e. 1 2 are collectively referred to as “Shell.” f. 3 Shell does substantial fossil fuel product-related business in California, and 4 a substantial portion of its fossil fuel products are extracted, refined, transported, traded, 5 distributed, marketed and/or sold in California. Among other endeavors, Shell operates a 6 petroleum refinery in Martinez, Contra Costa County, California; operates a distribution center in 7 Carson, California; and produces heavy oil and natural gas within the state. Shell also owned and 8 operated a refinery in Wilmington (Los Angeles), Los Angeles County, California, from 1998 to 9 2007, and a refinery in Bakersfield, Kern County, California, from 2001 to 2005. Shell also 10 11 operates hundreds of Shell-branded gas stations in California. 27. 12 Citgo Petroleum Corporation (“Citgo”) a. Citgo is a direct, wholly owned subsidiary of PDV America, Incorporated, 13 which is a wholly owned subsidiary of PDV Holding, Incorporated. These organizations’ ultimate 14 parent is Petróleos de Venezuela, S.A. (“PDVSA”), an entity wholly owned by the Republic of 15 Venezuela that plans, coordinates, supervises and controls activities carried out by its subsidiaries. 16 Citgo is incorporated in the State of Delaware and maintains its headquarters in Houston, Texas. 17 18 b. Citgo controls and has controlled companywide decisions about the quantity and extent of fossil fuel production and sales, including those of its subsidiaries. 19 c. Citgo controls and has controlled companywide decisions related to climate 20 change and greenhouse gas emissions from its fossil fuel products, including those of its 21 subsidiaries. 22 d. Citgo and its subsidiaries are engaged in the refining, marketing, and 23 transportation of petroleum products including gasoline, diesel fuel, jet fuel, petrochemicals, 24 lubricants, asphalt, and refined waxes. 25 SHER EDLING LLP Defendants Royal Dutch Shell PLC and Shell Oil Products Company LLC e. Citgo is registered to do business in the State of California and has 26 designated an agent for service of process in California. Citgo further does substantial fossil fuel 27 product-related business in California, and a substantial portion of its fossil fuel products are 28 extracted, refined, transported, traded, distributed, marketed, and/or sold in California. For COMPLAINT 14