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fact, as Stratus's own documents make clear, Chapman, who is the head of Stratus's natural
resource economics group, was personally involved in and knowledgeable of Stratus's secret
authorship of Cabrera's report. Indeed, it was Chapman who provided Donziger with the initial
outline and plan for Stratus to write the "damage estimate," and asked Donziger "when a final
report would have to be delivered to the Judge" so that Stratus could plan its resources
accordingly. Chapman's deposition misconduct, however, is not surprising given that Stratus
has remained actively involved in the conspiracy even after the evidence of wrongdoing was
made public. For example, Beltman held meetings for Stratus staff after Chevron filed for
discovery from Stratus in an attempt to mislead the employees and influence their potential
testimony regarding Stratus's authorship of the Cabrera Report. At these meetings, Beltman
repeatedly misstated that Cabrera was an independent expert and misrepresented the role of
Stratus in ghostwriting the Cabrera Report. BeItman consistently omitted any discussion of
Stratus's true involvement.
275. In another blanket denial, Stratus represented through counsel to the District of
Colorado on April 27, 2010 that Stratus was "astonish[ ed]" to see "similarit[ies]" between their
own work product and the Cabrera Report. It assured the court that Stratus did not have "an
opportunity to review Cabrera's report in draft form," and that what they provided their co­
conspirators was, "intended to assist them in their analysis of data," and in the "mediation," not
"to assist Cabrera." These were outright lies; Stratus ensured that its work product appeared in
the Cabrera Report, and Maest and Beltman both subsequently admitted that neither ofthem
were surprised by the presence of their work in the Cabrera Report, and that nobody at Stratus
would have been surprised by it. In a "Status Report" filed three weeks later, counsel for Stratus
informed the court that "continued inquiry suggests that there were communications between Mr.
Cabrera and two representatives of Stratus."
276. Allegedly before a subpoena issued under the authority of the Southern District
of California, co-conspirator and Stratus subcontractor Powers threw out a computer hard drive
containing responsive documents and deleted responsive emails. Evidence obtained by Chevron
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