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Response of CO Water Users and Officials to Motion to Stay Proceedings
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Response of CO Water Users and Officials to Motion to Stay Proceedings
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Last modified
6/8/2010 9:03:30 AM
Creation date
5/21/2010 12:58:45 PM
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Template:
Water Supply Protection
Description
Gunnison River
State
CO
Basin
Gunnison
Water Division
4
Date
9/22/2003
Author
Ken Salazar, Carol D. Angel, Bratton & McClow LLC, Moses, Wittemyer, Harrison and Woodruff P.C., Burns, Figs & Will, P.C.
Title
Response of CO Water Users and Officials to Motion to Stay Proceedings
Water Supply Pro - Doc Type
Court Documents
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Opposers have not shown the requisite "rare circumstances" that would justify the hundreds of <br />litigants here being "compelled to stand aside" while Environmental Opposers "settle[] the rule of <br />law that will define the rights of [all]." See Landis v. North American Co., 299 U.S. at 255. <br />For the same reason, a stay will not promote economy for either the parties or this court. If <br />Environmental Opposers were simply seeking resolution of purely federal issues of administrative <br />law, that might be the case. As their complaint shows, however, their ultimate aim is an order from <br />the federal court withdrawing the amended application and specifying the quantity and timing <br />of the Black Canyon reserved right. This is not an area in which the special expertise of a federal <br />court is required. Instead, both Congress and the United States Supreme Court have made it crystal <br />clear that state water courts, with their experience and expertise, are the preferred and proper forum <br />for quantification of reserved rights. See generally Eagle County H; Water Division No. 5;.; <br />Colorado River. That is all the more the case here when the decree that Environmental Opposers <br />seek to interpret and enforce was entered by Colorado water court, which expressly retained <br />jurisdiction over further quantification proceedings. All a stay will accomplish is to approve <br />Environmental Opposers' forum shopping, to the disadvantage ofthe hundreds ofopposers here who <br />should be entitled to defend against injury to their water rights in this Court. <br />The standards for evaluating a stay among related cases are remarkably similar to the <br />considerations that the United States Supreme Court cited in approving federal court deference to <br />Colorado water court adjudications in Colorado River. There, the Court found that the early stage <br />of the federal litigation; the extensive involvement of state water rights; the great distance (300 <br />miles) between the federal district court and the division 7 water court; and the federal government's <br />15 <br />
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