hLpb5

assuming responsibility for remediation, and, worse, that it believed it would cost an "extremely
low" $96 million. Fearful that Chevron would "say that the State finally assumed its duty and is
going to clean up what it ought to," Fajardo called on his co-conspirators to act. Donziger
responded in an email to Juan Saenz, "You have to go to Correa to put an end to this s[**]t once
and for all."
84. Other members ofthe Ecuadorian government have also signaled to the Lago
Agrio court the government's demand that Chevron be found liable. As the Ecuadorian Attorney
General Diego Garcia Carrion told a reporter in August 2008, the Correa administration's
position in this case is clear: "The pollution is [the] result of Chevron's actions and not of
Petroecuador." Again, in May 2010, Attorney General Garcia "dismissed any responsibility on
the part of the Ecuadorian State for the environmental damage caused in the Amazon region by
the U.S.-based oil company Chevron-Texaco." And in September 2009, Ombudsman Fernando
Gutierrez announced: (i) the Lago Agrio Litigation "has absolute priority and the judgment must
be rendered as soon as possible"; (ii) the case concerns "an assault on the entire country"; and
(iii) in a direct signal to the Lago Agrio court, Chevron, rather than the State, bears full
responsibility for any harm.
85. This support was not arrived at independently, but through collusion between the
RICO Defendants and the Republic of Ecuador. Ana Alban, then Ecuador's Minister of the
Environment, communicated with Donziger directly, assuring him that the government was
"giving the support that we can do" to the Lago Agrio Plaintiffs, reminding him that "we brought
the President to the zone," and assuring him that she had a "very close" "friend of the Frente de
Amazonia working with me doing all this."
86. The fact that President Correa and other members of the government have sided
with the Defendants and against Chevron sends a clear message to the Ecuadorian judiciary that
it must find Chevron liable. And it sends a message to Chevron that it must pay money to the
conspirators in the form of a "settlement" or face the fraudulent, politically influenced jUdgment
that the RICO Defendants intend to try to enforce in U.S. courts or elsewhere.
39