PLAINTIFFS’ NOTICE OF DEPOSITION OF REX TILLERSON

JULIA A. OLSON (OR Bar 062230) 

JuliaAOlson@gmail.com

WILD EARTH ADVOCATES 

1216 Lincoln Street 

Eugene, OR 97401 

Tel: (415) 786-4825 

DANIEL M. GALPERN (OR Bar 061950) 

dan.galpern@gmail.com

LAW OFFICES OF DANIEL M. GALPERN 

1641 Oak Street 

Eugene, OR 97401 

Tel: (541) 968-7164 

Attorneys for Plaintiffs 

JOSEPH W. COTCHETT 

jcotchett@cpmlegal.com

PHILIP L. GREGORY (pro hac vice) 

pgregory@cpmlegal.com

PAUL N. MCCLOSKEY 

pmccloskey@cpmlegal.com

COTCHETT, PITRE & McCARTHY, LLP 

San Francisco Airport Office Center 

840 Malcolm Road 

Burlingame, CA 94010 

Tel: (650) 697-6000 

Fax: (650) 697-0577 

 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

EUGENE DIVISION 

KELSEY CASCADIA ROSE JULIANA;

XIUHTEZCATL TONATIUH M., through 

his Guardian Tamara Roske-Martinez; et al.

Plaintiffs,

v.

The UNITED STATES OF AMERICA; 

BARACK OBAMA, in his official capacity as 

President of the United States; et al., 

Federal Defendants.

Case No.: 6:15-cv-01517-TC 

PLAINTIFFS’ NOTICE OF 

DEPOSITION OF 

REX TILLERSON

Exhibit 1 

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PLAINTIFFS’ NOTICE OF DEPOSITION OF REX TILLERSON 

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TO ALL PARTIES AND THEIR ATTORNEY OF RECORD: 

 PLEASE TAKE NOTICE that, pursuant to Rules 30 and 45 of the Federal Rules 

of Civil Procedure, Plaintiffs Kelsey Juliana, et al., will take the deposition of Rex 

Tillerson on January 19, 2017 at 10:00 a.m. at the Law Offices of Sidley Austin LLP, 

2021 McKinney Avenue, Suite 2000, Dallas, TX 75201. If the deposition is not 

completed on January 19, 2017, it will be continued from day to day, excluding Sundays 

and holidays, until completed. 

 PLEASE TAKE FURTHER NOTICE that the deposition will be taken before a 

notary public or other person authorized to administer oaths under applicable law, and 

will be conducted pursuant to Federal Rule of Civil Procedure 30. Pursuant to Rule 

30(b)(3) of the Federal Rules of Civil Procedure, Plaintiffs reserve the right to record the 

deposition testimony by videotape and instant visual display. Plaintiffs reserve the right 

to use the videotape deposition at the time of trial. 

 YOU ARE FURTHER NOTIFIED THAT the deponent is a representative and a 

board member of one or more parties to this action. So far as is known to Plaintiffs, the 

deponent’s address is as follows:

Rex Tillerson 

ExxonMobil 

5959 Las Colinas Boulevard 

Irving, Texas 75039 

The deponent is directed to produce and permit inspection and copying of the documents 

and/ or objects specified in Attachment A to this notice at the time of deposition. 

 A list of all parties or attorneys for parties on whom this Notice of Deposition is 

being served is shown on the accompanying Proof of Service. 

Dated: December 28, 2016 s/ Philip L. Gregory 

PHILIP L. GREGORY (pro hac vice) 

COTCHETT, PITRE & McCARTHY, LLP 

Attorneys for Plaintiffs 

Exhibit 1 

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PLAINTIFFS’ NOTICE OF DEPOSITION OF REX TILLERSON 

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ATTACHMENT A 

I. DEFINITIONS

A. As used herein, the term “DOCUMENT” means any kind of written, 

graphic or recorded matter, however produced or reproduced, of any kind or description, 

whether sent, received or neither, including drafts, originals, non-identical copies and 

information stored magnetically, electronically, photographically or otherwise, and 

including but not limited to, studies, papers, books, accounts, letters, diagrams, pictures, 

drawings, photographs, correspondence, telegrams, cables, text messages, emails, 

memoranda, notes, notations, work papers, intra-office and inter-office communications, 

communications to, between and among employees, transcripts, minutes, orders, reports, 

recordings or other documentation of telephone or other conversations, interviews, 

committee meetings, departmental meetings, company meetings or other meetings, 

affidavits, slides, statements, summaries, opinions, indices, analyses, publications, 

questionnaires, answers to questionnaires, statistical records, ledgers, journals, lists, logs, 

tabulations, charts, graphs, maps, surveys, sound recordings, data sheets, computer 

printouts, tapes, discs, microfilm, all other records kept by YOU, and thing similar to any 

of the foregoing, regardless of the title, author or origin. 

