November 29, 2017
| Legal Document
The Conservation Law Foundation (“CLF”) and co-counsel Earthjustice hereby give notice pursuant to 16 U.S.C. § 1540(g) of our intent to sue the U.S. Department of Commerce, the Secretary of Commerce, the National Ocean and Atmospheric Administration’s National Marine Fisheries Service, and the Assistant Administrator for Fisheries (collectively “NOAA Fisheries” or the “Agency”) for violations of the Endangered Species Act, 16 U.S.C. §§ 1531 et seq., specified below. The alleged violations concern the effects of the American lobster fishery on the endangered North Atlantic right whale (Eubalaena glacialis) (“right whale”). We intend to file suit in United States District Court seeking appropriate declaratory relief, injunctive relief, and other relief no earlier than sixty days from the postmark date of this notice letter.