A Regionally Based Professional Services Firm With a Global Purview SM

Practice

Services Offered and Provided

KLG offers and provides the following multidisciplinary services to secure and promote our clients' legal, economic and societal interests:

  • Transactional due diligence reviews, assessments, negotiations and document drafting;
  • Contract reviews;
  • Regulatory reviews and assessments;
  • Strategic advice and planning;
  • Regulatory applications;
  • Intellectual property protection audits and reviews;
  • Prospective entity combination and collaboration due diligence reviews;
  • Feasibility studies;
  • Freedom-to-operate reviews;
  • Internal organizational due diligence and corporate governance audits and reviews;
  • Supply-chain information and management audits and reviews;
  • External stakeholder reviews;
  • U.S. and non-U.S. legislative, regulatory promulgation reviews;
  • Regulatory compliance reviews;
  • Standard conformity assessments;
  • Public outreach and policy formulation initiatives:
    • Government liaison;
    • Intergovernmental liaison;
    • Nongovernmental liaison;
    • Trade and investment litigation support;
    • Draft public comments to proposed laws and regulations;
    • Draft citizen petitions for government agency review;
    • Draft amicus curiae briefs;
    • Draft public policy white papers;
    • Draft peer-reviewed published legal analyses in respected national and international distribution channels;
    • Organize institutional legal law and public policy briefings;
    • Organize and convene expert panels to address public policy issues;
    • Participate on government, industry and academic panels discussing public policy issues.
  • Civil Litigation


Representative Client Deliverables


  • Secured inbound tax-free reorganizations of private Saudi investment group-owned commercial real estate interests, preserving for clients substantial (USD$122M) depreciation/amortization deductions and/or (USD$98M) capital losses.
  • Assessed redrafted and secured substantial (USD$750K asset-backed lending facility for private U.S. solar energy leasing client to permit aggressive home solar installations in chosen market.
  • Settled strategically threatening minority shareholder action to protect private U.S. software developer client's ability to secure a new round of investor financing for commercialization of advanced software technology.
  • Thwarted an alleged design patent infringement claim filed against private U.S.-based textiles products importer-exporter to avoid significant liability and treble damages; assured the preparation of new patent design applications to enable client to secure substantial market share.
  • Negotiated and secured for a private U.S. investment group an exclusive (USD$600M) timber/forest product concession/licensing agreement with a land option and an option for semi-precious mineral extraction, benchmarked to international sustainable forest management and social responsibility standards that provided political credibility  supporting the group's economic activities in South Sudan.
  • Identified and analyzed for a U.S. trade association, within three internationally referenced World Trade Organization ('WTO')-focused white papers, the legal and economic bases of trade risks faced by such organization's public U.S. industrial and agricultural manufacturing and exporting members, triggered by emerging environment, health and safety regulations and related technical product standards denying such products access to European Union ('EU') and third world markets on putative safety grounds; briefed congressional committees and U.S. federal agencies and served as trade coalition liaison for purposes of informing the U.S. government response to such costly and burdensome measures.
  • Reduced regulatory risks posed to coal-based assets of U.S. public chemicals and energy extraction and refining company facing onerous U.S. regional and state-level climate change, environmental/
  • chemicals regulations, renewable portfolio standards, and non-financial reporting requirements, by reeducating decision-makers via congressional and administrative agency briefings and preparation and publication of an internationally referenced peer-reviewed legal monograph accompanied by numerous expert commentaries.
  • Identified and reduced intellectual property ('IP') risks for public U.S. and foreign pharmaceutical companies facing a substantial loss of revenues and profits derived from patent, trade secret and clinical testing data (IP)-protected products and processes as the result of WTO-non-compliant Brazil, Russia, India, China and South Africa ('BRICS') (mostly Brazil) 'compulsory licensing' laws, by helping to reshape government views via detailed submissions to Geneva World Intellectual Property Organization ('WIPO') and World Health Organization ('WHO') venues and the preparation and publication of internationally referenced analyses within peer-reviewed legal and economic journals.
  • Liaised with U.S. Government officials and prepared a provocative law review article, on behalf of U.S. pharmaceutical companies, analyzing the adverse implications of former Brazilian Government-promoted global compulsory licensing initiatives impairing the value of U.S. and foreign intellectual property-embedded life science technologies, prompting a formal rebuke from Brazil's Washington Embassy and the subsequent convening of a legal symposium at the law review publisher's premises featuring speakers from the Brazilian Government, U.S. industry, academia and civil society.
