Memorandum for the Petitioners | 28 intergovernmental organization. The IPCC’s findings serve as a starting point for the COP decisions, which are taken by the signatories to the UN Climate Change Convention during their climate conferences. Similarly, the Dutch and European decision-making processes pertaining to the climate policies to be pursued are also based on the climate science findings of the IPCC. The court — and also the Parties — therefore considers these findings as facts.*2 5.11. Notably, respondent Chevron, through one of its lawyers, Avi Garbow, appears to have admitted that IPCC findings are facts in an article about climate lawsuits: “Chevron is not going to be engaging in a debate on climate change science,” said Avi Garbow, co-chairman of the Environmental Litigation and Mass Tort Practice Group at Gibson, Dunn & Crutcher LLP and a Chevron lawyer. He’s administration also who a former defended the official Clean in the Power Obama Plan general counsel to then-U.S. EPA chief Gina McCarthy. as The company will “anchor its presentation” on the Fifth Assessment Report from the U.N. Intergovernmental Panel on Climate Change (IPCC), issued in 2014, he said on a call with reporters Monday. “Chevron’s neither going understate degrees of confidence. going to present the conclusions of Chevron thinks that’s the best and the of responding to the court’s tutorial said. counties San in Francisco California, and are Oakland, suing to overstate nor Chevron’s simply the IPCC because most accurate way request,” Garbow along Chevron, with BP several PLC, ConocoPhillips, Exxon Mobil Corp. and Royal Dutch Shell PLC for allegedly downplaying the threat of climate change. The local governments claim that the oil majors knew years ago that the emissions related to their products could cause sea-level rise and contribute to other damages.*} (Emphasis supplied) 5.12. The IPCC issues comprehensive Assessment Reports about knowledge on climate change, its causes, potential impacts and response options, the latest one being the IPCC Fifth Assessment Report (“IPCC ARS”) and the next one being the Sixth Assessment Report (IPCC AR6”). 82 Ibid. * Mulkern, A. (21 March 2018), Chevron Will Stick to IPCC Findings in Landmark Climate Change Trial, available at https://www.scientificamerican.com/article/chevron-will-stick-to-ipcc-findings-in-landmarkclimate-change-trial/ (last accessed on 12 September 2019).

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