TABLE OF CONTENTS (Memorandum of the Petitioners dated 18 September 2019) I. Prefatory Statement 2 II. The Case 7 III. The Proceedings 9 IV. The Honorable Commission’s Authority to Investigate and Grant the Reliefs prayed for by the Petitioners 20 V. Material Facts as Established by Evidence 25 A. Basic climate science and understanding climate change in a global context B. IPCC reports as material facts C. Impacts felt and projected can be attributable to specific human activities D. Respondent Carbon Majors’ knowledge of climate risks and actions and/or inactions in light of foreseeable climate harms 25 Brief Statement of Petitioners’ Position 67 A. Climate science B. The human rights harms being suffered by the petitioners and the Filipinos C. Respondent Carbon Majors’ knowledge of foreseeable climate risks and harms to people D. Respondent Carbon Majors’ responsibility to respect and protect human rights under international law and agreements E. Respondents’ moral and legal responsibility under general principles of tort and human rights law 67 68 VI. VII. Issues 27 38 41 68 70 71 72 A. Whether climate change is impacting the Philippines B. Whether climate change results in – and/or threatens -- the impairment, infringement, abuse, and/or violation of the human rights of Filipinos C. Whether respondent Carbon Majors significantly contribute to climate change D. Whether respondent Carbon Majors’ actions and/or inactions are linked to the climate change impacts occurring and/or threatening to occur in the Philippines E. Whether respondent Carbon Majors are responsible, under international laws and agreements and domestic laws to respect and protect the human rights of Filipinos in the context of climate

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