3 A5: Yes, I am familiar with the petition and have contributed to the drafting of legal documents referenced throughout that support arguments found in the petition. Q6: How did you become familiar with said Petition? A6: CIEL is one of a several expert organizations approached to provide advice and support to the petitioners in conjunction with the filing of the original petition in 2015. Q7: Given your background and extensive experience in climate, energy, and human rights issues as mentioned in your brief bio and Curriculum Vitae (Annex “A” hereof), what can you say about the Petition, if any? A7: As an attorney working on issues of energy, environment and climate change for the last 15 years, this is a pivotal moment in the course of human rights and climate change. This petition is both a moral and legal plea to address climate change as one of the greatest threats to human rights of our time and an opportunity to uphold the rule of law where corporate actors that have contributed to climate change and knew about the foreseeable harms caused by climate change have a responsibility to respect human rights. Q8: The Petition, on page 43, mentions that, “in April 2016, CIEL released hundreds of new documents demonstrating that the oil industry was explicitly warned of climate risks in the 1960.”2 Can you confirm this? A8: Yes. CIEL compiled the documents and made them publicly available for the first time with the launch of the Smoke and Fumes website in April 2016. Q9: How was CIEL able to get hold of these documents, if you know? A9: The documents compiled through CIEL’s Smoke and Fumes website were gathered through the course of five years of original research undertaken by CIEL staff. A significant portion of the early period of this research was spent developing a substantial understanding of the early history of climate science in order to identify the distinct terminologies, debates and biological figures relevant to research during different time periods, and to researching the structure, technical and scientific capacity of the oil industry at relevant periods as presented by the industry itself and by informed observers. Building upon this foundation, the documents were gathered through publicly accessible but sometimes obscure sources, including through webbased archives, scholarly databases, digitized patent collections and search engines. Most documents remain publicly available on the internet and free of charge, although some documents are behind paywalls and a fee is 2 See: Center for International Environmental Law, Press Release, New Documents Reveal Oil Industry Knew of Climate Risks Decades Earlier Than Suspected; Suggest Coordinated Efforts to Foster Skepticism, 13 April 2016, available at: http://www.ciel.org/news/smoke-and-fumes/, last accessed on 13 March 2018.