hLpb5

Cabrera Report itself. As Donziger has now admitted, "[T]he general idea" was "that Stratus
would draft the report in a form that it could be submitted directly to the Ecuadorian court by
Mr. Cabrera." The RICO Defendants and their co-conspirators took care to make it appear that
Cabrera had actually prepared the report. For example, Kohn corrected Beltman at one point,
telling him to use "1 ,000ppm instead of 100" because "Cabrera exclusively uses 1 000."
150. As Beltman, Donziger and others made decisions about the contents of
appendices to the report and which appendices to include, Beltman also turned his focus to
completing the draft of the report itself, writing to Maest and other colleagues on March 10,
2008: "Now that the annexes are out of the way, there's the little problem of the report itself.
Unfortunately, I've been too busy on annex stuff to work much on it, and it has to go to the court
in [two] weeks and get translated. It's a problem." Indeed, Beltman himselfwas responsible for
drafting the majority of the report, while the various annexes were parceled out among the
various Stratus employees and contractors and others hired by the RICO Defendants. When he
had an initial draft of the Cabrera Report written, Beltman sent it to Donziger, asking whether he
was "on track in terms of tone, language level, and content."
151. While Stratus was the primary coordinator of the work that went into the
Cabrera Report, other members of the U.S.-based team of experts the conspirators assembled,
including E-Tech, Uhl, Baron, Rana & Associates, Inc., and 3TM Consulting, also contributed to
the report without attribution in the report or disclosure to Chevron. Annex S of the Cabrera
Report, for example, was drafted by co-conspirator William Powers, who worked for E-Tech and
was a subcontractor for Stratus, and his calculations were used in Annex T. And Richard Clapp,
another consultant hired by Donziger and his co-conspirators, drafted one ofthe annexes to the
Cabrera Report. And Stratus retained contractors to prepare a large database of sampling data,
known to the RICO Defendants as the "Selva Viva Database," which was reviewed and further
revised by the RICO Defendants and their co-conspirators in Ecuador.
152. As the various consultants finished their portions of the Cabrera Report, Beltman
took on the delicate task of translating the report, written in English by U.S. consultants, into
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