Case: 10-1918 Document: 232-1 Page: 1 06/23/2010 57314 5

10-1918-cv(L), 10-1966-cv(CON)

IN THE UNITED STATES COURT OF APPEALSFOR THE SECOND CIRCUITCHEVRON CORPORATION, RODRIGO PEREZ PALLARES, andRICARDO REIS VEIGA,

Petitioners-Appellees,

v.JOSEPH A. BERLINGER, CRUDE PRODUCTIONS, LLC, MICHAELBONFIGLIO, THIRD EYE MOTION PICTURE CO., INC.,@RADICAL.MEDIA, and LAGO AGRIO PLAINTIFFS,

Respondents-Appellants.

On Appeal From the United States District CourtFor the Southern District of New York

UNOPPOSED MOTION OF NATIONAL ASSOCIATION OF CRIMINALDEFENSE LAWYERS FOR LEAVE TO FILE BRIEF AMICUS CURIAE INSUPPORT OF APPELLEES PALLARES AND VEIGA URGINGAFFIRMANCE

Richard D. Willstatter GREEN & WILLSTATTER 200 Mamaroneck Ave., Suite 605White Plains, NY 10601Telephone: (914) 948-5656John D. ClineK.C. Maxwell115 Sansome Street, Suite 1204San Francisco, CA 94104Telephone: (415) 747-8287Attorneys for Amicus Curiae NationalAssociation of Criminal Defense Lawyers

Case: 10-1918 Document: 232-1 Page: 2 06/23/2010 57314 5

UNOPPOSED MOTION OF NATIONAL ASSOCIATION OF CRIMINALDEFENSE LAWYERS FOR LEAVE TO FILE BRIEF AMICUS CURIAE INSUPPORT OF APPELLEES VEIGA AND PALLARES

The National Association of Criminal Defense Lawyers (NACDL), throughundersigned counsel, moves for leave to file its accompanying brief amicus curiaein this matter. In support of its motion, NACDL states as follows:1. NACDL is a nonprofit voluntary professional bar association thatworks on behalf of criminal defense attorneys to ensure justice and due process for those accused of crime or misconduct.2. NACDL was founded in 1958. It has a nationwide membership of more than 10,000 and an affiliate membership of more than 35,000. NACDL'smembers include private criminal defense lawyers, public defenders, militarydefense counsel, law professors, and judges. NACDL is the only nationwide professional bar association for public defenders and private criminal defenselawyers. The American Bar Association recognizes NACDL as an affiliatedorganization and awards it full representation in its House of Delegates.3. NACDL files numerous amicus briefs each year in the Supreme Courtand the courts of appeals, seeking to provide amicus assistance in cases that present issues of broad importance to criminal defendants, criminal defenselawyers, and the criminal justice system as a whole.

Case: 10-1918 Document: 232-1 Page: 3 06/23/2010 57314 5