From:

Subject:
Date:
To:
Cc:

Douglas Grandt answerthecall@icloud.com

Tell the truth, the whole truth, and nothing but the truth
December 31, 2016 at 9:18 AM
Rex Tillerson Rex.W.Tillerson@ExxonMobil.com, Darren W. Woods Darren.W.Woods@ExxonMobil.com
Suzanne M. McCarron Suzanne.M.McCarron@ExxonMobil.com, Malcolm Farrant Malcolm.A.Farrant@ExxonMobil.com,
Max Schulz max.schulz@exxonmobil.com

..

Dear Rex Tillerson,

..

Today is your last day as CEO and Chairman. Your legacy as CEO has been established. You
still have an opportunity to fix your legacy, and I am rooting for your honest atonement.
..

This morning, I learned that you will be testifying in the Our Childrens Trust case soon
(KELSEY CASCADIA ROSE JULIANA; XIUHTEZCATL TONATIUH M., through his Guardian
Tamara Roske-Martinez; et al. Plaintiffs, v. The UNITED STATES OF AMERICA; BARACK
OBAMA, in his official capacity as President of the United States; et al., Federal Defendants).
..

Tillerson called to testify on climate issues

By Daniel J. Graeber | Dec. 30, 2016 | Bit.ly/UPI30Dec16
..

EUGENE, Ore., Dec. 30 (UPI) -- Exxon Mobil CEO and U.S. secretary of state nominee
Rex Tillerson should testify before the inauguration on his climate change knowledge,
lawyers said.
..

Lawyers representing more than a dozen U.S. teens called on Tillerson to testify in a
case arguing there is a "fundamental constitutional right to a climate system capable of
sustaining human life."
..

Up to now, your legacy is one of deceit, obfuscation, subterfuge and hypocrisy, but you can
redeem yourself if you tell the truth, the whole truth and nothing but the truth. We expect
nothing less than full candor and transparency from youespecially if your hope to be
confirmed as Secretary of State.
..

Sincerely yours,
..

Doug Grandt

For Immediate Release

December 29, 2016
Contacts:
Julia Olson, 415-786-4825, Julia@ourchildrenstrust.org
Philip Gregory, 650-697-6000, pgregory@cpmlegal.com
To set up interviews with youth plaintiffs, contact:
Meg Ward, 503-341-8590, meg@ourchildrenstrust.org

Youth Seek to Obtain Testimony from Rex Tillerson

in Constitutional Climate Lawsuit
Today, attorneys representing 21 young people in their federal climate lawsuit, sought to obtain
testimony from Rex Tillerson, CEO of ExxonMobil and President-elect Trumps candidate for
Secretary of State. The Notice seeks Tillersons testimony by way of deposition on January 19,
2017 in Dallas, TX. The Notice was served on Sidley Austin, the law firm representing three
defendants in the constitutional climate lawsuit: American Petroleum Institute (API), National
Association of Manufacturers (NAM), and American Fuel & Petrochemical Manufacturers
(AFPM). In his deposition, Tillerson will be asked questions about his knowledge relevant to the
youths claims that their constitutional rights have been violated.
As CEO of ExxonMobil, Tillerson has unique personal knowledge of the fossil fuel industrys
historical relationship with the federal government. Tillerson and Exxon also have been
important leaders in API, NAM, and AFPM the trade associations that joined the federal
climate lawsuit as defendants. Tillerson serves on the board of API and he and other Exxon
executives also serve on the board of NAM. The youth plaintiffs seek to prove these trade
associations have known about the dangers of climate change since the 1960s and have
successfully worked to prevent the government from taking the necessary steps to fully address
climate change.
Alex Loznak, 19-year-old plaintiff and student at Columbia University, stated:
I was shocked when students at Columbia Journalism School uncovered ExxonMobils
deep knowledge of climate change as early as the 1970s. Whats even more disturbing is
that the Federal Government firmly knew about climate change in the 1950s. I look
forward to working on our research team in the months ahead to establish the depth and
breadth of the government and industrys knowledge of climate danger before trial.

