Goldstein V Climate Action Network Et Al

Case: 5:16-cv-00211-C As of: 09/13/2016 03:31 PM CDT 1 of 4
JURY
U.S. District Court

Northern District of Texas (Lubbock)
CIVIL DOCKET FOR CASE #: 5:16cv00211C
Goldstein v. Climate Action Network et al
Assigned to: Senior Judge Sam R Cummings
Cause: 18:1961 Racketeering (RICO) Act
Date Filed: 09/13/2016

Jury Demand: Plaintiff
Nature of Suit: 470 Other Statutes:
Racketeer Influenced and Corrupt
Organizations
Jurisdiction: Federal Question
Plaintiff
Leonid Goldstein
V.
Defendant
Climate Action Network
Defendant
Ceres Inc
Defendant
Rockefeller Brothers Fund Inc
Defendant
Generation Investment Management
US LLP
Defendant
Ford Foundation
Defendant
The Pew Charitable Trusts
Defendant
Greenpeace International Corp
Defendant
Environmental Grantmakers
Association Corp
Defendant
The Consultative Group On Biological
Diversity Corp
Defendant
Sierra Club Foundation Corp
Defendant
represented by Leonid Goldstein

12501 Tech Ridge Blvd
#1535
Austin, TX 78753
4089211110
Email: ah@defyccc.com
PRO SE

World Wide Fund for Nature Trust
Defendant
US Climate Action Network Corp
Defendant
Global Call for Climate Action Corp
Defendant
Generation Investment Management
LLP
Defendant
Alliance for Climate Protection Corp
Defendant
Fenton Communications Corp
Defendant
World Wildlife Fund Inc
Defendant
Greenpeace Inc
Defendant
Greenpeace Fund Inc
Defendant
Friends of Earth International Corp
Defendant
Friends of the Earth US Corp
Defendant
Friends of the Earth (Action) Inc
Defendant
Environmental Defense Fund, Inc
Defendant
Environmental Defense Action Fund
Corp
Defendant
Natural Resources Defense Council Inc
Defendant
NRDC Action Fund Corp
Defendant
Sierra Club Corp
Defendant
Earthjustice Corp

Defendant
The Union of Concerned Scientists Inc
Defendant
The Pew Memorial Trust
Defendant
Howard Pew Freedom Trust
Defendant
Mabel Pew Myrin Trust
Defendant
J.N. Pew Jr Charitable Trust
Defendant
The John D and Catherine T
MacArthur Foundation
Defendant
The William &Flora Hewlett
Foundation
Defendant
The David and Lucile Packard
Foundation
Defendant
Tides Foundation Corporation
Defendant
Tides Center Corporation
Defendant
Climateworks Foundation
Defendant
The Energy Foundation
Defendant
John and Jane Does 199
Date Filed
Docket Text
09/12/2016
1 COMPLAINT WITH JURY DEMAND against All Defendants filed by Leonid

Goldstein. (Filing fee $400.00; Receipt number LU008789) Unless exempted,
attorneys who are not admitted to practice in the Northern District of Texas must
seek admission promptly. Forms, instructions, and exemption information may be
found at www.txnd.uscourts.gov, or by clicking here: Attorney Information Bar
Membership. If admission requirements are not satisfied within 21 days, the clerk
will notify the presiding judge. (Attachments: # 1 Cover Sheet) (egp) (Entered:
09/13/2016)
09/12/2016
2 CERTIFICATE OF INTERESTED PERSONS/DISCLOSURE STATEMENT by

Leonid Goldstein. (egp) (Entered: 09/13/2016)

09/12/2016
3 New Case Notes: A filing fee has been paid. Pursuant to Misc. Order 6, Plaintiff is
provided the Notice of Right to Consent to Proceed Before A U.S. Magistrate
Judge. Clerk to provide copy to plaintiff if not received electronically. (egp)
(Entered: 09/13/2016)
09/12/2016
4 Notice and Instruction to Pro Se Party (egp) (Entered: 09/13/2016)
09/13/2016
***Clerk's Notice of delivery: (see NEF for details) Docket No:3,4. Tue Sep 13
10:27:26 CDT 2016 (crt) (Entered: 09/13/2016)
09/13/2016
***Clerk's Notice of delivery: (see NEF for details) Docket No:3,4. address
corrected for second clerk's notice to #1535 Tue Sep 13 10:31:07 CDT 2016 (crt)
(Entered: 09/13/2016)
09/13/2016
5 Summons Issued as to All Defendants. (egp) (Entered: 09/13/2016)
CIVIL COVER SHEET
JS 44 (Rev. 07/16)
Case 5:16-cv-00211-C Document 1-1 Filed 09/12/16 Page 1 of 1 PageID 70

The ~S 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law,
except llii
provtded by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of mttlatmg the ctvli docket sheet. (SEH INSTRUCTIONS ON NEX'J' PAGE OF THIS FORM)
I. (a) PLAINTIFFS
DEFENDANTS
LEONID GOLDSTEIN
CLIMATE ACTION NETWORK et al.

Travis County
(b) County of Residence of First Listed Plaintiff
County of Residence of First Listed Defendant
(EXChl'T IN U.S PLAINTIFF CASES)

NOTE:
{C) Attorneys (Firm Name,
(IN U.S. PLAINTIFF CASES ONLY)

IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
Attorneys (IfKnown)
Address, and Telephone Number)
5- t6 cv- 21
prose
II. BASIS OF JURISDICTION (Placean "X"inOneBoxOnlyJ

0 1
0 2
U.S. Government
Plaintiff
~ 3 Federal Question
U.S. Government
Defendant
0 4
(For Diversity Cases Only)

PTF
Citizen of This State
~ 1
(U.S. Government Not a Party)
Diversity
(Indicate Citizenship ofParties in Item III)
IV NATURE OF SUIT (Place an

0
0
0
0
0
III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an
Citizen of Another State
0
0
0
0
PERSONAL INJURY
0 310 Airplane
0 315 Airplane Product
Liability
0 320 Assault, Libel &
Slander
0 330 Federal Employers'
Liability
0 340 Marine
0 345 Marine Product
Liability
0 350 Motor Vehicle
0 355 Motor Vehicle
Product Liability
0 360 Other Personal
Injury
0 362 Personal Injury Medical Malpractice
PERSONAL INJURY
0 365 Personal Injury Product Liability
0 367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
0 368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
0 370 Other Fraud
0 371 Truth in Lending
0 380 Other Personal
Property Damage
0 385 Property Damage
Product Liability
0
0
0
0
0
0
210
220
230
240
245
290
0
0
0
0
Habeas Corpus:
0 463 Alien Detainee
0 510 Motions to Vacate
Sentence
0 530 General
0 535 Death Penalty
Other:
0 540 Mandamus & Other
0 550 Civil Rights
0 555 Prison Condition
0 560 Civil Detainee Conditions of
Confinement
Land Condemnation
Foreclosure
Rent Lease & Ejectment
Torts to Land
Tort Product Liability
All Other Real Property
V. ORIGIN (Place an
~ I Original
Proceeding
0 2
0 3
QIC
Incorporated and Principal Place

of Business In Another State
~5
Foreign Nation
0 6
"X" in one Box Only)
11 0 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excludes Veterans)
153 Recovery of Overpayment
of Veteran's Benefits
160 Stockholders' Suits
190 Other Contract
195 Contract Product Liability
196 Franchise
0
0
DEF
0 1
"X" in one BoxfiJr Plaintiff

and One Box for Defendant)
PTF
DEF
Incorporated or Principal Place
0 4
0 4
of Business In This State
440
441
442
443
Other Civil Rights

Voting
Employment
Housing/
Accommodations
0 445 Amer. w/DisabilitiesEmployment
0 446 Amer. w/DisabilitiesOther
0 448 Education
0 625 Drug Related Seizure

of Property 21 USC 881
0 690 Other
0 422 Appeal 28 USC 158

0 423 Withdrawal
28 usc 157
0 820 Copyrights
0 830 Patent
0 840 Trademark
0 710 Fair Labor Standards

Act
0 720 Labor/Management
Relations
0 740 Railway Labor Act
0 751 Family and Medical
Leave Act
0 790 Other Labor Litigation
0 791 Employee Retirement
Income Security Act
0
0
0
0
0
861
862
863
864
865
HIA (!395ft)
Black Lung (923)
DIWC/DIWW (405(g))
SSID Title XVI
RSI (405(g))
0 870 Taxes (U.S. Plaintiff

or Defendant)
0 871 IRS-Third Party
26 usc 7609
0 375 False Claims Act

0 376 Qui Tam (31 USC
3729(a))
0 400 State Reapportionment
0 410 Antitrust
0 430 Banks and Banking
0 450 Commerce
0 460 Deportation
Qi( 4 70 Racketeer Influenced ap.d
Corrupt Organizations
0 480 Consumer Credit
0 490 Cable/Sat TV
0 850 Securities/Commodities/
Exchange
0 890 Other Statutory Actions
0 891 Agricultural Acts
0 893 Environmental Matters
0 895 Freedom of Information
Act
0 896 Arbitration
0 899 Administrative Procedllre
Act/Review or Appeal of
Agency Decision
0 950 Constitutionality of
State Statutes
0 462 Naturalization Application

0 465 Other Immigration
Actions
"X" inOneBoxOnly)
0 2 Removed from
State Court
Remanded from
Appellate Court
0 4 Reinstated or
Reopened
0 5 Transferred from
Another District
(specifY)
0 6 Multidistrict
Litigation Transfer
0 8 Multidistrict
Litigation Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity :
VI. CAUSE OF ACTION ~T~h~e;:,.;R;.;.a=.;c::.k:.=e.:.:te:.:e~r.:.:.ln:.:..:fl.::.ue:::::n.:.:c:.:e:.::d..:a::..:n.::.d..:C:.:o:.:.:rru:.::~:.pt::..;O=.r:.oz.::a::.:n::iz.::.at::.:io:.:.n:.=s...:..A.:.:ct:.:..l.."~R::.:IC;,;O::..'-"',~1:.:8:....:U;.;:.=S~.C;,;~1~9:.:6;.,;.1_-1:.:9~6..;:.8_ _ _ _ _ ____._

Brief description of cause:
Damages by RICO violations, including witness retaliation, tampering, bribery, and embezzlement from pension,
VII. REQUESTED IN
0
COMPLAINT:
VIII. RELATED CASE(S)
IF ANY
DATE
CHECK IF THIS IS A CLASS ACTION

UNDER RULE 23, F.R.Cv.P.
(.~'ee
DEMAND $
CHECK YES only if demanded in complaint:

JURY DEMAND:
M Yes 0 No
instrnctions):
DOCKET NUMBER
JUDGE
SIGNATURE OF ATTORNEY OF RECORD
09/12/2016
/Leonid Goldstein/
FOR OFFICE U(E, ~N: ~

RECEIPT#
J..,aro~~
APPLYING lFP
JUDGE
MAG. JUDGE
Case 5:16-cv-00211-C Document 1 Filed 09/12/16
ORIGINAL
Page 1 of 69 PageID 1
,,.-~:.,': L~~; Ul:::.1rf:i~~:T
Wiii1H!El1d D!Sl. ~/ l;:.

FILE!l
UNITED STATES DISTRICT COURT'J..0/1,., \dJ

FOR THE NORTHERN DISTRICT OF TE~P 12 PH I: 31
LUBBOCK DIVISION
LEONID GOLDSTEIN
Plaintiff
v.
CLIMATE ACTION NETWORK, CERES INC.,
ROCKEFELLER BROTHERS FUND INC., GENERATION
INVESTMENT MANAGEMENT LLP, FORD
FOUNDATION, THE PEW CHARITABLE TRUSTS,
GREENPEACE INTERNATIONAL CORP.,
ENVIRONMENTAL GRANTMAKERS ASSOCIATION
CORP., THE CONSULTATIVE GROUP ON
BIOLOGICAL DIVERSITY CORP., THE SIERRA CLUB
FOUNDATION CORP., WORLD WIDE FUND FOR
NATURE TRUST, US CLIMATE ACTION NETWORK
CORP., GLOBAL CALL FOR CLIMATE ACTION CORP.,
GENERATION INVESTMENT MANAGEMENT US LLP,
ALLIANCE FOR CLIMATE PROTECTION CORP.,
FENTON COMMUNICATIONS CORP., WORLD
WILDLIFE FUND INC., GREENPEACE INC.,
GREENPEACE FUND INC., FRIENDS OF THE EARTH
INTERNATIONAL CORP., FRIENDS OF THE EARTH US
CORP., FRIENDS OF THE EARTH (ACTION) INC.,
ENVIRONMENTAL DEFENSE FUND INC.,
ENVIRONMENTAL DEFENSE ACTION FUND CORP.,
NATURAL RESOURCES DEFENSE COUNCIL INC.,
NRDC ACTION FUND CORP., SIERRA CLUB CORP.,
EARTHJUSTICE CORP., THE UNION OF CONCERNED
SCIENTISTS INC., THE PEW MEMORIAL TRUST, J.
HOWARD PEW FREEDOM TRUST, MABEL PEW
MYRIN TRUST, J.N. PEW JR. CHARITABLE TRUST,
THE JOHN D. AND CATHERINE T. MACARTHUR
FOUNDATION, THE WILLIAM & FLORA HEWLETT
FOUNDATION, THE DAVID AND LUCILE PACKARD
FOUNDATION, TIDES FOUNDATION CORPORATION,
TIDES CENTER CORPORATION, CLIMATEWORKS
FOUNDATION, THE ENERGY FOUNDATION, and JOHN
AND JANE DOES 1-99
Defendants
CIVIL CASE NO.
516CV- 21 1 --
JURY TRIAL DEMANDED
COMPLAINT
PRELIMINARY STATEMENT
1.
This is a civil suit against Climate Action Network and other corporations, who
engaged in a long-term criminal scheme, involving a false claim that anthropogenic release (or
emissions) of carbon dioxide caused a dangerous "global warming" or a dangerous "climate
change", and persecution of the dissidents or demanding government actions, based on this false
claim, including money transfer. In fact, the anthropogenic release of carbon dioxide significantly
increases agricultural production worldwide. The surface warming, theoretically caused by
increased concentration of carbon dioxide, is insignificant and almost undetectable, and is expected
to be globally beneficial.
2.
Beginning in early 1988 and continuing through the present (the "Scheme Period"),
the Defendants and other enterprise members acted in concert with each other in order to further
their criminal scheme (the "Climate Alarmism Enterprise"). Each defendant has participated in the
operation and management of the Enterprise, and has committed numerous acts to maintain and
expand the Enterprise.
3.
Because of the enormous scale and success of the Climate Alarmism Enterprise, some
historical background is necessary. The idea to use imaginary threat of the carbon dioxide emissions
as a lever to obtain power and money was first expressed in the report from the 1972 United Nations
Environmental Programme. Nevertheless, top US scientists discussed the potential influence of the
carbon dioxide emissions on the global climates, and Congress even convened the Carbon Dioxide
Assessment Committee (CDAC). CDAC worked on the question from 1979 to 1983, firmly rejected
alarm, and recommended further research. Further research and observation practically eliminated
the earlier concerns about the carbon dioxide emissions.
2
4.
Of course, the foreign and domestic environmental organizations and UN agencies
that used to environmental scares to raise money and grow their power, could not care less about the
science. Over 1993-2001, Clinton- Gore administration (in which AI Gore, who used to compare
the modem science and technology to a pact with devil, and judged scientists by their agreement or
disagreement with the Climate Cult, was responsible for science) conducted purges, systematically
removing distinguished scientists from positions of influence in the scientific agencies and
institutions, replacing them with environmentalists or their marionettes, and closing whole research
directions to satisfy the environmentalists' demands. The political bias of the academic and
scientific communities prevented them from seeing what was happening until it was too late. The
climate pseudo-science also avoided the public scrutiny, when Congress rejected Kyoto protocol
with the 95:0 vote, shielding the nation from the immediate direct impact of the climate alarmism.
5.
But following goring in 1993-2001, the American sciences and science-intensive
industries have been steadily declining (except for the biomedical research, which became
accustomed to live in fear of the federal government.) The last nuclear power plant was approved in
1979. The Space Shuttle was retired and not replaced. The US depends on Russia to launch its
astronauts. Silicon Valley manufactures very little "silicon" (meaning computer chips). Our
computers are made in China from parts made in China, South Korea, Taiwan, or Japan. Software
and Internet industries did boom, but almost all research for them had been conducted before 1993.
General scientific and technological literacy declined accordingly. Some Defendants and the whole
Climate Alarmism Enterprise heavily contributed to this decline, and benefitted from it.
6.
In 1980's, the climate alarmist claims did not have sound scientific grounds, but
could not be dismissed out of hand. The distinguished scientists politely called to the alarmists'
ungrounded statements and exaggeration as "uncertainties". With the time, the new research has
shown that the alarmist claims did not only contain "uncertainties", but were flat wrong. The
climate alarmists reacted by taking even more extreme anti-scientific positions, and persecuting their
opponents not only for dissent, but even for doubts. In doing that, they were misappropriating
progressively larger amounts of public money, starting with hundreds of millions and going up to
tens or even hundreds of billions of dollars per year. A large part of this money was "reinvested"
back into promotion of the climate alarmism. This is how we arrived to the current situation, when
the Climate Cult (the dogma and practice of the climate alarmism) is the state religion in California
and almost the state religion in the federal government.
7.
Plaintiff sues for injury inflicted by the Defendants on him directly, and, additionally,
based on standing of victims of racketeering activity to act as "private attorney generals" in

prosecuting that racketeering activity (Rotella v. Wood, 528 U.S. 549, 556; 2000).
8.
Unless stated otherwise, alleged below actions by Defendants were committed in the
10-years period from September 15, 2006 through the date of filing this Complaint.
JURISDICTION AND VENUE
9.
This action arises under The Racketeer Influenced and Corrupt Organizations Act
("RICO"), 18 U.S.C. 1961-1968, and common law.

