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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`Civil Action No. 1:20-cv-01429-UNA
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`STATE OF DELAWARE, ex rel. KATHLEEN
`JENNINGS, Attorney General of the State of
`Delaware,
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`Plaintiff,
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`v.
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`BP AMERICA INC., BP P.L.C., CHEVRON
`CORPORATION, CHEVRON U.S.A. INC.,
`CONOCOPHILLIPS, CONOCOPHILLIPS
`COMPANY, PHILLIPS 66, PHILLIPS 66
`COMPANY, EXXON MOBIL CORPORATION,
`EXXONMOBIL OIL CORPORATION, XTO
`ENERGY INC., HESS CORPORATION,
`MARATHON OIL CORPORATION,
`MARATHON OIL COMPANY, MARATHON
`PETROLEUM CORPORATION, MARATHON
`PETROLEUM COMPANY LP, SPEEDWAY
`LLC, MURPHY OIL CORPORATION,
`MURPHY USA INC., ROYAL DUTCH SHELL
`PLC, SHELL OIL COMPANY, CITGO
`PETROLEUM CORPORATION, TOTAL S.A.,
`TOTAL SPECIALTIES USA INC.,
`OCCIDENTAL PETROLEUM
`CORPORATION, DEVON ENERGY
`CORPORATION, APACHE CORPORATION,
`CNX RESOURCES CORPORATION, CONSOL
`ENERGY INC., OVINTIV, INC., and
`AMERICAN PETROLEUM INSTITUTE,
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`Defendants.
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`NOTICE OF JOINDER IN AND CONSENT TO REMOVAL
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`PLEASE TAKE NOTICE THAT defendant American Petroleum Institute (“API”), with its
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`principal place of business located at 200 Massachusetts Avenue, NW, Washington, DC 20001, by
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`and through the undersigned counsel, files this Notice of Joinder In and Consent To Removal
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`pursuant to 28 U.S.C. § 1446(b).
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`Case 1:20-cv-01429-UNA Document 28 Filed 10/26/20 Page 2 of 3 PageID #: 1364
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`1.
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`On September 10, 2020, plaintiff State of Delaware (“Plaintiff”) filed this civil
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`action against the above-named Defendants in the Superior Court of the State of Delaware, in a
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`case captioned State of Delaware v. BP America Inc. et al., and assigned Civil Action No. N20C-
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`09-097 AML CCLD (the “State Court Action”).
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`2.
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`API was allegedly served with a copy of the summons and complaint in the State
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`Court Action on October 14, 2020, c/o Cogency Global Inc., 850 New Burton Road, Dover,
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`Delaware 19904.
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`3.
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`On October 23, 2020, Defendants Chevron Corp. and Chevron U.S.A. Inc. filed a
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`Notice of Removal of the State Court Action to this Court.
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`4.
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`API hereby joins in and consents to the Notice of Removal of the State Court Action
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`to this Court filed by Defendants Chevron Corp. and Chevron U.S.A. Inc.
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`5.
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`API reserves all rights, including defenses and objections as to venue, service,
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`personal jurisdiction, etc., and further states that the filing of this Notice of Joinder In and Consent
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`To Removal is subject to, and without waiver of, any such defenses and objections.
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`2
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`Case 1:20-cv-01429-UNA Document 28 Filed 10/26/20 Page 3 of 3 PageID #: 1365
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`Dated: October 26, 2020
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`WOMBLE BOND DICKINSON (US) LLP
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`/s/ Kevin J. Mangan
`Kevin J. Mangan (DE No. 3810)
`Kristen H. Cramer (DE No. 4512)
`Nicholas T. Verna (DE No. 6082)
`1313 North Market Street, Suite 1200
`Wilmington, Delaware 19801
`Telephone: (302) 252-4320
`Facsimile: (302) 252-4330
`Email: kevin.mangan@wbd-us.com
`Email: kristen.cramer@wbd-us.com
`Email: nick.verna@wbd-us.com
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`Attorneys for American Petroleum Institute
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`OF COUNSEL:
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`MCGUIREWOODS LLP
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`Andrew G. McBride
`(pro hac vice forthcoming)
`2001 K Street N.W.
`Washington, D.C. 20006
`Telephone: (202) 857-1700
`Email: amcbride@mcguirewoods.com
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`Amanda S. Hawkins
`(pro hac vice forthcoming)
`501 Fayetteville Street
`Raleigh, NC 2760
`Telephone: (919) 755-6600
`Email: ashawkins@mcguirewoods.com
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`WBD (US) 50510224v2
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`3
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