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May 28, 2014, available<br />

https://www.greenbiz.com/blog/2014/05/28/exxonmobil-left-riskout-climate-risk-report<br />

(last accessed 8/5/16).<br />

31. Attached to this affidavit as Exhibit 32 is a true and accurate copy of a document<br />

made available by InsideClimate News as part of its series, Exxon: The Road Not Taken.<br />

identified as email from Joe Walker to a "Global Climate Science Team," with attached "draft<br />

Global Climate Science Communications Plan," dated Apr. 3, 1998, available at<br />

https://insideclimatenews.org/sites/default/files/documents/Global%20Climate%20Science%20C<br />

ommunications%20Plan%20%281998%29.pdf (last accessed 8/7/16).<br />

32. Attached to this affidavit as Exhibit 33 is a true and accurate copy of a webpage<br />

providing the status of ratification of the Kyoto Protocol, available at<br />

http://unfccc.int/kvoto protocol/status of ratification/items/2613.php (last accessed 8/1/16).<br />

33. Attached to this affidavit as Exhibit 34 is a true and accurate copy of an article,<br />

Justin Gillis and Clifford Krauss, Exxon Mobil Investigated for Possible Climate Change Lies by<br />

New York Attorney General, N.Y. Times, November 5, 2015, available at<br />

http://www.nvtimes.com/2015/ll/06/science/exxon-mobil-under-investigation-in-new-vorkover-climate-statements.html<br />

(last accessed 8/1/16).<br />

34. Attached to this affidavit as Exhibit 35 is a true and accurate copy of an article,<br />

Phil McKenna, Virgin Islands and Exxon Agree to Uneasy Truce Over to Climate Probe,<br />

InsideClimate News, July 7, 2016, available at<br />

https://insideclimatenews.org/news/06072016/virgin-islands-exxon-agree-climate-probesubpoena-claude-walker-schneiderman-healey<br />

(last accessed 8/1/16).<br />

35. Attached to this affidavit as Exhibit 36 is a true and accurate copy of a publicly<br />

available letter from Peter Kadzik, Assistant Attorney General, U.S. Department of Justice, to the<br />

9

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