  • Liaised with U.S. Government officials and prepared and submitted formal comments via the designated U.S. WTO enquiry points, on behalf of Colombian dietary supplement product companies prior to the entering into force of the Colombia-U.S. FTA,  explaining U.S. dietary supplements law and applicable Codex guidelines, and identifying domestic and foreign industry protectionism as the source of serial changes in Colombian Government health and sanitary registration laws and regulations then implemented to impede the market access of U.S.-based dietary supplement exports.
  • Identified and reduced IP risks for public U.S. wireless technology and software development companies facing substantial patent and trade secret licensing and royalty revenue losses as the result of emerging BRICS and EU Member State 'public interest' laws mandating royalty-free patent licensing practices for information & communication technology ('ICT') standards and open source software e-government procurement preferences, by reeducating industry and government officials via robust engagement at Geneva WIPO and Brussels European Commission Directorate General meeting venues, the convening of participation at symposiums, and the preparation of internationally referenced analyses appearing within various peer-reviewed  legal journals and media publications.
  • Identified and reduced environmental, health and chemical safety-related regulatory risks for public and private U.S. chemicals/ pesticides manufacturers facing higher formulation and production costs due to U.S. congressional and administration efforts to amend federal environmental and chemicals laws and regulations incident to the proposed U.S. accession to the UN Convention on the Law of the Sea ('UNCLOS'), by delivering congressional committee briefings, participating in robust panel discussions at the Reserve Officers Association and National Defense University, and publishing internationally referenced legal peer-reviewed and other analyses of the environmental, technological, economic and national security implications of said treaty, thereby permitting informed, cognizant congressional consideration in lieu of pursuing UNCLOS accession/ ratification.  
  • Advised a U.S.-based multinational apparel and footwear manufacturer concerning revised U.S. Department of Defense ('DOD') product procurement processes and procedures implementing such agency's reinterpretation of longstanding defense department procurement legislation putatively updated to provide statutory derogations reflecting U.S. outsourced manufacturing trends; developed unique strategic and tactical administrative approach, in light of the agency's numerous intra-organizational challenges, enabling the DOD Defense Logistics Agency to reclaim from Non-appropriated Funded Instrumentalities ('NAFIs') central product procurement responsibilities for U.S. designed and manufactured higher technology dual-use products without client's immediate resort to potentially antagonistic congressional intervention in DOD affairs.
  • Prepared and filed at the Supreme Court of the United States, on behalf of a nonprofit organization, at the cert petition stage, an Amicus Curiae Brief supporting Petitioners in the case of Chamber of Commerce of the United States of America, State of Alaska, and American Farm Bureau Federation v. Environmental Protection Agency, Docket No. 12-1272one of twelve separately filed cases previously consolidated by the United States Court of Appeals for the District of Columbia Circuit in the case of Coalition for Responsible Regulation, et al. v. Environmental Protection Agency, 684 F.3d 115 (D.C. Cir. 2012).  Amicus interest in this case stems from EPA’s disregard for the procedural due process requirements intended to ensure the quality of agency-disseminated third-party-developed scientific data that served as the basis for EPA’s Final Greenhouse Gas Endangerment Findings and subsequent promulgation of economically significant regulations governing mobile and stationary source GHG emissions.

  • Ascertained the qualitative legal risks faced by a non-U.S.-based multinational food product manufacturing and processing company arising from 
    emerging infant formula and complementary food product advertising and marketing regulations in Hong Kong and the Philippines severely restricting the public promotion and advertising of such products and the use of proprietary product and company trademarks, logos and trade dress deemed as making health claims.  Prepared five peer-reviewed law journal articles summarized in three Asia regional law blog entries analyzing the consistency of such rules with three WTO agreements in an effort to educate these governments about the potential international trade law consequences their regulatory promulgations may potentially trigger.  This reframing of the debate delayed the introduction of the proposed HK rules and helped to reshape the Philippine legislative debate for more than one calendar year, prompted media coverage of the issue, and assisted U.S. trade associations seeking resolution of the World Trade Organization dispute on plain tobacco packaging.
