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Amazon Watch and that sum did not include the donations he had personally made to Amazon
Watch. On information and belief, the conspirators use funds received in this manner to
continue to prosecute their unlawful scheme to defraud Chevron. In fact, Amazon Watch's tax
returns reveal that it has directed at least $90,000 in donations to the Front since 2002.
225. The RICO Defendants and their co-conspirators use other proxies besides
Amazon Watch to peddle their propoganda. For example, when one documentary filmmaker
came to Ecuador to shoot a movie about Lago Agrio, Donziger made sure that the RICO
Defendants had a say in how it was made and how it was marketed, telling the filmmaker, "It is
critically important I be brought into the strategy because it could affect the legal case." The
filmmaker subsequently gave Donziger access to the production plans. The RICO Defendants
recruited another filmmaker, Joseph Berlinger, to make Crude, a purported documentary about
the Lago Agrio Litigation that was released in 2009. The film, according to Donziger, shows
how he "manipulate[ d] the trial." While Berlinger has claimed that he intended his film to be
"fair," he and his team worked closely with Donziger and others in the planning, shooting,
editing and distribution of the film, and assured Donziger that he would be favorably presented
in the final product, stating, "We will live up to our end ofthe bargain."
226. Berlinger altered the film before release, at the RICO Defendants' and their co-
conspirators' request, to hide the relationship between the conspirators and Carlos Beristain, who
was publicly disclosed as the author of a major portion of the Cabrera Report, as discussed in
paragraph 305, infra. This was a critical change, because public disclosure of the prior
relationship between the RICO Defendants and Beristain could have been the visible tip that
would alert Chevron and the public to the mammoth iceberg of collusion between the RICO
Defendants and Cabrera. Well aware ofthis risk, Fajardo told the filmmakers that disclosure of
that relationship was, "so serious that we could lose everything," and that "the way it is, the
entire case will simply fall apart on us." He thus had the changes made even though they were
"costly."
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