Lack of Aerial Photographic Evidence for the Pit Count in the Sentencia Expert Report of William D.

Di Paolo
Qualifications I have Bachelor of Science and Master of Science degrees in Geology from Northern Illinois University, advanced study in Geophysics and Geochemistry from Arizona State University, and was a Visiting Scientist at Purdue University’s Laboratory for the Applications of Remote Sensing. I am a Registered Geologist in the State of Arizona. My work experience as a remote sensing geologist includes nine years with the U. S. Geological Survey (USGS) and the Bureau of Land Management and over thirty years in private industry and as a consultant. I have used and interpreted stereo aerial photography and satellite data worldwide to create geologic maps, and to identify, map, and inventory natural resources. I have also taught courses in aerial photo interpretation and the use of satellite data. I am the author or co-author of eight peer-reviewed professional papers related to geology, and the use of remote sensing for soil and vegetation surveys, including a chapter in the book Remote Sensing for Resource Management. I am the co-author of a USGS geologic map of the Sedona, Arizona area created from stereo aerial photo interpretation. I also have chaired sessions at international remote sensing conferences, have made numerous professional presentations, and have written over sixty industry technical reports. I submitted the report Rebuttal of the Methodology Used by Mr. Cabrera to Determine the Number and Size of Pits in the Petroecuador-Texaco Concession to the Sucumbios Provincial Court of Justice in Nueva Loja, Ecuador, in 2008. My current CV is attached as Attachment A. Opinion The Sentencia of the Sucumbios Provincial Court of Justice in Nueva Loja, Ecuador, February 14, 2011 (the “Sentencia”) states, on page 125, that the existence of 880 pits in the former Concession area has been proven from aerial photographs. Further, the clarification issued by the Ecuadorian Court on March 4, 2011 (the “Clarification”) claims, on page 15, that all photography used and interpreted in the Ecuadorian Court record was acquired before 1990: “the Court analyzed the various aerial photographs that form a part of the record and that were certified by the military Geographic Institute. The Court found this method appropriate since all of the photographs are from before 1990, and cannot reflect the existence of pits constructed after Petroecuador assumed the operations. Thus, they only reflect those constructed by Texpet.” Based on my review of aerial photos of the former Concession area, including the aerial photos in the record, it is my opinion to a reasonable degree of scientific certainty that it is impossible for the Ecuadorian Court to accurately identify the number of pits or the number of pits requiring remediation using aerial photo interpretation. I reviewed all the aerial photographs in the record, including the aerial photographs from the report of Richard Cabrera, Informe Sumario del Examen Pericial (the “Cabrera Report”), the plaintiffs’ report, Informe a la Corte Superior de Nueva Loja, Pruebas del Fraude de Chevron (the “Plaintiffs’ Report”), Judicial Inspection reports by experts nominated on behalf of Chevron, and other reports by court experts, all of which are listed in Attachment B. No aerial photos were found in the record for approximately 35% of the sites, so at those sites it would be impossible for the Ecuadorian Court to make a determination of pit totals from aerial photos. For the sites where aerial photos can be found in the record, aerial photography alone is insufficient to accurately assess oil field site details such as the existence and number of pits. The IGM (Instituto Geographico Militar) aerial photos in the 1

