hLpb5

Donziger has also admitted that the new expert reports were intended to give the RICO
Defendants "an argument" allowing them to "attempt to shut down Chevron's 1782 efforts in the
U.S."
192. The link between the fraudulent Cabrera Report and the work of the "new"
experts is made explicit in the retention agreement signed by the Weinberg Group, a consulting
firm, which, in turn, retained the "new" experts. The Weinberg Group's retention agreement
provides that it was retained for the purpose of"conduct[ing] a comprehensive review of selected
sections of an expert report prepared by Richard Stalin Cabrera Vega, "-not to produce a new,
independent scientific report. As one co-conspirator has described it, the role of the Weinberg
Group is merely to "provid[ e] a submission with their name on it."
193. The Weinberg Group provided copies of the Cabrera Report to the experts it
retained for use in their own reports. According to Donziger and his co-conspirators, all the
"new expert[ s]" needed was the "Cabrera report in and of itself' along with the data that Cabrera
relied upon. As the RICO Defendants and their co-conspirators intended, these "new" experts
then relied heavily on the Cabrera Report. According to Donziger, none of these "new" experts
had "go[ ne] to Ecuador," "did any kind of new site inspection," "did any kind of new sampling,"
or indeed, did "environmental testing of any kind."
194. One of the "new" experts, Douglas Allen, for example, made no independent
evaluation of the evidence, instead relying on the unsubstantiated findings contained in the
Cabrera Report. Indeed, the conspirators instructed Allen to use the Cabrera Report as his
"starting point." He relied entirely on the Cabrera Report for, among other items, the number of
pits requiring remediation. Despite the fact that he "[ did]n't know if there are in fact 917 pits
that require remediation," he relied on that number anyway-drawn from the fraudulent Cabrera
Report-in developing his own estimate. He relied on the Cabrera Report despite his opinion
that the conclusions in the Cabrera Report are unreliable and that that the report lacked
appropriate citations and references. Allen has admitted, however, that had he known that the
77