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U.S. law firms that the RICO Defendants retained to represent their interests in opposing
Chevron's Section 1782 applications learned of the full scope of the RICO Defendants'
relationship with Cabrera, the firms withdrew from the representation.
281. In response to Chevron's initial Section 1782 filings, the RICO Defendants
retained a respected New York firm to represent their interests. But when a senior partner with
that firm interviewed Stratus employees in Boulder, it was apparent to him that the RICO
Defendants' relationship with Cabrera was improper and contrary to the representations made to
him by Donziger. His law firm withdrew the next day.
282. Around this time, Donziger prepared a memorandum which he addressed to
lawyers from a Colorado firm also retained by the RICO Defendants to block Chevron's
discovery from Defendant Stratus. In that memorandum, Donziger misled those attorneys on
numerous material facts. For example, in a section ofthe memo titled "Role of Stratus
Consulting," he listed such innocuous activities as "helping Ecuadorian counsel respond to
scientific questions," and "giving media interviews," but failed to inform the attorneys that
Stratus had in fact written the Cabrera Report, the central allegation of the pending court
proceeding. And he listed "Opinions in Cabrera's report were taken directly from Stratus
materials," as one of Chevron's "inaccurate" factual assertions.
283. When this second firm was unable to obtain confirmation of any ofDonziger's
false representations, and after learning from its predecessor about the results of the interviews
he had conducted with Stratus, that firm also withdrew. Simultaneously with its withdrawal, it
sent Donziger an email citing the "troubling information" that it had learned regarding Stratus's
role in preparing the Cabrera Report, and that "we are concerned about our ability to satisfy our
obligations to Judge Kane and to the court if we continue in our representation of the Lago Agrio
plaintiffs in this case." The attorney concluded, "I'm sorry it has come to this, but I feel if we
proceed I may be compromising this firm's reputation and ethical stature and I cannot do that."
284. The conspirators then turned to counsel that they thought "appear[ ed] will ing to
sign anything," but their relationship with that counsel lasted only a month before that firm
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