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<br />with the construction of the Narrows project and/or the <br />commencement of the acquisition of land and right-of- <br />way in the take area of Narrows to be unlawful and <br />further enjoining ~aid defendants from proceeding until <br />compliance with NEPA, Freedom of Information Act, Federal <br />Water Project Recreation Act, Fish and wildlife Coordination <br />Act and all the laws of the United States have been effected. <br />B. Against defendants Kleppe, Stamm, Hall, Plummer <br />and Bechley and each of them, in the nature Of mandamus <br />or mandatory injunction, ordering said defendants to <br />comply with the procedural and substantive goals of <br />NEPA. <br />C. Declare void any contracts entered into or to be <br />entered into between the United States and LSPWCD in contra- <br />vention of the laws of the United States and the State of <br />Colorado and an order of mandamus against defendants Kleppe, <br />Stamm, Hall, Plummer and Bechley and each of them to comply <br />with the laws of the united States and State of Colorado <br />when and if the Repayment Contract is negotiated. <br />D. Personal judgment for damages against defendants <br />Kleppe, Stamm, Hall, Plummer and Bechley and each of them <br />for injuring plaintiffs under color of government authority, <br />but by intentional abuse of said authority and actions out- <br />side the scope of their official employment said defendants <br />are personally liable. <br />E. In favor of plaintiffs for their costs and <br />disbursements herein" including reasonable attorney and <br />expert witness fees, under the equity powers 'of this Court. <br />F. Providing such other and further relief as to the <br /> <br />-17- <br />