Rex Tillerson is one of the most knowledgeable executives in the fossil fuel world on the role of
his industry alongside our federal government in causing climate change and endangering my
youth plaintiffs and all future generations, said Julia Olson, attorney for the youth plaintiffs and
executive director of Our Childrens Trust. We intend to use his deposition to uncover his and
others culpability, on behalf of these defendants.
The young plaintiffs sued the federal government for violating their constitutional rights to life,
liberty, and property, and their rights to vital public trust resources, by locking in a fossil-fuel
based national energy system for more than five decades with full knowledge of the extreme
dangers it posed.
We believe the evidence shows both ExxonMobil and the fossil fuel industry knew about the
threat to our country posed by climate change and worked to encourage the federal government
to enable emissions of more greenhouse gas, declared Philip Gregory, counsel for the plaintiffs
and a partner with Cotchett, Pitre & McCarthy in Burlingame, CA. Mr. Tillersons testimony is
crucial to understanding what the fossil fuel industry did to prevent the government from fully
addressing this problem. The youth of America need to know the truth on how companies such
as ExxonMobil continue to use the government to cause horrific harm to our nations most
vulnerable people.
Through a federal court order issued on November 10, 2016, the young plaintiffs have already
secured the following critical legal rulings in this case:
1. There is a fundamental constitutional right to a climate system capable of sustaining
human life.
2. The federal government has fiduciary public trust responsibilities to preserve natural
resources upon which life depends.
3. The youths requested remedy (ordering the development and implementation of a
national climate recovery plan based on a scientific prescription) is an appropriate
remedy if the court finds a violation of the youths constitutional rights.
A federal judge indicated that the case will be set for trial in the summer or fall of 2017. Among
the facts to be determined at trial are whether the federal governments systemic actions over the
past decades enabling climate change have violated the young plaintiffs constitutional rights.
This federal case is one of many related legal actions brought by youth in several states and
countries, all supported by Our Childrens Trust, seeking the adoption of science-based
prescriptions to stabilize the climate system.
Counsel for Plaintiffs include Philip L. Gregory, Esq. of Cotchett, Pitre & McCarthy of Burlingame, CA,
Daniel M. Galpern, Esq. of Eugene, OR, and Julia Olson, Esq., also of Eugene, OR.
Our Children's Trust is a nonprofit organization, elevating the voice of youth, those with most to lose, to
secure the legal right to a healthy atmosphere and stable climate on behalf of present and future

generations. We lead a coordinated global human rights and environmental justice campaign to
implement enforceable science-based Climate Recovery Plans that will return atmospheric carbon
dioxide concentration to below 350 ppm by the year 2100. www.ourchildrenstrust.org/
Earth Guardians is a Colorado-based nonprofit organization with youth chapters on five continents, and
multiple groups in the United States with thousands of members working together to protect the Earth,
the water, the air, and the atmosphere, creating healthy sustainable communities globally. We inspire
and empower young leaders, families, schools, organizations, cities, and government officials to make
positive change locally, nationally, and globally to address the critical state of the Earth.
www.earthguardians.org
###

JULIA A. OLSON (OR Bar 062230)

JuliaAOlson@gmail.com
WILD EARTH ADVOCATES
1216 Lincoln Street
Eugene, OR 97401
Tel: (415) 786-4825
DANIEL M. GALPERN (OR Bar 061950)
dan.galpern@gmail.com
LAW OFFICES OF DANIEL M. GALPERN
1641 Oak Street
Eugene, OR 97401
Tel: (541) 968-7164

JOSEPH W. COTCHETT
jcotchett@cpmlegal.com
PHILIP L. GREGORY (pro hac vice)
pgregory@cpmlegal.com
PAUL N. MCCLOSKEY
pmccloskey@cpmlegal.com
COTCHETT, PITRE & McCARTHY, LLP
San Francisco Airport Office Center
840 Malcolm Road
Burlingame, CA 94010
Tel: (650) 697-6000
Fax: (650) 697-0577

Attorneys for Plaintiffs

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON
EUGENE DIVISION

KELSEY CASCADIA ROSE JULIANA;

XIUHTEZCATL TONATIUH M., through
his Guardian Tamara Roske-Martinez; et al.
Plaintiffs,

Case No.: 6:15-cv-01517-TC

PLAINTIFFS NOTICE OF
DEPOSITION OF
REX TILLERSON

v.
The UNITED STATES OF AMERICA;
BARACK OBAMA, in his official capacity as
President of the United States; et al.,
Federal Defendants.

