Cause of Action Complaint
RE: Complaint about information Quality.
“Information disseminated by NPS in the DEIS and Atkins Peer Review Report fails to conform to minimum information-quality standards established by the OMB Guidelines, DOI Guidelines, and Director’s Order #11B. This inaccurate, nontransparent, and deliberately misleading information is reasonably likely to cause severe harm to the Lunnys—who may be forced to close their family business, Drakes Bay Oyster Company (hereinafter “DBOC”)—and Dr. Goodman, who is a user of the information provided in these publications and adversely affected by the scientifically invalid data and methods used therein.”
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