Case 1:16-cv-01534-JEB Document 107 Filed 02/10/17 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
STANDING ROCK SIOUX TRIBE,

Case No. 1:16-cv-1534-JEB

Plaintiff,
and
CHEYENNE RIVER SIOUX TRIBE,
Plaintiff-Intervenor,
v.
U.S. ARMY CORPS OF ENGINEERS,
Defendant-Cross
Defendant,
and
DAKOA ACCESS, LLC,
Defendant-IntervenorCross Claimant.

STANDING ROCK SIOUX TRIBE’S JOINDER IN MOTION FOR TEMPORARY
RESTRAINING ORDER
Plaintiff Standing Rock Sioux Tribe (“Tribe”) hereby respectfully joins the motion filed
by intervenor Cheyenne River Sioux Tribe seeking a temporary restraining order (“TRO”) on
construction pending resolution of the legal issues in this case. The Tribe’s joinder is supported

(No. 1:16-cv-1534-JEB)

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Earthjustice
705 Second Ave., Suite 203
Seattle, WA 98104
(206) 343-7340

 Case 1:16-cv-01534-JEB Document 107 Filed 02/10/17 Page 2 of 3

by the Second Declaration of Standing Rock Chairman Dave Archambault, II, submitted
herewith. The Tribe has amended its complaint to include legal claims under the Religious
Freedom Restoration Act and First Amendment Right to Free Exercise of Religion. See ECF
106-1. As explained in the Second Archambault Declaration, the Tribe and its members—like
the Cheyenne River Sioux Tribe and its members—are irreparably harmed by ongoing
construction at the Lake Oahe crossing site, and are entitled to emergency injunctive relief
pending resolution of the Tribe’s legal claims on the merits. Based on the schedule
communicated to the Court during the status conference on February 6, 2017, the Tribe believes
that the merits claims can be resolved prior to the start of pipeline operations and intends to file
an expedited motion for partial summary judgment on the key issues expeditiously.
Accordingly, this motion for a TRO seeks to enjoin ongoing construction until the merits claims
are resolved.
Dated: February 10, 2017

Respectfully submitted,

/s/ Jan E. Hasselman
Patti A. Goldman, DCB # 398565
Jan E. Hasselman, WSBA # 29107
(Admitted Pro Hac Vice)
Stephanie Tsosie, WSBA # 49840
(Admitted Pro Hac Vice)
Earthjustice
705 Second Avenue, Suite 203
Seattle, WA 98104
Telephone: (206) 343-7340
pgoldman@earthjustice.org
jhasselman@earthjustice.org
stsosie@earthjustice.org
Attorneys for Plaintiff

(No. 1:16-cv-1534-JEB)

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Earthjustice
705 Second Ave., Suite 203
Seattle, WA 98104
(206) 343-7340

 Case 1:16-cv-01534-JEB Document 107 Filed 02/10/17 Page 3 of 3

CERTIFICATE OF SERVICE
I hereby certify that on February 10, 2017, I electronically filed the foregoing Standing
Rock Sioux Tribe’s Joinder in Motion for Temporary Restraining Order with the Clerk of the
Court using the CM/ECF system, which will send notification of this filing to the attorneys of
record and all registered participants.

/s/ Jan E. Hasselman
Jan E. Hasselman

(No. 1:16-cv-1534-JEB)

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Earthjustice
705 Second Ave., Suite 203
Seattle, WA 98104
(206) 343-7340