PLAINTIFFS NOTICE OF DEPOSITION OF REX TILLERSON

TO ALL PARTIES AND THEIR ATTORNEY OF RECORD:

PLEASE TAKE NOTICE that, pursuant to Rules 30 and 45 of the Federal Rules
of Civil Procedure, Plaintiffs Kelsey Juliana, et al., will take the deposition of Rex
Tillerson on January 19, 2017 at 10:00 a.m. at the Law Offices of Sidley Austin LLP,
2021 McKinney Avenue, Suite 2000, Dallas, TX 75201. If the deposition is not
completed on January 19, 2017, it will be continued from day to day, excluding Sundays
and holidays, until completed.
PLEASE TAKE FURTHER NOTICE that the deposition will be taken before a
notary public or other person authorized to administer oaths under applicable law, and
will be conducted pursuant to Federal Rule of Civil Procedure 30. Pursuant to Rule
30(b)(3) of the Federal Rules of Civil Procedure, Plaintiffs reserve the right to record the
deposition testimony by videotape and instant visual display. Plaintiffs reserve the right
to use the videotape deposition at the time of trial.
YOU ARE FURTHER NOTIFIED THAT the deponent is a representative and a
board member of one or more parties to this action. So far as is known to Plaintiffs, the
deponents address is as follows:
Rex Tillerson
ExxonMobil
5959 Las Colinas Boulevard
Irving, Texas 75039
The deponent is directed to produce and permit inspection and copying of the documents
and/ or objects specified in Attachment A to this notice at the time of deposition.
A list of all parties or attorneys for parties on whom this Notice of Deposition is
being served is shown on the accompanying Proof of Service.
Dated: December 28, 2016

s/ Philip L. Gregory
PHILIP L. GREGORY (pro hac vice)
COTCHETT, PITRE & McCARTHY, LLP
Attorneys for Plaintiffs

PLAINTIFFS NOTICE OF DEPOSITION OF REX TILLERSON

2

ATTACHMENT A
I.

DEFINITIONS
A.

As used herein, the term DOCUMENT means any kind of written,

graphic or recorded matter, however produced or reproduced, of any kind or description,

whether sent, received or neither, including drafts, originals, non-identical copies and
information stored magnetically, electronically, photographically or otherwise, and
including but not limited to, studies, papers, books, accounts, letters, diagrams, pictures,
drawings, photographs, correspondence, telegrams, cables, text messages, emails,
memoranda, notes, notations, work papers, intra-office and inter-office communications,
communications to, between and among employees, transcripts, minutes, orders, reports,
recordings or other documentation of telephone or other conversations, interviews,
committee meetings, departmental meetings, company meetings or other meetings,
affidavits, slides, statements, summaries, opinions, indices, analyses, publications,
questionnaires, answers to questionnaires, statistical records, ledgers, journals, lists, logs,
tabulations, charts, graphs, maps, surveys, sound recordings, data sheets, computer
printouts, tapes, discs, microfilm, all other records kept by YOU, and thing similar to any
of the foregoing, regardless of the title, author or origin.
B.

As used herein, the phrase REFERS, RELATES, REGARDS, OR

PERTAINS TO means containing, alluding to, responding to, commenting upon,

discussing, showing, disclosing, explaining, mentioning, analyzing, constituting,
comprising, evidencing, setting forth, summarizing or characterizing, either directly or
indirectly in whole or in part.
C.

As used herein, the term AMERICAN PETROLEUM INSTITUTE shall

refer to defendant American Petroleum Institute, and to all of its employees, agents,
officers, directors, representatives, consultants, affiliates, members, accountants, and
attorneys, including any PERSON who has served in any such capacity at any time.
PLAINTIFFS NOTICE OF DEPOSITION OF REX TILLERSON
3

D.

