Because the cognovit note deprives the debtor of notice that he is being sued, and of his right to a hearing, courts demand "clear and convincing evidence" that the written waiver was "voluntary, knowing, and intelligently made." Overmyer, at 185-86, 187 (assuming without deciding that the same standard of proof applies to waiver in the civil context as in criminal cases, and citing criminal cases); Leonard v. Clark, 12 F.3d 885, 889-90 (9th Cir. 1993) (citing Overmyer, 405 U.S. at 187; Davies v. Grossmont Union High Sch. Dist., 930 F.2d 1390, 1394 (9th Cir.), cert. denied, 111 S.Ct. 2892 (1991)). The question of waiver is factual.

Because we conclude that Public Lands Council has standing, we need not consider whether American Farm Bureau Federation also has standing. See Leonard v. Clark, 12 F.3d 885, 888 (9th Cir. 1993). Intervenors also challenge Plaintiffs' standing to assert their claims.

NRDC, Amigos Bravos, and Powder River have demonstrated, to this Court's satisfaction, association standing under the broad standing requirement applicable here. See Leonard v. Clark, 12 F.3d 885, 888 (9th Cir. 1994) (explaining that once the court determines that one of the plaintiffs has standing, it need not decide the standing of the others). V. STANDARD OF REVIEW

The Court need not consider whether NEC possesses standing because Alliance satisfies standing for all claims that Plaintiffs have asserted. See Leonard v. Clark, 12 F.3d 885, 888 (9th Cir. 1993).

Because the Court is satisfied that these Plaintiffs have standing, it need not reach the question of whether Mr. Doe #1 alleges standing in the FAC. See Leonard v. Clark, 12 F.3d 885, 888 (9th Cir. 1993), as amended (Mar. 8, 1994) ("The general rule applicable to federal court suits with multiple plaintiffs is that once the court determines that one of the plaintiffs has standing, it need not decide the standing of the others.")., Where, as here, Plaintiffs

While WEG could seek to appeal this court's order, if it did so independently of plaintiff WWP then WEG's independent standing would be considered at that juncture. Cf. Leonard v. Clark, 12 F.3d 885, 888 (9th Cir.1993) (finding that the district court's determination that one organizational plaintiff had standing normally would end the standing inquiry, but because the appellate court determined on appeal that the organizational plaintiff had waived its claims, the appellate court considered the standing of the other individual plaintiffs). Finally, the court denies BLM's motion to strike WWP's extra-record declarations, which WWP claims are submitted to supplement the record on standing. Courts may consider such declarations “not in order to supplement the administrative record on the merits, but rather to determine whether petitioners can satisfy a prerequisite to this court's jurisdiction.”

While WEG could seek to appeal this court's order, if it did so independently of plaintiff WWP then WEG's independent standing would be considered at that juncture. Cf. Leonard v. Clark, 12 F.3d 885, 888 (9th Cir. 1993) (finding that the district court's determination that one organizational plaintiff had standing normally would end the standing inquiry, but because the appellate court determined on appeal that the organizational plaintiff had waived its claims, the appellate court considered the standing of the other individual plaintiffs). Finally, the court denies BLM's motion to strike WWP's extra-record declarations, which WWP claims are submitted to supplement the record on standing. Courts may consider such declarations "not in order to supplement the administrative record on the merits, but rather to determine whether petitioners can satisfy a prerequisite to this court's jurisdiction."

Given this conclusion, the Court need not address the standing of other Plaintiffs. “The general rule applicable to federal court suits with multiple plaintiffs is that once the court determines that one of the plaintiffs has standing, it need not decide the standing of the others.” Leonard v. Clark, 12 F.3d 885, 888 (9th Cir.1993); see W. Watersheds Project v. Kraayenbrink, 632 F.3d 472, 484 n. 7 (9th Cir.2011). B. Merits.

The nonmoving party cannot carry their burden by relying solely on the facts alleged in their pleadings. Leonard v. Clark, 12 F.3d 885, 888 (9th Cir. 1994). Instead, their response, by affidavits or as otherwise provided in Rule 56, must designate specific facts showing there is a genuine issue for trial.