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Report and publicize its findings. To these ends, Lipton met with Donziger to
discuss the RICO Defendants' plan to draft portions of the Cabrera Report and
was included in various correspondence concerning Stratus's work in
ghostwriting the Cabrera Report.
d. David Chapman ("Chapman") is a Principal at Stratus and is a resident of
Colorado. Chapman proposed drafting the Cabrera Report to Donziger, worked
with Lipton and the RICO Defendants to coordinate the use of Stratus resources
in the ghostwriting of the Cabrera Report, and participated in the subsequent
obstruction of Chevron's efforts to uncover evidence of the fraud in U.S. court
proceedings. He met with Donziger to discuss the RICO Defendants' plan to
ghostwrite the Cabrera Report, signed Stratus's report endorsing the Cabrera
Report, and perjured himself in a deposition when he testified that he had no
reason to believe that Stratus had provided work product to Cabrera.
e. William Powers ("Powers") is a subcontractor for Stratus and is a resident of
California. Powers had responsibility for components of the fraudulent scheme to
ghostwrite the Cabrera Report; he worked on two annexes of the Cabrera Report
and drafted portions of Cabrera's supplemental repOli.
f. Amazon Watch is a "non-profit" organization with its main office at 221 Pine
Street, San Francisco, California 94104. Amazon Watch undertakes various
projects ostensibly on behalf of environmental and human rights causes in the
Amazon basin. In connection with the Lago Agrio Litigation, Amazon Watch
applied its experience and resources in public, media and government relations to
use the Cabrera Report and other false and fraudulent claims as the basis for the
RICO Defendants' public pressure campaign against Chevron. With the Amazon
Defense Front, Amazon Watch maintains at least one of the RICO Defendants'
websites, chevrontoxico.com, and through that and other means, distributes false
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