  • Legal counsel and representative of a community of generations-old privately held family agricultural, ranching and business interests operating on fee patented lands located on and appurtenant to the Flathead Indian Reservation in northwestern Montana ("Plaintiffs" and similarly situated persons), whose economically valuable land and water rights, constitutional rights of equal protection and due process of law, administrative right to open public hearings (guaranteed by statute and regulation) and, most recently, their right to personal safety, have been seriously threatened by years of ongoing arbitrary, capricious and illegal and deceptive U.S. federal government agency (Federal Energy Regulatory Commission (FERC) and Department of Interior Bureau of Indian Affairs (DOI-BIA) and Fish and Wildlife Service (DOI-FWS)) regulatory practices and procedures failing to honor the rule of law, and U.S. federal tribal self-governance/self-determination and sovereignty policies, and by the State of Montana's ceding of aboriginal time-immemorial instream flow rights to State waters to the Confederated Salish and Kootenai Tribes of the Flathead Indian Reservation (CSKT) pursuant to the Hellgate Treaty of 1855 and the recently executed CSKT Water Compact ("CSKT Water Compact") entered into between the State of Montana, the U.S. Department of Interior and the CSKT, which state and federal government practices, policies and actions collectively have enabled the CSKT to diminish Plaintiffs' exercise of and access to their legally and validly held water rights via unilateral assumption of actual control of ALL physical infrastructure (dams, reservoirs, irrigation pumping systems and canals paid for by Plaintiffs, including the large Kerr Dam, a "black start" "category 3" high safety risk dam exclusive ownership, control and management of which was turned over to the CSKT on 9/5/15) located above and on the Reservation.
    • 9/3/15 - Filed an Emergency Action for Temporary Restraining Order (TRO) and Preliminary Injunction (PI) in the U.S. Federal District Court for the District of Columbia, partially on national security grounds, in an effort to temporarily suspend the illegal conveyance of Kerr Dam to the CSKT
    • Complaint- Keenan v. Bay, Civil Action No. 1:15-cv-01440  
    • Motion for TRO/PI
    • Memorandum in Support of Motion for TRO/PI 
    • Proposed Order
    • Exhibits 1-68 of Evidence Supporting Complaint:
      • Exhibit 1   (FERC 1985 Agreement 7-17-85)
      • Exhibit 2   (FERC ALJ Order - 4-16-85)
      • Exhibit 3   (DOI 59 FR 28737 - Nov. '94)
      • Exhibit 4   (DOI 60 FR 2598 - Feb. '95)
      • Exhibit 5   (FERC Order Amending 1985 Agmt - 1997)
      • Exhibit 6   (FERC Order Amending 1985 Agmt - 1998)
      • Exhibit 7   (FERC Order Amending 1985 Agmt - 2000)
      • Exhibit 8   (DOI-BIA EIS Drought Mgmt Plan - 2002)
      • Exhibit 9   (DOI-BIA Draft EIS Drought MP - 2005)
      • Exhibit 10  (DOI -BIA Final EIS Drought MP - 2010)
      • Exhibit 11  (FBJC v DOI-BIA, dismissed 2015)
      • Exhibit 12  (AAA Final Award - Kerr Dam Price (2014)
      • Exhibit 13  (DOI Solicitor Gen'l Notice of Intervene(2014)
      • Exhibit 14  (CSKT Notice of Conveyance (2014)
      • Exhibit 15  (CSKT Apply Partial License Transfer 4-14-15)
      • Exhibit 16  (Jackson Files Motion to Intervene 5-30-14)
      • Exhibit 17  (Jackson Cov Ltr w/Motion toInterven 5-30-14)
      • Exhibit 18  (FERC Order Grants Jackson Interven 9-19-14)
      • Exhibit 19  (FERC OrdApprovPPLMT-NWLicTra 7-24-14)
      • Exhibit 20  (Jackson Request for Rehearing 8-22-14)
      • Exhibit 21  (FERC Ord.Dismisses Rehearing Req. 9-19-14)
      • Exhibit 22  (Jackson Req. Reclarify of Dismissal 9-24-14)
      • Exhibit 23  (FERC Responseto Jackson Reclarify 10-29-14)
      • Exhibit 24  (FERCOrd.CSKT-EKIExemptPubUtil 12-8-14)
      • Exhibit 25  (MRWRCC SignsCSKTWaterCompact 1-12-15)
      • Exhibit 26  (NWestern Instruments of Conveyance 1-13-15)
