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  • Motion For TRO PI 7-29-11

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    American Wild Horse Preservation
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    American Wild Horse Preservation Campaign and other plaintiffs filed a motion for a temporary restraining order and preliminary injunction against the Bureau of Land Management to halt the agency's plan to round up wild horses in Wyoming. The plaintiffs argue that the BLM's decision to round up the horses violates the National Environmental Policy Act, the Wild Free-Roaming Horses and Burros Act, and the Administrative Procedure Act. Although the BLM has until December to implement its decision, it intends to begin the round-up on August 16-17 and declined the plaintiffs' request to delay the action so the case could be decided through summary judgment motions. The plaintiffs therefore seek emergency relief from the court in the form of a temporary restraining order and

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    American Wild Horse Preservation Campaign and other plaintiffs filed a motion for a temporary restraining order and preliminary injunction against the Bureau of Land Management to halt the agency's plan to round up wild horses in Wyoming. The plaintiffs argue that the BLM's decision to round up the horses violates the National Environmental Policy Act, the Wild Free-Roaming Horses and Burros Act, and the Administrative Procedure Act. Although the BLM has until December to implement its decision, it intends to begin the round-up on August 16-17 and declined the plaintiffs' request to delay the action so the case could be decided through summary judgment motions. The plaintiffs therefore seek emergency relief from the court in the form of a temporary restraining order and

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    74 views2 pages

    Motion For TRO PI 7-29-11

    Uploaded by

    American Wild Horse Preservation
    American Wild Horse Preservation Campaign and other plaintiffs filed a motion for a temporary restraining order and preliminary injunction against the Bureau of Land Management to halt the agency's plan to round up wild horses in Wyoming. The plaintiffs argue that the BLM's decision to round up the horses violates the National Environmental Policy Act, the Wild Free-Roaming Horses and Burros Act, and the Administrative Procedure Act. Although the BLM has until December to implement its decision, it intends to begin the round-up on August 16-17 and declined the plaintiffs' request to delay the action so the case could be decided through summary judgment motions. The plaintiffs therefore seek emergency relief from the court in the form of a temporary restraining order and

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    of 2

    Case 1:11-cv-01352-ABJ Document 5

    Filed 07/29/11 Page 1 of 2

    THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

    AMERICAN WILD HORSE PRESERVATION CAMPAIGN, et al., Plaintiffs, v. KEN SALAZAR, Secretary Department of the Interior, et al., Defendants.

    ) ) ) ) ) ) ) ) ) ) )

    Civ. No. 11-01352 (ABJ)

    MOTION FOR A TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION Pursuant to Rule 65 of the Federal Rules of Civil Procedure and Local Rule 65.1, plaintiffs American Wild Horse Preservation Campaign, Western Watersheds Project, Donna Duckworth, Greg Duckworth, and Carol Walker hereby move for a temporary restraining order and preliminary injunction to halt defendants unlawful plan to round up wild horses in the White Mountain and Little Colorado Herd Management Areas in Wyoming. As demonstrated in plaintiffs accompanying memorandum, the decision by the Bureau of Land Management (BLM) concerning this matter violates the National Environmental Policy Act, 42 U.S.C. 4321 et seq., the Wild Free-Roaming Horses and Burros Act, 16 U.S.C. 1331 et seq., and the Administrative Procedure Act, 5 U.S.C. 706(1). As also demonstrated, although the BLM has publicly stated that it has until December 2011 to implement its decision, it nevertheless intends to begin the unlawful round-up on or about August 16-17, and has declined plaintiffs suggestion that it delay its action so that this case could be decided on cross-motions for summary judgment. Accordingly, plaintiffs have no

    Case 1:11-cv-01352-ABJ Document 5

    Filed 07/29/11 Page 2 of 2

    choice but to seek emergency relief, and respectfully request that the Court schedule a hearing on this matters as soon as possible, and preferably during the week of August 1-5. In support of this motion, plaintiffs submit the accompanying memorandum of law, declarations from several plaintiffs and experts, Exhibits A - AA, and a proposed order. Counsel for plaintiffs hereby certify that they have today served all of these materials on counsel for defendants. Respectfully submitted, _/s/___________________________ Katherine A. Meyer (D.C. Bar No. 244301) Jessica Almy (D.C. Bar No. 996921) MEYER GLITZENSTEIN & CRYSTAL 1601 Connecticut Ave., N.W. Suite 700 Washington, D.C. 20009 (202) 588-5206 Counsel for Plaintiffs Date: July 29, 2011

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