B. As used herein, the phrase “REFERS, RELATES, REGARDS, OR 

PERTAINS TO” means containing, alluding to, responding to, commenting upon, 

discussing, showing, disclosing, explaining, mentioning, analyzing, constituting, 

comprising, evidencing, setting forth, summarizing or characterizing, either directly or 

indirectly in whole or in part. 

C. As used herein, the term “AMERICAN PETROLEUM INSTITUTE” shall 

refer to defendant American Petroleum Institute, and to all of its employees, agents, 

officers, directors, representatives, consultants, affiliates, members, accountants, and 

attorneys, including any PERSON who has served in any such capacity at any time. 

Exhibit 1 

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PLAINTIFFS’ NOTICE OF DEPOSITION OF REX TILLERSON 

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D. As used herein, the term “NATIONAL ASSOCIATION OF 

MANUFACTURERS” shall refer to defendant National Association of Manufacturers, 

and to all of its employees, agents, officers, directors, representatives, consultants, 

affiliates, members, accountants, and attorneys, including any PERSON who has served 

in any such capacity at any time. 

E. As used herein, the term “AMERICAN FUEL & PETROCHEMICAL 

MANUFACTURERS” shall refer to defendant American Fuel & Petrochemical 

Manufacturers, and to all of its employees, agents, officers, directors, representatives, 

consultants, affiliates, members, accountants, and attorneys, including any PERSON who 

has served in any such capacity at any time. 

 F. As used herein, the term “EXXONMOBIL” shall refer to

EXXONMOBIL, and to all of its employees, agents, officers, directors, representatives, 

consultants, affiliates, members, accountants, and attorneys, including any PERSON who 

has served in any such capacity at any time. 

G. As used herein, the term “INTERVENOR DEFENDANTS” shall refer to 

defendants AMERICAN PETROLEUM INSTITUTE, NATIONAL ASSOCIATION OF 

MANUFACTURERS, AMERICAN FUEL & PETROCHEMICAL 

MANUFACTURERS, and their members. 

 H. As used herein, the term “COMMUNICATION(S)” means every manner 

or method of disclosure, exchange of information, statement or discussion between or 

among two or more PERSONS, including but not limited to, face-to-face and telephone 

conversations, correspondence, memoranda, telegrams, telexes, email messages, 

transcribed voice-mail messages, text messages, meetings, discussions, releases, 

statements, reports, publications or any recordings or reproductions. 

 I. As used herein, the words “YOU” and “YOUR” shall mean or refer to 

REX TILLERSON and all of his present or former agents, attorneys, consultants, 

employees, representatives, and/or anyone acting or purporting to act on his behalf. 

Exhibit 1 

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PLAINTIFFS’ NOTICE OF DEPOSITION OF REX TILLERSON 

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 J. As used herein, the term “PERSON” means all individuals, entities, firms, 

organizations, groups, committees, regulatory agencies, governmental entities, business 

entities, corporations, partnerships, trusts and estates. 

 K. As used herein, the term “AGENCY” shall mean any federal, state, 

regional or local governmental agency. The term shall include directors, employees, 

consultants and/or representatives of said AGENCY. 

x. As used herein, the term “CLIMATE CHANGE” shall mean any change 

in the state of the climate lasting for an extended period of time. In other words, the term 

“CLIMATE CHANGE” includes changes in surface and ocean temperature, 

precipitation, or wind patterns, among other effects, that occur over several decades or 

longer, attributed directly or indirectly to human activity. The term “CLIMATE 

CHANGE” shall include ocean acidification, sea level rise, and other impacts resulting 

from the increased concentration of greenhouse gases and carbon dioxide in the 

atmosphere and oceans. “CLIMATE CHANGE” also has been called climatic changes, 

global warming, global change, global heating, atmospheric pollution by carbon dioxide 

or other greenhouse gases, and dilution of carbon 14 by fossil carbon. 

II. INSTRUCTIONS 

A. Please produce and permit the inspection and copying of the 

DOCUMENTS described below which are in YOUR possession, custody, or control, or 

in the possession, custody, or control of YOUR attorneys, consultants, agents, or 

representatives. 

