Memorandum for the Petitioners | 49 5 .66 . As pointed out in the Pacific Coast Federation of Fishermen’s Association v. Chevron Corp. et al (Annex “B” hereof ), a climate lawsuit against many of the respondents herein, Exxon scientists pushed for additional research generated by scientists working for the fossil fuel industry: We should determine how Exxon can best participate in all these [atmospheric science research] areas and influence possible legislation on environmental controls. It is important to begin to anticipate the strong intervention of enviromnental groups and be prepared to respond with reliable and credible data. It behooves [Exxon] to start a very aggressive defensive program .. . , 189 (Emphasis supplied) r r 5.67. Exxon executives, and other respondents herein, were presented with this type of research throughout the 1970s, yet it appears that they actively chose to defend their climate polluting business models despite the scientific warnings and recommendations pointing to the need to transition out of fossil fuels. D. 4. By the 1980s, the fossil fuel industry knew there was broad scientific consensus that climate change was real, was caused by fossil fuel consumption, and would have significant impacts the on environment and human rights 5.68. By the 1980s, the fossil fuel industry understood that climate change was real, was caused by the burning of fossil fuels, and “would have significant impacts on the environment and human health » 190 The industry therefore, had actual knowledge of the potential human rights harms that would result from the use of their products. . , 5.69. Members of the oil industry were warned again when Dr. John Laurman,191 a consultant hired by API, gave a presentation entitled, “The CO2 Problem” (cited in Annex “B,” Pacific Coast Federation of Fishermen’s Pacific Coast Federation of Fishermen' s Association v. Chevron Corp. et ai 9 supra note 184, p. 31. citing Shaw, H. ( 19 November 1979), Research in Atmospheric Science [Memo to H. N. Weinberg ], p. 1 , available at https://insideclimatenews.org/sites/default/fiIes/documents/Probable%20Legislation %20Memo%20(1979). pdf (last accessed on 12 September 2019). 190 See Amicus Brief filed by Robert Brulle, Center for Climate Integrity, Justin Farrell , Benjamin Franta, Stephan Lewandowsky, Naomi Oreskes, and Geoffrey Supran in support of appellees and affirmance County of San Mateo v. Chevron Corp., p. 14, available at https://www.sheredling.com/wp~ content/uploads/2019/01/Center-for-Climate-Integrity-Amicus.pdf (last accessed 12 September 2019). 191 Dr. John Laurman appears to have been associated with Stanford University in 1977. Elliot, W., et al. ( 1979 ), Carbon dioxide effects: research and assessment program. Workshop on the global effects of carbon dioxide from fossil fuels, p. 120, available at https://www.osti .gov/servlets/purl/6385084 ( last accessed on 12 September 2019). 189 .