10.
This Court has subject-matter jurisdiction pursuant to 28 U.S.C. 1331.
11.
This Court has personal jurisdiction over all the Defendants pursuant to, inter alia, 18
U.S.C. 1965, because each Defendant resides in the United States, and/or transacts business on a
systematic and continuous basis here, and/or has engaged in criminal misconduct here in violation of
U.S. law, because, each Defendant, directly and through agents, transacts business within Texas;
committed tortious acts and omissions within the state; committed tortious injury in the state caused
by an act or omission outside the state; regularly does business, engages in persistent course of
conduct, or derives substantial revenue from activities in the state; owns, uses, and possesses real
4
property within the state; or is registered to do business in and has consented to personal jurisdiction
in this state.
12.
Venue for this action is proper in pursuant to 28 U.S.C. 1391(b) because a
substantial part of the events giving rise to Plaintiff' claims occurred in the Northern District of
Texas and all the Defendants are subject to personal jurisdiction in this judicial district. The
Defendants also injured Plaintiff in the Northern District of Texas, among other places. In addition,
as set forth herein, the Defendants' wrongful conduct and related activities caused substantial effects
in this jurisdiction and in this district, based on their criminal and/or tortious conduct in and outside
of Texas.
THE PARTIES
13.
Plaintiff Leonid Goldstein is a permanent resident of the United States of America, a
resident of Texas, and a citizen of Israel. Plaintiff has Master of Science degree in Mathematics,
more than 20 years of experience in software engineering, and multiple patents and publications in
peer-reviewed literature in a certain renewable energy field. Plaintiff performed a peer review for
some journals. Because of his education, professional experience and knowledge, Plaintiff is
qualified to give expert testimony on certain questions of physics, mathematics, and computer
modelling, relevant to a bone fide climate research and to the so-called "climate science." Plaintiff
also has additional knowledge and life experience that might qualify him to give expert testimony on
the corrupt activities of the climate alarmism bodies. Plaintiff is willing to testify on these subjects in
front of the US Congress, the Texas Legislature, the Supreme Court of the United States, and the
Supreme Court of Texas, without compensation. Plaintiff has been paying into the Social Security
for more than 15 years, and has savings in a retirement plan, protected by the Employee Retirement
Income Security Act of 1974. Plaintiff expresses his views on subjects relevant to climate debates
5
and climate alarmism on his not-for-profit website defyccc.com, which also features a search engine
(defyccc.cornlsearch), allowing anybody to find truthful information regarding the climate debates.
Plaintiff also writes for other reputable web publications under the pen name "Ari Halperin."
14.
Because of the significant number of defendants, they are divided into categories in
the following subsections.

A. Conglomerates
15.
Defendant Climate Action Network, sometimes calling itself Climate Action
Network International, ("CAN-I''), is an entity headquartered in Beirut, Lebanon. On information

and belief, CAN-I was incorporated in Germany. CAN-I describes itself as "a worldwide network of
over 1100 Non-Governmental Organizations (NGOs) in more than 120 countries, working to
promote government and individual action to limit human-induced climate change to ecologically
sustainable levels. "CAN-I is also an observer member of the International Panel on Climate Change
("IPCC"). CAN-I or its predecessors have been participating in the Climate Alarmism Enterprise
since 1989 or earlier.
16.
Defendant US Climate Action Network ("USCAN"). USCAN is a registered tax-
exempt 501(c)(3) "educational organization," based in Washington, DC. USCAN describes itself as
"a vital and growing network for organizations active on climate change in the United States. Our
network of 150+ organizations continues to grow "Bigger, Broader, and Better" with each new
member." USCAN calls itself an affiliate of CAN-I, while CAN-I calls USCAN its national node,
"responsible for its own governance and procedures, and conduct joint policy and advocacy work
within its given country or region. " Thus, USCAN is tasked to conduct the "policy and advocacy
work" of CAN-I within the USA. USCAN or its predecessors have been participating in the Climate
Alarmism Enterprise since 1989 or earlier.
17.
Defendant the Global Call for Climate Action ("GCCA"), also called the Global
Campaign for Climate Action and TckTckTck, is a Canadian corporation that calls itself"a diverse
network of more than 450 nonprofit organizations in more than 70 countries with a shared goal- a
world safe from runaway climate change." GCCA acknowledges USCAN and CAN-I as its
partners. GCCA has been participating in the Climate Alarmism Enterprise since 2008 or earlier.
B. Financial Cartel
18.
Defendant Environmental Grantmakers Association ("EGA") was founded in 1987
and incorporated not later than in 2007. EGA describes itself thus: "our membership spans more
than 200 foundations from around the world ... EGA member organizations collectively hold
approximately $200 billion in assets and give more than one billion dollars annually to
environmental causes." EGA has its main office in New York, NY, on the same floor of the same
building as another Defendant Rockefeller Brothers Fund, described below. EGA or its predecessors
have been participating in the Climate Alarmism Enterprise since 1993 or earlier.
19.
Defendant The Consultative Group on Biological Diversity ("CGBD"), established
in 1987, and incorporated as a 501(c)(3) "charitable organization," has headquarters in San

Francisco, CA. From its self-description: "The CGBD organizes Programs to target attention on
selected topics and to explore the process of strategic, collaborative grantmaking. Programs of2550 interestedfunders convene on a regular basis." CGBD is listed by EGA as its an "affinity
group," and CGBD lists EGA as its a "program participant." CGBD has been participating in the
Climate Alarmism Enterprise since 2002 or earlier.
20.
EGA and CGBD (together, the "Financial Cartel") are interconnected, have shared
purposes and shared membership, and are essentially two manifestations of the same association-infact.
C. Special Cases
21.
a)
Defendants Generation Investment Management (together, "GIM") comprises:
Defendant Generation Investment Management LLP ("GIM-LLP") is a limited liability

partnership registered in England and Wales, founded by former Vice President of the United
States of America Albert Gore in 2004, with the mission "To deliver superior investment
performance ... ". GIM-LLP has been co-owned and controlled by Al Gore since then.
b) Defendant Generation Investment Management US LLP ("GIM-US-LLP") is its daughter

company, registered in the US.
c) Defendant Alliance for Climate Protection ("GIM-ACP"), initially called The Climate Project,
is a putative nonprofit corporation, headquartered in Washington, D.C., and is registered as a taxexempt 501(c)(3) "charitable organization". Its 990 Form (2008) states: "FOUNDED IN 2006
BY VICE PRESIDENT AL GORE, THE ALLIANCE IS A UNIQUE SINGLE-PURPOSE
ORGANIZATION FOR THE PURPOSE OF IGNITING PUBLIC ACTION TO SOLVE THE
CLIMATE CRISIS." The document does not say what this "climate crisis" was. It further states,
"THE ALLIANCE IS UNDERTAKING AN UNPRECEDENTED MASS PERSUASION
EXERCISE BASED ON SCIENTIFIC FACTS." The document does not say what these scientific
facts were and how GIM-ACP could determine scientific facts after Al Gore and his sidekick
Carol Brown chased scientists out of the government scientific agencies. Through the period
2007-2014, GIM-ACP received contributions in excess of $200 Million, and reported assets of
less than $7 Million in 2014.
The GIM Defendants are associated in fact and it appears that each of them aided, abetted,
counseled, commanded, induced, or procured each of the other's actions alleged herein, at all times
both of them existed. This said, GIM-LLP, a foreign entity, is the master among the GIM
Defendants. GIM-LLP and GIM-US-LLP have been participating in the Climate Alarmism
8
Enterprise since their incorporation in 2004, or earlier. GIM-ACP has been participating in the
Climate Alarmism Enterprise since its incorporation in 2006, or earlier.
22.
Defendant Ceres, Inc. ("Ceres") is a putative nonprofit corporation, founded in or
around 1989 and based in Boston, MA. Ceres leads "a coalition" between public assets, including
the California and New York public pension funds, and extremist environmentalist groups, including
the non-defendant Earth Island Institute, and Defendants EDF, NRDC, and UCS, described below.
It describes the goal of this foxes-hens "coalition" as follows: "Ceres works with more than 130
member organizations that make up the Ceres Coalition to engage with corporations and help
advance our goal of building a sustainable global economy." In addition, Ceres operates what it
calls the Investors Network on Climate Risk, which includes state treasurers, institutional investors,
and labor groups - "1 00 leading investors collectively managing more than $11 trillion in assets."
$11 trillion ($11 ,000,000,000,000) is not a mistake or misspelling. Ceres is a member of USC AN
and a partner in GCCA. Ceres has been participating in the Climate Alarmism Enterprise since 1997
or earlier.
23.
Defendant Fenton Communications Corporation ("Fenton Communications") is a
public relations firm, calling itself"a social change communications agency". Defendants
MacArthur Foundation, Hewlett Foundation, and Packard Foundation are listed as its current clients.
To advance the interests of the Climate Alarmism Enterprise, Fenton set up and operated an entity
named Environmental Media Services from about 1994 until about 2005. Since about 2002-2005,
Fenton Communications managed or operated an entity named The Science Communication
Network, whose website stated that "The spirit of EMS will live on through EMS/Science
Communication Network ... " These might be one and the same entity. On information and belief,
Fenton Communications also serviced Defendants Earthjustice, Energy Foundation, EDF, Ford
Foundation, Greenpeace, Pew Trusts, Sierra Club, Tides, and WWF. Fenton Communications has
been participating in the Climate Alarmism Enterprise since 1994 or earlier.
D. Huge Transnational Green
24.
Defendants World Wildlife Fund for Nature (together, "WWF") comprise:
a) World Wide Fund Forfor Nature ("WWF-World") is a putative charitable trust, headquartered
in Gland, Switzerland. WWF-World comprises WWF International Secretariat, national offices,
regional offices, and associate organizations "in over 100 countries, on 6 continents". It reported
worldwide income in excess of $770 Million in 2015.
b) World Wildlife Fund, Inc. ("WWF-US") is a putative nonprofit corporation, headquartered in
Washington D.C. and registered for tax-exempt status as a Section 501(c)(3) natural resources
conservation and protection organization. It reported income in excess of $260 Million (possibly
included in the WWF World's income) and assets in excess of $470 Million for the 2015 tax
year. WWF-US calls itself a "part of the WWF global network". WWF-World calls WWF-US "a
national office".
WWF-US is a member ofUSCAN and a partner in GCCA. WWF-World is an observer member of
IPCC, a member of CAN, and a partner in GCCA. WWF-World and WWF-US are associated in
fact and it appears that each of them aided, abetted, counseled, commanded, induced, or procured
each other's actions alleged herein. This said, WWF-World, a foreign entity, is the master among
the two. WWF existed before the Scheme Period and has participated in the establishment and
operation of the Climate Alarmism Enterprise since early 1988 or earlier.
25.
Defendants Greenpeace (together, "Greenpeace") comprise:
a) Greenpeace International, aka Stichting Greenpeace Council, is a Dutch putative not-for-profit

foundation based in Amsterdam, the Netherlands.
10
b) Defendant Greenpeace, Inc. is a putative nonprofit corporation organized pursuant to the laws
of California and headquartered in Washington D.C., and is licensed to do business and raises
funds in the form of donations in many states throughout the United States, including Texas. It is
registered for tax-exempt status as a Section 50l(c)(4) "social welfare" organization with the
Internal Revenue Service, and describes its social welfare mission as "promot[ing] the protection
and preservation of the environment."
c) Defendant Greenpeace Fund, Inc. is also incorporated under the laws of California and
maintains its headquarters in Washington, D.C. Greenpeace Fund Inc. is a registered tax-exempt
501(c)(3) "charitable organization," and is licensed to do business and raises funds in the form of
donations in many states throughout the United States, including Texas. Greenpeace Fund Inc.
donates a significant funds each year to Greenpeace Inc. Both organizations share the same
address and some staff.
Greenpeace worldwide had income exceeding $380 Million and net assets exceeding $270 Million
(according to its 2015 report, including subsidiaries other than the Greenpeace Defendants.)
Greenpeace Inc. is a member of USCAN and a partner in GCCA. Greenpeace International is an
observer member of IPCC and a partner in GCCA. Greenpeace Defendants are associated in fact and
it appears that each of them aided, abetted, counseled, commanded, induced, or procured each
other's actions alleged herein. This said, Green peace International, a foreign corporation, alone or in
combination with its European branches, is the master among the Greenpeace Defendants.
Greenpeace existed before the Scheme Period and has participated in the establishment and
operation of the Climate Alarmism Enterprise since early 1988 or earlier.
26.
Defendants Friends of Earth (together, "FOE") comprise:
11
a) Defendant Friends of the Earth International ("FOEI") is another putative Dutch not-for-profit
foundation based in Amsterdam, the Netherlands. It claims to be "the world's largest grassroots
environmental network."
b) Defendant Friends of the Earth Corporation ("FOE US"), aka Friends of the Earth U.S., is a
putative nonprofit corporation, headquartered in Washington D.C. and registered as a tax-exempt
501 (c)(3) "educational organization".
c) Defendant Friends of the Earth (Action) Inc. ("FOE US ACTION"), is a putative nonprofit
corporation, headquartered in Washington D.C. and registered as a tax-exempt 501(c)(4) "civic
league". FOE US and FOE US ACTION share the same address.
The abbreviation "FOE" was selected by the FOE Defendants, not by Plaintiff. FOE has worldwide
annual income between $40M and $400M. FOE-US is a member of US CAN. A number of national
branches of FOEI are partners of in GCCA. The FOE Defendants are associated in fact and it
appears that each of them aided, abetted, counseled, commanded, induced, or procured each other's
actions alleged herein at any time both existed. This said, FOEI, a foreign corporation, alone or in
combination with its European branches, is the master among the FOE Defendants. The FOE
Defendants have been participating in the Climate Alarmism Enterprise since 1989 or earlier.
E. Big Green
27.
Defendants Environmental Defense Fund (together, "EDF") comprise:
a) Defendant Environmental Defense Fund, Inc. ("EDF-INC") is a putative nonprofit