B. In producing the DOCUMENTS demanded, YOU shall segregate those 

documents by each request set forth herein. 

C. For any claim that a DOCUMENT YOU are required to produce in 

response to any of these demands is privileged YOU will: 

 1. Identify its title and general subject matter; 

 2. State its date; 

Exhibit 1 

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PLAINTIFFS’ NOTICE OF DEPOSITION OF REX TILLERSON 

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 3. Identify its author(s); 

 4. Identify the PERSONS for whom it was prepared or to whom it 

was sent; 

 5. State the nature of the privilege claimed; and 

 6. State in detail each and every fact upon which YOU base your 

claim of privilege. 

D. The words “and” and “or” shall be construed in the conjunctive or 

disjunctive, whichever is most inclusive.

E. The singular form shall include the plural form and vice versa. 

F. The present tense shall include the past tense and vice versa. 

G. If any DOCUMENT cannot be produced in full, produce it to the extent 

possible, indicating what information is being withheld and the reason such information 

is being withheld. 

H. If a DOCUMENT once existed, but has been lost, destroyed, no longer 

exists, or is no longer in YOUR possession or control, identify each such DOCUMENT 

and separately state the details concerning the loss or destruction of the DOCUMENT, or 

the name and address of the current or last known custodian of any such document, if 

known to you. 

III. DOCUMENT REQUESTS

A. Each DOCUMENT that identifies YOUR position within the organizational 

structure of AMERICAN PETROLEUM INSTITUTE.

B. Each DOCUMENT that identifies YOUR position within the organizational 

structure of NATIONAL ASSOCIATION OF MANUFACTURERS. 

C. Each DOCUMENT that identifies YOUR position within the organizational 

structure of EXXONMOBIL. 

D. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO 

COMMUNICATIONS with any PERSON (other than COMMUNICATIONS 

Exhibit 1 

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PLAINTIFFS’ NOTICE OF DEPOSITION OF REX TILLERSON 

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with INTERVENOR DEFENDANTS’ attorneys and their representatives) 

regarding this litigation, including financial arrangements related to this litigation. 

E. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO 

participation by YOU on internal committees of the AMERICAN PETROLEUM 

INSTITUTE pertaining to CLIMATE CHANGE, including, but not limited to, 

any recommendations concerning any policy and initiative of the AMERICAN 

PETROLEUM INSTITUTE.

F. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO 

participation by YOU on internal committees of the NATIONAL 

ASSOCIATION OF MANUFACTURERS pertaining to CLIMATE CHANGE,

including, but not limited to, any recommendations concerning any policy and 

initiative of the NATIONAL ASSOCIATION OF MANUFACTURERS. 

G. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO 

participation by YOU in the Global Climate Coalition’s efforts pertaining to 

CLIMATE CHANGE from 1992-2001.

H. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO 

the participation by Randy Randol on the Global Climate Science 

Communications Team (“GCSCT”), including, but not limited to,

COMMUNICATIONS with the GCSCT and the development of the Global 

Climate Science Communications Plan.

I. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO 

YOUR COMMUNICATIONS with any representative of EXXONMOBIL 

concerning CLIMATE CHANGE, including, but not limited to, observations or 

predictions of CLIMATE CHANGE and effects on permafrost, extreme or 

unusual weather conditions, sea ice conditions and the impact of those changes on 

oil drilling operations in Alaska North Slope, Gulf of Mexico, Canada, Greenland, 

Norway, and Russia. 

Exhibit 1 

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PLAINTIFFS’ NOTICE OF DEPOSITION OF REX TILLERSON 

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J. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO 

YOUR COMMUNICATIONS with any representative of the administration of 

former President George W. Bush pertaining to the Kyoto Protocol.

K. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO 

YOUR COMMUNICATIONS with any representative of the administration of 

former President George W. Bush pertaining to the UN Framework Convention 

on Climate Change. 

L. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO 

YOUR COMMUNICATIONS with any representative of EXXONMOBIL and 

any representative of the AMERICAN PETROLEUM INSTITUTE regarding 

CLIMATE CHANGE. 

M. Each DOCUMENT that REFERS, RELATES, REGARDS, OR PERTAINS TO 

YOUR COMMUNICATIONS with any representative of EXXONMOBIL and 

any representative of the NATIONAL ASSOCIATION OF MANUFACTURERS 

regarding CLIMATE CHANGE. 

N. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS with any representative of the Competitive Enterprise 

Institute pertaining to the 2003 Competitive Enterprise Institute lawsuit against 

the Bush Administration White House Office of Science and Technology Policy 

and the National Science and Technology Council to stop the release of the 

National Assessment of Climate Variability and Change (National Assessment) 

and EPA’s 2002 Climate Action Plan.

O. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS with any representative of the administration of former 

President George W. Bush pertaining to actual or potential appointees of the Bush 

Administration who would be, as part of their duties, be working on CLIMATE 

CHANGE. 

Exhibit 1 

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PLAINTIFFS’ NOTICE OF DEPOSITION OF REX TILLERSON 

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P. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS with any representative of administration of former 

President George W. Bush pertaining to the removal of officials who had been 

working in the administration of former President William J. Clinton who, as part 

of their duties, were working on CLIMATE CHANGE. 

Q. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS with any representative of the administration of former 

President George W. Bush pertaining to the United Nations Intergovernmental 

Panel on Climate Change. 

R. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS with any representative of the administration of former 

President George W. Bush pertaining to the Bush Administration’s Climate 

Science Research Program.

S. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS with any representative of the administration of former 

President George W. Bush pertaining to the Bush Administration’s U.S Climate 

Change Research Initiative. 

T. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS with any representative of the administration of former 

President George W. Bush pertaining to the Bush Administration’s Climate 

Change Science Program.

U. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS with any representative of the administration of former 

President George W. Bush pertaining to the Bush Administration’s Climate 

Change Technology Program. 

V. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS with any representative of the administration of former 

Exhibit 1 

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PLAINTIFFS’ NOTICE OF DEPOSITION OF REX TILLERSON 

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President George W. Bush pertaining to the Bush Administration’s Committee on 

Climate Change Science and Technology Integration.

W. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS with any representative of the administration of former 

President George W. Bush pertaining to the Bush Administration’s Interagency 

Working Group on Climate Change Science and Technology. 

X. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS with any representative of the administration of former 

President George W. Bush pertaining to the UN Framework Convention on 

Climate Change. 

Y. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS with any representative of the administration of former 

President George W. Bush pertaining to the Kyoto Protocol.

Z. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS with any representative of the administration of former 

President George W. Bush pertaining to the Intergovernmental Panel on Climate 

Change. 

AA. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS with any representative of EXXONMOBIL regarding 

CLIMATE CHANGE, including, but not limited to, any COMMUNICATIONS 

to and from the following current and former representatives of EXXONMOBIL: 

1) Lee Raymond, CEO; 

2) Frank Sprow, Vice President, Safety, Health & Environment;

3) Kenneth Cohen, VP, Public and Government Affairs;

4) Arthur G. (Randy) Randol III, Ph.D, Public Affairs Manager;

5) Walt Buchholtz, Public and Government Affairs Manager; 

6) Brian P. Flannery, Science, Strategy and Programs Manager in Environmental 

Exhibit 1 

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PLAINTIFFS’ NOTICE OF DEPOSITION OF REX TILLERSON 

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Policy and Planning; 

7) David P. Bailey, Manager, Climate Policy;

8) Mark D. Boudreaux, Senior Director, Federal Relations;

9) Sherri Stuewer, VP Safety, Health & Environment; 

10)Jaime Spelling, VP Corporate Planning; 

11) David Kingston, VP Downstream Business Development and Portfolio 

Management; 

12) Elizabeth Beauvais, Advisor, Corporate Citizenship; 

13) Victoria Ceja, EXXONMOBIL Public Affairs, Corporate Citizenship and 

Community Investment Policy;

14) Lynn A. Gelner; and

15) Lauren Kerr.

BB. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO the 

2006-2007 program on climate change and public affairs administered by Public 

Affairs Director Kenneth Cohen, including plans, communications, and notes 

from the Airlie House meeting, which took place on December 4-6, 2006, called 

“Opinion Leader Dialogue.”

CC. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS regarding a carbon tax and/or fee, or other carbon pricing 

mechanisms.

DD. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS regarding government policy on CLIMATE CHANGE,

including internal analyses, lobbying reports and records, and plans. 

EE.Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS regarding the Waxman Markey 2009 American Clean 

Energy and Security Act of 2009, including, but not limited to, reports from 

lobbyists working with EXXONMOBIL. 

Exhibit 1 

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PLAINTIFFS’ NOTICE OF DEPOSITION OF REX TILLERSON 

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FF.Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS regarding the Waxman Markey 2009 American Clean 

Energy and Security Act of 2009, including, but not limited to, reports from 

representatives of AMERICAN PETROLEUM INSTITUTE. 

