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Spanish. As Beltman would later put it, they would treat "our original English version as ifit's a
translated version" of Cabrera's work. In March 2008, Beltman corresponded with several
translation firms, ultimately working mainly with Translating Spanish, Inc. On March 12,2008,
Beltman sent, via email with a copy to Maest, the actual Cabrera Report-which contained an
introduction falsely stating that "[t]his report was written by Richard Cabrera, ING to provide
expert technical assistance to the Court"-to be translated into Spanish for filing with the Lago
Agrio court. And as Beltman and other Stratus Consultants revised their work, they forwarded
new annexes of the report for translation as well. In addition, the critical annexes to the Cabrera
Report covering alleged remediation costs, excess cancer deaths, and other building blocks of
what would ultimately be a $27 billion fraud were also translated into Spanish at Beltman's
direction days before they were fraudulently submitted to the Lago Agrio court as the work of
Cabrera and the other Spanish-speaking personnel to whom the report would be attributed. In
order to facilitate the final preparations, the RICO Defendants discussed renting office space in
Ecuador as well, but Donziger stressed that it had to be "isolated," and could not be space shared
with those known to be affiliated with the RICO Defendants.
153. Prior to the Cabrera Report's submission, Beltman followed up to ensure that
those consultants who had actually written certain annexes had their "name[ s] taken off' the
documents that Cabrera would actually submit to the court. The RICO Defendants and their co­
conspirators determined "to whom Richard [Cabrera would] attribute each of the annexes," and it
was not to their actual authors. All of these contributions were orchestrated by the conspirators,
who maintained a master schedule identifying each portion of the report, which of their team
members would do the actual work, and to whom they could publicly and fraudulently
"attribute [ e] each in the filed Cabrera Report."
154. The conspirators did not entirely ignore Cabrera during this period of heavy
drafting. In January 2008, Donziger, Beltman, Maest, Fajardo and others met with Cabrera as
the conspirators were in the homestretch of drafting his report. Notably, this meeting was held at
a private home, and not at the conspirators' offices in Quito, in order to keep the meeting a
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