      • Exhibit 27  (CSKT-NW Apply Partial Lic.Transfer 4-14-15)
      • Exhibit 28  (Keenan-Jackson Intervene-PartialLic. 5-26-15)
      • Exhibit 29  (CSKT-EKI Response to Intervenors 6-9-15)
      • Exhibit 30  (CSKT Water Claims Filed - If NO Compact) 
      • Exhibit 31  (CSKT Water Claims Filed - If YES Compact)
      • Exhibit 32  (FERC Approv. NW Drought Mgt Plan 7-1-15)
      • Exhibit 33  (Keenan-JacksonResponse-CSKT-EKI 7-15-15)
      • Exhibit 34  (Pointer Kerr Proj.No.5 - FERC Interv 11-3-98)
      • Exhibit 35  (Pointer Kerr Proj.No.5 -FERCPhone 12-21-98)
      • Exhibit 36  (Pointer Kerr Proj.No.5 -FERC Interv 2-19-99)
      • Exhibit 37  (Pointer Kerr Proj.No.5 -FERC Phone 06-05)
      • Exhibit 38  (Pointer Kerr Proj.No.5 -Conveyance 8-24-15)
      • Exhibit 39  (FERCOrderApprovPartial Lic Transfer 9-1-15)
      • Exhibit 40  (CSKTFlathead Dams-ReservoirsOwned-8/12)
      • Exhibit 41  (Turkey Outreach Efforts to Tribes 2008-2015)
      • Exhibit 42  (Congressman Cole Testimony - H.R. 2362)
      • Exhibit 43  (TAC Pres. McCurdy Testimony - H.R. 2362)
      • Exhibit 44  (Turkey - Media Articles of Interest 2012-2015)
      • Exhibit 45  (IndianReservationsChosenbyTurkeyBusiness)
      • Exhibit 46  (DOD-Rel. Uranium Mines Locator Rpt 2014)
      • Exhibit 47  (DOD-Rel. Uranium Mines Rpt to Cong 2014)
      • Exhibit 48  (Los Alamos Labs Rpt - Uranium Flathead)
      • Exhibit 49  (Dry Fork Creek Ref. No. 304748)
      • Exhibit 50  (Dry Fork Creek Ref. No. 304747)
      • Exhibit 51  (Kalispell West (25 miles) Ref. No. 304712)
      • Exhibit 52  (Kalispell West (25 miles) Ref. No. 304712-a)
      • Exhibit 53  (Kalispell West (25 miles) Approx. Ref. - A)
      • Exhibit 54  (Kalispell West (25 miles) Approx. Ref. - B)
      • Exhibit 55  (Kalispell West (25 miles) Approx. Ref. - C)
      • Exhibit 56  (Flathead Lake W.(9-12 miles) Ref. No. 303394)
      • Exhibit 57  (Flathead Lake W.(9-12 miles) Ref. No. 303396)
      • Exhibit 58  (Flathead Lake W.(9-12 miles) Ref. No. 303398)
      • Exhibit 59  (Flathead Lake W.(9-12 miles) Ref. No. 303387)
      • Exhibit 60  (Smith Lake North (6 miles) Ref. No. 303365)
      • Exhibit 61  (Flathead Lake East Ref. No. 303502)
      • Exhibit 62  (Flathead Lake East Ref. No. 303506)
      • Exhibit 63  (Flathead Lake East Ref. No. 303509)
      • Exhibit 64  (USGS Water Res. Rpt Jefferson Cty, MT 2007)
      • Exhibit 65  (MBM Abandoned FlatheadForestMines 2002)
      • Exhibit 66  (DOI-BIAMemo-IndianRacialPreference 1973)
      • Exhibit 67  (GAO Rpt-Indian Irrig.Proj.Def. M&O$ 2006)
      • Exhibit 68  (GAO Testimony Re GAO 2006 Report 2015)
CSKT Annual Reports and Quarterly Newsletters Revealing Tribes' Uranium Mill Tailings Cleanup Expertise, Contracting for the Saudi Arabia Military and Embrace of Turkish 'Investment' on Reservation Lands Outreach Activities

New and Relevant Information:
  • Legal counsel and representative to generations-old farmers and ranchers holding fee patented land and consumptive water rights on the Flathead Indian Reservation ("FIR") and non-consumptive rights to use the state-owned waters of the Flathead Lake and River. A small group of these farmers and ranchers have courageously concluded that the Flathead Joint Board of Control does not adequately represent the interests of Flathead, Mission and Jocko Valley Irrigation District members, and sought to participate in the Federal Energy Regulatory Commission ("FERC") "confidential" nonpublic settlement conference proceedings that have been convened in lieu of a public hearing to address the terms and conditions for continuing to secure the low-cost block of power (electricity) long guaranteed to irrigators and other residents of the FIR by the 1930 and 1985 Kerr Dam licenses, the latter of which is subject to renegotiation following the conveyance of Kerr Dam to the Confederated Salish & Kootenai Tribes ("CSKT") this past September .
