Memorandum for the Petitioners | 50 Association v. Chevron Corp. et al.).'°* He explained that there was a “scientific consensus on the potential for large future climatic response to increased COz levels.”!*3 Moreover, he mentioned that there was “strong empirical evidence” that fossil fuel combustion was causing climate change.'™4 5.70. Dr. Laurman provided insights on climate modeling, including a foreseeable temperature rise of 2.5°C by 2038 resulting in “major economic consequences” and 5°C rise by 2067 resulting in “globally catastrophic effects.”!” 1. In the early 1980s, scientists from respondent Exxon recognized the scientific consensus on climate change, warned of potentially catastrophic effects, and highlighted the opportunities to act 5.71. On 02 September 1982, Roger Cohen, Director of Exxon’s Theoretical and Mathematical Sciences Laboratory, communicated the findings of internal corporate research in climate modeling. Cohen wrote about the “unanimous agreement in the scientific community” regarding the effects of a significant temperature increase, and he noted that the results of their research are “in accord with the scientific consensus on the effect of increased atmospheric CO2 on climate.” !% He stated that Exxon had a responsibility to publish its research in scientific literature because to do otherwise would be “a breach of Exxon’s public position and ethical credo on honesty and integrity.”!°7 5.72. A month later, on 12 November 1982, an Exxon briefing on “CO? ‘Greenhouse Effect’” was widely circulated to Exxon’s management. The briefing clearly communicated that “[m]itigation of the ‘greenhouse effect’ would require major reductions in fossil fuel combustion.”'"8 The briefing ‘2 See Annex “B” hereof, Pacific Coast Federation of Fishermen’s Association v. Chevron Corp. et al., supra note 184, p. 42, citing American Petroleum Institute, AQ-9 Task Force Meeting Minutes (18 Mach 1980), available at https://insideclimatenews.org/documents/aq-9-task-force-meeting-1980, attachment B (last accessed on 12 September 2019). AQ-9 refers to the “COz and Climate” Task Force. 193 194 i 195 Td. 16 Id., p. 45, citing Cohen, R. W. (1982), Memo to A. M. Natkin, Office of Science and Technology, Exxon Corporation, Linden, N. J., USA., pp. 1-2; available at http://www.climatefiles.com/exxonmobil/1982exxon-memo-summarizing-climate-modeling-and-co2-greenhouse-effect-research/ (last accessed 12 September 2019); Also see: Exhibit “MMMMM” to “MMMMM-3.” '°7 Id., p. 45, citing Cohen, R. W. (1982), Memo to A. M. Natkin, Office of Science and Technology, Exxon Corporation, Linden, N. J., USA, p. 3, supra note 196. '8 Glaser, M.B., (12 November 1982), Exxon Memo to Management about “COz ‘Greenhouse’ Effect,” Exxon Research and Engineering Co., p. 2, available at