record are relatively low resolution, black and white, monoscopic, and low contrast, acquired over the hazy and humid Ecuadorian jungle region, making accurate identification of some features very difficult, and therefore uncertain and inconclusive. To the extent the Sentencia relies on the aerial photo interpretations from either the Cabrera Report or the Plaintiffs’ Report, the Sentencia’s conclusion about the number of pits in the former Concession area is not supported by the underlying evidence. I found the interpretation results in those reports contradictory and many of the interpretations demonstrably inaccurate. The findings of the number of pits in the Cabrera Report are inconsistent within its own annexes and with the findings of the Judicial Inspections. For example, the Cabrera Report in one annex claims 118 “pits” at 39 sites on the aerial photos, but in another annex only identifies 62 “pits” at the same 39 sites using the same aerial photos, resulting in a nearly 50% discrepancy in pit count. In another example, comparing the pit counts in one annex of the Cabrera Report with those recorded during the site-specific Judicial Inspections by Chevron’s nominated experts for 42 sites, approximately 36% more “pits” were found in the Cabrera Report using aerial photography than were actually found during the Judicial Inspection site visits. These contradictory and inconsistent findings show that the pit counts based solely on aerial photo interpretation are not reliable, and any use of these pit totals by the Ecuadorian Court is unsupported by the underlying evidence. In the Cabrera Report and Plaintiffs’ Report, many site features were misidentified, incorrectly outlined, or non-existent, and in some cases the exact same obvious mistake was found in both the Cabrera Report and the Plaintiffs’ Report (as examples, see figures 1, 2, 3 and 4 below). In the Cabrera Report, I also found pits that were identified on the aerial photography and included in the pit totals as “TexPet pits,” but that were actually constructed by Petroecuador at production stations and at well sites drilled after 1990. I also found aerial photographs in the record that were acquired after 1990 and were mislabeled in those reports as being from 1990 or earlier years (as examples, see figures 5 and 6 below). The inconsistency in pit counts and errors in aerial photo interpretation were identified to the Ecuadorian Court in my 2008 report, Rebuttal of the Methodology Used by Mr. Cabrera to Determine the Number and Size of Pits in the Petroecuador-Texaco Concession. To the extent that the Ecuadorian Court is relying on its own interpretation of aerial photographs in the record, there is no evidence that the Ecuadorian Court has the experience, the expertise, or the equipment to accurately interpret aerial photography. Not only is it difficult to confirm the presence of pits from aerial photographs, it is impossible to accurately identify the contents of pits. For example, accurate identification of hydrocarbons such as crude oil is extremely difficult, and one cannot identify whether a pit contains crude oil without using sophisticated imaging techniques coupled with ground-truthing. It is impossible to discern the presence of oil in a pit using IGM’s black and white aerial photographs. The Sentencia fails to provide evidence to support its conclusion that 880 pits were interpreted from aerial photography. It fails to explain the methodology used in the examination of the aerial photographs in the record, and fails to describe the experience of the interpreter. It fails to account for the limitations of the photography used, or provide any confirmation of the conclusions with field verification.

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Figure 1– Claiming that a tree shadow is a pit.

Figure 1a: 1985 IGM air photo as seen in the record for the Shushufindi 33 well site. Note the darktoned area along the south edge of the light-toned well pad, which was photo interpreted as “Pit 3” in the Cabrera Report and in the Plaintiffs’ Report.

Figure 1b: 1985 IGM air photo (#44408) of the Shushufindi 33 well site, taken on the same date as the IGM photo above, enlarged to show that the dark “Pit 3” in Figure 1a is obviously a large tree with its shadow visible on the well pad to the left (northwest). The light-toned well pad can be seen through the shadows of the leaves and branches. This example was included in the 2008 report Rebuttal of the Methodology Used by Mr. Cabrera to Determine the Number and Size of Pits in the Petroecuador-Texaco Concession, submitted to the Ecuadorian Court. 4

Figure 2 – Misidentification of vegetation and shadows as pits or crude oil deposits.

Figure 2a: 1985 IGM air photo of the Sacha 56 well site showing three small dark toned features that were interpreted as “fosas” (pits) or “depositos de crudo” (deposits of crude) in the Plaintiffs’ Report.

Figure 2b: A different 1985 IGM air photo of Sacha 56 enlarged to show that the three dark tones are actually clumps of vegetation or trees. Stereo interpretation of multiple photos over this well site provided a clearer image of this area and confirmed these dark spots to be vegetation with their associated shadows to the south. Observing the shadow direction of other vegetation in this area facilitates the interpretation of these features.

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Figure 3 – Misidentification of a wellhead shadow as a pit.

1990 IGM air photo of Sacha 52 as shown in the Plaintiffs’ Report. What is misidentified as a “pit” is actually the shadow of the wellhead. When multiple photos are viewed in stereo, there is no indication of a pit at this location, and the wellhead is clearly visible. Similar mistakes were found at other sites.

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Figure 4 – Misidentification of a tank as a pit.

