1 Patrick Gallagher (CA Bar No.146105) Sierra Club 2 85 Second Street San Francisco, CA 94104 3 (415) 977-5709 (415) 977-5793 FAX 4
[email protected] 5 Attorney for Plaintiffs Sierra Club and 6 Tule River Conservancy 7 Additional Counsel listed on next page 8 IN THE UNITED STATES DISTRICT COURT 9 FOR THE NORTHERN DISTRICT OF CALIFORNIA 10 SIERRA CLUB, TULE RIVER ) CONSERVANCY, SIERRA NEVADA ) 11 FOREST PROTECTION CAMPAIGN, ) Case No.: EARTH ISLAND INSTITUTE, SEQUOIA ) 12 FORESTKEEPER, and CENTER FOR ) BIOLOGICAL DIVERSITY, non-profit ) 13 organizations, ) COMPLAINT FOR DECLARATORY 14 ) AND INJUNCTIVE RELIEF Plaintiffs, ) 15 ) (Administrative Procedure Act Case) v. ) 16 ) DALE BOSWORTH, in his official capacity ) 17 as Chief of the United States Forest Service, ) JACK BLACKWELL, in his official ) 18 capacity as Regional Forester, Region 5, ) United States Forest Service, KENT ) 19 CONNAUGHTON, in his official capacity ) as Deputy Regional Forester, Region 5, ) 20 United States Forest Service, ARTHUR ) 21 GAFFREY in his official capacity as Forest ) Supervisor, Sequoia National Forest, ) 22 UNITED STATES FOREST SERVICE, an ) agency of the U.S. Department of ) 23 Agriculture, MIKE JOHANNS, in his ) official capacity as Secretary of the U.S. ) 24 Dept. of Agriculture, and UNITED STATES ) DEPARTMENT OF AGRICULTURE, ) 25 ) Defendants. ) COMPLAINT 1 Eric E. Huber, (Colo. Bar No. SC 700024) Pro Hac Vice Application Pending Sierra Club 2 2260 Baseline Road, Suite 105 Boulder, CO 80302 3 (303) 449-5595 4 (303) 449-0740 FAX
[email protected] 5 Attorney for Plaintiffs 6 Sierra Club and Tule River Conservancy 7 8 Deborah Reames (CA Bar No.