corporation, headquartered in New York, NY, and registered as a tax-exempt 501(c)(3)
"educational organization", with annual income in excess of $188 Million and net assets in
excess of $204 Million (according to its 2014-2015 tax reporting). EDF-INC also has offices in
Beijing, China; London, UK; and La Paz, Mexico. EDF-INC is an observer member of IPCC
12
and a member ofUSCAN. EDF-INC existed before the Scheme Period and has participated in
the establishment and operation of the Climate Alarmism Enterprise since early 1988 or earlier.
b) Defendant Environmental Defense Action Fund Corporation ("EDF-AF") is a lobbying arm
ofEDF, headquartered in New York, NY, and registered as a 501(c)(4) "social welfare
organization". EDF-AF share the address and some staff with EDF-INC. EDF-AF has been
participating in the Climate Alarmism Enterprise since its incorporation in 2003.
The EDF Defendants are associated in fact and it appears that each of them aided, abetted,
counseled, commanded, induced, or procured each other's actions alleged herein at any time both
existed.
28.
Defendants Natural Resources Defense Council (together, "NRDC") comprise:
a) Defendant Natural Resources Defense Council, Inc. ("NRDC-INC") is a putative nonprofit

corporation, headquartered in New York, NY, and registered as a tax-exempt 501(c)(3)
"charitable organization", with annual income in excess of $151 Million and net assets in excess
of $246 Million (according to its 2014-2015 tax reporting). NRDC-INC also has an office in
Beijing, China. NRDC-INC is an observer member of IPCC, a member of USC AN, and a
partner in GCCA. NRDC-INC existed before the Scheme Period and has participated in the
establishment and operation of the Climate Alarmism Enterprise since early 1988 or earlier.
b) Defendant NRDC Action Fund Corporation ("NRDC-Action") is a lobbying arm of the
NRDC, headquartered in New York, NY, and registered as a 501(c)(4) "civic league". From its
website: "As a 50l(c)(4) nonprofit organization, the NRDC Action Fund engages in various
advocacy and political activities for which the Natural Resources Defense Council, a 50l(c)(3)
organization, faces certain legal limitations or restrictions. " NRDC-Action shares an address
and some staff with NRDC-INC. NRDC-Action has been participating in the Climate Alarmism
Enterprise since its incorporation in 1998.
13
NRDC Defendants are associated in fact and it appears that each of them aided, abetted, counseled,
commanded, induced, or procured each other's actions alleged herein at any time both existed.
29.
Defendants Sierra Club (together, "Sierra Club") comprise:
a) Defendant Sierra Club Corporation ("SCC") is a putative nonprofit corporation, headquartered

in San Francisco, CA, and registered as a 501(c)(4) "social welfare organization", with annual
income in excess of $113 Million and net assets in excess of $63 Million (according to its 2013
tax reporting). SCC is what most people think of as the "Sierra Club". SCC is a member of
USCAN and a partner in GCCA. Also, SCC openly endorses candidates in national and many
state elections, including candidates for the President, U.S. Senate, and U.S. House of the United
States Representatives. SCC has been participating in the Climate Alarmism Enterprise since
200 1 or earlier.
b) Defendant The Sierra Club Foundation Corporation ("SCF") is a putative nonprofit
corporation, headquartered in Oakland, CA, and registered as a tax-exempt 501(c)(3) "charitable
organization", with annual income in excess of $82 Million and net assets in excess of $85
Million (according to its 2013 tax reporting). On its website, SCF describes its relationships
with SCC as follows: "As the fiscal sponsor of the charitable programs of the Sierra Club, we
provide resources to it and other nonprofit organizations ... " and "We achieve our shared vision
of a healthy planet through collaboration with the Sierra Club, our donors, and stakeholders."
SCF and SCC share the same address. SCF has been participating in the Climate Alarmism
Enterprise since 2001 or earlier.
The Sierra Club Defendants are associated in fact and it appears that each of them aided, abetted,
counseled, commanded, induced, or procured each other's actions alleged herein at any time both
existed.
14
c) Defendant Earthjustice Corporation ("Earthjustice"), formerly Sierra Club Legal Defense

Fund, is a putative nonprofit corporation, headquartered in San Francisco, CA, and registered as
a tax-exempt 501(c)(3) "charitable organization", with annual income in excess of $54 Million
and net assets in excess of $68 Million (according to its 2014-2015 tax reporting). Defendant
Earthjustice is a member of USCAN. Earthjustice has been participating in the Climate
30.
Defendant The Union of Concerned Scientists, Inc. ("UCS") is a putative nonprofit
corporation, headquartered in Cambridge, MA, and registered as a tax-exempt 501(c)(3) "charitable

organization", with annual income in excess of $38 Million and net assets in excess of $37 Million
(according to its 2014-2015 tax reporting). Defendant UCS is a member ofUSCAN and a partner in
GCCA. The Defendant's name is intentionally misleading- UCS is not a scientific organization,
has no special affinity to any science or scientific organization, and the majority of its directors and
executive officers are non-scientists. UCS has been participating in the Climate Alarmism Enterprise
since 1993 or earlier.
F. Foundations
31.
Defendant Ford Foundation ("Ford Foundation") is a putative nonprofit trust treated
as a private foundation, headquartered in New York, NY, and registered as a tax-exempt 501(c)(3)
"charitable organization", with annual income exceeding $800 Million and net assets exceeding $11
Billion (according to its 2013 tax reporting). The Ford Foundation grew richer by more than $1
Billion in 2013 alone. The Ford Foundation is a participant in the Financial Cartel, a member in the
EGA, and a participant in the CGBD. The Ford Foundation has been participating in the Climate
32.
The Defendants Pew Trusts Defendants comprise:
15
a)
Defendant The Pew Charitable Trusts is a tax-exempt 501(c)(3) putatively
"charitable organization", headquartered in Philadelphia, PA, with net assets exceeding $800M
(according to its 2014 tax reporting). It calls itself "a global non-governmental organization:":
b)
Defendant The Pew Memorial Trust is a tax-exempt 501(c)(3) trust, headquartered
in Philadelphia, PA, with net assets exceeding $2.9B (according to its 2014 tax reporting).
c)
Defendant J. Howard Pew Freedom Trust is a tax-exempt 501(c)(3) trust,
headquartered in Philadelphia, PA, with net assets exceeding $600M (according to its 2014 tax
reporting).
d)
Defendant Mabel Pew Myrin Trust is a tax-exempt 501(c)(3) trust, headquartered in
Philadelphia, PA, with net assets exceeding $370M (according to its 2014 tax reporting).
e)
Defendant J.N. Pew Jr. Charitable Trust is a tax-exempt 501(c)(3) trust,
headquartered in Philadelphia, PA, with net assets exceeding $290M (according to its 2014 tax
reporting).
The latter four trusts share the same address and, upon information and belief, are effectively
controlled by the Pew Charitable Trusts. The total net assets of Pew Trusts exceed $4B. Pew Trusts
also funds and operates the Pew Research Center, using it to further the Climate Alarmism
Enterprise, among other things. In or around 2002, Pew Trusts created and funded a putative nonprofit, Strategies for Global Environment Inc., doing business as Pew Center for Climate and Energy
Solutions until2007-2008, then Pew Center on Global Climate Change until2011-2012, then and
finally as the Center for Climate and Energy Solutions. Thus, already in 2011-2012 Pew Trusts tried
to hide its role in the Climate Alarmism Enterprise. Pew Trusts is a member in of US CAN, a
participant in the Financial Cartel, a member in of EGA, and a member in of CGBD. The Pew Trusts
have been participating in the Climate Alarmism Enterprise since 1994 or earlier.
16
33.
Defendant Rockefeller Brothers Fund, Inc. ("RBF") is a 501(c)(3) exempt private
foundation, headquartered in New York, NY, with annual income exceeding $100 Million and net
assets exceeding $800 Million (according to its 2014 tax reporting). RBF is a participant in the
Financial Cartel, a member (and possibly a leader) of EGA, and a member of CGBD. RBF has been
participating in the Climate Alarmism Enterprise since 1993 or earlier.
34.
Defendant The John D. and Catherine T. MacArthur Foundation ("MacArthur
Foundation") is a putative nonprofit corporation, headquartered in Chicago, IL, and registered as a

tax-exempt 50l(c)(3) "charitable organization", with net assets exceeding $6 Billion (according to
its 2014 tax reporting). The MacArthur Foundation is a participant in the Financial Cartel, a member
of EGA, and a member of CGBD. The MacArthur Foundation has been participating in the Climate
35.
Defendant The William & Flora Hewlett Foundation ("Hewlett Foundation") is a
putative nonprofit private foundation, headquartered in Menlo Park, CA, and is registered as a taxexempt 50l(c)(3) "charitable organization", with annual income exceeding $280 Million and net
assets exceeding $8 Billion (according to its 2013 tax reporting). Hewlett Foundation is a participant
in the Financial Cartel, a member of EGA, and a member of CGBD. The Hewlett Foundation has
been participating in the Climate Alarmism Enterprise since 2002 or earlier.
36.
Defendant The David and Lucile Packard Foundation ("Packard Foundation") is a
putative nonprofit private foundation, headquartered in Los Altos, CA, and registered as a taxexempt 50l(c)(3) "charitable organization", with annual income exceeding $390 Million and net
assets exceeding $6 Billion (according to its 2013 tax reporting). The Packard Foundation is a
participant in the Financial Cartel, a member of EGA, and a member of CGBD. The Packard
Foundation has been participating in the Climate Alarmism Enterprise since 2002 or earlier.
17
G. Pass-through Funders
37.
The Tides Defendants Tides comprise:
a)
Defendant Tides Foundation Corporation ("Tides-F") is headquartered in San
Francisco, CA, and registered as a tax-exempt 501(c)(3) "charitable organization", with annual
income in excess of $180 Million and net assets in excess of $170 Million (according to its 2014 tax
reporting).
b)
Defendant Tides Center Corporation ("Tides-C") is headquartered in San
Francisco, CA, and registered as a tax-exempt 501(c)(3) "charitable organization", with annual
income in excess of $95 Million and net assets in excess of $75 Million (according to its 2014 tax
reporting).
Tides-F was incorporated in 1977, and spawned Tides-C in or around 1995. These entities share
some directors and officers and are so closely related, that they even have the same website,
www .tides.org. Since incorporation of Tides-F, Defendants Tides served as pass-through entities,
used to finance and/or incubate left radical leftist groups. The Tides Defendants are associated in fact
and it appears that each of them aided, abetted, counseled, commanded, induced, or procured each
other's actions alleged herein at any time both existed. The Tides Defendants have been
participating in the Climate Alarmism Enterprise since 1996 or earlier.
38.
Defendant ClimateWorks Foundation Corporation ("'Climate Works") is a putative
nonprofit corporation, headquartered in San Francisco, CA, and registered as a tax-exempt 501(c)(3)
"charitable organization", with annual income in excess of $180 Million and net assets in excess of
$160 Million (according to its 2014 tax reporting). In 2008, it received income in excess of $490
Million and ended that fiscal year with net assets in excess of $410 Million. ClimateWorks is a
participant in the Financial Cartel, a member of EGA, and is a partner in CGBD. ClimateWorks was
18
incorporated in 2008 or earlier with the single purpose of advancing the interests of the Climate
Alarmism Enterprise.
39.
Defendant The Energy Foundation Corporation ("Energy Foundation") is a
putative nonprofit corporation, headquartered in San Francisco, CA, and registered as a tax-exempt
501(c)(3) "charitable organization", with annual income in excess of$130 Million and net assets in
excess of $50 Million (according to its 2013 tax reporting). The Energy Foundation is a participant
in the Financial Cartel, a member of EGA, and a partner in CGBD. The Energy Foundation was
incorporated in 1991 and has been participating in the Climate Alarmism Enterprise since 2001 or
earlier.
G . .John and .Jane Does
40.
.John and .Jane Does 1 through 99, whose identities are presently unknown to
Plaintiff, include other participants in the Climate Alarmism Enterprise, as well as other
accomplices, co-conspirators, and/or aiders and abettors of the named Defendants in the scheme,
enterprise, and other misconduct alleged in this complaint.
STATEMENT OF FACTS
A. The Criminal Enterprise
The Enterprise Structure
41.
Majority of the Defendants used to be non-profit or charitable organizations, and
enjoyed public trust, which they betrayed and abused even before they launched or joined the
Climate Alarmism Enterprise. By abusing the public trust, these Defendants drifted far from their
declared goals. While doing so, they got accustomed to acting lawlessly and with impunity.
19
42.
All named Defendants invested at least part of their income in the operation of the
Climate Alarmism Enterprise.
43.
All named Defendants received at least part of their income from their participation in
the Climate Alarmism Enterprise.
44.
All the Defendants have been associated with the Climate Alarmism Enterprise
continuously and participated in its conduct through a pattern of racketeering activity, as defined in
18 U.S. Code 1961.
45.
The Climate Alarmism Enterprise has a complex and opaque structure, including
roles differentiation among participants. Based on the available information and belief, the
following non-exclusive specialization can be observed among the Defendants:
a)
Greenpeace and WWF are likely to be the top bosses among the Defendants.
b)
WWF, having European royals among its founders, provides or provided much of the
top-level of political connections, funding, and mainstream image.

c)
Greenpeace is or was an "enforcer", using its media influence, corrupt politicians, and
defamation campaigns to suppress opposition to the Climate Alarmism Enterprise.

d)
FOE used to serve as a conduit between the Climate Alarmism Enterprise and armed
terrorist groups, guerilla armies, current or former rogue regimes, or their supporters and front
groups.
e)
The alleged Financial Cartel and the Foundations used to be among the primary
funders of the Climate Alarmism Enterprise. They might have served or still serve as internal
enforcers, by cutting funding to the Enterprise members that disobey orders. Notably, funding
20
provided by the Financial Cartel and the Foundations Defendants is amplified many times through
misuse of public money.
t)
The Pass-through Funders appear to be tasked with obfuscating the flow of funds
from external sources and between the participants in the Climate Alarmism Enterprise.
g)
Defendants Sierra Club, EDF, NRDC, Earthjustice, USCAN, and UCS have been
primarily tasked with carrying out the policies of the Climate Alarmism Enterprise in the United
States. These policies include, but are not limited to, corrupting the election process.
This differentiation of roles is relative (not absolute), and alleged on information and belief. The
participants in the Climate Alarmism Enterprise performed and currently perform tasks, not typical
to the described roles. Each Defendant has also committed and/or continues committing other
actions, alleged about that Defendant in other paragraphs of this Complaint. Further, the Defendants
regularly engage in deception, so that the available information about their roles and, consequently,
their description in this paragraph might be inaccurate. The Defendants have or should have better
knowledge of their specializations.
46.
All named Defendants are corporations, funds, or foundations. Almost all are
headquartered either abroad, in DC, New York, or California.