Figure 4a: 1985 IGM air photo of the Sacha South Production Station and the Sacha 29 well site with pit interpretations from the Cabrera Report. A tank is misidentified as “Pit 4.”

Figure 4b: A better quality print of the same 1985 aerial photo (IGM# 45121) of the Sacha South Production Station and the Sacha 29 well site clearly shows that “Pit 4” is a tank with its shadow to the northwest. This example was included in the 2008 report, Rebuttal of the Methodology Used by Mr. Cabrera to Determine the Number and Size of Pits in the Petroecuador-Texaco Concession, submitted to the Ecuadorian Court. 7

Figure 5 – Misidentification of a pit at a site that was drilled by Petroecuador after 1990.

1985 IGM photo (#44598) showing the future location of the Yuca 8 well pad and the location of a “pit” (see arrow) identified in the Cabrera Report as being open in 1985. Note: Yuca 8 was not drilled by Petroecuador until September 9, 1993. Similar mistakes were found at other sites. These examples were included in the 2008 report, Rebuttal of the Methodology Used by Mr. Cabrera to Determine the Number and Size of Pits in the Petroecuador-Texaco Concession, submitted to the Ecuadorian Court.

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Figure 6 – Incorrectly labeling a 1991 IGM photograph as 1990 and including pits that were constructed by Petroecuador.

Figure 6a: 1991 IGM photograph of Lago Agrio Central Production Station that was incorrectly labeled in the Cabrera Report as being from 1990. Pit 3 was first visible in 2001 and Pits 4, 5, and 6 were first visible in 1991. All four pits were included in the Cabrera Report as “TexPet pits.”

Figure 6b: Actual 1990 IGM aerial photograph (#29406) for the Lago Agrio Central Production Station. Note that “Pits 3, 4, 5, and 6,” which were identified in the Cabrera Report as “TexPet pits,” did not exist in 1990. This same type of mistake was seen at the Lago Agrio North Production Station. These examples were included in the 2008 report, Rebuttal of the Methodology Used by Mr. Cabrera to Determine the Number and Size of Pits in the Petroecuador-Texaco Concession, submitted to the Ecuadorian Court. 9

Attachment A WILLIAM D. DI PAOLO P.O. Box 666 Cortez, Colorado 81321 (970) 564-1886 bill_dipaolo@msn.com

SUMMARY: Master of Science Degree, plus post Masters work. Professional Registered Geologist - State of Arizona. 9 years - Federal Government - geologic mapping, minerals, and environmental work. 30 years - Industry - petroleum exploration, remote sensing. 10 published professional papers, and numerous professional presentations. Over 60 written industry technical reports. EDUCATION AND TRAINING: B.S. Geology, Northern Illinois University, 1970 M.S. Geology, Northern Illinois University, 1972 Advanced Study Geophysics & Geochemistry, Arizona State University, 9/72 - 8/73 Lands & Minerals Training School Federal Mineral & Environmental Laws, U.S. Bureau of Land Management, , 7/74 - 11/74 Visiting Scientist Purdue University, Laboratory for the Applications of Remote Sensing, 9/78 8/79 PROFESSIONAL REGISTRATIONS: Professional Registered Geologist, State of Arizona # 11363 (inactive) PROFESSIONAL EXPERIENCE: 9/97 to Present. Di Paolo Consulting - Cortez, Colorado. President and Remote Sensing Geologist - A Landsat-TM interpretation and structural analysis was done over the Piceance Basin, western Colorado. Another project with an emphasis on fracture mapping was done over SE Montana. Potential field data and well data were used to enhance the structural interpretation. Other projects consisted of air photo interpretations documenting environmental change over various areas. 2/88 to 8/97. Unocal Corporation - Sugar Land, Texas. Remote Sensing Coordinator - Responsible for the management and applications of Unocal’s Remote Sensing efforts in support of worldwide exploration and business development. The interpretation and structural analysis of remote sensing imagery along with subsurface information and geophysical data, when available, contributed to Unocal’s international exploration program. A list of reports written for Unocal is attached to this resume.

