1 fictitiously named Defendants is responsible in some manner for the acts and occurrences herein 2 alleged, and that Plaintiff’s injuries and damages were caused by such Defendants. 3 C. Relevant Non-Parties: Fossil Fuel Industry Associations 4 40. As set forth in greater detail below, each Defendant had actual knowledge that its 5 fossil fuel products were hazardous. Defendants obtained knowledge of the hazards of their 6 products independently and through their membership and involvement in trade associations. 7 41. Each Defendant’s fossil fuel promotion and marketing efforts were assisted by the 8 trade associations described below. Acting on behalf of the Defendants, the industry associations 9 engaged in a long-term course of conduct to misrepresent, omit, and conceal the dangers of 10 Defendants’ fossil fuel products. 11 a. The American Petroleum Institute (API): API is a national trade 12 association representing the oil and gas industry, formed in 1919. At least the following 13 Defendants and/or their predecessors in interest are and/or have been API members at times 14 relevant to this litigation: Chevron, Exxon, BP, Shell, ConocoPhillips, Hess, Anadarko, 15 Occidental, Repsol, Marathon, Devon, Encana, and Apache.10 16 b. The Western States Petroleum Association (WSPA): WSPA is a trade 17 association representing oil producers in Arizona, California, Nevada, Oregon, and Washington.11 18 Its members include, and at times relevant to this Complaint, have included, at least Defendants 19 Chevron, BP, ConocoPhillips, Shell, and Exxon.12 20 c. The American Fuel and Petrochemical Manufacturers (AFPM) is a 21 national association of petroleum and petrochemical companies. At relevant times, its members 22 included, but were not limited to, at least BP Petrochemicals, BP Products North America, 23 Chevron U.S.A. Inc., CITGO Petroleum Corporation, Exxon Mobil Corporation, Occidental 24 25 26 27 10 American Petroleum Institute (API), Members, http://www.api.org/membership/members (accessed Nov. 5, 2018). WSPA, About, https://www.wspa.org/about (accessed Nov. 5, 2018). 12 Id. 11 28 SHER EDLING LLP COMPLAINT 25