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267. These obstruction efforts have been managed by Patton Boggs, among others. In
2010, when it appeared to the RICO Defendants that Chevron was going to uncover clear
evidence of their collusion with Cabrera, attorneys from Patton Boggs participated in a series of
meetings with RICO Defendants and co-conspirators in the United States and in Ecuador, to
apprise themselves ofthe nature ofthat relationship. They also asserted control over the defense
against Chevron's discovery actions behind the scenes, ghostwriting court papers and managing
lawyers at other firms. While their investigation was ongoing, and while by their own admission
they did not know "what there was to admit," they drafted and caused to be filed briefs and
declarations containing false and misleading statements denying the extensive collusion with
Cabrera.
268. Once it was clear that the RICO Defendants' earlier statements to U.S. courts
had been false and misleading, Patton Boggs doubled down, and not only repeated and reasserted
false statements about Cabrera, but also negotiated for itself a stake in the outcome of the Lago
Agrio Litigation in an agreement which gave it substantial influence over the future course of the
litigation.
269. Furthermore, Donziger, the ringleader of the enterprise, has himself personally
interfered with discovery proceedings in this Court and elsewhere, including repeated and
sustained violations of multiple orders issued by this Court. In this and other lies and
misconduct before various U.S. courts, the RICO Defendants and their co-conspirators, including
Patton Boggs and other law firms such as Emery Celli and Motley Rice, have brought their
pervasive fraud into the courts of this country and have attempted to hide their criminal scheme
from Chevron and the courts.
1. Attempting to Obstruct Chevron's Discovery Proceedings by Making
False and Misleading Statements Before U.S. District Courts and
Courts of Appeals
270. Faced with denials from the conspirators in Ecuador about the authorship of
Cabrera's report, Chevron turned to the United States to pursue discovery from the largely U.S.-
based enterprise directly through proceedings under 28 U .S.c. § 1782, which authorizes "[t]he
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