comm-appendix-support-cross

COMMONWEALTH OF MASSACHUSETTS
SUFFOLK, ss.
SUPERIOR COURT
CIVIL ACTION NO.: 16-1888F
IN RE CIVIL INVESTIGATIVE
DEMAND NO. 2016-EPD-36,
ISSUED BY THE OFFICE OF THE
ATTORNEY GENERAL
AFFIDAVIT OF MELISSA A. HOFFER
I, Melissa A. Hoffer, hereby depose and state under oath:
1. I am Chief of the Energy and Environment Bureau of the Office of Attorney
General Maura Healey (the "AGO" or "Office") of the Commonwealth of Massachusetts (the
"Commonwealth"), and am one of the attorneys representing the Commonwealth in this case. I
have personal knowledge of the facts stated herein, based on my experience or my consultation
with others, or they are known to me in my capacity as counsel for the Commonwealth, and each
of them is true and correct.
2. I submit this affidavit in support of the Commonwealth's Opposition to the
Petitioner Exxon Mobil Corporation's ("Exxon") Emergency Motion to Set Aside or Modify the
Civil Investigative Demand or Issue a Protective Order, and in support of the Commonwealth's
Cross-Motion to Compel Exxon Mobil Corporation to Comply with Civil Investigative Demand
No. 2016-EPD-36 (the "CID").
3. Attached to this affidavit as Exhibit 1 is a true and accurate copy of a document
made available by InsideClimate News as pail of its series, Exxon: The Road Not Taken,
identified as Henry Shaw, COi Greenhouse and Climate Issues, dated March 28, 1984, available