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actually been written by the RICO Defendants, or that the majority of materials upon which it
was based were not "trial evidence" at all, but that enterprise's files.
233. The RICO Defendants and their co-conspirators, in addition to portraying
Cabrera's report as independent to the media, also used the fraudulent "evaluation" drafted by
Stratus to enhance the credibility of the Cabrera Report in the media. For instance, on December
1,2008, Hinton and Amazon Watch issued a press release about the Stratus report entitled
"Chevron's $27 Billion Liability in Ecuador's Amazon Confirmed by Team of Independent
Scientists." That press release states that "[t]he independent expert report was prepared by
Richard Cabrera, an Ecuadorian environmental scientist appointed by the court as a Special
Master who has worked mostly for oil companies in preparing environmental damage
assessments," and quotes an endorsement from Defendant "Douglas Beltman, a scientist at
Stratus Consulting who, along with a team of scientists, reviewed the expert's report on behalf of
the [Lago Agrio] plaintiffs." It is unsurprising that Stratus employees "endorsed" the report,
given that they wrote it.
234. Stratus's involvement in the media campaign was envisioned as early as the
initial August 2007 contract between Kohn Swift and Stratus contemplating that Stratus would
engage in "discussions with the media" in addition to performing other tasks to further the
conspiracy. As an example, Defendants Beltman and Stratus were involved in orchestrating the
RICO Defendants' response to Chevron's allegations that Cabrera's supplemental report showed
evidence of collusion between Cabrera and the Lago Agrio Plaintiffs. Indeed, Beltman sent
Donziger draft language denying that the Lago Agrio Plaintiffs were in collusion with Cabrera
and claiming that "Cabrera's November response to the plaintiffs is clearly his own." This
response became part of the RICO Defendants' overall efforts to portray the Cabrera Report as
independent.
235. Now, despite the unequivocal evidence that the RICO Defendants' and their co-
conspirators' own team of experts ghostwrote Cabrera's report and its update, the conspirators
continue to spread the lie that Cabrera is independent. In May 2010, in response to a court filing
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