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Case 9:22-cv-00090-DWM Document 1 Filed 05/16/22 Page 1 of 16
`
`Lindsey W. Hromadka
`Michelle Tafoya Weinberg
`WEINBERG & HROMADKA, PLLC
`P.O. Box 652
`Whitefish, MT 59937
`Phone: (406) 730-2988
`lindsey@whlawmt.com
`michelle@tafoyalawfirm.com
`
`David K. Wilson
`MORRISON, SHERWOOD, WILSON & DEOLA, PLLP
`401 N. Last Chance Gulch
`Helena, MT 59601
`Phone: (406) 442-3261
`kwilson@mswdlaw.com
`
`Attorneys for Plaintiffs
`
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF MONTANA
`
`MISSOULA DIVISION
`
`
`
`Cause No. __________
`
`COMPLAINT
`FOR DECLARATORY AND
`INJUNCTIVE RELIEF
`
`
`
`
`
`
`
`FRIENDS OF THE FLATHEAD
`RIVER, a Montana Nonprofit
`Corporation,
`
`
`Plaintiff,
`
`vs.
`
`
`U.S. FOREST SERVICE, and
`LEANNE MARTEN, REGIONAL
`FORESTER FOR THE U.S.
`FOREST SERVICE REGION 1
`
`
`Defendant.
`
`
`
`COMPLAINT AND JURY DEMAND
`
`
`
`Page 1 of 16
`
`

`

`Case 9:22-cv-00090-DWM Document 1 Filed 05/16/22 Page 2 of 16
`
`INTRODUCTION
`
`1. This civil action requests declaratory and injunctive relief for violations of the
`
`Wild and Scenic Rivers Act (“WSRA”), 16 U.S.C. §§ 1271, et seq., the Forest
`
`Service Organic Administration Act of 1897 (“Organic Act”), 16 U.S.C. § 551, and
`
`the Administrative Procedure Act (“APA”), 5 U.S.C. §§ 701, et seq.
`
`2. Specifically, this action seeks to compel preparation of the long overdue
`
`review and update of the Flathead Comprehensive River Management Plan required
`
`to be prepared under the Act and, until finalized and implemented, enjoin dispersed
`
`overnight camping southwest of Blankenship Bridge on the gravel bar on the Middle
`
`Fork of the Flathead River (the “Gravel Bar”).
`
`3. In 1976, Congress designated three forks of the Flathead River in Montana to
`
`be protected under the Wild and Scenic Rivers Act. 16 U.S.C. § 1274 (a)(13).
`
`4. The WSRA requires the preparation of Management Plans to “protect and
`
`enhance…outstanding remarkable values” for “future generations.”
`
`5. The Forest Service Organic Administration Act of 1897, 16 U.S.C. § 551,
`
`requires the Forest Service to regulate the “occupancy and use” of the national
`
`forests and to “preserve the forests thereon from destruction.”
`
`JURISDICTION AND VENUE
`
`6. Jurisdiction is proper in this Court given the Defendant is an agency within
`
`the U.S. federal government, and under 28 U.S.C. § 1331 (federal question) as this
`
`COMPLAINT AND JURY DEMAND
`
`
`
`Page 2 of 16
`
`

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`Case 9:22-cv-00090-DWM Document 1 Filed 05/16/22 Page 3 of 16
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`action arises under the laws of the United States , including the National Wild and
`
`Scenic Rivers Act of 1968, 16 U.S.C. §§ 1271–1287, the Forest Service Organic
`
`Administration Act of 1897 (“Organic Act”), 16 U.S.C. § 551, the Administrative
`
`Procedure Act (“APA”), 5 U.S.C. §§ 701 et seq., the Declaratory Judgment Act, 28
`
`U.S.C. §§ 2201 et seq., and the Equal Access to Justice Act (“EAJA”), 28 U.S.C. §
`
`2412 et seq. An actual, justiciable controversy exists between the parties, and the
`
`requested relief is therefore proper under 28 U.S.C. §§ 2201–2202 and 5 U.S.C. §
`
`701–06.
`
`7. Venue is proper in this Court under 28 U.S.C. § 1391 because all or a
`
`substantial part of the events or omissions giving rise to the claims herein occurred
`
`within this judicial district, Plaintiff’s Directors and supporters reside in this district,
`
`and the public lands and resources in question are located in this district.
`
`8. The federal government has waived sovereign immunity in this action
`
`pursuant to 5 U.S.C. § 702.
`
`PARTIES
`
`9. Plaintiff Friends of the Flathead River, Inc. (“Friends”) is a Montana non-
`
`profit organization, whose mission is to protect and preserve the Flathead River
`
`watershed. Many of Friends’ Directors and supporters live near Blankenship Bridge
`
`on the Middle Fork of the Flathead River in Flathead County and enjoy activities
`
`such as hiking, fishing, wildlife watching, picnicking, running, and rafting within
`
`COMPLAINT AND JURY DEMAND
`
`
`
`Page 3 of 16
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`

