Free Joint Status Report - District Court of Federal Claims - federal

Case 1:01-cv-00444-MMS

Document 68

Filed 06/29/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________________________________________ ) QUINAULT INDIAN NATION, ) ) Plaintiff, ) ) No. 01-444 L v. ) ) THE UNITED STATES OF AMERICA, ) Judge Margaret M. Sweeney ) Defendant. ) __________________________________________) EIGHTH JOINT STATUS REPORT Pursuant to the Court's Order of May 14, 2007 (Doc. 67), the parties file this eighth Joint Status Report ("JSR") to report on their progress toward implementing the terms of the Settlement Agreement signed by the parties on September 20, 2004. As noted in previous Joint Status Reports, the settlement framework envisions the purchase (with appropriated and privately-donated monies) of several permanent conservation easements to be held by the United States Fish and Wildlife Service by no later than December 2006. At the parties' requests, the Court has granted several stays of proceedings to allow the parties and the third-party (the Trust for Public Lands) time to complete funding and acquisition. The parties are pleased to report that funds sufficient to complete the federal obligation under the parties' settlement agreement have been appropriated and paid to Plaintiff. In addition, the conservation easements required by the settlement agreement have been executed and recorded, and the Trust for Public Lands obligations in connection with the settlement have been completed.

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Case 1:01-cv-00444-MMS

Document 68

Filed 06/29/2007

Page 2 of 2

The final step in the parties' settlement process is the filing of a Joint Motion for Withdrawal and Dismissal of Claims With Prejudice. The parties have prepared this Joint Motion and expect to file it with the Court next week. In advance of that filing, however, Plaintiff will be filing a substitution of counsel in accordance with RCFC 83.1. This JSR was jointly prepared by counsel for the Nation and counsel for the United States and is filed by Defendant with consent of and on behalf of both parties.

Dated: June 28, 2007 Respectfully submitted, RONALD J. TENPAS Assistant Attorney General Environment & Natural Resources Division s/ Kristine S. Tardiff _ KRISTINE S. TARDIFF U.S. Department of Justice Environment & Natural Resources Section 53 Pleasant Street, 4th Floor Concord, NH 03301 TEL: (603) 230-2583 FAX: (603) 225-1577 Attorney of Record for Defendant Of Counsel: MARLENE ZICHLINSKY Office of the Regional Solicitor Pacific Northwest Region U.S. Department of the Interior 500 N.E. Multnomah, Suite 607 Portland, OR 97232 TEL: (503) 231-2128 FAX: (503) 231-2166

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