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9/87 to 1/88. Barringer Geoservices Company - Golden, Colorado. Senior Consulting Geologist - Interpreted and analyzed Landsat thematic mapper data over the Paradox and Big Horn Basins for oil and gas exploration. Technical reports were written on these areas, and presentations were made to clients. 3/87 to 9/87. U.S. Bureau of Land Management - Lakewood, Colorado. Physical Science Aid - Compiled land status and Known Geologic Structure information for the Bureau’s automated oil and gas base mapping program. 11/81 to 7/86. Amoco Production Company - Denver, Colorado. Staff Geologist - Exploration was carried out in the western U.S. and Alaska using photogeologic and remote sensing techniques as well as potential field data, geochemistry, and subsurface well data. As operations geologist, was responsible for Amoco’s drilling wells in western Colorado and eastern Utah including coal degasification. Exploitation work was done on fields in the Wind River Basin. A list of reports written for Amoco is attached to this resume. 7/74 to 11/81. U.S. Bureau of Land Management. Physical Scientist/Remote Sensing Specialist - Denver, Colorado. Remote sensing projects were done in southwestern Idaho and in Arizona using various digital analysis techniques combined with field work to produce computer classification maps for resource inventories and management plans. Area Geologist - Phoenix, Arizona. Responsible for all minerals activities within the Phoenix Resource Area. Performed mining claim validity determinations and served as the Government’s expert witness in court. Provided input on environmental, mineral, and hydrologic resource assessments. Aerial photography was used to inventory spring sites and other features. District Geologist - Winnemucca, Nevada. Responsible for the District-wide minerals program. 7/73 to 7/74. U.S. Geological Survey, Geologic Division - Flagstaff, Arizona. Geologist - Detailed geologic mapping, fracture mapping, and stratigraphic section measurements were carried out over north-central Arizona. An area of approximately 350 square miles was mapped using high altitude stereo aerial photography, Sky Lab, and Landsat data. A list of publications resulting from this work is attached to this resume. 5/72 to 8/72. Sergent, Hauskins, and Beckwith - Phoenix, Arizona. Geologist - Geologic field investigations were performed for soils and foundation engineering. 2/72 to 5/72. Holmquist and King, and City of Glendale, Arizona. Surveyor and Draftsman. 6/70 to 9/70. Northern Illinois Gas Company - Hudson, Illinois. Geologist - Performed geologic work in support of subsurface gas storage in central Illinois. PUBLICATIONS AND PROFESSIONAL PRESENTATIONS: Petrography of the Iron Mountain Trachybasalts, Iron Mountain, Montana, Masters Thesis, 1971. Lineament Systems of North-Central Arizona, presented to Arizona Academy of Science, Flagstaff, 1974.

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Identification and Correlation of Precambrian and Phanerozoic Orthogonal Fault and Lineament Systems in Central and Northern Arizona , NASA Earth Resources Survey Symposium, Houston, Texas, June 1975. Structural History of Central and Northern Arizona during the past 1800 m.y. - Evolution of Precambrian and Phanerozoic Orthogonal Fault and Lineament systems, unpublished manuscript, U.S. Geological Survey, 1975. Geologic map of the Sedona Area encompassing over six 7 1/2' topographic quadrangles (1:24,000 scale), on file with the U.S. Geological Survey, Flagstaff. Lineament maps of the Sedona area and north-central Arizona, on file with U.S. Geological Survey, Flagstaff. Lithologic descriptions of the stratigraphic sections measured in the Sedona area, to be published on open-file with the U.S. Geological Survey. Comparison of Skylab and Landsat Images for Geologic Mapping in Northern Arizona, NASA Final Report 7-100, Task Order RD-161, February 27, 1976. Pennsylvanian-Permian Stratigraphy of the Sedona Area and Environs, Central and Northern Arizona, in Four Corner Geol. Soc. Guidebook, 9th Field Conf., Permianland, 1979. Applications of Landsat Data for Resource Inventories on Federal Lands in the Western United States, presented at Machine Processing of Remotely Sensed Data Symposium, Purdue University, June, 1979. An Analysis of Landsat Data for Soils Investigations on Federal Lands in Southwestern Idaho, LARS Technical Report 082879, 1979. Remote Sensing and Landsat Applications for Resource Management and Soils Investigations, presented at American Society of Photogrammetry Regional Meeting, Denver, January, 1980. Geologic Map and Lineament Map of the Sedona Area, published by the U.S. Geological Survey in Water Resources In The Sedona Area, Arizona Water Commission Bulletin 11, April, 1980. An Analysis of Landsat Data For Soils Investigations in Southwestern Idaho, presented at Remote Sensing for Resource Management, Kansas City, Missouri, October, 1980. Chairman of session entitled Geologic Applications of Remote Sensing, Seventh International Symposium on Machine Processing of Remotely Sensed Data, Purdue University, June, 1981. Landsat Data for Soils Investigations on Federal Lands, chapter in Remote Sensing for Resource Management, Soil Conservation Society of America, 1982. Soil-Vegetation Inventories in Arizona, in Proc. 48th National Meeting, American Society of Photogrammetry, Denver, 1982. The Use of Remote Sensing for Soils Investigations on BLM Land, U.S. Bureau of Land Management Technical Note 361, Denver, Colorado, May, 1983. 12