47.
The following matrix ("Mutual Funding Matrix") shows some of the financial
relationships between the Defendants.
21

,.,
s::
..
;::.
"0
01
Q.l
,.,
0..
"'
a.
,.,
Q.l
:::T
c,
:::l
i5"
0..
0..
i5"
Pew Trusts
MacArthur Foundation
Hewlett Foundation
DD
Packard Foundation
R
x
R
ClimateWorks Foundatior R
Energy Foundation
WWF
Green peace
R
GIM-ACP
Ceres
R
R
EGA
CGBD (Consultative Grou~
UCS (Union of Concerned
EDF {Environmental Defer
NRDC {Natural Resources
Sierra Club
EarthJustice
USCAN (US Climate Action
Fenton Communications
)>
R,D
R,D
R,D
R,D
R
R
R
R
R
R
:::l
i5"
:::l
:::l
s.
"'c
:::l
Ill
....,
:?
~
c,
:::l
3
3
3"
D
D
R,D
D
R
:::l
D
D
D
D
Ill
Vl
Q.l
Ill
D
D
D
D
D
D
X
X
R
R
R
R,D
R
R
R
R
D
D
D
R
D
D
R
R
R
R
D
D
x
R
"R" means that the Defendant(s) in the row received direct funding from the Defendant(s) in the
column. "D" means that the Defendant(s) in the row gave direct funding to the Defendant(s) in the
column. Only money transfers, reported on Forms 990 from 2003, are included. The Defendants
also render "in- kind" services to each other, make payments to related parties, transfer money to
each other through third parties, and have undisclosed financial links.
48.
D
D
Vl
~-
::t1
Q.l
,.,
,.,0
:::l
Vl
:::l
...i5"
txJ
G\
-;:;
Q.l
0..
)>
Ill
DOD
G\
"'
xDDDDDD
FOE
n
~
Ill
Ill
:::l
Tides
D
R
,.,
0
:::l
""0
,.,
D
x
Ill
:::l
RBF
ffi
:::l
Q.l
Ford Foundation
;;;
:::l
G\
,.,
0..
-I
a:
This matrix shows that the Defendants RFB, Pew Trusts, MacArthur Foundation,
Hewlett Foundation, and Packard Foundation, all being members of the Environmental Grantmakers
Association and participants in the alleged Financial Cartel, together or provided direct funding to
all the named Defendants, with the possible exception of the Ford Foundation and Hoggan &
Associates. The latter receives or received indirect funding from the Defendants RFB, Hewlett
Foundation, and Packard Foundation through a non-defendant Suzuki Foundation, which has the
President of Hoggan & Associates as a board director.
22
49.
Defendants are linked in more ways than financial relations. Many apparently
separate (i.e., using different brand names) Defendants are interlinked through shared personnel,
including officials (board directors or officers), who serve two or more apparently separate
Defendants simultaneously. Many apparently separate Defendants are further interconnected
through officials, that served those multiple Defendants consecutively.
50.
Directors, officers, employees, and/or agents of apparently separate Defendants
regularly meet at international conferences and other gatherings. In some of these meetings they
discuss operation and management of the Climate Alarmism Enterprise, and conspire to commit
offenses, including but not limited to the predicate offenses under 18 U.S.C. 1961(1).
51.
Some of the apparently separate Defendants in the categories Big Green and Huge
Transnational Green share among them their membership lists with each other, acting as an
association-in-fact, and disregarding the privacy of their members.

52.
Defendants in categories Foundations, Big Green, and Huge Transnational Green
regularly permitted other members of the Climate Alarmism Enterprise, their allies, and some
marketing accessories to use of their brands, trademarks, and other closely held intellectual property
for the benefit of the Climate Alarmism Enterprise.
53.
On information and belief, Defendants gather, collect, store, and share with other
Defendants and third parties, both in the USA and abroad, personal information about their donors,
websites visitors, and opponents.
54.
Greenpeace possesses what it calls a "battle fleet", including a former Soviet naval
vessel, (larger than a typical World War II destroyer), speedboats, helicopters, drones, submarines,
and military-grade communication equipment. This "battle fleet" also includes a super-luxurious
yacht Rainbow Warrior, custom designed and built for Greenpeace. With its characteristic
23
derangement, Greenpeace asserts that: the "The Greenpeace fleet ofships is a unique asset in the
battle to save planet Earth ... "
55.
The Greenpeace "battle fleet" regularly engages in provocative naval maneuvers
against the US Navy ships.

56.
Criminal misconduct, giving rise to-this lawsuit, was conducted by an illegal
enterprise (the "Climate Alarmism Enterprise") consisting of various legally distinct but associatedin-fact organizations and individuals, who associated together for nefarious purposes, including
and/or requiring carrying out the pattern of racketeering activity alleged herein. This pattern of
racketeering activity included, but was not limited to retaliation against witnesses, tampering with
witnesses, making bribes to witnesses and public officials, theft of and/or embezzlement from
pension and/or welfare funds, and attempts and conspiracies to do the same. The Climate Alarmism
Enterprise associated for the purpose of carrying out these racketeering acts comprises all the
Defendants, as well as other persons.
57.
Although the Defendants are legally distinct from each other, and free to act in and
advance their own interests independently, they have associated in fact with a common purposes,
identifiable relationships, and sufficient longevity to pursue their common purposes. Specifically,
beginning from early 1988 through the present they have been engaged in a mutually understood,
agreed upon, and coordinated campaign of racketeering activity with the intent of obtaining huge
profits, degrading American scientific and intellectual capacity, creating internal polarization,
establishing the Climate Cult as the state religion, and undermining national energy infrastructure
and economy.
58.
On a frequent and long-term basis, the Defendants and enterprise members
collaborate and conspire with third-parties, currently unknown to Plaintiff, to retaliate against
24
witnesses, to tamper with witnesses, to bribe witnesses and public officials, or to steal from public
funds. This is a part of a broader enterprise practice.
59.
The Climate Alarmism Enterprise's campaign has entailed significant contacts with
and effects in Texas.
The Enterprise Allies
60.
From the beginning the Climate Alarmism Enterprise had powerful allies with
immunity from prosecution. Certain United Nations agencies, foreign governments, foreign and
international political parties, and their personnel with diplomatic immunity were among those allies.
Specifically, these allies include or included The United Nations Environmental Programme
(UNEP), the World Meteorological Organization (WMO), the United Nations Framework
Convention on Climate Change (UNFCCC - a namesake of a Convention, signed and ratified by the
US), the International Union for Conservation of Nature, and the Secretary-General of the United
Nations.
61.
The Plaintiff notes that the top position in the United Nations organization is called
Secretary-General, just like the top position in the former Soviet Union and in the former
Communist Party of the USSR. In the Soviet Union, Stalin used his temporary authority as a
"secretary" of a central committee of the ruling party to consolidate all power into his own hands.
62.
The most important ally of the Climate Alarmism Enterprise is the UN agency
Intergovernmental Panel on Climate Change (IPCC), headquartered in Geneva, Switzerland. It
was created in 1988 by a decision of UNEP and WMO and was given a number of mutually
contradictory tasks, from gathering scientific evidence of supposedly harmful anthropogenic climate
change to "telling the governments what to do".
25
63.
The IPCC is a political organization, not a scientific one. All 195 sovereign
governments UN members are also members of the IPCC. Each of them has one vote, irrespective
of their size, economic development, or scientific capacity. Additionally, a number of international,
transnational and foreign organizations, including some Defendants, are "observers". They do not
have voting rights, but can and do lobby the delegates, and have access to the otherwise confidential
information.
64.
IPCC Plenary Sessions appoint the IPCC Secretariat, IPCC Bureau, and IPCC
Executive Committee. One country- one vote; non-Western countries vote in accordance with their
interests or perceived interests. The Climate Alarmism Enterprise promised the so-called "thirdworld" countries that they would receive financial compensation from the US and other Western
countries upon "finding" that carbon dioxide emissions had caused dangerous climate change. Some
IPCC member countries are very small and poor, having budgets that are tiny compared to budgets
of some of the Defendants, and their governments are easily manipulated by Defendants.
65.
The main official products from the IPCC are so-called "Assessment Reports",
produced each 5-6 years. Besides stacking IPCC governing bodies with politicians, sympathetic to
the climate alarmism, a number of devices have been employed to bias IPCC reports even further:
a)
The IPCC does not perform any proper searches to fill responsible positions,
requiring scientific knowledge, such as Lead Authors. The Lead Authors are free to include or
exclude whomever they wish and whatever they wish in the preparation of the reports.
b)
The IPCC does not compensate authors working for it or contributing to its reports,
ensuring selection of authors favoring special interests, especially the Defendants.

c)
On each report, three working groups work in at the same time, in parallel: WGI
works on the physical science of the so-called "climate change"; WGII analyzes the supposed
impacts, vulnerability, and adaptation to the "climate change"; and WGIII is devoted to what IPCC
26
calls "mitigation". This is a sham. Evidently, WGII and WGIII are expected to be prescient about
the future conclusions of WGI regarding the physics of climate, even before WGI started its work,
and are sure that the conclusions would require "adaptation" and "mitigation".
d)
Each working group produces its own report. Then, these reports are merged, purged
of information about the benefits of carbon dioxide fertilization to the agriculture and nature, purged
of criticism of the computer models, and summarized into a draft Summary for Policymakers. This
draft is then brought in front of the political representatives of the 195 countries (including North
Korea, Cuba, ... , Tuvalu) who mess with its text until the Summary is approved by political
consensus.
e)
The last step in the "Assessment Report" preparation is the most bizarre one. The
IPCC changes the reports, produced by the working groups of scientists and putative scientists, to
match the changes, made by the political representatives of the 195 countries (including North
Korea, Cuba, ... , Tuvalu)! This step is not disclosed in the texts of these reports. On the contrary,
the reports contain recommendations to cite them as scientific literature.
f)
Neither the full "Assessment Reports" nor the Summaries for Policymakers are peer-
reviewed.
66.
Almost from the beginning, the IPCC served as a barrier to communication between
the scientists and general public, and as a tool to promote climate alarmism. This is clear in
hindsight, but the scientists could not know at the time that was happening. A number of
distinguished scientists participated in the work of the IPCC, contributed to the "Assessment
Reports", and even served as Lead Authors. Almost all of them condemned or heavily criticized the
IPCC process.
27
67.
Defendants heavily influenced the IPCC, using their privileged access as observers,
infiltrated IPCC working groups, injected their own papers into the scientific materials, reviewed by
the IPCC, and made undisclosed financial deals with IPCC head Rajendra Pachauri.
68.
Defendants Greenpeace, WWF, NRDC, and some agents or employees of other
Defendants had access to the confidential IPCC information, and used this access to become de-facto
speakers of IPCC and the main source of climate information for the general media. They used this
power to communicate their own message, falsely attributing it to the IPCC. For example, they
spread disinformation that the so-called "climate change" caused or would cause an increase in the
frequency or severity of hurricanes, even as the IPCC Summary for Policymakers flatly rejected that
claim.
69.
Defendants, together with their accessories and allies, spread other lies with the intent
to exaggerate the value of the IPCC, and their own weight as carriers and interpreters of the IPCC
message:
a)
Defendants, together with their accessories and allies, falsely claimed that IPCC texts
were peer-reviewed;
b)
Defendants, together with their accessories and allies, falsely claimed that IPCC
represented the consensus of thousands of scientists. In fact, the IPCC used the work of thousands
of scientists, but the vast majority of these scientists did not even how IPCC used their work, and
those scientists who did, had frequently rejected or otherwise disapproved of the IPCC conclusions.
70.
Thanks to the participation of legitimate scientists, the full IPCC "Assessment
Reports", especially contributions of the Working Group I, do contain large amounts of valuable
information. In particular, the scientists preparing the Third Assessment Report (published in 2001)
concluded that the global temperature changes and other "climate change" events they studied were
mostly natural variations, rather than consequences of human activity. Human activity was a minor
28
or even undetectable factor, and any rationalization for climate alarm disappeared. In the Third
Assessment Report, IPCC buried this discovery by re-defining the term climate change from
"anthropogenic change of climate in addition to the natural variability" to "change of climate due to
either natural variability, external forcing, or human activities."
Accessories, Front Groups, and former "Mainstream"
71.
From its inception, the Climate Alarmism Enterprise was tightly linked to UN
agencies. In the 1960's the United Nations strayed from its original purpose to aid the nations to live
in peace with each other. In 1972, Kurt Waldheim, a former Nazi officer who participated in mass
murder and deportations to exterminations camps, was appointed the UN Secretary-General. He was
re-appointed in 1976, and continued in this position until 1981. Climate alarmism absorbed and put
to its own use a lot of Nazi ideology. In particular, it adopted and applied the Nazi principle of
propaganda: "Make the lie big, make it simple, keep saying it, and eventually they will believe it."
72.
In order to advance its interests, the Climate Alarmism Enterprise established and/or
operated a large number of front groups, which acted as its agents. Further, the Climate Alarmism
Enterprise financed and directed some activities of other organizations.
73.
Among the organizations, which partnered or associated with the Climate Alarmism
Enterprise, and aided Defendants in commission of at least some of the alleged predicate criminal
acts, are the Center for American Progress, the Center for Media and Democracy, Media Matters,
and 350.org.
74.
To advance interests of the Climate Alarmism Enterprise, Defendants, their
accessories, accomplices, and front groups established and/or operated hundreds or thousands of
websites whose only purpose was to advance the interests of the Climate Alarmism Enterprise.
These sites include but are not limited to desmogblog.com, realclimate.org, skepticalscience.com,
29
insideclimatenews.org, climateaccountability.org, climatetruth.org, ourchildrenstrust.org,

eenews.net, polluterwatch.org, sourcewatch.t7rg, prwatch.org, climateprogress.org,
climaterealityproject. org, climatepolicyinitiative. org, climatefeedback. org,
climatechangecommunication.org, climatedesk.org, texasclimatenews.org, and climatenexus.org.
Most of these websites still operate. They and many other alarmist websites present themselves as
independent media outlets, featuring different "editorial teams" and authors, while in fact they were
and continue to be agents and marketing accessories of Defendants. Herein, an organization (which
might be an individual, an unincorporated entity, or an association-in-fact) is recognized as a
"marketing accessory" if all the following statements are true about it:
Most of its income comes, directly or indirectly, from the Defendants, or is conditioned on the
Defendants' approval; this includes funding from government agencies and quasi-governmental
non-profits that are or have been subject of the corrupt influence of the Defendants.
It frequently criticizes individuals, organizations, or governments, but does not criticize the
Defendants or their associates, or criticizes them only for insufficient devotion to the interests of
the Climate Alarmism Enterprise.
It does not exercise editorial discretion, or exercises only as much discretion as is typical to
marketing departments of non-media companies; lack of restraint in smearing opponents of the
Climate Alarmism Enterprise is not considered as "editorial discretion" for the purpose of this
definition.
Its message was abnormally synchronized with the message of the Climate Alarmism Enterprise
over long periods of time, especially when that involved repeating false or even absurd
statements and numbers, such as "97% of scientists agree".
75.
The Defendants' marketing accessories have been continuously repeating this "97%"
number since 2004, despite several obvious facts:

30
The "97%" number looks more like an outcome of voting in a Communist country, than a
survey of scientists' opinions.
This exact number has been alleged to come out of multiple "studies", conducted over the
period 2004-2015, something having a lower probability than winning a jackpot in the
Powerball two years in a row.
All "studies," allegedly showing this number, were immediately debunked.
The subject of the "agreement" was different in all the "studies", but the "97%" number was the
same.
Of course, this is not the fault of the copywriters working for the Defendants and their marketing
accessories. They received orders to write "97%", and carried them out. Those who had refused
went to look for other jobs.
76.
Some other websites that Defendants used to advance the Climate Alarmism
Enterprise are ecowatch.com, grist.org, thinkprogress.org, and takepart.com, which followed the
instructions of the Climate Alarmism Enterprise on the subjects of interest to the Enterprise, but not
necessarily on other subjects.
77.
Nevertheless, Defendants, using the marketing accessories in concert with each other,
heavily influenced witnesses in official proceedings, and, consequently to that, a large part of public
officials and of the general public. The impact of this corrupt persuasion was especially strong on
the scientific topics, because most people could not evaluate these topics themselves, and
Defendants successfully muzzled scientists, opposing their assault.
78.
Some, but not all, acts of retaliation against witnesses, tampering with witnesses, and
cover-ups of other criminal acts committed by Defendants were largely performed by utilizing the
marketing accessories.
31
79.
Since at least 2004, the Defendants and their marketing accessories compiled and
published on the Internet databases and lists of scientists, who testified or were expected to testify in
official proceedings adversely to the Defendants' interests (the "Target Lists"). As of the date of this
filing, Defendants and their marketing accessories continue to publish, expand, market, and promote
these Target Lists.
80.
Some of the most notorious Target Lists have been published by desmogblog.com,
Greenpeace, and the Center for Media & Democracy. The names of the individuals on the Target
Lists were linked to descriptions, containing outrageous lies about those persons. Some descriptions
openly stated for which testimony and even for which words the individual had been placed on the
Target List.
81.
These descriptions had cross-references to each other, and claimed to be and actually
created impression of well-researched articles, when in fact they were and still are lies, made up by
directors, officers, employees, or agents of Defendants or their co-conspirators, and repeated ad
infinitum.
82.
Acting in concert with each other, Defendants made references and web links to these
libelous descriptions of the targeted individuals on other websites, further disseminating their lies
and causing search engines to rank these injurious articles at or near the top of the search results,
when somebody searches for information about those individuals. The affected search engines
include but are not limited to Google, Microsoft Bing, and Yahoo Search.
83.
On their highly trafficked websites, Defendants and their accomplices placed calls for
action next to the names and libelous characterizations of their victims. Notably, many of the
Defendants' websites are intended for audiences with a large percentage of mentally underdeveloped
and emotionally unstable persons.
32
84.
Nevertheless, in many cases the only actions, that Defendants wanted from their site
visitors, was to donate them money, and to spread the word so that more people would donate more
money.
85.
For example, some individuals on the Target List of desmogblog.com are: lvar
Giaever, a Nobel Prize Laureate in Physics; Frederick Seitz, a distinguished physicist, and former
President of the National Academy of Science; and Fred Singer, a distinguished physicist, the
founder of the National Weather Satellite Service; and so on.
86.
The Target List of desmogblog.com was referred and linked to in publicly
broadcasted calls to murder individuals on that list.

