Memorandum for the Petitioners| 7 of THE CASE In the Philippines, super typhoon Haiyan certainly needs no introduction. With sustained winds of 305 kph, a width spanning 595 km (approximately 25 times the length of EDSA2!), and storm surges up to five meters in height, Haiyan is etched in the country’s collective memory as the most devastating typhoon in modern history.” The damage it left in its wake amounted to trillions of pesos. Worse yet, locals say it claimed many more lives than the official death toll of 6,340,”3 and it displaced millions of people who are still rebuilding their lives to this very day. Extreme weather events do not have a single cause, as there are various contributing factors. Human-induced climate change exacerbates and increases the likelihood of more of these natural disasters, turning them into human-made disasters. The warming caused by carbon dioxide is increasing the intensity of extreme weather events. This has long been established by science.” The catastrophe brought on by Haiyan and by Habagat, typhoons Pablo, Sendong, and Ondoy, and other extreme weather events show the stark reality of climate change and its that the world is on the verge of we are already in the midst of Philippines are among those responsible. lethal repercussions. Where once it was said climate change, now there is no denying that a climate crisis, and island nations like the at greatest risk despite being the least Thus, on 22 September 2015 or almost four (4) years ago, Greenpeace Southeast Asia (Philippines), Philippine Rural Reconstruction Movement, and twelve (12) other non-profit human rights and environmental organizations -- along with eighteen (18) individuals who are mostly farmers, fisherfolks, workers, and concerned Filipino citizens who bear the brunt of the impacts of climate change -- filed this Petition against the respondent investor-owned coal, oil, gas, and cement companies named in Mr. Heede’s breakthrough research. > The investor-owned Carbon Majors have 2! Epifanio Delos Santos Avenue Jazul, L. (08 December 2013), Catastrophe by Numbers, Rappler, available at https://www.rappler.com/nation/45464-in-photos-catastrophe-by-the-numbers (last accessed on 12 September 2019). Also see Effects of Typhoon Yolanda (Haiyan), p. 3, available at http://www.ndrrmc.gov.ph/attachments/article/1 329/Effects_of_Typhoon_YOLANDA_(HAIYAN) SitRep _No_10_10NOV2013_0600H.pdf (last accessed on 12 September 2019). 3 Sison, Jr., B. (05 January 2015), Yolanda death toll as high as 15,000, priest says, available at https://www. philstar.com/headlines/20 15/0 1/05/1409522/yolanda-death-toll-high-15000-priest-says (last accessed on 12 September 2019). Also see Effects of Typhoon Yolanda (Haiyan), p. 3, supra note 22. 24 See Part V (A to C): Material Facts as Established by Evidence and Part VIII: Arguments and Discussion sections of this memorandum for more elucidation. 25 See Exhibit “UUUU” to “UUUU- 103,” Exhibit “VVVV" to “VVVV-14,” Exhibit “TTTT” to “TTTT-1,” and Exhibit “TTTT-A,” supra note 18.

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