`

`Case 9:22-cv-00090-DWM Document 1 Filed 05/16/22 Page 4 of 16
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`and adjacent to the Flathead Wild and Scenic Corridor. The aesthetic, recreational,
`
`and conservation interests of Friends and its members have been, are being, and will
`
`continue to be adversely affected and irreparably harmed by Defendant’s (i) failure
`
`to update the Flathead Comprehensive River Management Plan and (ii) continued
`
`authorization of overnight camping southwest of Blankenship Bridge directly on the
`
`Gravel Bar of Middle Fork of the Flathead River, causing ongoing damage to its
`
`resources.
`
`10. Defendant United States Forest Service (the “Forest Service”) is the agency
`
`charged with the administration of the designated Flathead River wild and scenic
`
`river segments at issue here and is responsible for compliance with the Wild and
`
`Scenic Rivers Act and the Travel Management Rule (36 C.F.R. §§ 212, et. seq.) for
`
`these designated segments.
`
`LEGAL BACKGROUND
`
`National and Wild Scenic Rivers Act
`
`11. Congress enacted the National Wild and Scenic Rivers Act in 1968 to
`
`identify rivers that possess “outstandingly remarkable scenic, recreational, geologic,
`
`fish and wildlife, historic, cultural, or other similar values” and to preserve those
`
`rivers in free-flowing condition and protect their immediate environments “for the
`
`benefit and enjoyment of present and future generations.” 16 U.S.C. § 1271.
`
`12. The policy of the WRSA is to “preserve [] selected rivers or sections thereof
`
`COMPLAINT AND JURY DEMAND
`
`
`
`Page 4 of 16
`
`

`

`Case 9:22-cv-00090-DWM Document 1 Filed 05/16/22 Page 5 of 16
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`in their free-flowing condition to protect the water quality of such rivers and to fulfill
`
`other vital national conservation purposes.” Id.
`
`13. River corridors, including adjacent land, included in the wild and scenic
`
`rivers system are classified as wild, scenic, or recreational. Id. § 1273(b). Wild rivers
`
`are those rivers or sections of rivers that “are free of impoundments and generally
`
`inaccessible except by trail, with watersheds or shorelines essentially primitive and
`
`waters unpolluted.” Id. § 1273(b)(1). These rivers represent “vestiges of primitive
`
`America.” Id. Scenic rivers are “free of impoundments, with shorelines or
`
`watersheds still largely primitive and shorelines largely undeveloped, but accessible
`
`in places by roads.” Id. § 1273(b)(2). Finally, recreational rivers are “readily
`
`accessible by road or railroad [and] may have some development along their
`
`shorelines, and [] may have undergone some impoundment or diversion in the past.”
`
`Id. § 1273(b)(3).
`
`14. Once a river is designated, the federal agency charged with administration of
`
`that corridor “shall prepare a comprehensive management plan for such river
`
`segment to provide for the protection of the river values.” Id. § 1274(d)(1). These
`
`management plans must address resource protection, development, use, and other
`
`management practices that will achieve the purposes of the WSRA. Id.
`
`15. Each component of the system, regardless of its classification as wild, scenic,
`
`or recreational, “shall be administered in such manner as to protect and enhance the
`
`COMPLAINT AND JURY DEMAND
`
`
`
`Page 5 of 16
`
`

