JOHN C. CRUDEN 

Assistant Attorney General 

U.S. Department of Justice 

Environment & Natural Resources Division 

SETH M. BARSKY, Section Chief 

BRADLEY H. OLIPHANT, Trial Attorney 

U.S. Department of Justice 

Environment & Natural Resources Division 

Wildlife & Marine Resources Section 

999 18th Street 

South Terrace, Suite 370 

Denver, CO 80202 

(303) 844-1381 (tel) 

(303) 844-1350 (fax)

Email: bradley.oliphant@usdoj.gov

STEPHEN FINN 

U.S. Department of Justice 

Environment & Natural Resources Division 

Natural Resources Section 

P.O. Box 7611 

Washington, D.C. 20044 

(202) 305-3284 (tel) 

(202) 353-0506 (fax) 

E-mail: stephen.finn@usdoj.gov

Attorneys for Federal Defendants

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

AUDUBON SOCIETY OF PORTLAND, 

WILDLIFE DEFENSE FUND, CENTER 

FOR BIOLOGICAL DIVERSITY, FRIENDS 

OF ANIMALS,

Plaintiffs,

v.

U.S. ARMY CORPS OF ENGINEERS, U.S. 

FISH AND WILDLIFE SERVICE, USDA 

WILDLIFE SERVICES,

Defendants.

No. 3:15-cv-665-SI

DECLARATION OF STEPHEN FINN

Case 3:15-cv-00665-SI Document 50 Filed 05/06/15 Page 1 of 3
I, Stephen Finn, declare, pursuant to 28 U.S.C. §1746, as follows:

1. I am a trial attorney at the U.S. Department of Justice, 

Environment and Natural Resources Division, and an attorney or record for 

the Federal Defendants in the captioned litigation.

2. This declaration is submitted in support of Federal Defendants’ 

response to Plaintiffs’ motion for a preliminary injunction.

DOCUMENTS

3. Attached as Exhibit 1 (page USACE AR 000045) to this 

declaration is a true and correct copy of the March 19, 2015, Department of 

the Army, Corps of Engineers, Northwest Division, Record of Decision, 

Double-Crested Cormorant Management Plan to Reduce Predation of 

Juvenile Salmonids in the Columbia River Estuary Environmental Impact 

Statement obtained from the Corps of Engineers.

4. Attached as Exhibit 2 to this declaration is a true and correct 

copy of the March 23, 2015, U.S. Fish and Wildlife Service, Migratory Bird 

Depredation Permit Application, for the Corps of Engineers, obtained from 

the Fish and Wildlife Service.

5. Attached as Exhibit 3 (page USACE AR 000001) to this 

declaration is a true and correct copy of the April 13, 2015, U.S. Fish and 

Wildlife Service, Migratory Bird and Habitat Program, Record of Decision, 

Depredation Permit Associated with Double-crested Cormorant 

Management Plan to Reduce Predation of Juvenile Salmonids in the 

Columbia River Estuary, obtained from the Corps of Engineers.

6. Attached as Exhibit 4 (page USACE AR 000033) to this 

declaration is a true and correct copy of the April 13, 2015, U.S. Fish and 

FINN DECLARATION 2

Case 3:15-cv-00665-SI Document 50 Filed 05/06/15 Page 2 of 3
Wildlife Service, Federal Fish and Wildlife Depredation Permit issued to the 

U.S. Army Corps of Engineers, obtained from the Corps of Engineers.

I declare under penalty of perjury that the foregoing is true and correct. 

Executed in Washington, D.C., on May 6, 2015,

/s/Stephen Finn STEPHEN FINN (NY 2574986)

Natural Resources Section

Environment & Natural Resources Division

United States Department of Justice

FINN DECLARATION 3

Case 3:15-cv-00665-SI Document 50 Filed 05/06/15 Page 3 of 3