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Scardina's report was written largely by a person at the Weinberg Group whose identity and
qualifications are unknown to Scardina himself. Scardina, like the other experts, also relied
exclusively on the Cabrera Report and the Weinberg Group for information central to his report.
198. [n summary, the "new" expert reports submitted by the RICO Defendants are
new only in two aspects. First, they bear new names, despite being nothing more than another
repackaging of the Stratus report that was originally submitted as the Cabrera Report. And
second, they purport to support a new damages figure, a remarkable $113 billion, which is a
nearly $90 billion increase over Stratus's figure, despite offering no new analysis or evidence.
2. Colluding With the Republic of Ecuador to Bring Sham Charges
Against Chevron's Attorneys
199. As part of their scheme to defraud and extort Chevron, the RICO Defendants and
their co-conspirators conspired with officials from the Republic of Ecuador to advance baseless
criminal prosecutions against Ricardo Reis Veiga and Rodrigo Perez Pallares, lawyers
responsible for executing the 1998 Final Release that precludes Defendants' claims against
Chevron in the Lago Agrio Litigation. As co-conspirator Bonifaz explained the strategy to
Donziger and Kohn in 2005:
The day ChevronTexaco's management becomes convinced that Reiss Veiga [sic]
sold them a bill of goods with his promises that got [rid] of our case, that is the
day on which ChevronTexaco will want to talk. That is also the day that will see
the end of Reiss Veiga's [sic] corporate career .... Thus we have to destroy his
reputation with ChevronTexaco as an incompetent any way we can to see our case
settled.
200. With criminal convictions in hand, the RICO Defendants and their co-
conspirators and Ecuador could then seek to nullify the release, and "fully leverage the criminal
investigation"-in the media and otherwise-to force Chevron to "settle" the Lago Agrio
Litigation or face a massive judgment. According to Donziger, "[I]fthis penal case is brought,
this will be on the wires all over the world and it will really raise the cost to [Chevron]." Indeed,
footage from Crude shows the conspirators admitting that the criminal prosecutions are a means
to exert "personal psychological pressure [on Chevron's] top executives," and Donziger's own
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