Defendants' Motion for a PO Regarding Plaintiffs' Request for Production of MMS Audit Documents and

IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIA)ELOUISE PEPION COBELL, et al.,)) No. 1:96CV01285Plaintiffs, ) (Judge Lamberth) v. ) )GALE A. NORTON, Secretary of )the Interior, et al., )) Defendants. ))DEFENDANTS’ MOTION FOR A PROTECTIVE ORDER REGARDING PLAINTIFFS’REQUEST FOR PRODUCTION OF MMS AUDIT DOCUMENTS AND PLAINTIFFS'NOTICES OF DEPOSITION OF DEBORAH GIBBS TSCHUDY AND LONNIE J.KIMBALL WITH REQUESTS FOR PRODUCTION OF DOCUMENTSPursuant to Federal Rule of Civil Procedure 26(c)(1), Defendants move for a protectiveorder regarding Plaintiffs' October 1, 2003 request for production of Minerals ManagementService ("MMS") audit documents ("Request for MMS Audit Documents") (attached as Exhibit11), Plaintiffs' Notice of Deposition of Deborah Gibbs Tschudy with Request for Production ofDocuments (October 17, 2003) ("Gibbs Tschudy Deposition Notice") (attached as Exhibit 2) andPlaintiffs' Notice of Deposition of Lonnie J. Kimball with Request for Production of Documents(October 20, 2003) ("Kimball Deposition Notice") (attached as Exhibit 3). These discoveryrequests constitute unauthorized discovery and are unrelated to a future proceeding. To theextent Plaintiffs premise their right to discovery at this time on the Site Visit Report of theSpecial Master to the Dallas, Texas Office of the Minerals Revenue Management Division of theDepartment of the Interior's Minerals Management Service (undated) (filed ...