2—Buffalo Field Campaign Petition for Writ of Mandamus
public from obtaining public information, by failing to provide public information when requested,
and by obstructing Petitioners efforts to obtain public information from public employees. Such
conduct violates Petitioners’ fundamental rights under the Montana Constitution as well as
The preceding paragraphs are realleged as though set forth in full hereunder.
Petitioner Buffalo Field Campaign is a nonprofit 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 wildlife, and to work with people of all Nations to honor the sacredness of
the wild buffalo. Petitioner’s members are citizens who, as part of their work, have been actively
documenting wildlife and habitat impacts from hazing, capture and slaughter activities associated
with the bison management activities conducted by the MDOL with the assistance of other Montana
State and Federal agencies. BFC has sought public information from the MDOL on numerous
occassions, and has consistently and repeatedly been denied access to such information. On
various other occassions, BFC members have been given incomplete information.
Petitioner The Ecology Center, Inc. (TECI) is a non-profit, public-interest
conservation organization comprised of citizens working to protect biological diversity and
ecosystem integrity, primarily in the Wild Rockies bioregion, including Montana and the Greater
Yellowstone Ecosystem. As part of their work, they have been seeking information from the
Montana Department of Livestock about bison management, helicopter and other methods of bison
hazing, including times and places of hazing, and brucellosis testing, among other information.
TECI and its staff and counsel have consistently and systematically been denied access to public
information by the MDOL. MDOL has also, at various times, provided incomplete information to
Cold Mountain, Cold Rivers, Inc. (CMCR) is a nonprofit environmental and
human rights organization based in Missoula, Montana comprised of citizen members and staff
who concerned with the management activities, including the hazing and slaughtering, of