The Geology, History, Trails, and River of the Grand Canyon, Arizona, presentation given at the Denver Museum of Natural History, June, 1987. The Application of Remote Sensing Technology in Support of Unocal’s Worldwide Energy Resource Exploration Efforts, presented at the American Association of Petroleum Geologists National Convention, Houston, Texas, March, 1995. The Application of Remote Sensing Technology in Support of Unocal’s Worldwide Energy Resource Exploration Efforts, presented at the Rocky Mountain Association of Geologists meeting, Denver, Colorado, August, 1995. Contributed to an article on industry’s use of remote sensing data, published in Hart’s Oil and Gas World, January, 1996. The Role of Remote Sensing in a Changing Oil Industry, presented at the American Association of Petroleum Geologists National Convention, San Diego, California, May, 1996. A Radar-Structural Interpretation of Onshore Trinidad, poster presented at the AAPG symposium “Oil and Gas Exploration and Production in Fold and Thrust Belts”. Veracruz, Mexico, February 23-26, 1997. The Potential and the Pitfalls of Using Remote Sensing Imagery Data to Predict Fractured Reservoirs, poster presented at the Rocky Mountain Association of Geologists symposium on “Fractured Reservoirs: Practical Exploration and Development Strategies”. Denver, Colorado, January 19-20, 1998. Published Sichuan Basin, China imagery along with a written description in Earth Observation Magazine, May, 1998. Remote Sensing Data and Interpretation in International Exploration, presented at the Denver International Petroleum Society meeting, Denver, Colorado, January 12, 2001. Presented one day course An Introduction to Geologic Remote Sensing and Image Interpretation to the Rocky Mountain Association of Geologists, Denver, Colorado, October 23, 2002. OTHER PROFESSIONAL ACTIVITIES: Instructor for the summer field geology course of Pikes Peak College, Colorado Springs from 1976 to 1981. The course was taught in the Grand Canyon and Oak Creek Canyon areas of northern Arizona. Guest speaker, for the Science Department and geology classes of Pikes Peak College in Colorado Springs, Colorado, 1978, 1980. Invited instructor at the BLM Lands and Minerals School in Phoenix, Arizona to teach mineral and mining laws, and minerals trespass, 1976-1980. Invited instructor for the BLM Beginning and Advanced Minerals classes in Phoenix, Arizona to teach remote sensing and geologic applications, 1979 to 1981. Instructor for Amoco and Unocal photo interpretation and remote sensing courses. 13