    • Since the irrigators ended their intervention effort, the actions taken by the FJBC’s Washington D.C. Counsel at the FERC public hearing proceedings have, once again, caused major concern among Flathead irrigators.  These concerns focused, in particular, on the FJBC D.C. Counsel’s failure, in her May 2015 petition, to call for the broadest scope of administrative law judge review possible of Kerr Dam license Article 40(c) issues.  These issues concern both the value of the LCB and corresponding irrigator non-consumptive water rights, as well as, the right of the United States to remain the exclusive provider of electricity on the Flathead Indian Reservation, and the terms and conditions of such electricity delivery to reservation irrigator and non-irrigator households, schools, religious institutions, municipalities and businesses, as set forth in a specially prepared legal memorandum.
  • Legal counsel and representative to the members of the Klamath Irrigation District ("KID"), one of the largest districts of irrigators of the Klamath Irrigation Project ("Project"), which comprises a system of dams, canals and pumps developed by the U.S. Department of Interior ("DOI")'s Bureau of Reclamation ("BOR") long ago to supply farmers and ranchers in the Klamath Basin with irrigation water for farmlands spanning from southern Oregon to northern California.  The KID Board and many district members are very concerned about the ongoing clandestine efforts of the BOR, in cooperation with the DOI's Fish & Wildlife Service ("FWS"), the Federal Energy Regulatory Commission ("FERC"), the U.S. Department of Commerce ("DOC")'s National Oceanic and Atmospheric Administration ("NOAA") and National Marine Fisheries Service ("NMFS"), the Fish & Wildlife and Natural Resources Departments of the States of Oregon and California, the Klamath, Hoopa Valley, Karuk and Yurok Tribes, and Warren Buffet's PacifiCorps to diminish the use of irrigation in the Klamath Basin by: 1) removing four perfectly operational dams in the Lower Basin (John C. Boyle, Copco 1, Copco 2 and Iron Gate); 2) transferring to the BOR full title and control to two other dams in the Upper Basin one of which provides water to the KID which may potentially be curtailed; 3) recognizing the time-immemorial priority of reserved tribal water rights at the expense of irrigator water rights; and by 4) saddling the KID and its members with an exorbitantly high debt burden incident to the KID's forced undertaking of maintenance/replacement of  a key Project-related structure known as the "C Canal Flume."  The grand plan these federal, state and private actors have developed to curtail irrigation in the Klamath Basin features the execution and implementation of a complex panoply of new and existing federal-state-tribal agreements, including the Klamath Basin Restoration Agreement ("KBRA") (2010), the Upper Klamath Basin Comprehensive Agreement ("UKBCA") (2014), the Klamath Hydroelectric Settlement Agreement ("KHSA") (2010), and the new Klamath Power and Facilities Agreement ("KPFA") (2016) accompanied by proposed congressional legislation (the Merkley-Wyden bill), which individually and collectively overlook, ignore and expand upon the 1956 Klamath Basin River Compact ("KBRC").   Although the KBRA expired on January 1, 2016  when Congress refused to authorize it, the UKBCA and KHSA continue to live on, with the federal, state, tribal and private actors noted above endeavoring to insert amendments that would enable the implementation of these agreements without Congress' approval, and despite the failure of the scientific, engineering and economic studies supporting these agreements - i.e., the "Secretarial Determination Studies" to meet the rigorous peer review standards imposed by federal law - the Information Quality Act.
    • A compilation of all of these documents along with media reports of an evolving legal and political scandal in the Klamath Basin is available here.   
    • A recent exchange of email and hardcopy correspondences between governmental officials and public stakeholders regarding the former's nondisclosure of the Amended KHSA text and the new KPFA before the April 6, 2016 scheduled signing ceremony is available here and here.  
    • A recently dispatched letter to Interior Secretary Jewell by another public stakeholder is available here.  
    • The first media reports about the improper procedures behind the signing of these basin agreements are available here and here.
