19.

MDOL's refusal to provide the requested public information

violates Petitioners' fundamental rights, because Article 11 is in the

Declaration of Rights section of the Constitution setting forth

"inalienable" rights.20.Sections 2-6-102 and 2-6-104, MCA, provide that all citizens

have the right to inspect and copy any public writings, defined in 2-6101

(3), MCA, as written acts or records or other official documents of an

official executive body, and requires public officers having custody of

such public writings to provide citizens with copies when requested to do

so, and further provides that public records and other matters in the

office of any officer are at all times open to inspection during office

hours.

21.

MDOL's refusal to release the documents requested violates

Article II, Section 9 of the Montana Constitution, as well as §§2-6-102,

and 2-6-104, MCA.
WHEREFORE, Petitioners pray for relief from this Court as follows:

1.

For an Order requiring MDOL to provide copies of, and/or allow

inspection and copying of, public records, including the information

requested on March 26, 2001;
2.For an Order requiring the MDOL to comply with Article II,

Section 9 of the Montana Constitution and §§2-6-102 and 2-6-104, MCA

in the future;
3.In the alternative, for an Order requiring the MDOL to appear

and show cause why it should not be required to disclose the requested

information;