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to "ask for the head of [Chevron's lawyer Rodrigo] Perez Pallares-given what the President
said." Donziger explained: "[H]e's totally with us." The next day, on April 28, 2007, in a
national radio address, President Correa echoed the RICO Defendants' rhetoric, calling
Chevron's Ecuadorian lawyers traitors and demanding that they, along with the Petroecuador
officials who signed the 1998 Final Release, be criminally prosecuted. In the movie Crude,
Donziger is shown stating that "Correa just said that anyone in the Ecuadorian Government who
approved the so-called remediation is now going to be subject to litigation in Ecuador," and
adding that those persons who signed the 1998 Final Release "are shittin' in their pants right
now."
207. The fact that President Correa called for the criminal indictment of those who
signed the Final Release did not come as a surprise to the RICO Defendants and their co­
conspirators. A month prior to President Correa's tour of the Oriente, Fajardo met with
Ecuadorian government officials, including Alexis Mera, a Judicial Secretary and chieflegal
advisor to President Correa, in which Fajardo asked for Mera's assistance in providing the
President with a "basis" for "reopen[ing]" the "investigation for ... the responsible parties." The
conspirators explained to Mera that, while they could mobilize the public in an effort to overturn
the 1995 Settlement Agreement and the 1998 Final Release, "the official nature of the President
could do much more in this case ... [and] interest by the Executive Branch[] and pressure on the
Public Prosecutor's Office ... could do a lot on this subject." Mera, in response, proceeded to
outline various ways of nullifying the settlement and release. Remarkably, the RICO Defendants
managed to procure Mera's assistance, and thus collude with the government, despite Mera's
admission that there was no "sustainable" path to nullification.
208. The RICO Defendants and their co-conspirators made significant efforts to enlist
the support of President Correa and other Ecuadorian governmental officials, holding private
lunch meetings and conferences. Donziger personally met with President Correa on more than
one occasion, and Fajardo and Yanza also met with Correa repeatedly without Donziger in
attendance. After one such meeting with the President, Fajardo reported: "So, the President
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