Request for Status Conference
Alan L. Schneider, OSB No. 68147
Paula A. Barran, OSB No. 80397
Attorneys for Plaintiffs
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF OREGON
ROBSON BONNICHSEN, et al.,
UNITED STATES OF AMERICA, DEPARTMENT OF THE ARMY, et al.,
Defendants. CV No. 96-1481 JE
Request for Status Conference Fed. R. Civ. P. 16
Plaintiffs hereby request the Court to schedule a status conference so that the Court and the parties may discuss the schedule and procedures for the resumption of litigation between the parties. Plaintiffs believe the issue which warrant further discussion include:
1. Lifting the stay of proceedings so that they may proceed with their original claims.
2. The extension of the Court's curation order to preclude defendants from taking any action to harm or dispose of the skeleton pending the final resolution of this litigation.
3. Lifting the stay of proceedings so that they may amend their original complaint to assert additional causes including violations by defendants of the National Historic Preservation Act and the Freedom of Information Act.
4. Expeditious settlement of the administrative record and provision of all materials to plaintiffs including but not limited to all drafts, electronically stored materials, correspondence, scientific reports, data from DNA testing, and all drafts thereof, including original drafts of all scientific reports.
5. Plaintiffs discovery requests.
6. Plaintiffs request that the Court hear their challenge to this final action at the earliest possible time after receipt of the administrative record, and to discuss scheduling of the order in which remaining claims and issues will be adjudicated.
7. Court review of the present storage conditions of the skeleton to determine whether they are consistent with the Court's order for proper preservation of its physical integrity and scientific values.
Dated this 25th day of September, 2000.
BARRAN LIEBMAN LLP
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