IN THE UNITED STATES DISTRICT COURT - DISTRICT OF UTAH

CENTRAL DIVISION

WESTERN RANGELAND )
CONSERVATION ASSOCIATION, et al. )
)
Plaintiffs, )
) No. 2:14-cv-00327-PMW
v. )
) Judge Paul M. Warner
SALLY JEWELL in her official capacity as )
Secretary, UNITED STATES DEPARTMENT )
of the INTERIOR, et al. )
)
Defendants )
)

EXHIBIT C

TO MOTION TO INTERVENE BY AMERICAN WILD HORSE PRESERVATION
CAMPAIGN, THE CLOUD FOUNDATION, RETURN TO FREEDOM,
JOHN STEELE, AND LISA FRIDAY
Case 2:14-cv-00327-PMW Document 15-4 Filed 06/17/14 Page 1 of 6
IN THE UNITED STATES DISTRICT COURT - DISTRICT OF UTAH
CENTRAL DIVISION

WESTERN RANGELAND )
CONSERVATION ASSOCIATION, et al. )
)
Plaintiffs, )
) No. 2:14-cv-00327-PMW
v. )
) Judge Paul M. Warner
SALLY JEWELL in her official capacity as )
Secretary, UNITED STATES DEPARTMENT )
of the INTERIOR, et al. )
)
Defendants. )

DECLARATION OF NEDA DEMAYO
I, Neda DeMayo, hereby declare as follows:
1. I have been a horsewoman since the age of four. I spent my childhood and young adult
life competing in jumping, competitive trail riding, cross country riding, and horse show events.
Although my education focused on natural healing and work in the film industry, my love of
horses remained. In 1997, I established Return to Freedom (RTF), a sanctuary for wild horses
in Lompoc, California. Return to Freedom began by relocating intact families (called bands)
directly from the range to our sanctuary. The original bands came from Fish and Wild Service
(FWS) lands at Hart Mountain and the Sheldon Wildlife Refuge. Currently, we have
approximately 400 wild horses, many living in their natural herds at the sanctuary. I have
directly managed the wild horses at our sanctuary for the past sixteen years.
2. In 2004, I launched the American Wild Horse Preservation Campaign (AWHPC) to
create a unified message and provide a national educational and advocacy platform on the issue
of protecting and preserving the wild horses of the West. Since that time, AWHPC has been
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supported by over fifty organizations and groups nationwide, which collectively represents well
over ten million people across America.
3. For more than a decade, Return to Freedom has provided leadership to help define a
viable direction for the preservation of Americas wild horses with the understanding of their
natural social behaviors and needs for long-term genetic viability and social well-being. RTF has
done this both through the management and educational programs at its sanctuary; advocacy
events; local, national and international media; and through the American Wild Horse
Preservation Campaign, which reaches over 90,000 active supporters and is featured prolifically
in national media. RTF has pioneered the implementation of solution-based, non-intrusive wild
horse management methods at its sanctuary, such as the use of native PZP, a non-hormonal birth
control method that preserves the wild horses natural behavior, and vasectomies for stallions in
non-reproducing groups. RTF also advocates for the Bureau of Land Management (BLM) to
apply these minimally invasive management methods on the range.
4. Because the horses at our sanctuary live in their family and social bands, we have been
able to educate the public to help them understand and appreciate Americas wild horses by
providing the opportunity, through observation, to see the diversity of Americas wild horse
herds and learn from the horses exhibiting their natural behaviors and living in their natural
family and social band structures. We hold educational events at our sanctuary, such as hiking
tours and photography clinics. Through these outreach efforts, RTF has increased public
awareness of wild horse issues and made progress toward shifting the wild horse management
paradigm.
5. RTFs members enjoy viewing, studying, and photographing wild horses in the West in
their natural habitats, expressing the natural behaviors that stem from the horses social
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interactions on the range. RTFs members travel to various areas throughout the West, including
the Swasey and Sulphur Springs Herd Management Areas, specifically for the purposes of
viewing, photographing, filming and writing about wild horses. Return to Freedom also
maintains two harem bands from the Sulphur Springs Herd Management Area as part of a
conservation program to protect threatened strains of old world Spanish Colonial horses that
have almost disappeared from our public lands.
6. RTF seeks to intervene in this action on behalf of the government, and to represent both
its organizational interests and those of its members. RTF believes the relief requested by the
Plaintiffs in this case would seriously impair RTFs and its members interests in preserving
genetically diverse and viable wild horses in herds surviving through natural selection on the
range in the West.
7. For example, Plaintiffs are requesting that this Court require BLM to (1) conduct
immediate round-ups of wild horses in excess of Appropriate Management Levels in one Herd
Area and several Herd Management Areas in Utah; and (2) conduct immediate round-ups of wild
horses in excess of Appropriate Management Levels on public lands managed by the BLM and
school section lands managed by the Utah School and Institutional Trust Lands Administration
(SITLA). Such relief would impair RTFs efforts to promote management of wild horses on
the range to preserve their natural social dynamics and protect their genetic viability.
Additionally, if the Court were to grant the requested relief, RTF would have to devote more of
its resources to these campaign efforts.
8. The requested relief would also impair the interests of RTFs members in continuing to
view, study, and photograph wild horses on the range in the West, including Utah.
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9. The existing parties do not adequately represent RTFs interests or the interests of its
members. Plaintiffs have brought this case in an effort to require BLM to remove wild horses
from the range in Utah. However, removing more wild horses from the range in Utah would
conflict with RTFs efforts to maintain the genetic viability of wild horse herds and preserve
their intricate social dynamics on the range. The requested relief, if granted, would also conflict
with our members interests in continuing to visit public lands in Utah to observe and photograph
these majestic animals in their natural habitat.
10. The Defendants also do not represent RTFs or its members interests. BLM is required
to balance the interests of private livestock grazing and wild horses on public lands. In my view,
BLM consistently prioritizes the interests of cattle grazing over the interests of wild horses. In
fact, in two other cases brought by organizations with interests similar to those of the Western
Rangeland Conservation Association and the other Plaintiffs in this case, organizations
representing those who wish to preserve wild horses on the range were granted intervention
because the government could not adequately represent their interests. See Order Granting
Motion to Intervene, Rock Springs Grazing Assn v. Salazar, Civ. No. 2:11-CV-00263-NDF (D.
Wyo. Nov. 2, 2011) (Attach. 1 to Roy Decl.); Order, Nev. Assn of Counties v. U.S. Dept of the
Interior, Civ. No. 3:13-cv-00712-MMD-WGC (D. Nev. Apr. 2, 2014) (Attach. 2 to Roy Decl.).






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Pursuant to 28 U.S.C. 1746, I declare under penalty of perjury that the foregoing is true and
correct:

_/s/ Neda DeMayo*________________
(* I certify that I have the signed original of this document which
is available for inspection during normal business hours by the
Court or a party to this action.)

Neda DeMayo

Date: June 5, 2014

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