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thinks that if we put in a little effort, before getting the public involved, the Prosecutor will yield,
and will re-open that investigation into the fraud of, of the contract between Texaco and the
Ecuadorian Government." By seeking assistance from Ecuadorian government representatives,
this is precisely the "strategic development" the RICO Defendants ultimately achieved.
209. The plan to procure the criminal prosecution of Chevron's attorneys included
more than obtaining President Correa's support. The RICO Defendants and their co-conspirators
also aimed, as called by one of their associates, their "troops [and] artillery" against Chevron's
attorneys through a series of demonstrations, and they publicly pressured Ecuadorian officials.
As Defendant Yanza proclaimed during a July 31, 2008 press conference, in order to ensure
prosecution, the RICO Defendants and their co-conspirators would "have to take legal actions
against these officials ... make public denunciations ... put pressure through the people, all
these mechanisms .... " Yanza warned that "nothing is ruled out." According to Donziger, this
was part of the conspirators' strategy of conducting a "guerrilla campaign" against Veiga and
Pallares.
210. And this campaign was successful. As Donziger boasted, "[W]e are kicking
some ass, and it feels awfully good." Donziger was elated not only because criminal charges
would be useful to the RICO Defendants' and their co-conspirators' extortionate scheme, but
also because it would satisfy a personal vendetta. As Donziger described his feelings toward Mr.
Veiga, "Some days, I fantasize about putting my strong hands around Reis Veiga's neck and
squeezing until he begs for mercy. I want him to know how it feels to suffer .... "
211. The RICO Defendants' and their co-conspirators' objective was fInally achieved
on August 26, 2008 when the Ecuadorian government announced criminal charges for fraud
against Ricardo Reis Veiga and Rodrigo Perez Pallares, the two Chevron attorneys who signed
the 1995 Settlement Agreement and the 1998 Final Release. The charges were issued after two
previous Prosecutors General had determined that there was no evidence of fraud and had
requested that the case be closed. But that was before the RICO Defendants manufactured the
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