jjR0b

actual remediation work once the RICO Defendants obtained a fraudulent judgment against
Chevron.
147. Meetings and communications continued between the conspirators as they
prepared Cabrera's report. Leading up to the April 2008 filing of Cabrera's first report, Stratus,
Donziger, Kohn, and environmental consultants exchanged hundreds of emails regarding draft
outlines ofthe Cabrera report and proposed annexes, schedules for completion of various
annexes, and discussing review, analysis, and translation of the annexes including
"[e]nvironmental standards," "[e]co impacts from contamination," "[p]it (plus) cleanup costs,"
"[v]alue of human life losses," "[h]abitat losses at wells and stations," "TexPet [r ]emediation
summary," "[h]istorical data summary," "[d]ata extrapolation" and "[t]oxicity of site chemicals
to humans." (Additional details concerning the emails exchanged in furtherance of the
conspiracy's scheme to defraud Chevron are included in Appendix B, which is incorporated by
reference as if set forth herein in its entirety.)
148. During this period, Donziger continued to press for higher and higher damages
numbers, explaining at one point that an estimate for unjust enrichment "sound[ ed] awfully low"
and implored that the Stratus consultants not "say or even suggest anything that backs away from
the [Lago Agrio plaintiffs'] figures." And as another means of getting the high numbers he
wanted-and getting the most impact from the "independent" expert-Donziger during this
period suggested to Stratus that they "define the norms of clean-up" and then "propose these
norms to the Ministry of Energy which governs these norms[,] and whose Minister is a good
friend of ours, so that the Ministry issues them as an official decree before the trial ends."
149. The numerous emails among the Stratus team and between Stratus and Donziger
were necessary because, as Beltman explained in a February 22, 2008 email urging his Stratus
colleagues' support: "We have to write, over the next 2 to 3 weeks, probably the single most
important technical document for the case. The document will pull together all ofthe work over
the last 15 or so years on the case and make recommendations for the court to consider in making
its judgment." And that "single most important technical document for the case" was the
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