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confrontation. This is a critical part of our strategy that is allowing the case to go forward."
Over the ensuing months, the conspirators' private army would make numerous appearances at
judicial inspections of environmental sites, at the courthouse, and in the streets of Lago Agrio,
always seeking to remind the judiciary that this was not litigation, but a "flat-out street brawl."
At one such protest at a judicial inspection of the Sacha Sur Station, the RICO Defendants and
their co-conspirators amassed their "army" of protesters who the judge would not permit to enter
the Station due to the risk that such a large mob would pose to the Station's operation. When
Donziger saw that what he described as his "army" would not be able to enter, he demanded that
the "f1**]kin' judge" come to the gate to deal with the mob himself and warned that "they're
provoking a violent incident." Although the RICO Defendants' and their co-conspirators'
"army" was rebuffed at this inspection, the RICO Defendants and their co-conspirators achieved
their purpose of letting the judiciary know that it was being watched by a potentially violent
group. In another incident, the conspirators organized a protest at the judge's office after a
canceled judicial inspection. The intimidation was successful, causing the judge to "sweat" and
"promis[e] to make a decision" on a new date by the following day.
77. The RICO Defendants also employed extortion to get what they wanted. For
example, the RICO Defendants "wrote up a complaint against [Judge] Yanez, but never filed it,
while letting him know [they] might file it ifhe does not adhere to the law and what [they]
need." And on a task list he prepared in February 2006, Donziger wrote: "accuse [Judge] of
being involved in corruption with Chevron; ask for recusal."
78. The RICO Defendants' and their co-conspirators' plan to instill fear in the
judiciary was only one approach to illegally obtaining a favorable ruling. Another approach
involved numerous attempts to personally influence, intimidate or negotiate with the judge in the
Lago Agrio Litigation, often through ex parte meetings. Donziger described such actions as
"lobbying." Donziger, for example, has held numerous meetings with presiding judges, often
over lunch at the judges' homes, during which he has "t[ aken] advantage of the situation to
explain [the RICO Defendants'] theory of the case." During one such meeting, Donziger pressed
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