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of an Application to Make Absolute a Conditional Water Right ( "Quantification Application "). <br />Environmental Opposers joined the proceedings by filing statements of opposition. <br />On April 2, 2003, the Applicant and the State of Colorado signed the "Agreement: Black <br />Canyon of the Gunnison National Park" ( "Settlement Agreement"), according to which the <br />United States would withdraw much of its water claim presented in the Quantification <br />Application. Pursuant to the Settlement Agreement, on April 2, 2003, Applicant filed The <br />United States' Motion to Amend and For Further Stay of the Proceedings ( "Motion to Amend ") <br />and United States First Amended Quantification of Reserved Rights for Black Canyon of the <br />Gunnison National Park in the Form of an Application to Make Absolute a Conditional Water <br />Right ( "Proposed Amended Application "). Environmental Opposers filed a Response to the <br />Motion to Amend, objecting to the Motion to Amend and the Proposed Amended Application. <br />The Settlement Agreement, Motion to Amend, and Proposed Amended Application <br />violate several provisions of federal law and, accordingly, Environmental Plaintiffs filed the <br />Complaint in federal court on September 5, 2003, against four agents or agencies of the United <br />States ( "Defendants "). By the Complaint, a copy of which is attached hereto, Environmental <br />Plaintiffs seek judicial review of the Defendants' failure to protect the natural resources of the <br />Black Canyon and the Defendants' decisions to enter the Settlement Agreement and to relinquish <br />much of the federal reserved water right for the Black Canyon. The Environmental Plaintiffs are <br />requesting that the federal court hold unlawful and set aside the Proposed Amended Application <br />and order compliance with various provisions of federal law. <br />ARGUMENT <br />A decision to stay proceedings resides in the discretion of a trial court. In re Marriage of <br />Fleet, 701 P.2d 1245, 1247 (Colo. App. 1985). "[T]he power to stay proceedings is incidental to <br />Oa <br />