Plaintiffs' Reply to Defendants
Part 1
Defendants Have Not Shown That Their 1492 Rule is Proper
Defendants' Cultural Affiliation Determination Violated the Administrative
Procedures Act
Part 2
Defendants Repatriation to a Coalition Violates the Statute
Defendants Use of Informal Adjudication Was Improper and Contrary
to the Court's Order
Defendants' First Amendment Arguments Misstate the Law and Facts
Part 3
Defendants Violated NHPA
Defendants' Curation Arguments Are Not Credible
Defendants Violated the Freedom of Information Act
A Second Remand to Defendants Would Not be Appropriate
Appendix C
Cultural Affiliation Information Submitted by Plaintiffs
Appendix D
Plaintiffs' Participation in Administrative Process (Meetings,
Telephone Conferences, Letters and other Forms of Remote Communication)
Appendix E
Handling (9/1996 - 12/1998)
Affidavits
Dr. Robson Bonnichsen
Dr. Douglas Owsley
Ms Cleone Hawkinson
Return to Briefs
|
