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227. A few months later, when Fajardo visited the University of Oregon, he expressed
alarm at his discovery that students there had obtained copies of the version showing Beristain,
and told Donziger that they had a "serious problem," although he assured Donziger that nobody
at Oregon knew that there was a "conflict." And when the RICO Defendants learned that CNN
intended to show clips from Crude, they and the filmmaker engaged in a scramble to ensure that
the Beristain scenes were not shown, obliquely instructing CNN, "Please do NOT include any
footage during Trudie's visit to the Cofan community that features a man wearing a white t­
shirt." Berlinger has also stated that he expected-as did the RICO Defendants-that the
documentary Crude could "have some real-life impact on a decision or a potential settlement."
Through Section 1782 discovery proceedings authorized by this Court, Chevron has obtained a
substantial volume of outtakes from Crude, outtakes that make clear the scope of the RICO
Defendants' lies and stonewalling, and from which many of the direct quotations in this
Amended Complaint are taken.
228. Although Donziger and his conspirators were involved in the making of the film
Crude, they knew that the film would be far more useful to their cause if it appeared
independent. Donziger emphasized to Berlinger during filming, "I do not want to been seen as
helping [you] ... in front ofthe Chevron lawyers." But behind the scenes, one of Crude's major
financial backers was Russell Deleon, a law school friend of Donziger who has also been a major
financial supporter of the Lago Agrio Litigation. Upon Crude's completion, the conspirators
promoted and relied upon the released version of the film in their pressure campaign against
Chevron, and to raise money for that campaign. At http://chevrontoxico.com/take-action/crude­
house-party.html, they urge readers to hold Crude "screening parties" and to ask for donations
(for the RICO Defendants) at those events. On that web page, the RICO Defendants assert, "[i]n
order to change Chevron, one of the largest and dirtiest oil companies on the planet, we need to
build a movement a million times more powerful than them. Crude will educate and inspire
thousands of people to commit to changing Chevron in the coming weeks and months."
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