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environmental and human impacts ofthe oil exploration and production activities. This expert
report was recently submitted to the court." Stratus asked the representative to review the
Cabrera Report for a fee and provide comments via telephone conversation-comments that, if
favorable, could later be submitted by the RICO Defendants and their co-conspirators to the
court.
182. Similarly, on June 26,2009, Beltman emailed a representative of Brazil's Aggeu
Magalhaes (Haggai Magellan) Research Center seeking an endorsement of the Cabrera Report.
In that communication, Beltman referred to "the Court Expert report in which [Cabrera] presents
the results of his studies and makes recommendations to the judge about the damages caused by
Texaco and what needs to be done as reparation for those damages." Beltman asked the Haggai
Magellan Research Center to "please review the Court Expert report and read our evaluation of
it, and think about how you could provide support. Our first choice is for you to sign the
evaluation that we drafted (I can provide you with a blank signature page for you to sign and
return)."
183. The RICO Defendants' and their co-conspirators' goal of obtaining fifteen or
twenty endorsements from academics in addition to consultants, however, proved difficult given
what Beltman called the "weaknesses" ofthe Cabrera Report. As Beltman explained to
Donziger in an email: "Our original concerns about this have come to pass. . . . [Academics]
are trained and they function to be critical, not accepting. [Additionally], they know that signing
their names onto some kind of endorsement of the Cabrera report is setting them up for public
attack from Chevron (and perhaps attack within their academic circles as well) .... And finally,
some of the underlying work in the Cabrera report has weaknesses that an academic would
probably have a hard time defending." Beltman explained, "[w]e're having better success with
consultants being willing to sign endorsements than academics (something I am not proud of)."
184. The RICO Defendants and their co-conspirators did, however, ultimately
succeed in convincing third parties to review the Cabrera Report that Stratus held out as having
been drafted by a "Technical Special Master." For example, on July 15,2008, Stratus executed a
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