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(c) authorizing or permitting the commencement of <br />construction of any part of Stage II Project; and <br />(d) failing to issue a stop order should the <br />Cheyenne Board of Public Utilities begin construction of any <br />part of Stage II wit°:out authorization therefor. <br />2. Declare that the agency actions challenged herein <br />i.e., the Decision and issuance of occupancy documents by the <br />Forest Service and the "biological opinion" issued on June 23, <br />1982, purporting to address recovery of endangered species <br />impacted by the project are abuses of discretion, arbitrary <br />and capricious and not otherwise in accordance with law, and <br />in accordance therewith (a) reverse the Decision, (b) remand <br />the matter to Defendants for compliance with law and <br />(c) declare the easetient void. <br />3. Award Plaintiffs' attorneys fees and costs of suit. <br />4. Such other and further relief as the Court may deem <br />just and proper. <br />Respectfully submitted, <br />Hbrrick i stone <br />f, <br />S ran A. Bond <br />1075 Broadway, Suite 20600 <br />Denver, Colorado 80202 <br />Telephone: (303) 623 -2700 <br />-14- <br />