1
Chemical Corporation, Phillips 66, Shell Chemical Company, and Total Petrochemicals &
2
Refining USA, Inc.13
d.
3
The Information Council for the Environment (ICE): ICE was formed
4
by coal companies and their allies, including Western Fuels Association and the National Coal
5
Association. Associated companies included at least Pittsburg and Midway Coal Mining
6
(Chevron),14 and Island Creek Coal Company (Occidental).
e.
7
The Global Climate Coalition (GCC): GCC was an industry group formed
8
to oppose greenhouse gas emission reduction policies and the Kyoto Protocol. It was founded in
9
1989 shortly after the first Intergovernmental Panel on Climate Change meeting was held, and
10
disbanded in 2001. Founding members included the National Association of Manufacturers, the
11
Edison Electric Institute, and the United States Chamber of Commerce. The GCC’s early
12
individual corporate members included Amoco (BP), API, Chevron, Exxon, Shell Oil, Texaco
13
(Chevron) and Phillips Petroleum (ConocoPhillips). During its existence, other members and
14
funders included ARCO (BP), the National Mining Association, and the Western Fuels
15
Association. The coalition also operated for several years out of the National Association of
16
Manufacturers’ offices.
17
III.
AGENCY
42.
18
At all times herein mentioned, each of the Defendants was the agent, servant,
19
partner, aider and abettor, co-conspirator, and/or joint venturer of each of the remaining
20
Defendants herein and was at all times operating and acting within the purpose and scope of said
21
agency, service, employment, partnership, conspiracy, and joint venture and rendered substantial
22
assistance and encouragement to the other Defendants, knowing that their conduct was wrongful
23
and/or constituted a breach of duty.
24
IV.
43.
25
26
JURISDICTION AND VENUE
This court’s personal jurisdiction over Defendants named herein is proper because
each Defendant maintains substantial contacts with California by and through its fossil fuel
27
28
SHER
EDLING LLP
13
14
AFPM, Membership Directory, https://www.afpm.org/membership-directory (accessed Nov. 5, 2018).
Hereinafter, parenthetical references to Defendants indicate corporate ancestry and/or affiliation.
COMPLAINT
26
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