87.
As time passed, Defendants added to the Target Lists some elected politicians and
authors that they particularly hated.

88.
The following table ("Marketing Accessories Funding") shows support of some
marketing accessories by Defendants and their allies:

Organization
Websites
"T'I
..,
;>;:1
OJ
a.
"T'I
s::
Ql
..,)>
.....
"T'I
~
~
..,
:J
a.
Ql
.....
"T'I
ci"
:J
:J
a.
Ql
.....
::c
ro
::E
iii"
::+
"T'I
""0
Ql
"'
..,
Ql
a.
--1
c:
"'
ro
:J
ro
:J
a.
.....
s::
""0
Ql
a.
:J
a
:J
"T'I
Gl
):..
n
:J
"C
<
a.
Ql
.....
Gl
..,
ro
ro
OQ
"T'I
m
ro
..,
:J
ro
Ql
.....
Ql
climateprogress.org, thinkprogress.org
CMD
prvvatch.org,sourcevvatch.org
CAl
lnsideCiimate Nevvs
climateaccountability.org
insideclimatenevvs.org
F
F
Media Matters
mediamatters.org
grist.org
realclimate.org
SCN
Suzuki Foundation
realclimate.org
sciencecommunicationnetvvork.org
davidsuzuki.org
skepticalscience.com skepticalscience.com
2;1
c:
3
3
:::s
:J
g.
Ill
G)
0
<::
Ill
!:::!".
:::s
""'
:::s
Ill
:::s
Cl"
:J
"'
Hoggan & Associates desmogblog.com, hoggan.com

Green peace
pollutervvatch.org
Grist
""'
.o
:::s
:J
:J
CAP
2;1
c:
;:;
Ql
.....
:J
:J
VI
"T'I
:J
.....
0
ro
F
F
F
K
K
F
F
F
F
F
F
F
F
F
F,K
33
--------------
"F" stands for direct funding, as shown on Form 990, and "K" stands for the in-kind services.
Desmogblog.com (DeSmog) was launched and has been operated by James Hoggan of Hoggan &
Associates and the David Suzuki Foundation. Desmogblog.com also received funding from proceeds
of money laundering by John Lefebvre, who was convicted of money laundering. CAP stands for
the Center for American Progress. CMD stands for the Center for Media & Democracy. CAl stands
for the Climate Accountability Institute.
89.
Even more amazing are the substantial payments made by Defendants to some former
scientific organizations, and the formerly mainstream newspaper The New York Times. These
payments, as well as payments to the America-hating British paper The Guardian, are shown in the
following table ("Defendants Funding Others"):
Organization
"T1
0
......
a.
"T1
c
:::s
a.
QJ
1""'1"
6"
:::s
::::c
0
n
s:
QJ
"C'C'DD
C'D
"T1
"T1
......
c
:::s
a.
V'l
)>
......
1""'1"
:::J'"
::c
:E
c
:::s
a.
QJ
!:!".
0
......
Otl
C'D
<
1""'1"
1""'1"
"T1
......
:::::tJ
0
C'D
c
:::s
a.
QJ
!:!".
0
:::s
"T1
"T1
c
a.
:::S
QJ
!:!".
0
:::s
c
:::s
a.
QJ
. !:!".
0
~
~
rl)
:::::::
rl)
..,
;r
:::s
:::s
NAS
AAAS
F
F
National Geographic Society
F
F
American Geophysical Union

New York Times Company
The Guardian (Guardian News & Media LLC)
F
F
F
F
F
F
F
F
F
F
F
F
F
F
NAS is the National Academy of Sciences, which used to be the top scientific body of the nation.
From its website: "The National Academy of Sciences (NAS) is a private, non-profit society of
distinguished scholars. Established by an Act of Congress, signed by President Abraham Lincoln in

1863, the NAS is charged with providing independent, objective advice to the nation on matters
related to science and technology. "
34
AAAS is the American Association for the Advancement of Science, and calls itself "The World's
Largest General Scientific Society." It was once a reputable scientific society with open
membership, and the publisher of the journal Science.

The New York Times Company (NYT) is a for-profit corporation, which makes "donating" to it
even stranger.
Plaintiff does not know what strings were attached to these payments, but Defendants do or should
know. All these organizations aided and continue to aid the Defendants in advancing the goals of
the Climate Alarmism Enterprise, including retaliation against witnesses, tampering with witnesses,
bribery of witnesses, and embezzlement from pension and welfare funds. The Guardian also
participated in at least one high-profile act of espionage against the USA.
90.
The Defendants Ford Foundation, RFB, Pew Trusts, MacArthur Foundation, Hewlett
Foundation, Packard Foundation, and Energy Foundation gave money to scientific societies and
media organizations that (except for The Guardian) used to have full public trust. Starting at
different times, but not later than from 2010, these organizations gave full support to the Climate
Alarmism Enterprise, and backed its climate pseudo-science with their scientific or journalistic
credibility, all while failing to disclose that they had been paid by the Enterprise.
B. The Criminal Activities

Retaliation against Witness
91.
The behavior of the Defendants and their accomplices is unprecedented. Having lost
their case in the Congress and in the court of public opinion, they directed their most extreme attacks
not against opposing politicians, but against distinguished physicists, biologists, and other experts,
who had testified before Congress or in other official proceedings.
35
92.
Starting not later than 2()06 and continuing to the present, the Defendants caused,
attempted, or conspired to cause bodily injuries, as defined in 18 U.S. Code 1515(5), to certain
scientists and experts, who had been witnesses in official proceedings related to carbon dioxide,
alleged "global warming", and so-called "climate change", and had given testimonies that displeased
the Defendants or other members of the Climate Alarmism Enterprise.
93.
The following scientists were among those who had attended and testified in official
proceedings, and against whom the Defendants retaliated:
Frederick Seitz (1911-2008)- a distinguished physicist, the President of the National Academy of
Science from 1962 to 1969, and the President of Rockefeller University from 1968 to 1978, where
he supervised a Nobel Prize winning biomedical study, that led to the discovery of prions (the cause
of the "mad cow" disease.) Frederick Seitz was also the main supporter of the Oregon Petition.
Robert Jastrow (1925-2008)- a distinguished astronomer and physicist, the founder of the NASA
Goddard Institute for Space Studies.
Fred Singer (b. 1924)- a distinguished physicist and science administrator, the first director of the
National Weather Satellite Service (1962-64), Vice Chairman of the National Advisory Committee
for Oceans and Atmosphere (NACOA) (1981-86), and Chief Scientist of the U.S. Department of
Transportation (1987- 89). Singer theoretically predicted the existence of the Earth's radiation belt,
later confirmed by observations. He also designed satellites and their sensors, and was one of the
visionaries behind GPS.
William Happer (b. 1939) - a distinguished physicist, and Director of Energy Research at the
Department of Energy (DOE) from 1990 to 1993, where he supervised all of the DOE's work on
climate change. The founder, co-owner, and Chairman of GIM, then Vice President Al Gore, fired
Prof. Happer in 1993.
36
Richard Lindzen (b. 1940)- a distinguished physicist, Alfred P. Sloan Professor of Meteorology,
Department of Earth, Atmospheric and Planetary Sciences at MIT. Lindzen has researched the
carbon dioxide -vs. climate changes connection since at least 1979. His theoretical calculation of
the low sensitivity of surface temperatures to the carbon dioxide was experimentally confirmed in
the 1990's.
94.
Defendants also smeared William Nierenberg (1919-2000), a distinguished physicist
and the Chairman of the Carbon Dioxide Assessment Committee (1979-1983), the first scientific
body that conducted a systematic investigation of possible links between anthropogenic emission of
carbon dioxide, other infrared absorbing gases, and climate changes. From 1980 until his death in
2000, he was the most knowledgeable person in the world on the subjects of the climate debates.
95.
Since 2006 and continuing to the present day, Defendants also counseled,
commanded, or induced others to retaliate against the these and other witnesses, including those who
would have been likely to testify in the future, and other persons, whom Defendants linked to the
witnesses.
96.
On multiple occasions since 1996, Greenpeace and some other Defendants retaliated
against these and other witnesses by damaging tangible property of ExxonMobil and other
companies, which the Defendants believed to have been "linked" to the witnesses.
97.
The Defendants attempted or conspired to retaliate against witnesses by damaging
tangible property of businesses, that the Defendants claimed had financed research or public activity
by the witnesses, or threatened to do so.
Tampering with Witness
98.
Acts of retaliations against witnesses, listed in the Retaliation against Witness
subsection, were performed publicly, and had the intent and effect of influencing or preventing
37
testimonies of other persons in official proceedings related to carbon dioxide, alleged "global
warming", and so-called "climate change".
99.
Since 1996, the Defendants committed multiple additional acts of retribution against
the same and many other persons. These individuals who had been expert witnesses in official
proceedings related to carbon dioxide, alleged "global warming", so-called "climate change", and
other subjects in the climate debates, and had given testimonies that displeased the Defendants or
other members in the Climate Alarmism Enterprise.
100.
These acts of retribution included smear campaigns in the media, character
assassination, and interference with the lawful employment of the witnesses, and had the intent and
effect of influencing or preventing testimonies of other persons in official proceeding related to
carbon dioxide, alleged "global warming", so-called "climate change", and other subjects in the
climate debates.
101.
In 1997, the founder, co-owner, and Chairman of Defendants GIM, then Vice
President AI Gore, acting against the explicit advice of the Senate (the Bird-Hagel Resolution),
signed or authorized signing of the so-called "Kyoto Protocol", which would have had an extremely
damaging effect on the American economy and society, if it went into effect. In response, a group of
scientists wrote and circulated among their colleagues a petition against Kyoto Protocol ratification
("the Oregon Petition", 1998).
102.
The full text of the Oregon Petition:
"We urge the United States government to reject the global warming agreement that was written in
Kyoto, Japan in December, 1997, and any other similar proposals. The proposed limits on
greenhouse gases would harm the environment, hinder the advance of science and technology, and
damage the health and welfare of mankind.
38
There is no convincing scientific evidence that human release of carbon dioxide, methane, or other
greenhouse gasses is causing or will, in the foreseeable future, cause catastrophic heating of the
Earth's atmosphere and disruption of the Earth's climate. Moreover, there is substantial scientific
evidence that increases in atmospheric carbon dioxide produce many beneficial effects upon the
natural plant and animal environments of the Earth. "
103.
From 1998 to 2008, this petition was signed by more than 30,000 scientists and other
experts on the scientific subjects related to climate and the interaction between climate and human
activities. There were questions about the signatures verification procedures, employed by the
petition organizers, and some prank signatures were found there. Nevertheless, at least 20,000
signers were qualified experts, capable and willing to testify in the relevant official proceedings,
including Congressional hearings. The subsequent intimidation campaigns, conducted by
Defendants separately and in coordination with each other, had the intent and effect of preventing
them from attending and giving testimonies in official proceedings. Each Defendant committed
multiple acts of tampering with each witness. Per this paragraph alone, each named Defendant
committed at least 20,000 counts of tampering with witness in each of the ten-year periods 19982007 and 2008-2016.
104.
As an additional example of witness tampering, in December 2015, Greenpeace
targeted distinguished physicist William Rapper the day before he was to testify to Congress on
COz. Attempting to intimidate and discredit Dr. Rapper, Greenpeace engaged in a pre-textual email
contact in which it impersonated a representative of a Middle Eastern fossil fuel company and
offered to hire Dr. Rapper to write a paper to support their COz position. Dr. Rapper first sent them
prior papers he had already published to make clear what his position was, and then also warned
them that he did believe fossil fuels caused environmental problems even though he believed certain
exaggerated concerns about COz were not scientific. Dr. Rapper asked for no remuneration, and
39
when Greenpeace kept pressing to provide some, he made clear that (unlike Greenpeace) he was not
motivated by money but would write what he believed as "a labor of love" for science and a subject
he cared deeply about: "My activities to push back against climate extremism are a labor of love, to
defend the cherished ideals of science ... " Instead, "if' the company wanted to reimburse him, he
explained he would rather they donate "whatever" amount to a charitable scientific organization that
educated on this issue but paid him nothing: "If your client was considering reimbursing me for
writing something, I would ask for whatever fee would come to me would go directly to C02
coalition . .. {which] occasionally covers travel expenses but pays me no fees or salary." Ignoring
this impeccable exchange, the evening before he was to testify, Greenpeace attempted to intimidate
Dr. Happer by threatening to publish a story about him and "how fossil fuel companies are able to
pay academics to produce research which is of benefit to them." Of course, his exchange showed no
such thing and, in fact, reflected the opposite. When he testified anyway, Greenpeace carried out its
threat by publishing a report about him called "Academic-For-Hire" falsely claiming that he had
agreed to be "secretly pa[id]" to "write research sowing doubts about climate change and promote
the company's commercial interests." The story was pure libelous smear, as Dr. Happer (a) made
clear he did not want to get paid but would write out of "a labor oflove";" (b) was not going to get
paid anything; (c) made clear he would only write about research and conclusions he had already
published; and (d) merely deflected Greenpeace's repeated efforts to get him to accept payment by
stating that "if' Greenpeace wanted to "consider[ ] reimbursing" him it could instead donate
"whatever" amount to a charity from which he received no remuneration. Greenpeace then publicly
confronted Dr. Happer in Congress as he sat for testimony by loudly repeating these slanderous
charges before being forcibly removed from the chamber.
105.
Some of the most relevant scientific fields for in the climate debates are geophysics,
mathematical statistics, computer modeling, chemistry, and electrical engineering. A large

40
percentage, and possibly the majority, of all seientists and experts, qualified to give a relevant expert
testimony, worked for the energy industry. The scientific knowledge of these experts had been
proven beyond any doubt by their success in finding oil or gas fields, designing power stations, or
achieving other tangible results. Many of these experts had decades of experience, and along with
unblemished records of honesty, integrity, and good character. They typically had a stable source of
income, ensured by their knowledge and professional skills, independent of politics and improper
pressures. These qualities naturally made them suitable expert witnesses in the official proceedings.
And this is why Defendants, aided and abetted by corrupt, co-conspiring, or obscurantist politicians,
launched campaigns to threaten and intimidate these experts. Their actions, which started in 1999 or
earlier, prevented these experts from attending the official proceedings related to the climate debates,
or forced them to withhold parts of their testimonies if they attended. Defendants even created and
disseminated a conspiracy theory, in which Defendants' false claims about the physics of the
atmosphere, plant biology, and the technical merits of energy conversion technologies were assumed
as facts, the demands of foreign governments and non-governmental bodies were accepted as orders
for America to obey, and the energy industry was blamed for any disagreement with those false
claims and "failure" to obey those demands. In most cases, tampering with witnesses employed by
or contracting with energy companies was camouflaged as fighting the "corporate interests".
106.
Defendants and their accomplices practice attempt retribution and intimidation
against witnesses and potential witnesses by threatening or harassing persons within two degrees of
separation from these witnesses, including witness' employers and employers' partners or donors.
107.
Defendants took and executed contracts on the third parties - organizations not
employing the scientists whom Defendants labeled "climate deniers", not opposing Defendants, and
not obviously threatening the Defendants' agendas. For example, Defendants apparently took a
contract on the American Legislative Exchange Council (ALEC), a prominent conservative
41
organization founded in 1973. Defendants ran a perfectly orchestrated public campaign, that falsely
accused ALEC of"climate change denial", threatened its corporate members and donors, and caused
many of them to leave or to stop donating to the organization.
108.
Defendants corruptly persuaded, attempted, or conspired to corruptly persuade
witnesses in official proceedings, including hearings in Congress, Congressional committees and

sub-committees, and government agencies, to testify falsely that humans, and especially Americans,
Western Europeans, and residents of British Commonwealth countries, caused dangerous climate
changes.
109.

