Brenda Lindlief Hall
REYNOLDS, MOTL AND SHERWOOD
401 North Last Chance Gulch
Helena, MT 59601
(406) 442-3261
Attorney for Petitioners

MONTANA FIRST JUDICIAL DISTRICT COURT LEWIS AND CLARK COUNTY

BUFFALO FIELD CAMPAIGN,
THE ECOLOGY CENTER, INC., and
COLD MOUNTAIN, COLD RIVERS,

No. CDV-2001-475

PETITION FOR
WRIT OF MANDAMUS OR
OTHER APPROPRIATE RELIEF

Petitioners,

v.

MONTANA DEPARTMENT OF
LIVESTOCK,

Defendant.

___________________________________

1.

INTRODUCTION

1.

By this Petition, Petitioners Buffalo Field Campaign (BFC), The

Ecology Center, Inc. (TECI), and Cold Mountain Cold Rivers (CMCR)

(hereafter collectively Petitoners) challenge the Montana Department of

Livestock's (MDOL's) withholding of public information that has been

requested by Petitioners on numerous occasions.
II.THE PARTIES

2.

The preceding paragraphs are realleged as though set forth in

full hereunder.

3.

Petitioner Buffalo Field Campaign is a non-profit organization

founded to stop the slaughter of Yellowstone's wild buffalo herd, to

protect the natural habitat of wild free-roaming buffalo and other native