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themselves described it, "pretty much irrefutable evidence of us collaborating with the
[government] to get Reis Veiga and Perez convicted." In an email to Donziger and others, one
of the conspirators reminded them that they "had to resort to very sophisticated methods to
disassociate ourselves from the case (Amicus Curiae submitted by third parties etc)," and urged
Donziger and others not to undo this work by associating themselves publicly with the
prosecutions. In an email to the Republic of Ecuador's U.S. counsel discussing the potential
prosecution, Donziger assured him that an Ecuadorian colleague working on the matter,
"understands the need to keep his contacts with your client's office totally confidential and non­
public." Martha Escobar-the deputy Attorney General with whom Wray exchanged emails­
even perjured herself in a deposition taken in an action pending in the Southern District of New
York on November 21, 2006 and denied that she ever had any communications with the
conspirators concerning the Lago Agrio Litigation. But when confronted with her own 2005
email with Wray proving otherwise, she confirmed that she had been acting in that
correspondence at the direction of the Attorney General.
205. The collusion with the Republic of Ecuador to obtain sham criminal charges, and
the extortionate purpose of that collusion, is documented in the film Crude and its outtakes. In a
January 2007 meeting between Donziger and Kohn captured in the Crude outtakes, in which
they are reviewing materials the RICO Defendants provided to the Ecuadorian Attorney General
in support of criminal prosecutions, Kohn discussed the RICO Defendants' extortion plan: "So,
again, that may be something that we could facilitate going away at the right time .... if they
wanted it to go away." Donziger replied, "Precisely." Donziger told Kohn that Chevron is
alleging a "conspiracy" between them and the Ecuadorian government, to which Kohn
responded, "If only they knew."
206. On April 26, 2007, President Correa toured the Lago Agrio oil fields with the
RICO Defendants and their co-conspirators. That same day, he issued a press release demanding
the criminal prosecution of the Ecuadorian officials who had signed the 1998 Final Release. On
the following day after hearing this news, Donziger mused as to whether the time might be right
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