sub-committees, and government agencies, to falsely testify falsely that carbon dioxide, an invisible
and harmless gas, exhaled with each human breath, was a pollutant.
110.

sub-committees, and government agencies, to omit from their testimonies that carbon dioxide was a
plant food that increases agricultural production and typically decreases crops' water demands,
making them more drought tolerant.
111.

sub-committees, and government agencies, to change their testimonies in other ways, in order to
advance the Climate Alarmism Enterprise.
112.
To achieve these purposes, Defendants counseled, commanded, or induced employees
of some government agencies, scientists, and pseudo-scientists, working under government grants to
corruptly alter current and historical surface temperature records, to present results of dubious
42
calculations as records, or to conceal computer codes, containing errors or intentional fraud, but
alleged to provide scientific evidence favorable to the Climate Alarmism Enterprise.
113.
Additionally, in orderto corruptly persuade the witnesses and potential witnesses,
Defendants told them many lies, including but not limited to:
that the IPCC was an authority
that IPCC Assessment Reports had alleged certain alarmist conclusions which they had
not alleged, or even explicitly rejected
that 97% of scientists, or so-called "climate scientists", supported the Climate Cult dogma
that there was a "scientific consensus" behind the Climate Cult dogma
that sea level rise was caused by anthropogenic climate change, when in fact it has been
happening since the last glacial episode 20,000 years ago
that anthropogenic release of carbon dioxide caused dangerous climate change
that burning fossil fuels in the US and other Western countries caused hurricanes and
other natural disasters in the poor countries - what was called "weather cooking" in the
times of medieval witch hunts
that the dissent from the Climate Cult was funded by ExxonMobil or "fossil fuels"
114.
Note that the phrase "scientific consensus" is an oxymoron, because consensus is a
decision-making method, used exclusively in situations that are beyond the reach of science, like
jury trials or some political forums. Thus there is a consensus among Defendants to stir up
unfounded climate alarm in order to advance their goals and the goals of the Climate Alarmism
Enterprise and its allies.
115.
Additionally, in order to corruptly persuade the witnesses and potential witnesses,
Defendants and their directors, officers, agents, or employees widely disseminated, or caused to be
disseminated various graphs, pictures, animations, and videos, alleged to be scientific evidence, but
43
which were in fact produced or manipulated by common graphing, image processing, animation, or
movie-making software.
Bribery of Witnesses
116.
On multiple occasions, Defendants gave, offered, and/or promised money, services,
and/or other things of value to putative scientists, for or because of their false testimonies in official
proceedings, including but not limited to Congressional hearings and hearings before authorized
governments agencies.
117.
On multiple occasions, Defendants gave, offered, and/or promised money, services,
and/or other things of value to putative scientists, for intentionally corrupting (including but not
limited to altering, destroying, or concealing) objects or records (including but not limited to
scientific measurements, historical records, processed data, computer programs, published scientific
works, or the metadata associated with them) with knowledge and intent that these corrupted objects
or records would be introduced in official proceedings, possibly by persons not aware that the
objects or records had been corrupted, or used for corrupt persuasion of witnesses.
118.
On other occasions, Defendants corruptly gave, offered, and/or promised money,
services, and/or other things of value to organizations or individuals associated with these
organizations, for or because of the false testimonies by these organizations or their representatives
in official proceedings, including but not limited to Congressional hearings.
119.
An example of this bribery is the relationship between Defendants and Dr. Michael E.
Mann ("Mann," born 1965), born in 1965, probably the most famous among the putative "climate
scientists", aiding or abetting the Climate Alarmism Enterprise. Currently, Mann is a Distinguished
Professor of Atmospheric Science at Penn State University, with joint appointments in the
44
Department of Geosciences and the Earth and Environmental Systems Institute (EESI). He is also a
director of the Penn State Earth System Science Center (ESSC).
120.
In 1998, the undistinguished and unremarkable Mann received his PhD and was
employed as an adjunct assistant professor at the University of Massachusetts (not to be confused

with the famous MIT.)
121.
By that time, the Climate Alarmism Enterprise, supported by governments of many
Western European countries and then Vice President Al Gore, was already in power, hostile to
science and reason.
122.
It is a well-known fact, that plants grow by photosynthesis- a process of converting
carbon dioxide from the air into biomass, using sunlight as the energy source. Carbon dioxide is the
plant food, and higher carbon dioxide concentrations improve the yields of agricultural crops and
accelerate the growth of trees. The concentration of the carbon dioxide in the air has increased over
the last 150 years, mostly because of burning fossil fuels and converting forests into agricultural
land.
123.
The extent and effect of this fertilization effect depend on the plant species. For
instance, Bristlecone Pine is a tree, in which the fertilization effect is especially pronounced, and
much of the added biomass is stored in its trunk, leading to thicker tree rings. For this reason, the
Greening Earth Society, a non-profit organization founded in 1997 to educate those who had neither
learnt about photosynthesis on the farm nor in the school, even selected the Bristlecone Pine as its
symbol. The Greening Earth Society was known to many Defendants since at least 1998.
124.
It is a well-known fact, that solar radiance is the main factor determining land surface
temperature.
125.
For example, winters (seasons of lower solar radiance) are colder than summers
(seasons of higher solar radiance.) Within the same season, days when the sun is shining tend to be
45
hotter than days when sunlight is blocked. Nights are colder than days. Years with higher solar
radiance tend to be warmer than years with the lower solar radiance. Geographically, average land
temperatures tend to decrease toward the poles, because annual solar radiance in the local horizontal
plane decreases toward the poles. All the Defendants know these facts.
126.
Since the solar radiance largely determines both the surface temperatures and plants
photosynthesis rates (when other factors do not change significantly), the thickness of the tree rings
of many tree species is frequently used to determine past temperatures (what is called "temperature
proxies"). This is also a well-known fact. There are additional factors, and not all tree species are
suitable, but the methodology was mature and these issues were known to the specialists long before
1998. Bristlecone Pine was known as an unsuitable species.
127.
In 1998, Michael Mann, together with Raymond Bradley and Malcolm Hughes
(Mann was the main author) published an article called "Global-scale temperature patterns and
climate forcing over the past six centuries" in the then prestigious scientific journal Nature. In 1999,
they published another article in the Geophysical Research Letters., this time pretending to have
reconstructed global temperature patterns over the last 1,000 years. These articles purported to show
that the last decades of the 20th century exhibited average hemispheric temperatures higher than any
in the last 1,000 years, contrary to the historical records and the settled science of the past climates.
The Summary for Policymakers from the IPCC Third Assessment Report prominently displayed a
hockey stick-like graph, based on these articles, as a "proof' of allegedly unprecedented warming.
128.
These articles were based on fraud. Mann added Bristlecone Pine, already known to
be unsuitable as a "temperature proxy", to the list of suitable proxies, and assigned to it a

disproportionately large weight in his calculation of multi-proxy weighted average, thus creating the
infamous hockey-stick graph.
46
129.
In simple words, Mann's own data had shown a positive fertilizing effect of increase
in the carbon dioxide concentration (denied or downplayed by the Defendants), but his words
alleged negative and dangerous warming, to the delight of Defendants.
130.
On July 29, 2003, Mann testified before the U.S. Senate Committee on Environment
and Public Works. Having been "incentivized" by Defendants, he made multiple materially false
statements and omissions. Among them:
a)
Mann falsely claimed to be a Professor in at UV, when he was only an Assistant
Professor;
b)
Mann falsely claimed that "Evidence from paleoclimatic sources overwhelmingly
supports the conclusion that late-20th century hemispheric-scale warmth was unprecedented over at
least the past millennium and probably the past two millennia or longer," knowing that the opposite
was true;
c)
Mann called his activities "research", and failed to disclose the scientific fraud he had
committed instead of research;

d)
Mann failed to disclose the remuneration that he had received, or had been promised
by Defendants or their co-conspirators.

131.
On July 27, 2006, Mann testified before a sub-committee of the House Committee on
Energy and Commerce. Having been "incentivized" by Defendants, he again made multiple
materially false statements and omissions. Among them:
a)
Mann falsely stated: "Numerous independent studies using different data and
different statistical methods have re-affirmed the most important conclusions of the work". In fact,
all the "studies" that purported to re-affirm conclusions of his work were derived from his work, not
independent, and used the same method of injecting and overweighting an inappropriate proxy.
47
b)
Mann alleged that his "research" had been peer-reviewed and falsely stated: "Peer
review in my field is anonymous. Authors play no role in selecting peer reviewers." In fact, Mann
had been selecting, or attempting to select, not only the "peer reviewers", but even the journal
editors. He had even threatened scientists and editors, who criticized his work, and at least
attempted to get them fired from their jobs, or interfered with their livelihood in other ways.
c)
Mann called his activities "research", and failed to disclose the scientific fraud he had
committed instead of research.

d)
Mann failed to disclose remuneration, promised remuneration, and other undue
influence by Defendants and their co-conspirators.

132.
These materially false statements, made by Mann in these testimonies, have greatly
advanced the interests of Defendants and the Climate Alarmism Enterprise.

133.
The Defendants rewarded Mann both financially and in other ways (providing him
fame, power, and, at the time of filing this Complaint, even immunity from justice.) Immediate! y
after publication of MHB98, Mann was appointed a Lead Author in the IPCC. In 2005, Mann was
appointed a Director of the Earth System Science Center in PSU. In 2009, he became a full
Professor. In 2013, he became a Distinguished Professor. All these positions, which he achieved
through influence of Defendants, paid much more than his prior job. In addition, Defendants
advertised and promoted Mann's books. Defendants assisted Mann to receive a number of then
prestigious and/or valuable awards and appointments. In addition, Defendants promoted Mann's
career as a highly compensated speaker. As a speaker, Mann is represented by Jodi Solomon
Speakers Bureau, which also represents Annie Leonard, the Executive Director of Greenpeace USA.
134.
Defendants spent somewhere between $50 Million and $2 Billion (including
misappropriated public funds) to protect Mann against criticism and to empower him to abuse, or to
attempt to abuse his critics, and to shield him from justice:
48
a)
In 2006, at the request of Rep. Joe Barton of the United States House Committee on
Energy and Commerce, three statisticians, led by Prof. Edward Wegman, prepared a report,
addressing the putative scientific merits of Mann's articles MBH98 and MBH99. Prof. Wegman
also testified about this report in person. The statisticians were neutral, and not involved in the
climate debates prior to that. The report concluded, that Mann applied the statistical methods
incorrectly, and the results of his research were invalid. No investigation of Mann's actions was
requested or performed at that time. Defendants launched a concerted campaign of character
assassination, libel and threats against Prof. Wegman and individuals around him, including at least
one student of his. Defendants also attempted to cause bodily injuries to Prof. Wegman, and put his
name on the Target Lists.
b)
In April2010, the Virginia Attorney General started a probe, based on evidence of
fraud related to grants, received by Mann at UV A. Defendants and their collaborators obstructed
and eventually shot down this probe.
c)
Mann launched a number of abusive lawsuits against those who criticized him. In at
least one of these lawsuits, Mann falsely claimed to be a Nobel Laureate. On information and
belief, at least some of these abusive lawsuits, strategically directed against public participation,
were assisted by direct or indirect funding and/or services from Defendants.
d)
Defendant Fenton created and promoted the website RealClimate.org, used by Mann
and his collaborators to insult and defame his critics, and attempted to conceal its (Fenton's)
participation.
135.
Defendants bribed employees of NASA Goddard Institute of Space Studies (NASA
GISS.)
49
Bribery of Officials
136.
To achieve their illegal goals, Defendants regularly bribed and continue to bribe
public officials, including, but not limited to some members of Congress and certain state Attorneys
General. Bribes have been given directly or through intermediaries, in cash, "in-kind", by providing
services of value, and in other forms.
137.
For example, the Sierra Club endorsed Representative Raul Grijalva (D-AZ) and
actively promoted his re-election bid, using their highly trafficked website sierraclub.org as one of
the tools, and continue promoting him at the time of filing this Complaint.
138.
On or around February 24, 2015, Grijalva sent letters to Presidents of seven
Universities, that employed five distinguished scientists -Richard Lindzen of MIT, John Christy of
the University of Alabama in Huntsville, Willie Soon of Harvard Smithsonian Center for
Astrophysics, David Legates of the University of Delaware, and Judith Curry of Georgia Tech- and
two academic experts on policy and environment: Roger Pielke Jr. of the University of Colorado and
Steven F. Hayward of Pepperdine University. All of these experts had testified before Congress on
the so-called "climate change", thus displeasing the Climate Alarmism Enterprise. The letters
slandered these academics, and illegally demanded that the Universities to conduct extensive
discovery and investigation against these persons. The letters also demanded all drafts of their
testimonies before all government bodies, all their communications of the academics related to these
testimonies, their private financial information, and their private communication- all over an eightyear period.
139.
These letters served no other purposes but to harass these witnesses, to cause them
pain or even illness, to interfere with their lawful employment, and to deter other scientists from
attending and giving truthful testimony at official proceedings related to carbon dioxide emissions
and their putative linkage to the so-called "climate change." Grijalva's Communications Director,
50
Adam Sarvana, brazenly admitted that there were no grounds to suspect any wrongdoing and the
scientists were targeted solely because of their Congressional testimonies: "The way we chose the list
of recipients is who has published widely, who has testified in Congress before, who seems to have
the most impact on policy in the scientific community."
140.
In another example, the Sierra Club Defendants endorsed Kamala Harris, current
Attorney General of California, and actively promoted her election campaign to US Senate, using
their highly trafficked website sierraclub.org as one of the tools.
141.
In or around November 2015, prompted by the Climate Alarmism Enterprise and a
PR campaign by its marketing accessory insideclimatenews.org, California Attorney General

Kamala Harris and New York Attorney General Eric Schneiderman launched an investigation of
ExxonMobil, a Texas oil company. The pretext for this investigation was some public interest
research, conducted by ExxonMobil more than 40 years ago, but Harris and her accomplices openly
admitted that the real cause was their belief that ExxonMobil supported witnesses, whose testimony
the Climate Alarmism Enterprise had been trying to suppress. Harris and her accomplices failed to
admit to another motive- the "failure" by ExxonMobil to make sufficient financial contributions to
Harris, her party comrades, and the Climate Alarmism Enterprise, compared with the contributions
that Exxon's competitors (many of whom were foreign oil companies) made.
142.
Having been corruptly influenced by or even having conspired with Defendants, US
Attorney General Loretta Lynch has opened a case against "climate change deniers", and had even
referred this case to FBI, as she acknowledged in a press conference on March 9, 2016.
143.
There is a revolving door between the Defendants and many government agencies,
especially the EPA, and Congressional staff.
51
Embezzlement from Pension Funds
144.
Defendant Ceres and other Defendants embezzled, attempted to embezzle, or
conspired to embezzle trillions of dollars from pension and welfare plans, including, but not limited
to, the Social Security Trust Fund, and continue to do so at the time of filing this complaint.
145.
Ceres attempts to justify these actions as follows: "In order to limit global warming
to below 2C and avoid the worst effects of climate change, the world needs to invest more than an
additional $1 trillion per year in clean energy through 2050- the "Clean Trillion. " ... Meeting the
Clean Trillion goal will be a tremendous challenge, but it is achievable
if businesses, investors and
policymakers join forces. "
146.
Ceres and other Defendants intend to misappropriate at least half of this money -
$500 billion per year, or $18 trillion ($18,000,000,000,000) over the next 36 years- from citizens
and legal residents of the United States of America. Neither Ceres nor the other Defendants are
willing or able to obtain any significant (in this context) amount of money from China, or from any
country in the world outside of the Western Europe and the British Commonwealth, and are unlikely
to succeed even in these countries.
147.
Together, the Defendants own more than $40 billion in cash and liquid assets, and
have an annual income of more than $3 billion. The Defendants have full control of almost all of
their assets and income. Nevertheless, hardly any of their money is invested in what they call "clean
energy". When Ceres writes "the world needs to invest" it means "we want to put our hands on your
money".
148.
In this scheme, Defendants see themselves as recipients or redistributors of the
money, not as the donors. Further, no person or private business is willing to waste their money on
the "clean energy" schemes. The US Treasury is empty, and owes a huge debt, in part by reason of
actions by Defendants. The only places from which such amounts of money can be misappropriated
52
are welfare benefit plans, pension benefit plans, or funds connected therewith, as defined in 18 U.S.
Code 664, including Social Security funds.
149.
Ceres is obscenely sincere, saying that its goal is possible only if"policymakers join
forces". Unfortunately, many policymakers and union bosses do just this, although it is forbidden to
them and anybody else to divert even $1 of the public money "to limit global warming to below
2C", or to take any other action based on the Climate Cult dogma.
150.
In order to facilitate and accelerate embezzlement from the pension and welfare funds
by participants in the Climate Alarmism Enterprise, Defendant Ceres operates what it calls the
"Ceres Coalition", which includes:
a) Defendants WWF, FOE, NRDC, EDF, UCS, and Sierra Club;
b) Some other members of the Climate Alarmism Enterprise and their aiders, abettors, and/or
accessories;
c) Pension funds, welfare funds, and their de-facto managers, including the AFL-CIO (the union
federation), SEIU (Service Employees International Union), CalPERS (California Public
Employees' Retirement System), CalSTRS (California State Teachers' Retirement System),
California State Controller's Office, California State Treasurer's Office, and Connecticut Office
of the State Treasurer.
151.
With the same goal to embezzle from pension and/or welfare funds, Defendant Ceres
also operates what it calls the "Investor Network on Climate Risk", which it describes as follows:
"The Investor Network on Climate Risk (/NCR) is a network of more than 120 institutional investors
representing more than $14 trillion in assets committed to addressing climate change and other key
sustainability risks, while building low-carbon investment opportunities. /NCR includes the largest
institutional investors in North America as well as leading religious and labor funds, asset managers
and socially responsible investment funds. "
53
152.
Defendant Ceres and its accomplices have developed and shared with other
Defendants a Blueprint for Sustainable Embezzlement, which is unavailable to Plaintiff.

