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IN THE MATTER OF FACTUAL
INQUIRY RELATED TO CHEVRON
U.S.A. INC’S COMPLIANCE WITH
RICHMOND MUNICIPAL CODE
CHAPTER 7.04
LEGISLATIVE SUBPOENA
Date: May 27, 2025
Time: 3:30 p.m.
Place: City Hall, Council Chamber
Community Services Building
440 Civic Center Plaza
Richmond, California 94804
To: Custodian of Records for Chevron U.S.A., Inc.
841 Chevron Way
Richmond, CA 94801
Chevron Corporation
2710 Gateway Oaks Drive
Sacramento, CA 95833
Pursuant to City of Richmond (“City”) Municipal Code section 7.04.430 and chapter 13.08 in furtherance of an investigation into apparent noncompliance with Chapter 7.04 of the Richmond Municipal Code, the Richmond City Council hereby orders Chevron U.S.A., Inc. to produce all documents, records, and other materials described in Exhibit A (the “Records”) at the Richmond City Council meeting on May 27, 2025 at 3:30 p.m. to be held at Council Chamber at the Community Services Building, 440 Civic Center Plaza, Richmond, CA 94804.
You are not required to appear at the City Council meeting on the date and time set forth above if, prior to May 27, 2025, you produce and permit inspection and copying of the Records, by mailing or otherwise delivering such materials, together with a certification from an officer authorized to provide that certification, dated and signed under penalty of perjury under the laws of the State of California that the documents provided are true, correct and complete copies of all documents responsive to this Legislative Subpoena, to the City Council in care of the City Clerk at the following address:
City Council
c/o Pamela Christian, City Clerk
450 Civic Center Plaza
Richmond, California 94804
The subpoenaed items are relevant to the City’s investigation of possible violations of law, including its Business License Tax (Richmond Municipal Code, chapter 7.04) and the documents requested are believed to contain evidence of such violations.
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If you demonstrate to the reasonable satisfaction of the Richmond City Attorney’s Office that the privacy rights of third parties are in issue, the City Attorney’s Office is authorized to enter into an appropriate confidentiality agreement with you. Your own privacy rights are protected by section
13.08.040 of the Richmond Municipal Code.
If you have any questions regarding compliance with this subpoena, contact Assistant City Attorney Christopher J. Dykzeul , Tel: ( 510) 620-6507 or via email at [email protected].
Please be advised that destruction or concealment of any items requested will result in a referral to law enforcement for criminal prosecution under California Penal Code section 135.
Failure to comply with the commands of this subpoena may subject you to citation for contempt or other penalties before the Superior Court of the State of California
Signed in the City of Richmond this 22nd day of April 2025
By: _________________________________
Eduardo Martinez
Mayor
By: _________________________________
Pamela Christian
City Clerk
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EXHIBIT A
1. Request No. 1. Documents sufficient to explain how Chevron U.S.A. Inc. , a California corporation (hereinafter, “Chevron”) calculated its December 19, 2024 and April 1, 2025 2025 payments of the City of Richmond ’s (hereinafter, “City”) business license tax pursuant to Chapter 7.04 et seq. of the City of Richmond’s Municipal Code with respect to its business activity in the City in calendar year 2024 (together, “the Payment”).
2. Request No. 2. Chevron’s Richmond Refinery Income Statements (“the Statements”) and general ledgers (“General Ledgers”) by quarter and year-end for the 2024 calendar year.
3. Request No. 3. Documents sufficient to reconcile the information provided under Request No. 2 to the revenues Chevron reported on Securities and Exchange Commission 10Q and 10K reports for 2024;
4. Request No. 4 . Documents sufficient to explain or reconcile any differences between Chevron’s audited financial statements for 2024 related to Chevron’s Richmond refinery and the Statements ;
5. Request No. 5. An excel file showing the line item details in the General Ledger of all accounts which comprise annual revenues received by Chevron. This should tie to the Statements;
6. Request No. 6. An excel file showing the line item details in the General Ledger of all accounts which support any deductions Chevron took for raw materials processed at Chevron’s Richmond refinery for the year 2024 in calculating the Payment;
7. Request No. 7. A detailed listing and documents sufficient to explain any exclusions from Chevron’s gross receipts used in calculating the Payment;
8. Request No. 8. Documents sufficient to disclose the a verage cost of crude or otherwise unrefined oil refined at the Richmond refinery during 2024;
9. Request No. 9. Documents sufficient to disclose the number of barrels of oil refined during 2024 at the Richmond refinery. This should agree with published financial disclosures or any discrepancy should be explained.
10. Request No. 10: Please produce the information requested under Request Nos. 1 through 9 above as electronically stored information . This information may be provided in pdf, Microsoft Word, or Microsoft Excel format unless a specific format is requested . Upon demonstration to the reasonable satisfaction of the City Attorney’s Office such production is not feasible, the information shall be produced in a format to which the City Attorney’s Office agrees in writing.