As used herein, the term NATIONAL ASSOCIATION OF

MANUFACTURERS shall refer to defendant National Association of Manufacturers,

and to all of its employees, agents, officers, directors, representatives, consultants,
affiliates, members, accountants, and attorneys, including any PERSON who has served
in any such capacity at any time.
E.

As used herein, the term AMERICAN FUEL & PETROCHEMICAL

MANUFACTURERS shall refer to defendant American Fuel & Petrochemical

Manufacturers, and to all of its employees, agents, officers, directors, representatives,
consultants, affiliates, members, accountants, and attorneys, including any PERSON who
has served in any such capacity at any time.
F.

As used herein, the term EXXONMOBIL shall refer to

EXXONMOBIL, and to all of its employees, agents, officers, directors, representatives,

consultants, affiliates, members, accountants, and attorneys, including any PERSON who
has served in any such capacity at any time.
G.

As used herein, the term INTERVENOR DEFENDANTS shall refer to

defendants AMERICAN PETROLEUM INSTITUTE, NATIONAL ASSOCIATION OF

MANUFACTURERS, AMERICAN FUEL & PETROCHEMICAL
MANUFACTURERS, and their members.
H.

As used herein, the term COMMUNICATION(S) means every manner

or method of disclosure, exchange of information, statement or discussion between or

among two or more PERSONS, including but not limited to, face-to-face and telephone
conversations, correspondence, memoranda, telegrams, telexes, email messages,
transcribed voice-mail messages, text messages, meetings, discussions, releases,
statements, reports, publications or any recordings or reproductions.
I.

As used herein, the words YOU and YOUR shall mean or refer to

REX TILLERSON and all of his present or former agents, attorneys, consultants,
employees, representatives, and/or anyone acting or purporting to act on his behalf.
PLAINTIFFS NOTICE OF DEPOSITION OF REX TILLERSON
4

J.

As used herein, the term PERSON means all individuals, entities, firms,

organizations, groups, committees, regulatory agencies, governmental entities, business

entities, corporations, partnerships, trusts and estates.
K.

As used herein, the term AGENCY shall mean any federal, state,

regional or local governmental agency. The term shall include directors, employees,
consultants and/or representatives of said AGENCY.
x.

As used herein, the term CLIMATE CHANGE shall mean any change

in the state of the climate lasting for an extended period of time. In other words, the term
CLIMATE CHANGE includes changes in surface and ocean temperature,
precipitation, or wind patterns, among other effects, that occur over several decades or
longer, attributed directly or indirectly to human activity. The term CLIMATE
CHANGE shall include ocean acidification, sea level rise, and other impacts resulting
from the increased concentration of greenhouse gases and carbon dioxide in the
atmosphere and oceans. CLIMATE CHANGE also has been called climatic changes,
global warming, global change, global heating, atmospheric pollution by carbon dioxide
or other greenhouse gases, and dilution of carbon 14 by fossil carbon.
II.

INSTRUCTIONS
A.

Please produce and permit the inspection and copying of the

DOCUMENTS described below which are in YOUR possession, custody, or control, or

in the possession, custody, or control of YOUR attorneys, consultants, agents, or
representatives.
B.

In producing the DOCUMENTS demanded, YOU shall segregate those

documents by each request set forth herein.

C.

For any claim that a DOCUMENT YOU are required to produce in

response to any of these demands is privileged YOU will:

1.

Identify its title and general subject matter;

2.

State its date;

PLAINTIFFS NOTICE OF DEPOSITION OF REX TILLERSON

5

3.

Identify its author(s);

4.

Identify the PERSONS for whom it was prepared or to whom it

5.

State the nature of the privilege claimed; and

6.

State in detail each and every fact upon which YOU base your

was sent;

claim of privilege.
D.

The words and and or shall be construed in the conjunctive or

disjunctive, whichever is most inclusive.

E.

The singular form shall include the plural form and vice versa.

F.

The present tense shall include the past tense and vice versa.

G.

If any DOCUMENT cannot be produced in full, produce it to the extent

possible, indicating what information is being withheld and the reason such information
is being withheld.
H.

If a DOCUMENT once existed, but has been lost, destroyed, no longer

exists, or is no longer in YOUR possession or control, identify each such DOCUMENT

and separately state the details concerning the loss or destruction of the DOCUMENT, or
the name and address of the current or last known custodian of any such document, if
known to you.
III.