153.
On multiple occasions, Defendants counseled, commanded, induced, or procured
embezzlement from pension and/or welfare funds, each of these acts of embezzlements having
benefitted the acting Defendant(s), other Defendants, other members of the Climate Alarmism
Enterprise, their aiders or abettors, or the Climate Alarmism Enterprise as the whole.
154.
On multiple occasions, Defendants used illegal means to force publicly traded
companies, whose shares were owned by pension and/or welfare funds, to act against their (the
companies') interests, the interests of their shareholders, and the public interest, or manipulated
stock prices of those public companies. While the pension and/or welfare funds suffered losses,
Defendants shielded or even enriched themselves and their accomplices by providing advance
warnings of the Defendants' actions to other Defendants or their associates, receiving advance
warnings from other Defendants or their associates, trading on this information, or by receiving
payments from the affected companies, other Defendants, or their associates, who had financially
gained from trading in the stock of the affected companies. Using this scheme, the Defendants
directly victimized pension and welfare funds.
155.
In 2008-2012, the Defendants conspired with and/or induced some managers,
employees, and/or agents of California Public Employees' Pension System (CalPERS) to invest
almost a billion dollars of CalPERS funds in certain "clean tech" schemes, financially benefitting
Defendants. CalPERS lost tens or hundreds of millions of dollars on these "investments", while
Defendants gained from them financially and re-invested some of the income into the Climate
Alarmism Enterprise. Defendants also touted these investments as a "proof' that their "clean
energy" schemes (ranging from residential solar panels to making gasoline from algae) were mature
technologies, capable of replacing oil, coal, and natural gas. In 2013, Joseph Dear, the CalPERS'
54
chief investment officer, mocked the victimized workers by commenting on this episode: "Our
experience is that this has been a noble way to lose money. "
Other Misconduct
156.
China emits more carbon dioxide than the USA, and many times more of other so-
called "greenhouse gases" than the USA. Additionally, China emits large amounts of real pollutants,
including particulate matter and chemicals, unknown to Plaintiff. This pollution travels a long
distance and reaches the US territory, causing health consequences, unknown to Plaintiff. The US
emits much fewer pollutants, and practically none of them reach China.
157.
Nevertheless, since at least 2010 and continuing through the present, the Climate
Alarmism Enterprise, Defendants, and many of their directors, officers, employees, and agents,
including American citizens, have been siding with the government of China and against the United
States of America on almost every matter, related to the international "climate change" negotiations,
energy policies, and environmental policies. For example, the Climate Alarmism Enterprise
members cursed the US for "insufficient" decreases in emissions of the so-called "greenhouse
gases", the gases that they declared harmful, in the same time praising China for increased in
emissions of the same gases. Defendants and individuals associated with them advised the federal
government to de-develop the United States and to enact regulations having the effect of transferring
many remaining industries from the United States to China and other countries. On information and
belief, at some point between 2001 and 2010, leaders of the Climate Alarmism Enterprise made a
secret deal with the government of China, under which Defendants and Defendants' allies and
accomplices would perform these and other actions in exchange for support, including but not
limited to money, from China. On information and belief, Defendants have been receiving and
carrying out instructions from the government of China since at least 2010.
55
158.
Defendants knowingly and willfully damaged, attempted, or conspired to damage
property of energy facilities. If the object of the attempt or the conspiracy had been achieved, it
would have resulted in the death of multiple persons and damages over $100,000.
159.
Defendants knowingly and willfully damaged, attempted, or conspired to damage
property of energy facilities, and caused, attempted, or conspired to cause a significant interruption
or impairment of the function of at least one energy facility.
160.
Moreover, Defendants knowingly and willfully attempted or conspired to destroy
most of the national energy infrastructure. If the object of these attempts or the conspiracies had
been achieved, it would have resulted in millions of deaths.
161.
On multiple occasions or continuously over more than ten years, many directors,
officers, employees, and agents of Defendants have been corresponded with foreign governments
with the intent to influence their conduct in disputes with the United States adversely to the United
States, and to defeat the measures of the United States. In particular, this behavior happened in the
run-up to and in during the Conferences of the Parties to the UNFCCC, including the latest COP21
that was held in Paris, France, from 30 November to 12 December 2015.
162.
On multiple occasions and on a very large scale, Defendants illegally aided foreign
powers and foreign entities to influence US presidential elections, US Congress elections, and state
elections illegally, transferring illegal foreign donations and/or "in-kind" gifts to candidates who
promised to accommodate various agendas of those foreign powers or entities; in many cases they
linked those agendas to the so-called "climate change". Those agendas frequently included control
over the anthropogenic release of carbon dioxide. Some Defendants illegally influenced the
elections, being foreign entities themselves. Defendants continue these illegal activities through the
date of this filing.
56
163.
Defendants assaulted and continue to assault the use of both fossil fuels, hydropower,
and nuclear power. Their assault on the nuclear power is as fraudulent as their assault on the fossil
fuels consumption. For example, in 2006, Greenpeace mistakenly released an unfinished draft email
about nuclear power awaiting only the insertion of what the drafter described as an "ALARMIST
AND ARMAGEDDONIST FACTOID:" "In the twenty years since the Chernobyl tragedy, the
world's worst nuclear accident, there have been nearly [FILL IN ALARMIST AND
ARMAGEDDONIST FACTOID HERE]."
C. The Climate Alarmism Enterprise's Texas Activities

164.
The Climate Alarmism Enterprise's activities have entailed significant contacts with
and effects in Texas.

165.
Many actions of each and every Defendant and the Climate Alarmism Enterprise as a
whole have been directed towards or occurred within Texas.

166.
In the daily conduct of the Climate Alarmism Enterprise, each and every Defendant
damaged, attempted, or conspired to damage tangible property of Texas persons. For example, on
multiple occasions Defendants damaged tangible property of ExxonMobil, the largest Texas
company.
167.
Each and every Defendant embezzled, or attempted or conspired to embezzle, from
pension or welfare funds, that have Texas persons as beneficiaries, or are located in Texas.
168.
Defendants supported and/or counseled others to support illegal foreign boycotts
against ExxonMobil and other Texas companies.

169.
Combined, it is clear that various members of the Climate Alarmism Enterprise and
their ongoing activities have significant connections to Texas, and that the Climate Alarmism
Enterprise has caused Plaintiff to suffer substantial damages in Texas.
57
D. Injury and Damages

170.
The Climate Alarmism Enterprise's activities has inflicted and continues to inflict
substantial harm on the public in general, and on Plaintiff as a part of the public. The following
paragraphs allege additional injuries, inflicted on Plaintiff.
171.
The scientific ignorance of the majority of acolytes of climate alarmism, combined
with their fervor and intolerance of any dissent, have led to them being frequently called a cult.
Herein, Plaintiff refers climate alarmist dogma and practice the Climate Cult. Plaintiff is not a
public figure, but has published his criticism of the pseudo-science, peddled by the Defendants in
order to justify and advance the Climate Alarmism Enterprise. Further, Plaintiff published articles
and blog posts critical of the politics of climate alarmists.
172.
The Defendants, acting directly or through their marketing accessories and corrupt
officials, singled out individuals, who publicly criticized the dogma of Climate Cult or objected to its
establishment as state religion, and labeled them as "climate change deniers" or "climate deniers".
Although not on any Target List at the time of filing this Complaint, Plaintiff is a "climate denier" in
the terminology of the Defendants, and easily recognized as such within seconds by anybody with an
Internet access.
173.
In their campaign to silence dissenting speech, Defendants have threatened and
continue to threaten Plaintiff, and maliciously smeared and defamed Plaintiff, including but not
limited to harming his professional qualification, judgement, and capabilities, causing Plaintiff loss
of business and employment opportunities now and in the future. The Defendants contacted
multiple companies in Texas and other states, demanding them that they not hire Plaintiff and not to
do any business with Plaintiff. These threats, smears, and interference with lawful employment are
inseparable from the whole pattern of retaliating against witnesses, tampering with witnesses, and
58
bribery, committed by the Defendants. Thus, Plaintiff suffered direct damage to his business and
employment opportunities by reason of these racketeering activities by the Defendants.
174.
Plaintiff resides and is employed as a software engineer in Texas. Plaintiff estimates
that he has suffered damage exceeding $30,000 from lost wages or other income just from January 1
through August 31,2016 by reason ofDefendants' tampering with witnesses and bribing officials.
When trebled in accordance with 18 U.S.C. 1964, the expected recovery exceeds $90,000.
Further, past and ongoing illegal activities of the Defendants threaten Plaintiffs current job, and are
likely to cause Plaintiff substantial financial damages in the future.
175.
Plaintiff has been paying into the Social Security Fund for more than 15 years, and is
entitled to a pension when and if he reaches the retirement age, established by Law. The Defendants
embezzled, attempted, or conspired to embezzle from the Social Security Fund and from funds
connected therewith, on an unprecedented scale. State- and union- managed pension funds, such as
CalPERS, are connected with the Social Security Fund, because their managers have significant
political power and will attempt to divert funds from the Social Security to cover shortages, caused
by their complicity in the activities of the Climate Alarmism Enterprise. The Defendants also
exercise enormous corrupt influence in the federal government, allowing them to move the Social
Security Fund losses from some beneficiaries to others, and even to third parties in other countries.
Thus, Plaintiff suffered direct damage to his property by reason of the embezzlement from pension
funds, committed or attempted by the Defendants and their co-conspirators.
176.
The total amount of these damages can only be calculated once the full scope and
activities of the Climate Alarmism Enterprise are revealed.
DISCLOSURE UNDER 18 U.S.C. 2382
177.
The nerve center of the Climate Alarmism Enterprise is outside of the US. Some
individuals, affiliated with the Defendants, other members and/or allies of the Climate Alarmism
59
Enterprise, might be committing Treason against the United States of America. The suspicious
activities are as follows:
a) Defendants and their accessories and associates falsely assert authority of the
Intergovernmental Panel on Climate Change on the territory of the United States and/or its waters.
The Intergovernmental Panel on Climate Change includes North Korea, which is in a state of war
with the United States and threatens military attacks against the United States; asserting enemy's
authority might be considered as adhering to enemies or giving them aid. Note also that many
Defendants and their collaborators in the Climate Alarmism Enterprise maintain offices in China, the
ally of North Korea; these offices enable easy and undetectable contacts between North Korea and
individuals participating in the Climate Alarmism Enterprise.
b) Some Defendants have been undermining or attempting to undermine US military

