PDF《litigation.》

S DELIBERATE CONTAMINATION A. FUNDING FOR THE PROVISION OF ADEQUATE HEALTHCARE TO THE AFFECTED POPULATION 1. Toxicity to human health caused by exposure to constituents in the Concession Area 2. Methodology used in Cabrera'

s Report 3. Methodology used Dr. Picone'

s Report B. FUNDING FOR THE DELIVERY OF DRINKING WATER 1. Condition of drinking water in Ecuador 2. Remediation Options 3. Cabrera'

s Report cost projection 4. Scardina'

s cost projection C. COMPENSATION FOR PAST AND FUTURE CANCER DEATHS IN EXCESS OF BASELINE STATISTICS 1. Excess cancer mortality rate 2. Calculating excess cancer deaths 3. Calculating the total monetary value of excess cancer deaths 4. Amended calculation of excess cancer deaths and valuation. 5. Kelsh'

s mortality rate VI. FINAL PLEA FOR DAMAGES iii ii I. INTRODUCTION The Plaintiffs'

report submitted to this Court on January 17,

2011 contains a summary of a vast record of overwhelming and unassailable evidence demonstrating Chevron'

s liability in this case. The evidence submitted by the parties is part of a dossier that Chevron has desperately tried to bury beneath an avalanche of malicious communications and requests that address anything but the merits of this cause. This dossier reveals serious contamination at each of the sites examined during the course of this trial C contamination which has been identified not only by Plaintiffs and third parties, but also, in many instances, by Chevron'

s own technical experts. The dossier also establishes beyond any doubt that Texaco'

s practices violated Ecuadorian law, were completely inadequate compared to the industry'

s customary practices, constituted a breach of Texaco'

s operation contract, and violated the company'

s legal duty to exercise due care in its activities in Ecuador. Indeed, perhaps the most irrefutable condemnation of Texaco'

s practices in Ecuador comes from none other tha........