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Attachment a Case Number: PC-2018-4716 Filed in Providence/Bristol County Superior Court Submitted: 7/2/2018 9:57 AM Envelope: 1610605 Reviewer: Alexa G

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Attachment a Case Number: PC-2018-4716 Filed in Providence/Bristol County Superior Court Submitted: 7/2/2018 9:57 AM Envelope: 1610605 Reviewer: Alexa G Attachment A Case Number: PC-2018-4716 Filed in Providence/Bristol County Superior Court Submitted: 7/2/2018 9:57 AM Envelope: 1610605 Reviewer: Alexa G. STATE OF RHODE ISLAND SUPERIOR COURT PROVIDENCE, SC. STATE OF RHODE ISLAND Plaintiff, vs. Case Number: CHEVRON CORP.; CHEVRON U.S.A. INC.; JURY TRIAL DEMANDED EXXONMOBIL CORP.; BP P.L.C.; BP AMERICA, INC.; BP PRODUCTS NORTH AMEIUCA, INC.; ROYAL DUTCH SHELL PLC; MOTIVA ENTERPRISES, LLC; SHELL OIL PRODUCTS COMPANY LLC; CITGO PETROLEUM CORP.; CONOCOPHILLIPS; CONOCOPHILLIPS COMPANY; PHILLIPS 66; MARATHON OIL COMPANY; MARATHON OIL CORPORATION; MARATHON PETROLEUM CORP.; MARA THON PETROLEUM COMPANY LP; SPEEDWAY LLC; HESS CORP.; LUKOIL PAN AMERICAS, LLC; GETTY PETROLEUM MARKETING, INC.;AND DOES 1 through 100, inclusive, Defendants. Case Number: PC-2018-4716 Filed in Providence/Bristol County Superior Court Submitted: 7/2/2018 9:57 AM Envelope: 1610605 Reviewer: Alexa G. TABLE OF CONTENTS I. INTRODUCTION ............................................................................................................ 1 II. PARTIES ........................................................................................................................... S A. Plaintiff ...................................................................................................................... 5 B. Defendants ................................................................................................................. 7 III. AGENCY ......................................................................................................................... 27 IV. JURISDICTION AND VENUE...................................................................................... 27 V. FACTUAL BACKGROUND......................................................................................... 27 A. Global Wanning-Observed Effects and Known Cause ......................................... 27 B. Sea Level Rise-Known Causes and Observed Effects .......................................... 33 C. Warming Air Temperatures-Known Causes and Observed Effects...................... 38 D. Disruption to the Hydrologic Cycle-Known Causes and Observed Effects ......... 41 i. Extreme Precipitation...................................................................................... 43 ii. Drought ........................................................................................................... 44 E. Ocean Warming and Acidification-Known Causes and Observed Effects........... 45 F. Public Health Impacts of Anthropogenic Global Wanning ..................................... 46 G. Attribution ................................................................................................................ 47 H. DefendantsWent to Great Lengths to Understand the Hazards Associated with, and Knew or Should Have Known of the Dangers Associated with the Extraction, Promotion, and Sale of Their Fossil Fuel Products. ................................................ 50 I. DefendantsDid Not Disclose Known Harms Associated with the Extraction, Promotion, and Consumption of Their Fossil Fuel Products, and Instead Affirmatively Acted to Obscure Those Harms and Engaged in a Concerted Campaign to Evade Regulation. .............................................................................. 70 J. In Contrast to Their Public Statements, Defendants' Intemal Actions Demonstrate Their Awareness of and Intent to Profit fromthe Unabated Use of Fossil Fuel Products.................................................................................................................... 87 K. Defendants' Actions Prevented the Development of AlternativesThat Would Have Eased the Transition to a Less Fossil Fuel Dependent Economy . ........................... 89 L. Defendants Caused Rhode Island's Injuries. ........................................................... 97 1 Case Number: PC-2018-4716 Filed in Providence/Bristol County Superior Court Submitted: 7/2/2018 9:57 AM Envelope: 1610605 Reviewer: Alexa G. VI. CAUSES OF ACTION ................................................................................................. 115 FIRST CAUSE OF ACTION ......................................................................................... 115 Public Nuisance .............................................................................................................. 115 SECOND CAUSE OF ACTION .................................................................................... 120 Strict Liability for Failure to Warn................. ................................................................ 