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violations that seeks a Declaratory Judgment, 28 U.S.C. <br />§ 52201 -2202 and injunctive relief under NEPA, FLPMA and the <br />Administrative Procedures Act, (hereafter "APA ") 5 U.S.C. <br />§ §701 et seq., this court has jurisdiction over the <br />controversy herein presented under 28 U.S.C. §1331. <br />Plaintiffs are persons aggrieved by final agency action of the <br />Defendants, and, therefore, are entitled to judicial review <br />thereof. 5 U.S.C. §702. Plaintiffs are seeking judicial <br />review of a public land adjudication decision. 43 U.S.C. <br />§701(a)(6). <br />5. As more fully explained in paragraph 9 below, <br />Plaintiffs have exhausted their administrative remedies, set <br />forth at 36 C.F.R. §211.19, and have no adequate remedy at <br />law. <br />6. The interests of all Plaintiffs in their health, <br />their enjoyment of their property, and their enjoyment of the <br />public domain and the aesthetic and recreational values it <br />serves will be directly, irreparably, and substantially <br />injured and har-ned by the unlawful issuance by of occupancy <br />documnents unless the injunctive relief herein requested is <br />granted and the status quo of the parties temporarily <br />maintained. The interests Plaintiffs hereby act to protect <br />are within the zone of interests protected by NEPA, FLPMA, and <br />APA. <br />III. VENUE <br />7. This controversy is properly before the United <br />States District Court for the District of Colorado pursuant to <br />28 U.S.C. 51391(e) because this is a civil action in which the <br />Defendants are officials of agencies of the United States, and <br />officers and employees of the United States acting in their <br />official capacities and because Colorado is the district in <br />t - -- cl^ailanged Decision was issued and from which the <br />ease:^ent has been or will be issued. The District of <br />Colorado, therefore, is the judicial district in which the <br />-3- <br />