1—Cold Mountain Cold Rivers Complaint

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MONTANA
HELENA DIVISION

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COLD MOUNTAIN, COLD RIVERS, INC.;
BUFFALO FIELD CAMPAIGN, and
THE ECOLOGY CENTER, INC.

No.

Plaintiffs,

COMPLAINT AND DEMAND
FOR DECLARATORY AND
INJUNCTIVE RELIEF

-vs-

MONTANA DEPARMENT OF
LIVESTOCK; DAVID GARBER,
SUPERVISOR, GALLATIN NATIONAL
FOREST; UNITED STATES
FOREST SERVICE; DALE BOSWORTH,
CHIEF OF THE FOREST SERVICE;
ANN VENNEMAN, SECRETARY OF
AGRICULTURE;UNITED STATES FISH
AND WILDLIFE SERVICE;
GAIL NORTON, SECRETARY
OF INTERIOR; and NATIONAL PARK
SERVICE,

Defendants.

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I.

INTRODUCTION

1.

In this action, Cold Mountain, Cold Rivers, Inc.

(CMCR), The Ecology Center, Inc. (TECI), and Buffalo Field

Campaign (BFC) (hereinafter Plaintiffs) challenge the United

States Forest Service’s and Montana Department of Livestock’s

failure to pre-monitor bald eagle nests on the Horse Butte

Peninsula (Peninsula) in 2001 prior to constructing the bison