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Bureau, Montrose County Farm Bureau and the Southeastern Colorado Water Conservancy District <br />( "Colorado Water Users and Officials "), through their attorneys, herein respond in opposition to <br />Environmental Opposers' Motion for Stay of Proceedings. The issue before this Court is whether <br />these proceedings should be stayed because the Environmental Opposers' have filed a complaint in <br />the United States District Court for the District of Colorado against Gale Norton, the United States <br />Department of the Interior, Fran Minella and the National Park Service ( "United States "). <br />Environmental Opposers' federal complaint warrants careful scrutiny because it is the sole <br />basis for their eleventh -hour request for a stay. The heart of Environmental Opposers' complaint <br />is the prayer for relief at pages 23 and 24, where they set forth the remedy they seek from the federal <br />court. If they are not allowed to stay this case in order to pursue those federal remedies, <br />Environmental Opposers assert that their federal rights "could be severely prejudiced." Motion for <br />Stay at 1. <br />The first five paragraphs of Environmental Opposers' prayer for relief request various <br />declaratory judgments, primarily under the federal Administrative Procedure Act and the National <br />Environmental Policy Act. The two actions Environmental Opposers seek from the United States <br />District Court are then set forth: (1) "Order [the United States] to cease [its] violations of [federal] <br />law, specifically by securing river flows for the Black Canyon in quantities and with the <br />frequencies necessary to fulfill [the United States'] obligations to the Park under the NPS Act <br />' The Enviromnental Opposers include the following parties: Trout Unlimited; Counsel for <br />Environmental Defense, High Country Citizens' Alliance; The Wilderness Society; Western <br />Colorado Congress; and Western Slope Environmental Resource Council. Counsel for <br />Environmental Defense has not joined in the federal complaint. <br />2 <br />