9 A19: The report’s key findings are that (1) fossil fuel companies had the knowledge and expertise to understand both the threat of climate change and the impact that continued production, marketing and sale of fossil fuel products would have on climate change and the resulting climate change impacts and (2) instead of actively warning the public and taking action to prevent harm they continued and increased the production and sale of fossil fuels and (3) did so while actively sowing doubt and confusion about the reality of climate change among the general public. Q20: On page 26 of the report, Appendix I enumerates fifty-one (51) investorowned carbon majors, ranked by cumulative emissions contribution. Have any of these investor-owned companies, all respondents herein3, reached out to your organization after the release of this report in November 2017? A20: CIEL has not been directly contacted by any of the enumerated companies after the release of the Smoke & Fumes Synthesis report in November 2017.4 Q21: Do you know if this report has been used in any legal proceeding? And if so, how? A21: Globally, a number of lawsuits have been filed in civil court in the United States by plaintiffs that have been harmed by climate change and seek redress and remedy from several of the Carbon Majors for their contributions to climate change. Evidence gathered in CIEL’s Smoke and Fumes research have been cited in legal complaints and other documents in the following cases:  City of Richmond v. Chevron et al., C-18-00055, Superior Court of the State of California, County of Santa Cruz (January 22, 2018).  New York City v. BP, Chevron, ConocoPhillips, Exxon Mobil, Shell, 18-cv- 182, (U.S. District Court for the Southern District of New York) (Filed 01/09/18).  County of Santa Cruz v. Chevron et al., 17-CV-03242, Superior Court of the State of California, County of Santa Cruz (December 20, 2017).  City of Santa Cruz v. Chevron et al., 17-CV-03243, Superior Court of the State of California, County of Santa Cruz (December 20, 2017).  Oakland v. BP, Chevron Corp., Exxon Mobil Corp., Royal Dutch Shell PLC and ConocoPhillips, RG-17-875-889, Superior Court of the State of California, Counties of San Francisco and Alameda (Filed 09/19/17) removed to U.S. District Court for the Northern District of California (No. C 17-06011 WHA).  San Francisco v. BP, Chevron Corp., Exxon Mobil Corp., Royal 3 Due to mergers and acquisitions, the total number was reduced to forty-seven (47) when the Petition was filed in September 2015. 4 On November 9, 2016, Carroll Muffett—CIEL’s President and lead researcher and co-author on the report—was personally subpoenaed by ExxonMobil in a suit the company has filed against the Attorneys General of New York and Massachusetts. The subpoena seeks an array of documents related to CIEL’s research, writings and advocacy with respect to climate change. It does not explicitly reference Smoke & Fumes.

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