1—Petitioners’ Prehearing

Brief

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

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

No. CDV-2001-475

PETITIONERS’
PREHEARING BRIEF
ON APPLICATION FOR
WRIT OF MANDAMUS

Petitioners,
v.

MONTANA DEPARTMENT OF
LIVESTOCK,

Defendant.

___________________________________

COME now, Petitioners, Buffalo Field Campaign (BFC), The Ecology

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

file this prehearing brief.
I.

FACTUAL

BACKGROUND

This case, although tangentially related to a case that Petitioners

have pending in Federal Court against Defendant Montana Department of

Livestock (MDOL), is wholly separate from the federal court case. It is

necessary, however, to briefly apprise the Court of the circumstances

giving rise to the federal court case, which in turn give rise to the facts

of this case, in order to convey the urgency of the need for a speedy and

adequate remedy by this Court.