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<br />Answer, Page 3(con't), <br />3. Recognizing that perhaps the Court, as stated by the <br />Defendant's representative,may not be the proper venue for the <br />termination of a Federal employee for cause, Plaintiff, in his <br />Amended Complaint, has asked that a Jury determine as a recom- <br />mendation to the proper authority, such action , based on the <br />facts presented to them. The proper authority is without doubt <br />the Defendant, Gale Norton in her capacity as Secretary of the <br />Interior. <br />4. Administrative appeals and remedies by Plaintiff were <br />exhausted when he completed the following series of contacts; <br />He verbally discussed the matter with Colo State BLM, Chief of <br />Solid MInerals, Mr. Jim Edwards at 370 239 3790 on Sept. 28,2004 <br />and he basically repeated what was said in the 2004 NON "You will <br />have to move y .our trailer". A Complaint Letter was subsequently <br />FAXED to Mr. Edwards on Sept. 29,2004, referring to Babbitt's 1Q93 <br />directive to discontinue patenting. Previously, several attempts <br />to file a patent application were refused by the Denver BLM office. <br />Subsequent to Mr.Edwards refusal to adjust the NON, a phone <br />conversation with Mr. Tom Loni, Assistant Director for Minerals, <br />Washington, D.C., resulted in the assignment of Mr. Bob Anderson, <br />Mining Law Administrator, to resolve the matter. I had hopes at <br />that point that the BLM would make a reasonable adjustment to <br />resolve the matter(For that to happen, all that was needed was a <br />letter similar to the one received in 1987, authorizing the use <br />of the trailer for a guard residence,which we felt was essential), <br />But,almost immediately I had further difficulties with Rob Ernst <br />in the Craig BLM office, when I request? him to provide computer <br />information on mining claims, and he refused to do so. I complained <br />about that to Mr. Edwards, and he assigned Juanita Brown in the <br />Denver Office to get me the claim information. However, after a <br />month's delay, Mr. Anderson made no progress in changing the NON.