`

`Case 9:22-cv-00090-DWM Document 1 Filed 05/16/22 Page 6 of 16
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`values which caused it to be included in said system without, insofar as is consistent
`
`therewith, limiting other uses that do not substantially interfere with public use and
`
`enjoyment of these values. Id. § 1281(a) (emphasis added). Further, “primary
`
`emphasis shall be given to protecting its aesthetic, scenic, historic, archeologic, and
`
`scientific features.” Id.
`
`16. In addition to protecting a river’s free-flowing condition and outstandingly
`
`remarkable values, the WSRA specifies that managing agencies must protect the
`
`water quality of all rivers added to the National Wild and Scenic Rivers System. 16
`
`U.S.C. §§ 1271, 1283(c).
`
`17. The WSRA emphasizes the mandatory nature of these duties, stating that
`
`“the Secretary of Agriculture, and the head of any other Federal department or
`
`agency having jurisdiction over any lands which include, border upon, or are
`
`adjacent to, any river within the National Wild and Scenic Rivers System . . . shall
`
`take such action respecting management policies, regulations, contracts, plans,
`
`affecting such lands . . . as may be necessary to protect such rivers in accordance
`
`with the purposes of this chapter.” Id. § 1283(a).
`
`National Forest Organic Administration Act
`
`18. The Forest Service Organic Administration Act of 1897, 16 U.S.C. § 551,
`
`requires the Forest Service to regulate the “occupancy and use” of the national
`
`forests and to “preserve the forests thereon from destruction.”
`
`COMPLAINT AND JURY DEMAND
`
`
`
`Page 6 of 16
`
`

`

`Case 9:22-cv-00090-DWM Document 1 Filed 05/16/22 Page 7 of 16
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`19. The Travel Management Rule, promulgated in 2005, requires each National
`
`Forest to identify and designate those roads, trails, and areas that are open to motor
`
`vehicle use. 36 C.F.R. §§ 212, et. seq. After designation of areas open to motor
`
`vehicle use, the responsible official must “monitor” the effects of motor vehicle use.
`
`36. C.F.R. § 212.57
`
`20. The Travel Management Rule additionally requires the responsible official to
`
`temporarily close National Forest Service lands to motor vehicle use if it is
`
`determined that the use is “directly causing or will directly cause considerable
`
`adverse effects on public safety or soil, vegetation, wildlife, wildlife habitat, or
`
`cultural resources associated with….that area…until the official determined that
`
`such adverse effects have been mitigated or eliminated and that measures have been
`
`implemented to prevent future recurrence.” 36 C.F.R. § 212.52
`
`ALLEGATIONS COMMON TO ALL COUNTS
`
`21. In 1976, Congress designated 219 miles of the Flathead River for inclusion
`
`in the WSRA as part of the National Wild and Scenic River (“WSR”) System.
`
`22. In 1980, the Forest Service completed the Flathead Wild and Scenic River
`
`Management Plan (“the Plan”). The Plan was intended to be a “comprehensive
`
`document for management of the Flathead National Wild and Scenic River for a five-
`
`year period beginning with the date of approval” and was to be “reviewed” yearly.
`
`Plan, 23 (emphasis added).
`
`COMPLAINT AND JURY DEMAND
`
`
`
`Page 7 of 16
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`

`

`Case 9:22-cv-00090-DWM Document 1 Filed 05/16/22 Page 8 of 16
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`23. The Plan acknowledges the importance of the Flathead River as an
`
`“exceptionally valuable element of the nation’s outdoor recreation estate[,]” but
`
`emphasizes the need to “adequately maintain resource integrity” by thoroughly
`
`monitoring resource degradation. Id. at 7.
`
`24. The Plan states the intent of the Wild and Scenic Rivers Act is to “protect and
`
`enhance the water quality of those Rivers.” Id. at 17. To that end, the Plan requires
`
`management to “give priority to protection of water quality in case of conflict
`
`between water quality and other resource uses.” Id. at 18. The Plan acknowledges
`
`that “existing water quality is directly dependent on management activities within
`
`the watershed,” and further acknowledges that “activities within the riparian zone
`
`will usually have a greater effect on water quality than activities outside this zone.”
`
`Id. at 17.
`
`25. The management direction in the Plan for “recreational” segments is to “(1)
`
`control access of cattle, motorized vehicles, horses, and pedestrians on river banks
`
`and channels to prevent on-site sediment erosion and downstream sedimentation[;]
`
`(2) control sanitary facilities (from houses, campgrounds, and etc.) so no pollution
`
`from them reaches river.” Id. at 19.
`
`26. The Plan identified migratory spawning populations of cutthroat and bull
`
`trout, the latter being an endangered species, in all three forks of the Flathead River.
`
`It also discusses the grizzly bear in depth, which were known to frequent the North
`
`COMPLAINT AND JURY DEMAND
`
`
`
`Page 8 of 16
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`