120 TlIIRD CAUSE OF ACTION ........................................................................................ 123 Strict Liability for Design Defect ................................................................................... 123 FOURTH CAUSE OF ACTION .................................................................................... 128 Negligent Design Defect ................................................................................................. 128 FIFTH CAUSE OF ACTION ......................................................................................... 131 Negligent Failure to Warn .............................................................................................. 131 SIXTH CAUSE OF ACTION ........................................................................................ 133 Trespass ........................................................................................................................... 133 SEVENTH CAUSE OF ACTION .................................................................................. 135 Impairment of Public Trust Resources ........................................................................... 135 EIGHTH CAUSE OF ACTION ..................................................................................... 138 State Environmental Rights Act, Equitable Relief Action .............................................. 138 VII. PRAYER FOR RELIEF .............................................................................................. 140 REQUEST FOR JURY TRIAL ............................................................................................... 141 11 Case Number: PC-2018-4716 Filed in Providence/Bristol County Superior Court Submitted: 7/2/2018 9:57 AM Envelope: 1610605 Reviewer: Alexa G. PLAINTIFF'S COMPLAINT I. INTRODUCTION 1. Defendants, major corporate members of the fossil fuel industry, have known for nearly a half century that unrestricted production and use of their fossil fuel products create greenhouse gas pollution that warms the planet and changes our climate. They have lmown for decades that those impacts could be catastrophic and that only a narrow window existed to take actjon before the consequences would be iiTeversible. They have nevertheless engaged in a coordinated, multi-front effort to conceal and deny their own knowledge of those threats, discredit the growing body of publicly available scientific evidence, and persistently create doubt in the minds of customers, consumers, regulators, the media, journalists, teachers, and the public about the reality and consequences of the impacts of their fossil fuel pollution. At the same time, Defendantshave promoted and profitedfrom a massive increase in the extraction and consumption of oil, coal, and natural gas, which has in turn caused an enormous, foreseeable, and avoidable increase in global greenhouse gas pollution and a concordant increase in the concentration I of greenhouse gases, 1 particularly carbon dioxide ("CO2") and methane, in the Earth's atmosphere. Those disruptions of the Earth's otherwise balanced carbon cycle have substantially contTibuted to a wide range of dire clhnate-related effects, including, but not limited to, global warming, rising atmospheric and ocean temperatures, ocean acidification, melting polar ice caps and glaciers, more extreme and volatile weather, drought, and sea level rise. Plaintiff, the State of Rhode Island,2 along with the State's citizens, inrastructure,f and natural resources, suffer the consequences. 1 As used in this Complaint, "greenhouse gases" refers collectively to carbon dioxide, methane, and nitrous oxide. Where a source refers to a specific gas or gases, or when a process relates only to a specific gas or gases, this Complaint refers to them by name. 2 As used in this Complaint when referring to geographic locations, "Rhode Island" and "State" refer to all non-federal lands within the geographic boundaries of the State of Rhode Island. 1 Case Number: PC-2018-4716 Filed in Providence/Bristol County Superior Court Submitted: 7/2/2018 9:57 AM Envelope: 1610605 Reviewer: Alexa G. 2. Defendants are vertically integrated extractors, producers, refiners, manufacturers, distributors, promoters, marketers, and sellers of fossil fuel products. Decades of scientific research show that pollution from the production and use of Defendants'fossil fuel products plays a direct and substantial role in the unprecedented rise in emissions of greenhouse gas pollution and increased atmospheric CO2 concentrations since the mid-20th century. This dramatic increase in atmospheric CO2 and other greenhouse gases is the main driver of the gravely dangerous changes occurring to the global climate. 3. Anthropogenic (human-caused) greenhouse gas pollution, primarily in the form of CO2, is far and away the dominant cause of global warming, and results in severe impacts including,
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