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this panel, there are other indications of bias and prejudice against Chevron. For example,
Judge Orellana is a part-time judge who also acts as a lawyer and currently represents an
individual who recently filed a complaint against Chevron for alleged personal injuries
supposedly caused by TexPet's prior operations in Ecuador.
328. The jeopardy that Chevron faces as a result of this fraudulent jUdgment is
compounded by the fact that the RICO Defendants continue to have access to significant funds to
carry out their criminal scheme. Until 2010, Kohn had been the primary source of funds for the
criminal scheme, supporting it with over $7 million in less than seven years-"the largest single
component" of which, according to Kohn, was over $1 million provided to Donziger personally.
This money was made available by Kohn upon specific requests from Defendants Donziger and
Yanza, who worked with Kohn to prepare budgets for the case, and would contact him as often
as monthly to request amounts ranging from $40,000 to $100,000 each time. These funds were
distributed to U.S. consultants, including Defendant Stratus, and to Ecuador, mainly through
Selva Viva and the Front, to fund the RICO Defendants' activities in that country.
329. After Donziger, Yanza, and Fajardo had a falling out with Kohn, they secured
additional ongoing funding from Burford. The RICO Defendants' relationship with Burford
began in October 2009, and by June 2010, Burford had spent hundreds of hours working on
issues related to the RICO Defendants' scheme, and had been active in developing strategy. In
the summer and fall of201 0, the RICO Defendants, along with co-conspirators H5, Emercy
Celli, Motley Rice and Patton Boggs discussed a $15 million investment from Burford, and by
December, $4 million had already been provided to further the RICO Defendants criminal
scheme. The relationship with Burford was largely orchestrated by Patton Boggs, which acts as
Burford's outside counsel and even shares space in its New York offices with Burford. In
exchange, Burford received not only an interest in any money obtained from Chevron, but also
approval authority over the use of its funds, which authority is exercised by James Tyrell, a
senior Patton Boggs partner. Another substantial source of funds has been Russell DeLeon, an
online gambling entrepreneur who was a major source offunding for Crude.
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