`

`Case 9:22-cv-00090-DWM Document 1 Filed 05/16/22 Page 9 of 16
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`Fork and South Fork drainages. Id. at 14-15. According to the Plan, the
`
`“conservation of endangered and threatened species and their habitats will receive
`
`priority management with regard to facility development and recreation use.” Id. at
`
`14.
`
`27. Blankenship Bridge, the precise location at issue here, is located at the
`
`confluence of the North Fork and Middle Fork designations and is included in the
`
`Lower Middle Fork Recreational WSR designation. “Recreational” river
`
`classification emphasizes “diversity of river qualities and recreational opportunities
`
`including, basically, free-flowing and unpolluted waters, ready public recreational
`
`access, potential for accommodating large numbers of recreationists with a variety
`
`of recreational experiences provided, and high scenic values.” Id. at 3.
`
`28. With regard to motorized use, the Plan simply states that “motorized overland
`
`vehicle travel in the corridor is generally limited to established roads due to terrain
`
`and vegetation.” Id. at 51. The Plan allows “areas or roads in the river corridor [to]
`
`be closed to all or certain types of motorized travel to protect resource values.” Id.
`
`at 52.
`
`29. The Plan protects scenic qualities of the Flathead River by directing the
`
`Forest Service to “provide for a natural-appearing landscape within the classified
`
`river corridor, maintain variety in the landscape by having a mixture of openings,
`
`mature forest cover, and the various stages of forest succession[.]” Id. at 21.
`
`COMPLAINT AND JURY DEMAND
`
`
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`Page 9 of 16
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`

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`Case 9:22-cv-00090-DWM Document 1 Filed 05/16/22 Page 10 of 16
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`30. In 2013, the Forest Service and the National Park Service (“NPS”) completed
`
`an Outstanding Remarkable Values Assessment of the Flathead River System.
`
`According to the Assessment, the Blankenship Bridge location has outstanding
`
`fisheries, geologic, water quality, wildlife, recreation, scenic, and historic values.
`
`31. In 2010, the Forest Service, pursuant to the 2005 Travel Management Rule,
`
`issued the “CHR Decision Notice,” which allows motorized use of the area at issue.
`
`32. Since at least 2020, the use of motorized vehicles on the Gravel Bar on the
`
`banks of the Flathead River just south of Blankenship Bridge has grown
`
`exponentially.1 The nature of the motorized vehicle use is predominately overnight
`
`camping. Rob Davies, the Hungry Horse Ranger District Ranger, stated “It’s like
`
`Daytona Beach over spring break[;] this year is off the charts in terms of use and
`
`visitation at that gravel bar.” The Forest Service has admittedly failed to adequately
`
`monitor or manage this increased usage on the Gravel Bar. Instead, the Forest
`
`Service placed two temporary porta potties on the Gravel Bar itself.
`
`33. The motorized vehicle use on the Gravel Bar is degrading the water quality of
`
`the Flathead River. The average number of camping vehicles (whether trucks, cars,
`
`recreational vehicles, etc.) have been observed to be approximately 50-70 per day
`
`during the summer months. Affidavit of Dan Diamond, ¶ 4, attached as Exhibit A.
`
`
`1“Blankenship Bridge Camping Usage Triples Amid Pandemic,” August 4, 2020; accessed at
`https://flatheadbeacon.com/2020/08/04/blankenship-bridge-camping-usage-triples-amid-pandemic/
`
`COMPLAINT AND JURY DEMAND
`
`
`
`Page 10 of 16
`
`