DOCUMENT REQUESTS
A. Each DOCUMENT that identifies YOUR position within the organizational
structure of AMERICAN PETROLEUM INSTITUTE.
B. Each DOCUMENT that identifies YOUR position within the organizational
structure of NATIONAL ASSOCIATION OF MANUFACTURERS.
C. Each DOCUMENT that identifies YOUR position within the organizational
structure of EXXONMOBIL.
D. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO
COMMUNICATIONS with any PERSON (other than COMMUNICATIONS

PLAINTIFFS NOTICE OF DEPOSITION OF REX TILLERSON

6

with INTERVENOR DEFENDANTS attorneys and their representatives)

regarding this litigation, including financial arrangements related to this litigation.
E. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO
participation by YOU on internal committees of the AMERICAN PETROLEUM
INSTITUTE pertaining to CLIMATE CHANGE, including, but not limited to,
any recommendations concerning any policy and initiative of the AMERICAN
PETROLEUM INSTITUTE.
F. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO
participation by YOU on internal committees of the NATIONAL
ASSOCIATION OF MANUFACTURERS pertaining to CLIMATE CHANGE,
including, but not limited to, any recommendations concerning any policy and
initiative of the NATIONAL ASSOCIATION OF MANUFACTURERS.
G. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO
participation by YOU in the Global Climate Coalitions efforts pertaining to
CLIMATE CHANGE from 1992-2001.
H. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO
the participation by Randy Randol on the Global Climate Science
Communications Team (GCSCT), including, but not limited to,
COMMUNICATIONS with the GCSCT and the development of the Global
Climate Science Communications Plan.
I. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO
YOUR COMMUNICATIONS with any representative of EXXONMOBIL
concerning CLIMATE CHANGE, including, but not limited to, observations or
predictions of CLIMATE CHANGE and effects on permafrost, extreme or
unusual weather conditions, sea ice conditions and the impact of those changes on
oil drilling operations in Alaska North Slope, Gulf of Mexico, Canada, Greenland,
Norway, and Russia.
PLAINTIFFS NOTICE OF DEPOSITION OF REX TILLERSON
7

J. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO

YOUR COMMUNICATIONS with any representative of the administration of
former President George W. Bush pertaining to the Kyoto Protocol.
K. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO
YOUR COMMUNICATIONS with any representative of the administration of
former President George W. Bush pertaining to the UN Framework Convention
on Climate Change.
L. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO
YOUR COMMUNICATIONS with any representative of EXXONMOBIL and
any representative of the AMERICAN PETROLEUM INSTITUTE regarding
CLIMATE CHANGE.
M. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO
YOUR COMMUNICATIONS with any representative of EXXONMOBIL and
any representative of the NATIONAL ASSOCIATION OF MANUFACTURERS
regarding CLIMATE CHANGE.
N. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR
COMMUNICATIONS with any representative of the Competitive Enterprise
Institute pertaining to the 2003 Competitive Enterprise Institute lawsuit against
the Bush Administration White House Office of Science and Technology Policy
and the National Science and Technology Council to stop the release of the
National Assessment of Climate Variability and Change (National Assessment)
and EPAs 2002 Climate Action Plan.
O. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR
COMMUNICATIONS with any representative of the administration of former
President George W. Bush pertaining to actual or potential appointees of the Bush
Administration who would be, as part of their duties, be working on CLIMATE
CHANGE.
PLAINTIFFS NOTICE OF DEPOSITION OF REX TILLERSON
8

P. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR

COMMUNICATIONS with any representative of administration of former
President George W. Bush pertaining to the removal of officials who had been
working in the administration of former President William J. Clinton who, as part
of their duties, were working on CLIMATE CHANGE.
Q. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR
COMMUNICATIONS with any representative of the administration of former
President George W. Bush pertaining to the United Nations Intergovernmental
Panel on Climate Change.
R. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR
COMMUNICATIONS with any representative of the administration of former
President George W. Bush pertaining to the Bush Administrations Climate
Science Research Program.
S. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR
COMMUNICATIONS with any representative of the administration of former
President George W. Bush pertaining to the Bush Administrations U.S Climate
Change Research Initiative.
T. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR
COMMUNICATIONS with any representative of the administration of former
President George W. Bush pertaining to the Bush Administrations Climate
Change Science Program.
U. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR
COMMUNICATIONS with any representative of the administration of former
President George W. Bush pertaining to the Bush Administrations Climate
Change Technology Program.
V. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR
COMMUNICATIONS with any representative of the administration of former
PLAINTIFFS NOTICE OF DEPOSITION OF REX TILLERSON
9

President George W. Bush pertaining to the Bush Administrations Committee on

Climate Change Science and Technology Integration.
W. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR
COMMUNICATIONS with any representative of the administration of former
President George W. Bush pertaining to the Bush Administrations Interagency
Working Group on Climate Change Science and Technology.
X. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR
COMMUNICATIONS with any representative of the administration of former
President George W. Bush pertaining to the UN Framework Convention on
Climate Change.
Y. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR
COMMUNICATIONS with any representative of the administration of former
President George W. Bush pertaining to the Kyoto Protocol.
Z. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR
COMMUNICATIONS with any representative of the administration of former
President George W. Bush pertaining to the Intergovernmental Panel on Climate
Change.
AA.

Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR

COMMUNICATIONS with any representative of EXXONMOBIL regarding

CLIMATE CHANGE, including, but not limited to, any COMMUNICATIONS
to and from the following current and former representatives of EXXONMOBIL:
1) Lee Raymond, CEO;
2) Frank Sprow, Vice President, Safety, Health & Environment;
3) Kenneth Cohen, VP, Public and Government Affairs;
4) Arthur G. (Randy) Randol III, Ph.D, Public Affairs Manager;
5) Walt Buchholtz, Public and Government Affairs Manager;
6) Brian P. Flannery, Science, Strategy and Programs Manager in Environmental
PLAINTIFFS NOTICE OF DEPOSITION OF REX TILLERSON
10

Policy and Planning;

7) David P. Bailey, Manager, Climate Policy;
8) Mark D. Boudreaux, Senior Director, Federal Relations;
9) Sherri Stuewer, VP Safety, Health & Environment;
10) Jaime Spelling, VP Corporate Planning;
11) David Kingston, VP Downstream Business Development and Portfolio
Management;
12) Elizabeth Beauvais, Advisor, Corporate Citizenship;
13) Victoria Ceja, EXXONMOBIL Public Affairs, Corporate Citizenship and
Community Investment Policy;
14) Lynn A. Gelner; and
15) Lauren Kerr.
BB.

Each DOCUMENT that REFERS, RELATES OR PERTAINS TO the

2006-2007 program on climate change and public affairs administered by Public

Affairs Director Kenneth Cohen, including plans, communications, and notes
from the Airlie House meeting, which took place on December 4-6, 2006, called
Opinion Leader Dialogue.
CC.

Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR

COMMUNICATIONS regarding a carbon tax and/or fee, or other carbon pricing

mechanisms.
DD.

Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR

COMMUNICATIONS regarding government policy on CLIMATE CHANGE,

including internal analyses, lobbying reports and records, and plans.
EE.Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR
COMMUNICATIONS regarding the Waxman Markey 2009 American Clean
Energy and Security Act of 2009, including, but not limited to, reports from
lobbyists working with EXXONMOBIL.
PLAINTIFFS NOTICE OF DEPOSITION OF REX TILLERSON
11

FF. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR

COMMUNICATIONS regarding the Waxman Markey 2009 American Clean
Energy and Security Act of 2009, including, but not limited to, reports from
representatives of AMERICAN PETROLEUM INSTITUTE.
GG.

Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR

COMMUNICATIONS regarding the Waxman Markey 2009 American Clean

Energy and Security Act of 2009, including, but not limited to, reports from
representatives of NATIONAL ASSOCIATION OF MANUFACTURERS.
HH.

Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR

COMMUNICATIONS regarding the McCain-Lieberman 2003 Climate

Stewardship Act, including, but not limited to, reports from lobbyists working
with EXXONMOBIL.
II. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR
COMMUNICATIONS regarding the McCain-Lieberman 2003 Climate
Stewardship Act, including, but not limited to, reports from representatives of
AMERICAN PETROLEUM INSTITUTE.
JJ. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR
COMMUNICATIONS regarding the McCain-Lieberman 2003 Climate
Stewardship Act, including, but not limited to, reports from representatives of
NATIONAL ASSOCIATION OF MANUFACTURERS.
KK.

Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR

COMMUNICATIONS regarding the 2005 Climate Stewardship and Innovation

Act, including, but not limited to, reports from lobbyists working with
EXXONMOBIL.
LL. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR
COMMUNICATIONS regarding the 2005 Climate Stewardship and Innovation
Act, including, but not limited to, reports from representatives of AMERICAN
PLAINTIFFS NOTICE OF DEPOSITION OF REX TILLERSON
12

PETROLEUM INSTITUTE.
MM.

Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR

COMMUNICATIONS regarding the 2005 Climate Stewardship and Innovation

Act, and the, including, but not limited to, reports from representatives of
NATIONAL ASSOCIATION OF MANUFACTURERS.
NN.

Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR

COMMUNICATIONS regarding the 2007 Climate Stewardship and Innovation

Act, including, but not limited to, reports from lobbyists working with
EXXONMOBIL.
OO.

Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR

COMMUNICATIONS regarding the 2007 Climate Stewardship and Innovation

Act, including, but not limited to, reports from representatives of AMERICAN
PETROLEUM INSTITUTE.
PP. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR
COMMUNICATIONS regarding the 2007 Climate Stewardship and Innovation
Act, including, but not limited to, reports from representatives of NATIONAL
ASSOCIATION OF MANUFACTURERS.

PLAINTIFFS NOTICE OF DEPOSITION OF REX TILLERSON

13

PROOF OF SERVICE
I am employed in San Mateo County where service of the document(s) referred to
below occurred. I am over the age of 18 and not a party to the within action. My business
address is Cotchett, Pitre & McCarthy, LLP, San Francisco Airport Center, 840 Malcolm
Road, Suite 200, Burlingame CA 94010. I am readily familiar with the firm ' s practices for
the service of documents. On this date, I served or caused to be served a true copy of the
following:
PLAINTIFFS' NOTICE OF DEPOSITION OF REX TILLERSON
XXX BY E-MAIL: My e-mail address is palmasi@cpmlegal.com and service of this
document(s) occurred on the date shown below. This document is being served
electronically and the transmission was reported as complete and without error.
XXX BY MAIL:
I placed a true copy of the aforementioned document(s) in a sealed
envelope with postage fully paid. I am familiar with this firm's practice of collection and
processing of mail for delivery by the United States Postal Service on the next day in the
ordinary course of business.
[SEE ATTACHED SERVICE LISTI
I declare under penalty of perjury, under the laws of the State of California, that the
foregoing is true and correct. Executed at Burlingame, California, on December 28, 2016.

POUNEH ALMASI

PROOF OF SERVICE OF PLAINTIFFS' NOTICE OF DEPOSITION OF REX

TILLERSON

SERVICE LIST
Sean C. Duffy
sean.c.duffy@usdoj.gov
Peter Dykema
Peter. Dykema@usdoj.gov
Sarah Himmelhoch
Sarah.Himmelhoch@usdoj.gov
Guillermo Montero
Guillermo.Montero@usdoj .gov
U.S. Department of Justice
Environment & Natural Resources Division
Natural Resources Section
601 D Street NW
Washington, DC 20004

Julia Olson
julia@ourchildrenstrust.org
Wild Earth Advocates
1216 Lincoln St.
Eugene, OR 97401

Quin Sorenson
qsorenson@sidley.com
David T. Buente
dbuente@sidley.com
Sidley Austin LLP
1501 K Street, NW
Washington, DC 20005

Daniel M. Galpem
dan.gal_Qem@ gmai I.com
Law Offices of Daniel M. Galpern
2495 Hilyard St., Suite A
Eugene, OR 97405

PROOF OF SERVICE OF PLAINTIFFS' NOTICE OF DEPOSITION OF REX

TILLERSON