Lectures given on remote sensing, and the Grand Canyon to various organizations, including seven Jefferson County libraries and various senior citizens groups. Space science lectures given to local area elementary schools. AWARDS AND ACHIEVEMENTS: U.S. Bureau of Land Management $200 Special Achievement Award for performance of duties during the period of 10/1/76-9/30/77. U.S. Department of the Interior Unit Award Citation for work on the geothermal leasing program in Nevada during the period 1/74-1/77, signed by the Secretary of the Interior. Received acknowledgments in Landscapes of Arizona, The Geological Story, for geologic mapping and investigations in northern Arizona: published by University Press of America, 1984. Letters of commendation were received from the Office of the U.S. Attorney in Phoenix, Arizona and the U.S. Department of the Interior Field Solicitor for work on BLM minerals cases, and also for work as an expert witness for the Federal Government in court. Passed Arizona State Board of Technical Registration exams in 1977 for registration as a professional geologist in the state of Arizona. U.S. Bureau of Land Management Employee Suggestion Award. June 20, 1979 Received letter of commendation from the Director of the Soils Survey Investigation Division, Soil Conservation Service, for remote sensing work done in southwestern Idaho. Received various letters of commendation from Pikes Peak College, Colorado Springs, for lectures and teaching assistance. U.S. Bureau of Land Management $600 Special Achievement Award for recognition of service performed in a manner exceeding the requirements of the position, February 26, 1981. Promotion from Senior Geologist to Staff Geologist, Amoco Production Company - October, 1983. Promotion from Remote Sensing Geologist to Senior Remote Sensing Geologist, Unocal International Oil and Gas Division - April, 1990. Promotion from Senior Remote Sensing Geologist to Consulting Remote Sensing Geologist, Unocal International Oil and Gas Division - May, 1991. Unocal Special Performance Award - May, 1994. Received acknowledgments in the book Remote Sensing for Geologists: A Guide to Image Interpretation, published by Gordon and Breach, 1994. Unocal Special Award - December, 1995. Presented for work contributing to discoveries in the Balikpapan area. 14

Unocal Special Recognition Award - October, 1996. Presented for work on a project in central Peru.

Reports written for Amoco Production Company by: William D. Di Paolo 1. 2. 3. 4. 5. 6. Remote Sensing Analysis of the San Simon Valley Area, Southeast Arizona. Geology, Structure, and Petroleum Potential of Pine Valley, Nevada. Remote Sensing Analysis of the Newark Valley Area, Nevada. Structure, Geology, and Remote Sensing Analysis of Dixie Valley, Nevada. Remote Sensing Analysis and Petroleum Potential of the Carson Sink Area, Nevada. Remote Sensing Analysis, Structure, and Petroleum Potential of the Bacon Flat Area, Railroad Valley, Nevada. Remote Sensing Analysis of Lake Valley, Nevada. Structural Interpretation, Deer Lodge, Canyon Ferry, and Three Forks Basins, Montana. Remote Sensing Trends in the Overthrust Belt, Wyoming. Reconnaissance Drainage and Landsat Analysis, Wind River Basin, Wyoming. Remote Sensing Analysis and Structural Interpretation of the Alaska Peninsula. Side-Scan Sonar Interpretation, Pt. Conception to Pt. Arguello, Offshore California. Point Arguello to Point Conception State Sale Evaluation.. Remote Sensing Analysis of the Raton Basin Coal Degasification Area. Structure, Geology, and Petroleum Potential of the Pedregosa Basin, Southwest New Mexico. Photogeology of the Bull Mountain 7.5 Minute Quadrangle, Southern Piceance Basin, Colorado. Geologic Analysis of the Late Cretaceous Lewis - Fox Hills Sequence in the Blue Gravel Field Area, Northwestern Colorado. Petroleum Potential and Evaluation of the Sheldon Dome Field and Surrounding Area, Wind River Basin, Wyoming. Final Reports on Amoco's Coal Degasification Wells, Piceance Basin, Colorado. Final Report Amoco Taylor Creek Unit No. 1 Wildcat, Paradox Fault and Fold Belt, Utah. Final Report Amoco Geyser Creek Unit No. 1 Wildcat, Paradox Fault and Fold Belt, Utah.. 15

7. 8. 9. 10. 11. 12. 13. 14. 15. 16.

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19. 20. 21.