`

`Case 9:22-cv-00090-DWM Document 1 Filed 05/16/22 Page 11 of 16
`
`The sheer number of vehicles is causing sediment and other substances to pollute
`
`the River. Id. at ¶ 5. Friends’ Directors and supporters have witnessed the following
`
`conduct: (i) campers urinating and defecating directly into the River; (ii) campers
`
`washing dishes and throwing away food scraps directly into the River; and (iii)
`
`recreational vehicles emptying their “black tank,” allowing feces and toilet paper to
`
`go directly into the river; and (iv) vehicles driving into the River and into the
`
`spawning creek adjacent to the River. Id. at ¶ 7, x; Affidavit of Paul Roper, ¶ 7,
`
`attached as Exhibit B. Friends’ Directors have also witnessed dozens of campers
`
`throw their trash directly into the River or leave it on the Gravel Bar; including
`
`broken glass and human waste. Aff. D. Diamond, ¶ 7; Aff. Paul Roper, ¶ 7. In 2021,
`
`a bus drove into the rising water and became stuck in the River, clearly degrading
`
`the water quality by its mere existence in the River, which was worsened by the
`
`efforts to remove the bus from the River. Aff. D. Diamond, ¶ 8.
`
`COMPLAINT AND JURY DEMAND
`
`
`
`Page 11 of 16
`
`

`

`Case 9:22-cv-00090-DWM Document 1 Filed 05/16/22 Page 12 of 16
`
`34. The overnight camping and excessive use on the Gravel Bar is also
`
`threatening the scenic views and the natural landscape of the Flathead River. Aff.
`
`D. Diamond, ¶ 9; Aff. Paul Roper, ¶ 5.
`
`35. The overnight camping and excessive use on the Gravel Bar also pose a
`
`distinct wildfire threat. Friends counted 94 rock fire rings and campfire sites on
`
`April 14, 2022 during its last monitoring of the site. Aff. D. Diamond, ¶¶ 10, 11.
`
`Directors and supporters of Friends witnessed illegal campfires during the Stage 1
`
`fire restrictions in Summer of 2022, illegal fireworks and gunfire, illegal firewood
`
`cutting, and complete disregard for wildfire safety. Id.
`
`36. The overnight camping and excessive use on the Gravel Bar will likely lead
`
`to Grizzly Bear-human conflicts due to the trash issue. The pollution of the River
`
`by the human waste, vehicle use, and excessive overnight camping will likely harm
`
`the cutthroat and bull trout.
`
`37. In 2017, the Forest Service started the process to prepare a new
`
`Comprehensive River Management Plan for the Flathead River. In 2019, the Forest
`
`Service conducted “scoping” and released a Scoping Release on July 31, 2019. In
`
`November 2021, the Forest Service stated it was to “resume” the planning process.
`
`There has been no Environmental Assessment prepared or released to date, nor a
`
`projected date for release of a final plan.
`
`COMPLAINT AND JURY DEMAND
`
`
`
`Page 12 of 16
`
`

`

`Case 9:22-cv-00090-DWM Document 1 Filed 05/16/22 Page 13 of 16
`
`38. The Proposed Action for the Comprehensive River Management Plan,
`
`released in June 2019, recommends the Gravel Bar to be used as day use only.
`
`
`
`COUNT I –VIOLATION OF THE WILD AND SCENIC RIVERS ACT
`
`39. The allegations set forth in all paragraphs above are plead and incorporated
`
`herein as if fully set forth.
`
`40. The Forest Service is in violation of the Plan. The Forest Service has failed
`
`to adequately monitor the overnight camping and excessive use of the Gravel Bar.
`
`The Forest Service has failed to ensure the water quality of the Flathead River is not
`
`degraded, and has failed to prioritize water quality above recreation use as directed
`
`by the Plan, by failing to manage the overnight use on the Gravel Bar. The Forest
`
`Service has failed to ensure the scenic and natural vistas are preserved by allowing
`
`dozens of motor vehicles, including large recreational vehicles, to overnight camp
`
`on the Gravel Bar for extended periods of time. The Forest Service is in violation of
`
`the Plan and the Wild and Scenic Rivers Act
`
`41. The Forest Service has a mandatory duty to prepare a new Comprehensive
`
`Management Plan for the Flathead River. The deadline for completing a new
`
`Comprehensive Management was ostensibly in 1985. The Forest Service has
`
`continually delayed updating the Comprehensive Management Plan since 2017. The
`
`Forest Service is in violation of the Plan and the Wild and Scenic Rivers Act.
`
`42. By failing to monitor and enforce the Plan (which remains in effect although
`
`COMPLAINT AND JURY DEMAND
`
`
`
`Page 13 of 16
`
`

