Shell Oil Company v. Greenpeace, Inc.

Filing 6

First MOTION for Temporary Restraining Order Motion for Temporary Restraining Order and Preliminary Injunction (Rule 65) by Shell Oil Company. (Attachments: # 1 Proposed Order [Proposed] Order Granting Motion for Temporary Restraining Order & Preliminary Injunction)(Leppo, Jeffrey)

James E. Torgerson (Bar No. 8509120)
Jeffrey W. Leppo (Bar No. 0001003)
Ryan P. Steen (Bar No. 0912084)
STOEL RIVES LLP
510 L Street, Suite 500
Anchorage, AK 99501
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiff

STOEL RIVES LLP

510 L Street, Suite 500, Anchorage, AK 99501
Main [phone]
Fax [phone]

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ALASKA
SHELL OIL COMPANY, a Delaware
corporation,

Case No.: 3:12-cv-00042-SLG
Plaintiff,

v.

MOTION FOR TEMPORARY
RESTRAINING ORDER AND
PRELIMINARY INJUNCTION (RULE
65)

GREENPEACE, INC., a California
corporation, and JOHN and JANE DOES 1-20,
Defendants.
Pursuant to Rule 65 of the Federal Rules of Civil Procedure, Plaintiff Shell Oil Company
(“Shell”) moves for immediate entry of a temporary restraining order in the form attached hereto
as the [Proposed] Order Granting Temporary Restraining Order and for entry of preliminary and
permanent injunctive relief for the purpose of avoiding irreparable harm to Shell that will be
caused by Defendants’ (collectively, “Greenpeace”) unlawful acts.

Shell requests that the

temporary restraining order remain in place until such time as the Court has ruled on the request
for a preliminary injunction. This motion is supported by the legal memorandum filed herewith,
the declarations of Mark Duplantis, Joseph Leone and Peter Scott, and the exhibits thereto.
MOT. FOR TRO & PRELIMINARY INJUNCTION (RULE 65)
Shell Oil Company v. Greenpeace, Inc., et al.
Page 1 of 2

DATED: February 27, 2012
STOEL RIVES LLP

By: s/ Jeffrey W. Leppo
JAMES E. TORGERSON
(BAR NO. 8509120)
JEFFREY W. LEPPO
(BAR NO. 0001003)
RYAN P. STEEN
(BAR NO. 0912084)

STOEL RIVES LLP

510 L Street, Suite 500, Anchorage, AK 99501
Main [phone]
Fax [phone]

Attorneys for Plaintiff

CERTIFICATE OF SERVICE
I hereby certify that on the 27th of February, a copy of the foregoing MOTION FOR
TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION (RULE 65) was
served on the following parties via hand-delivery and regular U.S. mail:
Greenpeace, Inc.
125 Christensen Drive, Ste. 2
Anchorage, AK 99501
Greenpeace, Inc.
475 Katlian Street
Sitka, AK 99835
Greenpeace, Inc.
75 Arkansas Street, Ste. 1
San Francisco, CA 94107

s/ Jeffrey W. Leppo
Jeffrey W. Leppo

71297593.1 0079498-00001

MOT. FOR TRO & PRELIMINARY INJUNCTION (RULE 65)
Shell Oil Company v. Greenpeace, Inc., et al.
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