Correspondence on Bonneville Unit of Central Utah Project

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SIERRA CLUB LEGAL DEFENSE FUND, INC. by Ansel Adams in This is the American Earth JAMES W. MOORMAN Executive Director BARRY A. FISHER JOHN D. HOFFMAN LAURENS H. SILVER Staff Attorneys, San Francisco H. ANTHONY RUCKEL Staff Attorney, Denver December 19, 1973 Mr. Curtis Oberhansley No. 12 Exchange Place Salt Lake City, UT 84111 Re: Central Utah Project Dear Curt: Pursuant to our telephone conversation, here are my current ideas of our procedure. We must file our complaint together with accompanying motions and supporting documents on Monday, January 7, 1974. At the time of filing we should request a Temporary Restraining Order from the judge that we draw or in the alternative, the judge that is present. Naturally, the accompanying motion for preliminary injunction will make much of the February 5, 1974, bid opening date, and our need to have the preliminary relief matter resolved by that time in order to avoid changed conditions on the part of the parties and a possible bond situation which our clients would be unable to surmount. Allen Stokes, my assistant, is in the process of preparing and will be preparing during the holidays a brief to accompany the motion for preliminary injunction. My general experience in environmental cases regarding preliminary injunctions, and my experience on the Circle Cliffs matter in Utah, teaches me that two things are of primary interest to the court: (1) irreparable harm to the plaintiffs should the contemplated federal action proceed without preliminary relief pending determination of San Francisco: 311 California Street, Suite 311, 94104; Telephone [phone] Denver: 508 Majestic Bldg., 209 16th Street, 80202; Telephone [phone]