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CONCLUSION <br />Considering the specific facts of this case, issuance of the requested stay is appropriate <br />and would serve the interest of justice. Granting the stay will promote judicial economy, <br />conserve time and effort by the many parties to the present case, and is particularly appropriate <br />in this instance because resolution of the federal issues will substantially impact issues to be <br />resolved in the state court proceeding. In addition, Environmental Plaintiffs' rights under federal <br />law could be severely prejudiced if proceedings in this Court continue before resolution of the <br />federal issues. Therefore, Environmental Opposers respectfully request that this Court stay the <br />proceedings herein until such time as the issues presented in the federal Complaint have been <br />resolved or until such time as this Court determines that Environmental Plaintiffs are not <br />pursuing resolution of those issues with diligence. <br />Respectfully submitted this 12 day of September, 2003. <br />Bart Miller <br />Andrew Peternell <br />/s/ Bart Miller /s/ Andrew Peternell <br />Duly Signed Copy on File. Duly Signed Copy on File. <br />Bart Miller, Reg. No. 27911 Andrew Peternell, Reg. No. 32455 <br />CERTIFICATE OF SERVICE <br />The undersigned hereby certifies that on this 12 day of September 2003, a true and correct copy <br />of the foregoing MOTION FOR STAY OF PROCEEDINGS was served via CourtLink to all <br />parties of record as reflected in the attached list. <br />Bart Miller <br />/s/ Bart Miller <br />Duly Signed Copy on File. <br />11 <br />