`

`Case 9:22-cv-00090-DWM Document 1 Filed 05/16/22 Page 14 of 16
`
`it is 37 years out of date), and by failing to complete a new Comprehensive River
`
`Management Plan for the Flathead River, the Forest Service has unlawfully withheld
`
`or unreasonably delayed compliance with the Wild and Scenic Rivers Act 16 U.S.C.
`
`(§§ 1271, 1274 and 1283), within the meaning of the Administrative Procedure Act.
`
`5 U.S.C. § 706(1).
`
`COUNT II – VIOLATION OF THE ORGANIC ACT
`
`43. The allegations set forth in all paragraphs above are plead and incorporated
`
`herein as if fully set forth.
`
`44. The Travel Management Rule requires the Forest Service to “monitor” the
`
`motorized use as authorized by the CHR Decision Notice. The Forest Service has
`
`failed to monitor the exponential growth in overnight camping and excessive use of
`
`the Gravel Bar. 36 C.F.R. § 212.57.
`
`45. The Travel Management Rule additionally requires the Forest Service to
`
`immediately close an area if it determines that motor vehicle use is “causing or will
`
`directly cause considerable adverse effects on public safety or soil, vegetation,
`
`wildlife habitat or cultural resources.” 36 C.F.R. § 212.52.
`
`46. The Forest Service has determined that motor vehicle use will cause adverse
`
`effects to the Wild and Scenic Flathead River, public safety, vegetation, and wildlife
`
`and fish spawning habitat, but has failed to immediately close the Gravel Bar to
`
`motorized use and overnight camping as required by 36 C.F.R. § 212.52.
`
`COMPLAINT AND JURY DEMAND
`
`
`
`Page 14 of 16
`
`

`

`Case 9:22-cv-00090-DWM Document 1 Filed 05/16/22 Page 15 of 16
`
`47. Alternatively, the Forest Service has failed to monitor the motorized use at the
`
`Gravel Bar and thus has failed to determine whether motor vehicle use is causing
`
`considerable adverse effects to the Wild and Scenic Flathead River, public safety,
`
`vegetation, and wildlife habitat.
`
`48. By failing to monitor the effects of motorized use on the Gravel Bar, and by
`
`failing to immediately close the Gravel Bar to motorized vehicle use after finding
`
`that the motor vehicle use is causing or will directly cause considerable adverse
`
`effects on the Wild and Scenic Flathead River, public safety, vegetation, and wildlife
`
`habitat, the Forest Service has unlawfully withheld or unreasonably delayed
`
`compliance with the Travel Management Rule within the meaning of the
`
`Administrative Procedure Act. 5 U.S.C. § 706(1).
`
`PRAYER FOR RELIEF
`
`WHEREFORE, the Plaintiffs pray for judgment and relief from this Court in
`
`their favor and against Defendants as follows:
`
`1.
`
`Against Defendants on all Counts:
`
`a. That the Court issue a declaratory judgment that the Forest Service is
`in violation of the Wild and Scenic Rivers Act, 16 U.S.C. §§ 1271,
`1274 and 1283;
`
`b. That the Court issue a declaratory judgment that the Forest Service is
`in violation of the Forest Service Organic Act, through the Travel
`Management Rule;
`
`c. That the Court issue a temporary restraining order and preliminary
`injunction enjoining dispersed overnight camping southwest of
`
`COMPLAINT AND JURY DEMAND
`
`
`
`Page 15 of 16
`
`

`

`Case 9:22-cv-00090-DWM Document 1 Filed 05/16/22 Page 16 of 16
`
`Blankenship Bridge on the Gravel Bar of the Middle Fork of the
`Flathead River, pending release and implementation of the final
`Comprehensive River Management Plan for the Flathead River;
`
`d. That the Court award Plaintiffs their attorney’s fees pursuant to 42
`U.S.C. § 1988;
`
`e. That the Court award Plaintiffs costs of suit; and
`
`f. That the Court grant such other and all relief to which Plaintiffs are at
`law or equity entitled.
`
`Dated this _13_ day of _May________, 2022
`
`Weinberg & Hromadka, PLLC
`
`By:
`Lindsey W. Hromadka
`Attorney for Plaintiffs
`
`COMPLAINT AND JURY DEMAND
`
`Page 16 of 16
`
`

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