GG. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS regarding the Waxman Markey 2009 American Clean 

Energy and Security Act of 2009, including, but not limited to, reports from 

representatives of NATIONAL ASSOCIATION OF MANUFACTURERS.

HH. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS regarding the McCain-Lieberman 2003 Climate 

Stewardship Act, including, but not limited to, reports from lobbyists working 

with EXXONMOBIL. 

II. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS regarding the McCain-Lieberman 2003 Climate 

Stewardship Act, including, but not limited to, reports from representatives of 

AMERICAN PETROLEUM INSTITUTE. 

JJ. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS regarding the McCain-Lieberman 2003 Climate 

Stewardship Act, including, but not limited to, reports from representatives of 

NATIONAL ASSOCIATION OF MANUFACTURERS. 

KK. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS regarding the 2005 Climate Stewardship and Innovation 

Act, including, but not limited to, reports from lobbyists working with 

EXXONMOBIL. 

LL.Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS regarding the 2005 Climate Stewardship and Innovation 

Act, including, but not limited to, reports from representatives of AMERICAN 

Exhibit 1 

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PLAINTIFFS’ NOTICE OF DEPOSITION OF REX TILLERSON 

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PETROLEUM INSTITUTE.

MM. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS regarding the 2005 Climate Stewardship and Innovation 

Act, and the, including, but not limited to, reports from representatives of 

NATIONAL ASSOCIATION OF MANUFACTURERS. 

NN. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS regarding the 2007 Climate Stewardship and Innovation 

Act, including, but not limited to, reports from lobbyists working with 

EXXONMOBIL. 

OO. Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS regarding the 2007 Climate Stewardship and Innovation 

Act, including, but not limited to, reports from representatives of AMERICAN 

PETROLEUM INSTITUTE.

PP.Each DOCUMENT that REFERS, RELATES OR PERTAINS TO YOUR 

COMMUNICATIONS regarding the 2007 Climate Stewardship and Innovation 

Act, including, but not limited to, reports from representatives of NATIONAL 

ASSOCIATION OF MANUFACTURERS.

Exhibit 1 

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PROOF OF SERVICE 

I am employed in San Mateo County where service of the document(s) referred to 

below occurred. I am over the age of 18 and not a party to the within action. My business 

address is Cotchett, Pitre & McCarthy, LLP, San Francisco Airport Center, 840 Malcolm 

Road, Suite 200, Burlingame CA 94010. I am readily familiar with the firm's practices for 

the service of documents. On this date, I served or caused to be served a true copy of the 

following: 

PLAINTIFFS' NOTICE OF DEPOSITION OF REX TILLERSON 

XXX BY E-MAIL: My e-mail address is palmasi@cpmlegal.com and service of this 

document(s) occurred on the date shown below. This document is being served 

electronically and the transmission was reported as complete and without error. 

XXX BY MAIL: I placed a true copy of the aforementioned document(s) in a sealed 

envelope with postage fully paid. I am familiar with this firm's practice of collection and 

processing of mail for delivery by the United States Postal Service on the next day in the 

ordinary course of business. 

[SEE ATTACHED SERVICE LISTI 

I declare under penalty of perjury, under the laws of the State of California, that the 

foregoing is true and correct. Executed at Burlingame, California, on December 28, 2016. 

POUNEH ALMASI 

PROOF OF SERVICE OF PLAINTIFFS' NOTICE OF DEPOSITION OF REX 

TILLERSON 

Exhibit 1 

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SERVICE LIST 

Sean C. Duffy Julia Olson 

sean.c.duffy@usdoj.gov julia@ourchildrenstrust.org 

Peter Dykema Wild Earth Advocates 

Peter. Dykema@usdoj.gov 1216 Lincoln St. 

Sarah Himmelhoch Eugene, OR 97401 

Sarah.Himmelhoch@usdoj.gov 

Guillermo Montero 

Guillermo.Montero@usdoj .gov 

U.S. Department of Justice 

Environment & Natural Resources Division 

Natural Resources Section 

601 D Street NW 

Washington, DC 20004 

Quin Sorenson Daniel M. Galpem 

qsorenson@sidley.com dan.gal_Qem@gmai I .com 

David T. Buente Law Offices of Daniel M. Galpern 

dbuente@sidley.com 2495 Hilyard St., Suite A 

Sidley Austin LLP Eugene, OR 97405 

1501 K Street, NW 

Washington, DC 20005 

PROOF OF SERVICE OF PLAINTIFFS' NOTICE OF DEPOSITION OF REX 

TILLERSON 

Exhibit 1 

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