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President Correa, at which the President complained about delays and demanded "expedited
treatment of cases that are of interest to Ecuador." Judge Nunez was ultimately forced to excuse
himself from the case, not because of his apparent bias, but because ofa bribery solicitation
scandal where he was caught on video expressing his prejudgment against Chevron.
92. Just after this bribery solicitation story broke and the videos become public, on
September 2,2009, co-conspirator Juan Pablo Saenz wrote to Donziger and assured him that the
Front's "sources at the government tell us they're actively looking for [Ecuadorians involved in
the scandal], to cut their heads off. We should focu[s] on [the Americans involved], since
they're the Chevron stooges. Correa and his cronies will take care of the rest."
93. On the following day, September 3, 2009, Judge Nllnez filed a motion to excuse
himself from the Lago Agrio Litigation. The next day, Prosecutor General Pesantez publicly
declared that he had asked Judge Nunez to excuse himself"to prevent any delay of the trial."
Pesantez then added that Chevron had "probably caused serious environmental damages for
decades and also caused illnesses" and confirmed that the government of Ecuador expected to
receive 90% of the prospective jUdgment against Chevron.
94. Although Chevron filed a petition to annul all of Judge NLlnez's biased and
politically influenced rulings in the Lago Agrio Litigation, that petition was denied by Judge
Nunez's replacement. Thus, Judge Nunez's improper and bad-faith judicial decisions continued
to taint the Lago Agrio Litigation and undermine Chevron's rights, just as the RICO Defendants
hoped they would. After all, the conspirators' underlying strategy has been that the more
Chevron fears an unfair ruling in the sham Lago Agrio Litigation, the better target for an extorted
payment it becomes.
95. Against this backdrop of collusion and corruption, the RICO Defendants have
obtained a judgment in their favor and against Chevron by playing the "game" "dirty" and
currying favor from the Ecuadorian government. And this is all part ofthe conspirators' scheme
to convince Chevron to pay up-or else. Chevron has initiated international arbitration under the
Bilateral Investment Treaty, seeking relief from the Republic of Ecuador's violations of
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