    • Recently dispatched letters to U.S. Congressman Doug LaMalfa (CA-R) and Greg Walden (OR-R) describing the oppressive terms and conditions imposed by the BOR's non-negotiable, one-sided extortion contract and requesting their presence at the Klamath Irrigation District's scheduled April 21, 2016 meeting with senior BOR officials in Sacramento, CA are available here and here.
    • Evidence of questionable non-transparent prior KID Board activities is available here.
    • The first media reports about the one-sided extortion contract the BOR has compelled the Klamath Irrigation District to sign under veiled threat of water shut-off and unavailability of government funds is available here.
    • The KID's response to the Bureau of Reclamation's explanation of why it has been unable, since 2001, to provide the KID and other Klamath Project irrigation districts a yearly accounting of the net balance of each district's portion of Project capital costs and operation and maintenance (O&M) expenditures, is available here. 
    • Bureau of Reclamation's official confirmation for the first time that the KID is debt-free to the Bureau - clear on its share of Project construction costs under the 1954 contract, AND clear on its current (2015-2016) O&M expenditures - is available here.
    • KID correspondence (5/18/16) to Congressman Doug LaMalfa (R-CA)'s legislative director concerning desired changes to the Wyden-Merkley bill intended to address guaranteed C Canal Flume replacement non-reimbursable financing and dam removal-related issues:  
      • Legislative language KID submitted for S.A. 3288 (Wyden-Merkley) seeking Congressional review and ratification of all agreements into which the Secretary has entered into or will enter into in the future with States, Tribes and other parties (including the Amended KHSA and the KPFA) to promote the objectives of the defunct KBRA and UKBCA and KHSA); 
      • Legislative language guaranteeing C Canal Flume replacement non-reimbursable financing that the current bill language fails to guarantee; and
      • Inquiries with federal and state officials about issues concerning dam removal. 
    • The Wyden-Merkley Amendment -
    • Local biased media reporting by the Klamath Falls Herald & News (H&N) has assisted proponents of the Klamath Basin Agreements (currently sitting KID minority Board members and their patrons) to disparage, harass and intimidate the current KID Board majority and their District patrons in Klamath Falls, Oregon.  Their objective has been to disrupt District business and to tortiously interfere with current District counsels' legal representation (and thereby raise District legal costs) to ensure a successful recall of the majority Board members and the minority's retaking of political and financial control over the District which they previously held for more than 25 years with the assistance of a family of local lawyers advising the District for 90 years.  The KID Board majority had hired new counsels consistent with their November 2015 electoral mandate to prevent the implementation of the Obama administration-favored Klamath Basin Agreements which will compromise Klamath Irrigation Project farmer and rancher water and land interests.   
      • Evidence of biased media reporting resulting in KID minority Board member and media disclosure of this counsel's unredacted confidential and privileged engagement agreement is available here, here, here, here, here, & here
    • KID Correspondence to BOR Objecting to New Contract Changes Reducing Funding for C Flume Replacement
    • BOR Response to KID Correspondence
    • Most Interior Department monies budgeted for the Klamath Basin during FYs 2012-2017 have been allocated to the BOR, BIA and FWS for purposes of funding Klamath Basin restoration and tribal settlement rather than Klamath Irrigation Project activities.
    • Three California-based federally recognized tribes filed with the BOR and the NOAA-based National Marine Fisheries Service (NMFS) 60-day notices-of-intent-to-sue under the citizen suit provisions of the Endangered Species Act, alleging that BOR's implementation of the joint 2013 U.S. Fish & Wildlife Service (FWS)-NMFS Biological Opinion governing the levels and flows of the Upper Klamath Lake and the Klamath River resulted in too much Lake water being diverted into the Klamath Irrigation Project rather than the Klamath River, causing coho salmon to contract and die from C Shasta Bacteria.  The tribal reservations are located more than 240 miles southwest of Upper Klamath Lake, which suggests that the following tribes are also asserting off-reservation fishing and water rights:
    • The Earthjustice environmental group filed a similar 60-day notice-of-intent-to-sue under the citizen suit provisions of the ESA on behalf of three fisherman conservation groups (July 20, 2016):
      • Pacific  Coast Federation of Fishermen's Associations
      • Institute for Fisheries Resources
      • Klamath Riverkeeper
    • EACH OF THESE NOTICES CALLS FOR SUSPENSION OF WATER DIVERSIONS FROM UPPER KLAMATH LAKE TO THE KLAMATH IRRIGATION PROJECT.