SUMMARY OF CHIEF YOWELL'S ARGUMENT AT HEARING ON PRELIMINARY INJUNCTION
(MAY 4, 1998)

FOUR POINTS

1. There is a likelihood of irreparable harm to Western Shoshone cattle ranchers if an injunction is denied:

2. There is no likelihood of irreparable harm to the BLM if an injunction is granted:

3. The Plaintiffs have raised "serious questions" of law which are "a fair ground for litigation" [the cases which set forth this test are cited in Plaintiffs' Reply to Defendant's Opposition to the Preliminary Injunction]:

4. An injunction will serve the public interest in the orderly administration of law:

CONCLUSIONS:



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