responding to Interior Defendants' February 21, 2003 Discovery and (2) to Grant 
Plaintiffs an Enlargement of Time by facsimile in accordance with their written request of October 
31,2001 upon: 
Keith Harper, Esq. 
Native American Rights Fund 
1712 N Street, N.W. 
Washington, D.C. 20036-2976 
(202) 822-0068 
By U.S. Mail upon: 
Elliott Levitas, Esq. 
1100 Peachtree Street, Suite 2800 
Atlanta, GA 30309-4530 
By facsimile and U.S. Mail upon: 
Alan L. Balaran, Esq. 
Special Master 
1717 Pennsylvania Avenue, N.W. 
13th Floor 
Washington, D.C. 20006 
(202) 986-8477 
By hand upon: 
Joseph S. Kieffer, LII 
Special Master Monitor 
420 7fhStreet, N.W. 
Apartment 705 
Washington, D.C. 20004 
(202)248-9543 
Dennis M Gingold, Esq. 
Mark Kester Brown, Esq. 
1275 Pennsylvania Avenue, N. W. 
Ninth Floor 
Washington, D.C. 20004 
(202) 318-2372