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secret. The RICO Defendants also delegated various aspects of the report to nominal authors
who had not been publicly identified as working with the Lago Agrio Plaintiffs, but who in fact
were close associates of the RICO Defendants. The RICO Defendants kept a close eye and a
firm hand on their work. For example, Luis Miguel Garcia Aragon, who was later disclosed to
be a member of Cabrera's team, engaged in ongoing email communication with Beltman and
Maest regarding the drafting of extensive portions of the Cabrera Report. On January 22, 2008,
Aragon emailed Beltman, "We're moving forward with our model thanks to your help. Now I'm
maling [sic] you after the doccuments [sic] you told me about. Do you remember, about the
discount rate and so? I'd appreciate you sending me those." The RICO Defendants and their co­
conspirators also retained and worked with another consultant, Juan Cristobal Villao Yepez, who
was also later identified in the filed Cabrera Report as a member of Cabrera's "independent"
team, and the technical reports on water issues that he wrote as a paid consultant for the RICO
Defendants ultimately appeared in the Cabrera Report. Another supposed member of Cabrera's
"independent" team is Ximena Echeverria who has since been revealed to be an employee of
Defendant Selva Viva and who was actively working with Stratus, a fact never disclosed to
Chevron or the Lago Agrio court until it was revealed in Chevron's U.S. discovery efforts.
Accordingly, the RICO Defendants and their co-conspirators and "Cabrera's team" were one and
the same.
155. And it was the RICO Defendants and their agents who finalized the Cabrera
Report, down to the last comma. At most, Cabrera had a few hours to skim the report and the
4,000 pages of supporting material, but he made no changes, and could not have given it a
substantive review-that is, ifhe reviewed it at all. The bulk of the report was drafted in
English-a language Cabrera does not speak-and was not complete until the middle of March.
After the translation was finished on or around March 18, 2008, the RICO Defendants still had
work to do on the Cabrera Report, prompting BeItman to complain that they were in a "tight
bind" with so little time left. The RICO Defendants and their co-conspirators continued to
maintain control of the document during this time, revising the Spanish text directly, until the
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