Stephen H.M.Bloch,# 7813 Brent V. Manning, # 2075 Joseph J. Bushyhead, # 15046 Jess M. Krannich, # 14398 SOUTHERN UTAH WILDERNESS Timothy M. Considine, #13179 ALLIANCE MANNING, CURTIS, BRADSHAW 425 East 100 South & BEDNAR LLC Salt Lake City, UT 84111 136 East South Temple, Suite 1300 Telephone: (801)428-3161 Salt Lake City, UT 84111 Facsimile: (801) 428-4233 Telephone: (801)363-5678
[email protected] Facsimile: (801)364-5678
[email protected] [email protected] [email protected] [email protected] Attorneys for Plaintiffs IN THE THIRD JUDICIAL DISTRICT COURT IN AND FOR TOOELE COUNTY, STATE OF UTAH MICHAEL ABDO, an individual; and SOUTHERN UTAH WILDERNESS ALLIANCE, a nonprofit corporation, COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF Plaintiffs, Case No. vs Judge SEAN D. REYES, in his official capacity as Attorney General ofUtah; TOOELE COUNTY; J. BRUCE CLEGG, in his official capacity as Tooele County Commissioner; JERRY HURST in his official capacity as Tooele County Commissioner; and SHAWN MILNE in his official capacity as Tooele County Commissioner, Defendants. {00764755.DOCX /> Plaintiffs Michael Abdo and the Southern Utah Wilderness Alliance bring this action against defendants Sean D. Reyes, in hisofficial capacity, theTooele County Commission, each individuallyin his official capacity, and Tooele County (collectively"Defendants"), seeking a judgmentdeclaringDefendants' federal court quiet title action involvingalleged R.S. 2477 rights-of-way in Tooele County illegal, unconstitutional, andan ultraviresaction brought outside theauthority of the Office of Attorney General, as well as an orderenjoining the implementation and fundingofthis litigation. For causes of action, plaintiffs show this Honorable Court as follows: INTRODUCTION 1. Since 2012, Tooele County's Commissioners, through the Utah Attorney General, have pursued a quiet title action against the United States claiming title to alleged R.S.