Case 3:17-cv-06011-WHA Document 164 Filed 03/20/18 Page 1 of 3 1 2 3 Eugene Illovsky (SBN 117892) ILLOVSKY LAW OFFICE 1611 Telegraph Avenue, Ste. 806 Oakland, CA 94612 Tel: (510) 394-5885 Email: eugene@illovskylaw.com 4 5 Attorneys for William Happer, Steven E. Koonin, and Richard S. Lindzen 6 7 UNITED STATES DISTRICT COURT 8 NORTHERN DISTRICT OF CALIFORNIA 9 SAN FRANCISCO DIVISION 10 11 12 THE PEOPLE OF THE STATE OF CALIFORNIA, Plaintiff, 13 14 15 16 v. B.P. P.L.C., et al., Defendants. Case No. C 17-06011 WHA Case No. C 17-06012 WHA Hearing Date: March 21, 2018 at 8:00 a.m. RESPONSE OF WILLIAM HAPPER, STEVEN E. KOONIN, AND RICHARD S. LINDZEN TO REQUEST FOR INFORMATION RE AMICUS CURIAE MATERIALS The Honorable William H. Alsup 17 18 19 The Court has asked Professors William Happer, Steven E. Koonin, and Richard S. Lindzen 20 three questions. The responses are as follows: 21 1. The source of any funding received by amici in connection with the general research 22 described in their submissions. This should include a clear statement regarding whether 23 (and the extent to which) amici have received funding from individuals or entities on either 24 side of the climate change debate (e.g., from any environmental or industry group). 25 Professor Happer is retired from Princeton University. He receives no funds from any 26 organization or person to support his climate science research. In 2017 he received an honorarium of 27 $1,000.00 for a speech on climate science at the Heritage Foundation. Best Schools donated $15,000 28 RESPONSE TO REQ. FOR INFORM. RE AMICUS CURIAE MATERIALS Case No.: C 17-06011-WHA Case No.: C 17-06012-WHA Case 3:17-cv-06011-WHA Document 164 Filed 03/20/18 Page 2 of 3 1 on his behalf to the University of North Carolina for his participation in Focused Civil Dialogue on 2 Global Warming in 2016 organized by Best Schools. Peabody Coal donated a comparable amount (he 3 believes it was around $10,000 to $15,000, though he does not recall the precise number) to the CO2 4 Coalition on his behalf, earned in connection with testimony given in a Proceeding of the Minnesota 5 Public Utilities Commission in September 2015. 6 Professor Koonin receives no funds from any organization or person to support his climate 7 science research. His salary from New York University does not constrain what research he does. 8 Since 2014, he has been compensated by the National Academies for assisting in the oversight of its 9 study activities. In 2016, Professor Koonin participated for 2.5 days in Exxon’s Core Technical 10 Capabilities Assessment, for which he received $8,000. The focus at that event was on biological and 11 environmental sciences research; he estimates that about 10% of the presentations dealt with responses 12 to a changing climate (but not with climate science itself). 13 Professor Lindzen is retired from the Massachusetts Institute of Technology. He has, since 14 2013, received $25,000 per year as a Distinguished Visiting Scholar at the Cato Institute, which he 15 believes has had scholars taking positions on both sides of the climate change debate. This is his last 16 year serving in that role. He earned approximately $30,000 from Peabody Coal in connection with 17 testimony given in a Proceeding of the Minnesota Public Utilities Commissions in September 2015. 18 He received $1,500 from the Texas Public Policy Foundation for a climate science lecture in 2017. 19 20 2. Whether amici are in any way affiliated (directly or indirectly) with any party to the aboveentitled actions. 21 Professor Happer has no affiliation with any parties to the above-entitled actions. 22 Professor Koonin has no affiliation with any parties to the above-entitled actions, except for 23 some money vested in a BP pension plan arising from his employment that ended nine years ago. 24 During his subsequent service for President Obama, that pension plan interest was reviewed by the 25 government and deemed not to be a conflict of interest. 26 Professor Lindzen has no affiliation with any parties to the above-entitled actions. 27 // 28 2 RESPONSE TO REQ. FOR INFORM. RE AMICUS CURIAE MATERIALS Case No.: C 17-06011-WHA Case No.: C 17-06012-WHA Case 3:17-cv-06011-WHA Document 164 Filed 03/20/18 Page 3 of 3 1 3. Why amici waited until shortly before the tutorial to file their proposed submissions such 2 that the parties only have limited time to react. 3 Amici apologize to the Court for the timing of their submission. 4 Amici became aware of the Court’s questions on or about March 9 and started to organize their 5 writing on March 10. There was a considerable amount of work required (and each of the professors 6 had other work to attend to). Amici did not finalize their work on their submission until the Sunday 7 before it was filed, so their work was done in that 9-day period. The intent of Amici was not to hinder 8 the parties’ ability to respond, but rather to provide information that was as helpful as possible to the 9 Court. 10 11 12 13 14 15 16 DATED: March 20, 2018 ILLOVSKY LAW OFFICE EUGENE ILLOVSKY By: /s/ Eugene Illovsky Eugene Illovsky Attorneys for Amicus Curiae William Happer, Steven E. Koonin, and Richard S. Lindzen 17 18 19 20 21 22 23 24 25 26 27 28 3 RESPONSE TO REQ. FOR INFORM. RE AMICUS CURIAE MATERIALS Case No.: C 17-06011-WHA Case No.: C 17-06012-WHA