...ExxonMobil”petitions the Court for an order authorizing it to conduct depositions and obtain documents pertaining to potential claims of abuse of process, civil conspiracy, and violations of ExxonMobil’s constitutional rights. ExxonMobil has identified [sixteen] individuals who are believed to possess evidence that would allow ExxonMobil to investigate claims and perpetuate testimony for use in an anticipated suit.

...A collection of special interests and opportunistic politicians are abusing law enforcement authority and legal process to impose their viewpoint on climate change...ExxonMobil finds itself directly in that conspiracy’s crosshairs. Even though it has long acknowledged the risks presented by climate change, supported the Paris climate accords, and backed a revenue-neutral carbon tax, ExxonMobil has nevertheless been targeted by state and local governments for pretextual investigations and litigation intended to cleanse the public square of alternative viewpoints.

...Despite having made stark claims in their respective complaints of near certain injury to their jurisdictions because of climate change and rising sea levels, none of the municipalities have made disclosures to investors remotely similar to the dire allegations in their complaints...The irreconcilable differences between the allegations in the 217 Ex. 12 at App. 171. 49 municipalities’ tort complaints and the disclosures in the municipal bond offerings suggest that an improper motive or undue influence might have caused the municipalities to include allegations in their complaints that were not honestly held.