Free Status Report - District Court of Federal Claims - federal

Case 1:01-cv-00444-MMS

Document 66

Filed 05/07/2007

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. ) __________________________________________) SEVENTH JOINT STATUS REPORT Pursuant to the Court's Order of March 15, 2007, the parties file this seventh 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 ("JSRs"), 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 settlement continues to proceed as envisioned in the settlement agreement. As previously report, the federal party has appropriated funds sufficient to complete the federal obligation. Plaintiffs have prepared the final conservation easement encompassing the lands at issue in the settlement. Defendant is in the process of reviewing the final conservation easement. This review process is taking longer than originally anticipated, but Defendant expects to

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Case 1:01-cv-00444-MMS

Document 66

Filed 05/07/2007

Page 2 of 2

complete this review process in the next two to three weeks. Once this process is completed, the settlement calls for final payment by Defendant to be made and for the conservation easement to be executed and recorded. Thereafter, the Trust for Public Land is expected to complete its obligation. Given the additional time needed by Defendant to complete it review process, the parties respectfully request that the stay of proceedings in this case be continued through June 29, 2007. The parties further propose to report back to the Court on or before June 29, 2007, regarding the status of their settlement implementation. 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 behalf of both parties. Respectfully submitted, MATTHEW J. McKEOWN Acting 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 -2-