defenses from 1980's. Especially notorious, but not exceptional, are the Union of Concerned
Scientists and Greenpeace. In fact, it is likely that Defendants retaliated against some witnesses also
for their testimonies in the hearings on the anti-ballistic missiles defense programs. Notably, the
development by North Korea of nuclear weapons and long range ballistic missiles is a growing
threat to the United States.
c) Defendants and their puppets attempt to degrade, damage, or even shut down the US
energy infrastructure - oil and gas extraction, transportation, and processing; military and civilian
fuel supply; coal, natural gas, nuclear, and hydro power stations, as well as the electricity
distribution grid. Such activities might be considered as waging war on the United States, especially
in light of the fact that they have been initiated and are being sustained from abroad.
60
d) Defendants and their accessories declared various "wars" on Americans, conducted and
continue to conduct "mobilizations" to fight these "wars" and separate "battles". Even if the words
in quotes were used metaphorically, they reflect state of the minds of many Defendants' officers.
e) There was a sharp escalation in climate alarmism activity in 2004-2006, in the time of the
Iraq war, coinciding with a large Iraqi insurgency. Some evidence suggests that the Climate
Alarmism Enterprise might be a part or a tool of an organization, a group, or an informal association
of individuals (possibly linked with certain United Nations bodies), aspiring to be a global
government or global governance, and currently waging a war on the United States, or preparing to
wage a war on the United States. In such a war, the enemy group might use means other than the
recognizable arms of war, or might commandeer military or civilian assets of other parties, including
the United States, and use them as tools of war. Plaintiff discloses this information, as has become
known to him through analyzing publicly available documents, to the Honorable Judge and does not
attempt to give a legal interpretation.
CAUSES OF ACTION
COUNT I
RACKETEERING IN VIOLATION OF RICO, 18 U.S.C. 1962(c)
(AGAINST ALL DEFENDANTS)
178.
Plaintiff restates each and every allegation in the foregoing paragraphs as if fully set
forth herein.
179.
All the Defendants are persons within the meaning of 18 U.S.C. 1961(3).
180.
From at least 2008 and continuing through the present, all the
Defendants and enterprise members were associated in fact and comprised an "enterprise" within the
meaning of 18 U.S.C. 1961(4) and 1962(c) willfully and with actual knowledge of the illegality
of their actions and those of the enterprise. Some Defendants were members of this enterprise since
61
1988. The Climate Alarmism Enterprise is engaged in, and its activities affect, interstate and foreign
commerce.
181.
The Climate Alarmism Enterprise has an existence beyond that which is merely
necessary to commit predicate acts and, among other things, oversaw and coordinated the
commission of numerous predicate acts, each of which caused direct harm to Plaintiff, on an ongoing basis in furtherance of the scheme.
182.
During the Scheme Period, each of the Defendants agreed to and did conduct and
participate in the affairs of the Climate Alarmism Enterprise through a pattern of racketeering
activity within the meaning of 18 U.S.C. 1961(1) and (5), and 1962(c). It was among the
purposes of the Climate Alarmism Enterprise to establish the Climate Cult dogma, declaring that
human breath is pollution, as the state religion; to suppress dissent, including but not limited to
witness testimonies in official proceedings; to undermine the Constitution; to inflict enormous
damage on the USA, its citizens, and residents; and to steal enormous amount of money. This
scheme was also intended to, and did, in fact, result in huge profits for the members of the Climate
Alarmism Enterprise, and caused harm to Plaintiff.
183.
The Defendants' conduct and acts in furtherance of the enterprise's goals included,
but were not limited to the predicate RICO acts of: Retaliation against a witness and/or victim and/or
an informant in violation of 18 U.S.C. 1513, as set forth in 18 U.S.C. 1961(l)(B); Tampering
with a witness and/or victim and/or an informant in violation of 18 U.S.C. 1512, as set forth in 18
U.S.C. 1961(1)(B); Embezzlement from pension and/or welfare funds in violation of 18 U.S.C.
664, as set forth in 18 U.S.C. 1961(1)(B); Bribery in violation of 18 U.S.C. 201, as set forth in
18 U.S.C. 1961(1)(B); Bribery in violation of Texas Penal Code, Title 8, Chapter 36, punishable
by imprisonment for more than one year, as set forth in 18 U.S.C. 1961(1)(A); Bribery,
chargeable under laws of other states and punishable by imprisonment for more than one year, as set
62
----------------------------------------------------------------------------Case 5:16-cv-00211-C Document 1 Filed 09/12/16
forth in 18 U.S.C. 1961(l)(A); Bribery, chargeable under laws of the District of Columbia,
punishable by imprisonment for more than one year, as set forth in 18 U.S.C. 1961(l)(A). Each
Defendant committed at least two such acts over a period of ten years in connection to establishment
or operation of the enterprise, which constitutes a pattern of racketeering activity pursuant to 18
U.S.C. 1961(5).
184.
Among other things, throughout the Scheme Period, in furtherance of the Climate
Alarmism Enterprise and its goals, including establishment of the Climate Cult, and acting in concert
with at least one other enterprise member, each Defendant, on numerous occasions, made or caused
to be made or broadly disseminated communications and publications containing threats against
Plaintiff, and/or maliciously false and damaging statements about Plaintiff, causing direct injury to
Plaintiff.
185.
Moreover, throughout the Scheme Period, in furtherance of the Climate Alarmism
Enterprise and its goals, including establishment of the Climate Cult, and acting in concert with at
least one other enterprise member, each Defendant, on numerous occasions, embezzled, stole from,
or otherwise misappropriated from public funds, including the Social Security Fund, or attempted to
do so; doing so as an enterprise on an unprecedented scale and using unprecedented methods; and
causing direct injury to Plaintiff.
186.
Each of the predicate acts referred to in the preceding paragraphs was for the purpose
of executing the Climate Alarmism Enterprise's schemes, and the Defendants and enterprise
members engaged in such acts with the specific intent of furthering those schemes, willfully and
with full knowledge. Each of the Defendants performed or participated in the performance of at least
two of the predicate acts in the ten-year period ending on the date of this complaint.
187.
The conduct and actions set forth herein were related to each other by virtue of: (a)
common participants; (b) common victims; and (c) the common purpose and common result of
63
obtaining huge profits, degrading American scientific and intellectual capacities, creating political
polarization unprecedented in the last 150 years, establishing the Climate Cult as the state religion
(fully achieved only in California), undermining national energy infrastructure, and causing vast
economic damage.
188.
The Defendants' activities were interrelated, not isolated, and involved a calculated
series of repeated violations of the law in order to promote their scheme. The Climate Alarmism
Enterprise has existed since at least 1988, and all the named Defendants and others as yet unknown
participated in its management or operation since at least 2008, and this conduct and these activities
have continued as of the date of this Complaint.
189.
The Defendants' direct and indirect participation in the Climate Alarmism
Enterprise's affairs through the pattern of racketeering and activity described herein constitutes a
violation of 18 U.S.C. 1962(c).
190.
As a direct and proximate cause ofthe Defendants' violations of 18 U.S.C. 1962(c),
Plaintiff has sustained damage to his property, reputation, business, and employment opportunities,
including injury by reason of the predicate acts constituting the pattern of racketeering activity set
forth above, that was not only foreseeable but intended and an objective of the predicate activity.
191.
As a result of the violations of 18 U.S.C. 1962(c), Plaintiff has suffered damages in
an amount to be proven at trial. Plaintiff is entitled to recover from the Defendants the amount in
which he has been damaged, to be trebled in accordance with 18 U.S.C. 1964(c), together with
interest, costs, and any fees incurred by reason of the Climate Alarmism Enterprise's violations of 18
U.S.C. 1962(c), and disgorgement of Defendants' illicit proceeds.
COUNT II
RACKETEERING IN VIOLATION OF RICO, 18 U.S.C. 1962(a)
192.
Plaintiff restates paragraphs 1-191 as if fully set forth herein.

64
193.
The Climate Alarmism Enterprise is an "enterprise" within the meaning of 18 U.S.C.
1961 (4) and 1962( a), which was engaged in, or whose activities of which affected, interstate
and/or foreign commerce.

194.
In furtherance of the Climate Alarmism Enterprise, Defendants committed the
predicate racketeering acts as pleaded herein. It was a part of the purpose of the Climate Alarmism
Enterprise to establish the Climate Cult, declaring that human breath is pollution, as the state
religion, to suppress dissent, including but not limited to witness testimonies in official proceedings,
to inflict enormous damage on the USA, its citizens, and residents, and to steal an enormous amount
of money. This scheme was intended to, and did, in fact, result in huge profits for the members of
the Climate Alarmism Enterprise, and caused harm to Plaintiff.
195.
The Climate Alarmism Enterprise's conduct and acts in furtherance of the
enterprise's goals included, but were not limited to, the predicate RICO acts of: Retaliation against a
witness and/or victim and/or an informant in violation of 18 U.S.C. 1513, as set forth in 18 U.S.C.
1961(1)(B); Tampering with a witness and/or victim and/or an informant in violation of 18
U.S.C. 1512, as set forth in 18 U.S.C. 1961(1)(B); Embezzlement from pension and/or welfare
funds in violation of 18 U.S.C. 664, as set forth in 18 U.S.C. 1961(1)(B); Bribery in violation of
18 U.S.C. 201, as set forth in 18 U.S.C. 1961(1)(B); Bribery in violation of Texas Penal Code,
Title 8, Chapter 36, punishable by imprisonment for more than one year, as set forth in 18 U.S.C.
1961(1)(A); Bribery, chargeable under laws of other states and punishable by imprisonment for more
than one year, as set forth in 18 U.S.C. 1961(1)(A); Bribery, chargeable under laws of the District
of Columbia, punishable by imprisonment for more than one year, as set forth in 18 U.S.C.
1961(1)(A); which constitutes a pattern of racketeering activity pursuant to 18 U.S.C. 1961(5).
196.
In conducting the affairs of the Climate Alarmism Enterprise, all the Defendants used
and invested income that was derived from the pattern of racketeering activity, directly or indirectly,
65
in the operations of other Defendants, enterprise members, and the Climate Alarmism Enterprise,
which are entities and an enterprise engaged in, and the activities of which affect, interstate and
foreign commerce, in violation of 18 U,S.C. 1962(a). Specifically, the Defendants used funds they
procured through the alleged pattern of predicate acts to: (a) fund the Climate Alarmism Enterprise;
(b) fund retaliation against witnesses, tampering with witnesses, bribing witnesses and public
officials, and stealing from pension funds; (c) fund filing of abusive lawsuits and/or abusive motions
in legitimate litigation; and (c) fund propaganda campaigns in the media; including but not limited to
the use of illicit funds to fund direct and indirect actions against the Plaintiff.
197.
As a direct and proximate cause ofthe Defendants' violations of 18 U.S.C. 1962(a),
Plaintiff has sustained damage to his property, reputation, business, and employment opportunities.
198.
As a result of the violations of 18 U.S.C. 1962(a), Plaintiff has suffered substantial
damages in an amount to be proven at trial. Plaintiff is entitled to recover from the Defendants the
amount in which he has been damaged, to be trebled in accordance with 18 U.S.C. 1964(c),
together with interest, costs, and any fees incurred by reason of the Climate Alarmism Enterprise's
violations of 18 U.S.C. 1962(a), and disgorgement of Defendants' illicit proceeds.
COUNT III
CONSPIRACY IN VIOLATION OF RICO, 18 U.S.C. 1962(d)
199.
Plaintiff restates paragraphs 1-191 as if fully set forth herein.
200.
During the Scheme Period, each of the Defendants willfully, knowingly, and
unlawfully conspired to, and did further the efforts of the Climate Alarmism Enterprise to perpetrate
the illegal scheme through a pattern of racketeering activity in violation of 18 U.S.C. 1962(c) and
1962(a).
66
201.
In furtherance of the conspiracy and to effectuate its objectives, each of the
Defendants agreed that the following predicate acts, among others, would be committed by one or
more members of the conspiracy: Retaliation against a witness and/or victim and/or an informant in
violation of 18 U.S.C. 1513, as set forth in 18 U.S.C. 1961(l)(B); Tampering with a witness
and/or victim and/or an informant in violation of 18 U.S.C. 1512, as set forth in 18 U.S.C.
1961(1)(B); Embezzlement from pension and/or welfare funds in violation of 18 U.S.C. 664, as set
forth in 18 U.S.C. 1961(l)(B); Bribery in violation of 18 U.S.C. 201, as set forth in 18 U.S.C.
1961 ( 1)(B); Bribery in violation of Texas Penal Code, Title 8, Chapter 36, punishable by
imprisonment for more than one year, as set forth in 18 U.S.C. 1961(l)(A); Bribery, chargeable
under laws of other states and punishable by imprisonment for more than one year, as set forth in 18
U.S.C. 1961(l)(A); Bribery, chargeable under laws of the District of Columbia, punishable by
imprisonment for more than one year, as set forth in 18 U.S.C. 1961(1)(A); which constitutes a
pattern of racketeering activity pursuant to 18 U.S.C. 1961(5).
202.
It was specifically intended and foreseen by the Defendants that the Climate
Alarmism Enterprise would engage in, and conduct activities which affected interstate commerce.
Each Defendant was aware of the various racketeering schemes, assented to the efforts of the
Climate Alarmism Enterprise to carry out these acts, and acted in furtherance of the conspiracy.
203.
The pattern of racketeering consisted of multiple acts of racketeering by each of the
Defendants. The activities of these Defendants were interrelated, not isolated, and were perpetrated
for the same or similar purposes by the same persons. These activities extended for many years, and
continued up to the commencement of this action. The Defendants' conduct constitutes a conspiracy
to violate 18 U.S.C. 1962(c) and 1962(a), in violation of 18 U.S.C.
1962(d).
67
204.
Plaintiff has been injured in his property, reputation, business, and employment
opportunities by reason ofthe Defendants' conspiracy to violate 18 U.S.C. 1962(c) and 1962(a),
and by the overt acts taken in furtherance of that conspiracy.
205.
Plaintiff has been injured in his property, reputation, business, and employment
opportunities by reason ofthe Defendants' violations of 18 U.S.C. 1962(d).

206.
As a result of the violations of 18 U.S.C. 1962(d), Plaintiff has suffered substantial
damages in an amount to be proven at trial. Plaintiff is entitled to recover from the Defendants the
amount in which he has been damaged, to be trebled in accordance with 18 U.S.C. 1964(c),
together with interest, costs, and any fees incurred by reason of the Climate Alarmism Enterprise's
violations of 18 U.S.C. 1962(d), and disgorgement of Defendants' illicit proceeds.
68
DEMAND FOR JURY TRIAL
Demand is hereby made for a trial by jury for all issues so triable.
WHEREFORE, Plaintiff demands judgment:
(a)
Awarding Plaintiff compensatory damages in amounts to be determined
at trial, together with interest, attorneys' fees, costs and disbursements;

(b)
Awarding Plaintiff punitive and exemplary damages in amounts to be
determined at trial;
(c)
Awarding Plaintiff treble damages, costs of the suit, attorney's fees, and costs of litigation
under 18 U.S.C. 1964(c), in amounts to be determined at trial;

(d)
Ordering the Defendants to disgorge all monies they have improperly secured;
(e)
Prejudgment and post-judgment interest; and
(f)
Such other and further relief as is just and proper.
Dated: September 12, 2016

Lubbock, Texas
12501 Tech Ridge Blvd., #1535

Austin, TX 78753
(408) 921-1110
ah@defyccc.com
69

Goldstein V Climate Action Network Et Al

Transféré par

Informations du document

Titre original

Copyright

Formats disponibles

Partager ce document

Partager ou intégrer le document

Options de partage

Avez-vous trouvé ce document utile ?

Ce contenu est-il inapproprié ?

Droits d'auteur :

Formats disponibles

Goldstein V Climate Action Network Et Al

Transféré par

Droits d'auteur :

Formats disponibles

Case: 5:16-cv-00211-C As of: 09/13/2016 03:31 PM CDT 1 of 4

U.S. District Court

Date Filed: 09/13/2016

represented by Leonid Goldstein

Case: 5:16-cv-00211-C As of: 09/13/2016 03:31 PM CDT 2 of 4

Case: 5:16-cv-00211-C As of: 09/13/2016 03:31 PM CDT 3 of 4

1 COMPLAINT WITH JURY DEMAND against All Defendants filed by Leonid

2 CERTIFICATE OF INTERESTED PERSONS/DISCLOSURE STATEMENT by

Case: 5:16-cv-00211-C As of: 09/13/2016 03:31 PM CDT 4 of 4

4 Notice and Instruction to Pro Se Party (egp) (Entered: 09/13/2016)

5 Summons Issued as to All Defendants. (egp) (Entered: 09/13/2016)

CIVIL COVER SHEET

Case 5:16-cv-00211-C Document 1-1 Filed 09/12/16 Page 1 of 1 PageID 70

CLIMATE ACTION NETWORK et al.

(b) County of Residence of First Listed Plaintiff

County of Residence of First Listed Defendant

(EXChl'T IN U.S PLAINTIFF CASES)

{C) Attorneys (Firm Name,

(IN U.S. PLAINTIFF CASES ONLY)

Address, and Telephone Number)

II. BASIS OF JURISDICTION (Placean "X"inOneBoxOnlyJ

(For Diversity Cases Only)

(U.S. Government Not a Party)

IV NATURE OF SUIT (Place an

III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an

Citizen of Another State

Incorporated and Principal Place

"X" in one Box Only)

"X" in one BoxfiJr Plaintiff

Other Civil Rights

0 625 Drug Related Seizure

0 422 Appeal 28 USC 158

0 710 Fair Labor Standards

0 870 Taxes (U.S. Plaintiff

0 375 False Claims Act

0 462 Naturalization Application

CHECK IF THIS IS A CLASS ACTION

CHECK YES only if demanded in complaint:

FOR OFFICE U(E, ~N: ~

Case 5:16-cv-00211-C Document 1 Filed 09/12/16

Wiii1H!El1d D!Sl. ~/ l;:.

UNITED STATES DISTRICT COURT'J..0/1,., \dJ

CIVIL CASE NO.

JURY TRIAL DEMANDED

Case 5:16-cv-00211-C Document 1 Filed 09/12/16

Case 5:16-cv-00211-C Document 1 Filed 09/12/16

Of course, the foreign and domestic environmental organizations and UN agencies

But following goring in 1993-2001, the American sciences and science-intensive

Case 5:16-cv-00211-C Document 1 Filed 09/12/16

based on standing of victims of racketeering activity to act as "private attorney generals" in

JURISDICTION AND VENUE

("RICO"), 18 U.S.C. 1961-1968, and common law.

This Court has subject-matter jurisdiction pursuant to 28 U.S.C. 1331.

Case 5:16-cv-00211-C Document 1 Filed 09/12/16

Venue for this action is proper in pursuant to 28 U.S.C. 1391(b) because a

Plaintiff Leonid Goldstein is a permanent resident of the United States of America, a

Case 5:16-cv-00211-C Document 1 Filed 09/12/16

the following subsections.

Defendant Climate Action Network, sometimes calling itself Climate Action

Network International, ("CAN-I''), is an entity headquartered in Beirut, Lebanon. On information

Defendant US Climate Action Network ("USCAN"). USCAN is a registered tax-

Case 5:16-cv-00211-C Document 1 Filed 09/12/16

Defendant Environmental Grantmakers Association ("EGA") was founded in 1987