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PLP filed this lawsuit on the Eldorado National Forest Travel Management Plan on 6/24/2009.

As many of you already know the Forests around the country are closing

1000's of miles of roads. The purpose of this lawsuit is to stop those roads from being closed. Since Eldorado NF was the first to complete their Environmental Impact Study and make their Record of Decision, we are hopeful that we can stop the closures and influence the problem in all National Forest from not doing their road closures.

We have an early jump on this situation and feel confident the we can make a major difference in the the FS policies of closing the roads.

We are looking for some help in raising funds to support this lawsuit and we feel that all of those who have supported un in the past will continue that support. Tell your freinds that they need to support us as well.

Donations can be handled through paypal on the front page of this website or mail to:

PLP

c/o Barret Wetherby

3700 Santa Carlotta

La Crescenta, Ca. 91214

Contact for questions:

Jerry Hobbs

jerhobbs2@verizon,net

909-889-3039

LAW OFFICES OF DAVID YOUNG

David Young, SBN 55341

11150 Olympic Blvd., Suite 1050

Los Angeles, CA 90064

Telephone: (310) 575-0308 Facsimile: (310) 575-0311

E-mail: dyounglaw@verizon.net

Attorney for Plaintiffs

UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF CALIFORNIA

PUBLIC LANDS FOR THE PEOPLE, INC., a California 501 C-3, non-profit corporation; GERALD E. HOBBS, an individual; ROBERT HAIDUCK, an individual; BRYAN BUNTING, an individual; HILLARIE BUNTING, an individual; STEVE WANDT, an individual; GENE E. BAILEY, an individual; RICHARD NUSS, an individual; and RANDY BURLESON, an individual;

Plaintiffs.

v.

UNITED STATES DEPARTMENT OF AGRICULTURE; UNITED STATES FOREST SERVICE; TOM VILSACK, in his official capacity as Secretary Of Agriculture; TOM TIDWELL, in his official capacity as the Chief Forester Of The USDA Forest Service; RANDY MOORE, in his official capacity as Regional Forester USDA Forest Service Regional Office R5; and RAMIRO VILLALVAZO, in his official capacity as Forest Supervisor Of The Eldorado National Forest; Does 1-10.

Defendants.

CIVIL ACTION NO.

COMPLAINT FOR:

VIOLATIONS OF THE NATIONAL ENVIRONMENTAL POLICY ACT, 43 U.S.C. § 4321; TRANSFER ACT, 16 U.S.C. § 472; NATIONAL FOREST MANAGEMENT ACT,16 U.S.C. §§ 1600 et seq.; WILDERNESS ACT, 16 U.S.C. § 1131 et seq.; MULTIPLE USE SUSTAINED YIELD ACT, 16 U.S.C. § 528; MULTIPLE SURFACE USE ACT, 30 U.S.C. §§ 612 et seq.; FEDERAL LAND POLICY AND MANAGEMENT ACT, 43 U.S.C. §§ 1701 et seq.; RS 2477, 43 U.S.C. § 942; ADMINISTRATIVE PROCEDURE ACT, 5 U.S.C. § 706 et. seq.; MINING AND MINERALS POLICY ACT OF 1970, 30 U.S.C. § 21a; VIOLATION OF OTHER FEDERAL STATUTES; AND REQUEST FOR

DECLARATORY JUDGMENT; INJUNCTIVE RELIEF; QUIET TITLE; AND DAMAGES.

DEMAND FOR JURY TRIAL

JURISDICTION AND VENUE

1. Jurisdiction is proper in this Court under 28 U.S.C. § 1331 because this action arises under the laws of the United States. The conduct complained of creates an actual, justiciable controversy and is made reviewable under the Administrative Procedures Act (“APA”), 5 U.S.C. § 701 et seq. (1966).

2. This Court has jurisdiction, among other matters, pursuant to 28 U.S.C. § 1331 (federal question), §§ 2201, 2202 (declaratory relief), § 2202 (injunctive relief), and § 2409(a) (quiet title). Judicial review is also sought pursuant to § 10 of the APA, 5 U.S.C. §§ 701-706.

3. This action arises under the various acts, regulations, laws.........

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