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In order to implement its defense for the imminent trial, Chevron

and its team of experts manufactured the evidence in order to be


prepared for the expected judicial inspections.

Chevron used these pre-inspections with the purpose of locating
specific sample sites where it could extract soil from the old oil
wells.

In these oil sites, the result is as follows:

LAGO AGRIO 2

Chevron identified 4 pits and confirmed that there existed non-
remediated hydrocarbons in at least one pit, number 3, which was
opened before 1976 and closed by Texaco in 1990. It also
confirmed that existing hydrocarbons had migrated through the
sides of the pit and contaminated a nearby stream.

However, Texaco did not mention this pit in the release of liability
agreement since Texaco maintained that that it had previously
closed it and therefore there was nothing to remediate.

GUANTA 6

This is pit of burnt material, a type of oil swamp.

When Chevron investigated by its own account, it encountered
contamination in the sediments. The documents establish that the
contamination had spread 800 meters downstream, where the local
habitants obtain water for their use.

In order to avoid problems, Chevron took samples from upstream
waters instead of downstream waters where there was no
contamination, according to their own report.

SHUSHUFINDI 25

Texaco began operations in this oil field in 1973. During the
course of its operations, Chevron dug up 4 pits at this site, three of
which were remediated as indicated in the agreement signed with
the State in 1995.

Chevron experts found widespread contamination at this site
during its investigations prior to the trial. The tests taken in
January of 2004 revealed and documented the presence of high oil
contamination. Such contamination was found under the ground of
an apparently remediated area, which Texaco had covered with
topsoil during the remediation process. Texaco confirmed that the
contamination had reached underground waters.

AGUARICO 2

This well was never operated by CEPE. It was one of the last
wells to be closed in 1990, and was included in the remediation
plan with the Duran Balln administration. However, the
remediation was inadequate.

During the pre-inspections at this site, Chevron experts found that
contamination was present. Chevrons samples showed significant
hydrocarbon contamination up to NINE TIMES higher than limits
allowed by international regulations. The experts also confirmed
that the contamination had drained into a nearby stream.

YUCA 2

In 2004 and 2006, Chevron experts confirmed that an oil spill,
which occurred in mid eighties, still affects the pastures located
northeast of this pit. This contamination was confirmed to have a
level that is TEN TIMES higher than what is permitted. In its
defense, Chevron alleged that the spill had occurred immediately
prior to the judicial inspection.

All of this was denied by Chevron during the judicial process

CONCLUSION

According to the expert report by Mr. Bjorkman, retained by
Chevron, and obtained legally by Ecuador, it concludes that:

CHEVRON TOOK OVER 1,500 DIFFERENT SAMPLES
DURING ITS ATTEMPT TO FIND CLEAN LOCATIONS TO
DEFEND ITS POSITION. THESE SAMPLES CONCLUDE
THAT:

1. 162 OF THE SAMPLES OBTAINED FROM SEDIMENTS
EXCEED INTERNATIONAL STANDARDS.
2. 264 OF THE SAMPLES OBTAINED FROM THE SOIL
EXCEED INTERNATIONAL STANDARDS

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