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action," and falsely claimed that Chevron had "been forced to admit at trial that Texaco ...
dumped over 18 billion gallons oftoxic water into the rainforest .... " Although Donziger
personally informed Amazon Watch Executive Director Soltani that the Russell report was
grossly excessive (see paragraph 107, supra), Amazon Watch never corrected its false statements
to the SEC or Chevron shareholders. In fact, the next month, Soltani and Amazon Watch sent a
follow-up letter, accusing Chevron of distorting the report of the "settlement experts" from the
then-ongoing "judicial inspection" process-the same proceeding in which the conspirators
submitted the false expert report with Dr. Calmbacher's fraudulently obtained signature. Shortly
thereafter, Donziger reported to Lehane that, "The SEC is actively investigating [Chevron's]
failure to disclose this liability in its public ftlings-I know this for a fact, because I was just
interviewed by an SEC investigator last week[.]"
240. On March 18, 2008, Amazon Watch reprised this effort, writing another letter
signed by Soltani to the SEC. In this letter, written weeks before the fraudulent Cabrera Report
was filed but obviously well-aware of its secret contents, Soltani emphasized the forthcoming
report, and the independence of its purported author, "an independent special master" that had
prepared his report "mak[ing] use of all evidence collected" with "a large team of technical
experts under [his] supervision." The letter demanded an investigation and "the imposition of a
penalty on Chevron for failing to comply with its obligations." Soltani argued "that Cabrera is
being attacked by Chevron precisely because he is qualified to conduct a credible damages
assessment." Soltani and Amazon Watch made these statements knowing that Cabrera's report
was being ghostwritten by Stratus and the RICO Defendants' other consultants. Indeed, despite
knowing that the Cabrera Report was a fraud, Soltani accused Chevron of"contriv[ing] claims of
procedural unfairness" and called Chevron's position that the process had been unfair
"ludicrous."
241. When Donziger heard that the SEC might actually be investigating Chevron, he
wrote that this was a "huge victory for A W [Amazon Watch]." He instructed his team to "keep
feeding them [the SEC] stuff," even though, he wrote, "I sort of feel this is bogus."
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