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Than 12,500 Massachusetts Consumers Under Settlement With Volkswagen Over Emissions<br />

Fraud," dated June 28, 2016, available at http://www.mass.gov/ago/news-and-updates/pressreleases/2016/2016-06-28-vw-settlement.html<br />

(last accessed 8/6/16).<br />

18. On July 19, 2016, Massachusetts, New York, and Maryland announced the filing<br />

of separate state suits against Volkswagen alleging state environmental law violations that were<br />

not covered under the settlement and that arose from the corporate misconduct identified through<br />

the multi-state investigation, including depositions and document productions in response to the<br />

states' CIDs.<br />

19. Attached to this affidavit as Exhibit 20 is a true and accurate copy of a press<br />

release announcing the separate state lawsuits against Volkswagen alleging various state<br />

environmental law violations, "NY A.G. Schneiderman, Massachusetts A.G. Healey, Maryland<br />

A.G. Frosh Announce Suits Against Volkswagen And Porsche Alleging They Knowingly Sold<br />

Over 53,000 Illegally Polluting Cars and Suvs, Violating State Environmental Laws," dated July<br />

19, 2016, available at http://www.ag.ny.gov/press-release/nv-ag-schiieiderman-massachusettsag-healey-maryland-ag-frosh-announce-suits-against<br />

(last accessed 8/8/16).<br />

20. Attached to this affidavit as Exhibit 21 are true and accurate copies of the<br />

following articles: Jess Bidgood, At a Cape Cod Landmark, a Strategic Retreat From the Ocean,<br />

N. Y. Times, Jul. 6, 2016, available at http://www.nvtimes.coni/2016/07/07/us/at-a-cape-codlandmark-a-strategic-retreat-from-the-ocean.html<br />

(last accessed 8/7/16); David Abel, Climate<br />

change could be even worse for Boston than previously thought, Boston Globe, June 22, 2016,<br />

available at https://www.bostonglobe.com/metro/2016/06/22/climate-change-could-have-evenworse-impact-boston-than-previouslv-expected/S6hZ4nDPeUWNvTsx6ZckuL/storv.html<br />

(last<br />

accessed 8/7/16).<br />

5

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