Court Documents Concerning Black Canyon National Park Water Right

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District Court Water Division No. 4 Colorado Court Address: Montrose Combined Court 1200 N. Grand Ave. Montrose, CO 81401 . CONCERNING THE APPLICATION FOR WATER RIGHTS OF: THE UNITED STATES OF AMERICA IN MONTROSE COUNTY. COURT USE ONLY David W. Gehlert Case Number: 01 CW 05 U.S. Department of Justice Environment & Natural Resources Div. 999 - 18 St., Suite 945 Denver, CO 80202 Attorney Reg. No. 021852 Division 4 Courtroom 2 Phone Number: (303) 312 -7352 FAX Number: (303) 312 -7379 E -mail: david.gehlert@usdoj.gov THE UNITED STATES' MOTION TO AMEND AND FOR FURTHER STAY OF THE PROCEEDINGS Pursuant to Colorado Rules of Civil Procedure 15 (a) and Colorado Water Court Rule 4, . the United States respectfully requests leave of court to amend its QUANTIFICATION OF THE RESERVED RIGHT. FOR BLACK CANYON OF THE GUNNISON NATIONAL PARK IN THE FORM OF AN APPLICATION TO MAKE ABSOLUTE A CONDITIONAL WATER RIGHT ( "the application '). The United States seeks to amend its application to quantify. the federal reserved water right for Black Canyon National Park at 300 cfs, or natural flow, whichever is less because it will pursue additional water for Park purposes through an instream flow right under Colorado law. The United States' amended application is attached hereto. The United States further requests that litigation of this matter be stayed, with the exception of consideration of the United States' motion to amend, for an additional six month period to allow the process for obtaining an instream flow right under Colorado law to proceed, circulation of a proposed decree and withdrawal of oppositions. A stay warranted to allow the objectors opportunity to consider whether they wish to continue their opposition in light of the United States' amended application while avoiding having to expend_ substantial sums of money and resources in litigation that will effectively be mooted by the United States' amended application. The United States suggests a status conference be held at the end of the sixth month period to assess progress..