16—Cold Mountain Cold Rivers Complaint

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that this Court:

A)

Declare that Defendants have violated each law as set forth in the Counts alleged

above;

B)

Void the Special Use Permit issued by the Gallatin National Forest; C)

Issue a

permanent injunction prohibiting operation of the Horse Butte Bison Capture Facility and

all hazing of bison in the Horse Butte Area; or

D)

As a non-preferred alternative, require that activities be limited to those analyzed in

the December1998 Environmental Analysis, Biological Assessment, Biological Evaluation and

incorporated into the Biological Opinion which does not include helicopter use, and require the

Defendants to strictly adhere to all terms and conditions set forth in the December 1998 Biological

Opinion; or

E)

As a non-preferred alternative, prohibit helicopter hazing of bison in the Horse

Butte Area and over open waters of the Madison River, the Madison Arm of Hebgen Lake,

Hebgen Lake, and the Horse Butte Area; or

F)

Require the Federal agencies to conduct the appropriate levels of analysis required

by the Endangered Species Act and the National Environmental Policy Act; and

G)

Issue such other relief as the Court deems just and proper.

DATED this ____ day of _______________, 2001.

REYNOLDS, MOTL & SHERWOOD

_____________________________
Brenda Lindlief Hall
Attorney for Plaintiffs
Cold Mountain, Cold Rivers, Inc.
Buffalo Field Campaign, and
The Ecology Center, Inc.