UNITED STATES DISTRICT COURT NORTHERN ... - Bizjournals

Case 1:13-cv-03241-AT Document 1 Filed 09/30/13 Page 63 of 64claim that five of the beluga whales proposed for import were nursing at the timeof collection violates the MMPA and the APA because it has no foundation in lawor fact and is arbitrary, capricious and not in accordance with law.PRAYER FOR RELIEFPlaintiff respectfully requests that this Court:A. Maintain jurisdiction over this action until Defendants are incompliance with the MMPA, APA, and every order of this Court inthis action;B. Find that Defendants have violated the MMPA and the APA as setforth above;C. Vacate the denial of the permit to Georgia Aquarium for theimportation into the United States of 18 beluga whales from Russiaand order Defendants to issue the permit and enjoin Defendants fromtaking any action to prevent the import of the whales;D. Award Plaintiff its costs of litigation, including reasonable attorneys’fees and expert witness fees; andE. Grant Plaintiff such further and additional relief as the Court maydeem just and proper under the circumstances.63