May 14, 2015 - I am writing you on behalf of Shell Offshore, Inc. and Shell Gulf of Mexico, Inc. (collectively. "Shell")
STOEL I". I \ r r~ ^
600 Universlly Street. Suite 3600
Seattle, Washington 98101
|\ I V t J
main 206.624.0900 fax 206.386.7SO0 www.siocl.com
ATTORNEYS AT LAW
Ryan P. Steen
Direct (206) 386-7610
May 14,2015
[email protected]
Greenpeace International Ottho Heldrlngstraat 5 1066 AZ Amsterdam The Netherlands MA^ Arctic Sunrise
Captain Ame Sorensen or Current Vessel Master Re:
Notice of Preliminary Injunction - Greenpeace Direct Action Campaign Against Shell's Alaska Exploration Activities and Assets
Dear Greenpeace International, and Captain Ame Sorensen or Current Vessel Master:
I am writing you on behalf of Shell Offshore, Inc. and Shell Gulf of Mexico, Inc. (collectively "Shell") to provide you with notice of the Order Granting Motion for Preliminary Injunction ("Preliminary Injunction") entered on May 8, 2015 against Greenpeace, Inc., its officers, agents, servants, employees, and attorneys ("Greenpeace USA"), and all others who are in active concert or participation with Greenpeace USA (collectively "Greenpeace"), by the United States District Court in Anchorage, Alaska.
A copy ofthe Preliminary Injunction is attached. Please note that it prohibits Greenpeace from taking unlawful actions against the vessels Polar Pioneerand Noble Discoverer, as well as ^ supporting vessels (as listed in the Preliminary Injunction), while on the high seas, within the Exclusive Economic Zone of the United States ("EEZ") (i.e., within 200 miles of the baseline shore),
in United States navigable and territorial waters, and when located in port within the United States. In addition, the Preliminary Injunction establishes safety zones around the Polar Pioneer, the Noble Discoverer, and supporting vessels when underway on the high seas, within the EEZ and within the territorial waters of the United States, as well as during drilling operations and while
completing drilling operations in the Chukchi Sea. The Preliminary Injunction prohibits Greenpeace USA and all others who are in active concert or participation with it from entering into these safety zones. Finally, the Preliminary Injunction establishes airspace safety zones around the Noble Discoverer, Polar Pioneer, and other specified vessels, and prohibits the use of drones
anywhere within the Burger Prospect in the Chukchi Sea from June 25, 2015 through October 31, 2015, except as expressly allowed by courtorder. The full termsof the court's injunction orderare detailed in the attachment to this letter.
Sincerely,
Ryan IvanT/Steen
Attachment: Order Granting Motion for Preliminary Injunction
79028894.10079498-00003
Alaska Minnesota and
California
Oregon
Utah
Washington.
Idaho Washington D.C.
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ALASKA
SHELL OFFSHORE, INC., a Delaware corporation, and SHELL GULF OF
MEXICO INC., a Delaware corporation. Plaintiffs, V.
GREENPEACE. INC., a California
corporation, and JOHN and JANE DOES
Case No. 3:15-cv-00054-SLG
1-20, Defendants.
ORDER GRANTING MOTION FOR PRELIMINARY INJUNCTION
Plaintiffs Shell Offshore, Inc. and Shell Gulf of Mexico, Inc. (collectively "Shell")
filed a Motion for a Temporary Restraining Order and a Preliminary Injunction on April 8,
2015.'' After a hearing on April 10, 2015 at which both Shell and Greenpeace, Inc. ("Greenpeace USA") participated, this Court entered a Temporary Restraining Order
("TRO") on April 11, 2015 which enjoined Greenpeace USA and those acting in concert
with it from engaging in certain illegal or tortious acts against three vessels, the Blue Marlin, the Noble Discoverer, and the Polar Pioneer, an arctic drilling vessel that had
been loaded on the Blue Marlin.^ The TRO also established safety zones around each of those vessels.
^ Docket 17 (Preliminary Injunction Mot.). 2 Docket 34 (Order re TRO).
Case 3:15-cv-00054-SLG Document 111 Filed 05/08/15 Page 1 of 19
