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government officials" in addition to the Front's "wide influence in Ecuador" and "ab[ility] to
command meetings with government ministers and even the President."
81. The collaboration between the RICO Defendants and Republic of Ecuador is so
close that one U.S. District Court has concluded that it was "an established fact" that the
Republic of Ecuador was supporting the Lago Agrio Plaintiffs. The Republic of Ecuador
recently asserted in court filings that it has had a formal "common interest agreement" with
representatives of the Lago Agrio Plaintiffs since 2006. In pursuit of that alleged common
interest, the RICO Defendants and the Republic of Ecuador have coordinated their legal and
public relations strategies, both directly and through Ecuador's U.S. legal counsel. As part of
this cooperation, the RICO Defendants have received assistance from the highest levels of
government in Ecuador, from "allies [who were] firmly entrenched at the top." For example,
Donziger himself ghostwrote a letter from Ecuador's ambassador to the United States, Dr. Luis
Gallegos, to The Wall Street Journal.
82. The RICO Defendants have also worked with Winston & Strawn LLP ("Winston
& Strawn"), the U.S. law firm hired by Ecuador to represent it against Chevron in proceedings in
the United States. The RICO Defendants have provided information and other assistance to
Winston & Strawn, including having Stratus provide scientific analysis and Donziger help with
the drafting of legal documents. Donziger, aware that this level of cooperation crossed the line,
was concerned it might lead Chevron to believe the RICO Defendants and the Ecuadorian
government were "in bed" together. Thus, upon realizing he had been photographed alongside a
Winston & Strawn attorney for a newspaper article, Donziger vowed to deny that the man in the
photograph was him. However, Donziger recognizes that the RICO Defendants and the
Republic of Ecuador have been "really helping each other."
83. The RICO Defendants have also turned to the government to shut down
Petroecuador's remediation, because ofthe negative impact it would have on their scheme. For
example, in 2009, in an email to Donziger and other conspirators with the subject line
"WORRISOME," Fajardo warned them that a newspaper was reporting that the government was
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