Projects completed for UNOCAL CORPORATION by: William D. Di Paolo 1. 2. 3. A Remote Sensing Analysis of the Surma Basin Area, Northeast Bangladesh. May, 1988. Landsat Interpretation of the Sibi Reentrant Area, Pakistan. September, 1988. Remote Sensing Interpretation, Structural Analysis, and Petroleum Potential of the East Shabwa Concession and Surrounding Area, South Yemen. December, 1988. Remote Sensing Interpretation of Northern Somalia - Conoco Farmout Proposal. January, 1989. A Remote Sensing Analysis of Eastern Kenya. March, 1989. Remote Sensing Interpretation of Northwest Qatar - Ras Busdad and Ras Umm El Hish Lead Areas. (With R. de Zoeten) August, 1989. A Remote Sensing Analysis and Structural Interpretation of Syria, and the El Hasekah Block Area of Northeast Syria. November, 1989. A Remote Sensing Analysis of the Khorat Plateau Area, Thailand. February, 1990. A Landsat Interpretation of Unocal's Myanmar (Burma) Concession and Surrounding Area. April, 1990.

4. 5. 6.

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8. 9.

10. A Landsat Interpretation of Bulgaria and Southern Romania. April, 1990. 11. A Remote Sensing Interpretation of Blocks 28 and 29, Pakistan. (With M. New) May, 1990. 12. Landsat Thematic Mapper Structural Interpretation of Blocks 1, 2, 3, 7, and Surrounding Area, South Yemen. May, 1990. 13. A Landsat Structural Interpretation of Romania and the Southwest Ukraine. March, 1991. 14. A Remote Sensing Interpretation of Block E, Myanmar. April, 1991. 15. A Landsat Interpretation of the Casamance Area, Senegal. May, 1991. 16. A Landsat Structural Interpretation of Albania. August, 1991. 17. A Remote Sensing Interpretation of the Rajasthan Area, N.W. India. December, 1991. 18. A Landsat Interpretation of the Kutch Basin Area, N.W. India. January, 1992. 19. A Radar Structural Interpretation of Onshore Gabon. March, 1992. 20. A Remote Sensing Intepretation of the Tel Abyad Concession, Syria. February, 1993. 21. A Radar-Structural Interpretation of Onshore Trinidad. June, 1993. 22. A Landsat Interpretation of the Cook Inlet Area, Alaska. July, 1993. 16

23. A Regional Remote Sensing Interpretation of the Peru/Bolivia Fold Belt. November, 1993. 24. A Regional Landsat Interpretation of North-Central Columbia. January, 1994. 25. A Landsat-TM Interpretation of the Mekong Delta Area, Viet Nam. May, 1994. 26. A Remote Sensing Structural Interpretation of the Balikpapan Area Regional Study (BARS), East Kalimantan. July, 1994. 27. A Landsat-TM Interpretation of the Sichuan Basin, China. October, 1994. 28. A Quick-Look Landsat-TM Interpretation of the Akkaz Field Area, Southeast Syria-Western Iraq. December, 1994. 29. A Remote Sensing Interpretation of the Uch Structure, Pakistan. June, 1995. 30. A Landsat-MSS Interpretation of the Chittagong Hills Area, Bangladesh. June, 1995. 31. A Landsat-TM Interpretation of the Longmenshan Block, Sichuan Basin, China. September, 1995. 32. An Airborne Radar Interpretation of Central Peru. October, 1995. 33. A Landsat Interpretation of the Ft. Norman Project Area, Northwest Territories, Canada. January, 1996. 34. A Landsat Interpretation of the Neuquen Basin, Argentina. July, 1996. 35. A Landsat-MSS Interpretation of the Karachi, Pakistan Area. August, 1996. 36. A Landsat-MSS Interpretation of the Sulaiman Fold Belt, Pakistan. September, 1996. 37. A Landsat-TM and SPOT-XS Interpretation of the Mirawak Structure Area, Pakistan. October, 1996. 38. Oil Seep Detection Using Radarsat Data Over the Gulf of Tonkin, Viet Nam. December, 1996. 39. A Landsat-MSS Interpretation of the Tripura Foldbelt, Bangladesh. December, 1996. 40. A Remote Sensing Interpretation over Unocal's Geothermal Area of Interest in Northwestern Nicaragua. February, 1997.

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Attachment B List of Documents Considered* Court Reports Anexo E, Anexo H, and Anexo U4 in the Report of Richard Cabrera, Informe Sumario del Examen Pericial, Aguinda, et al. v. Chevron Corp., Sucumbios Provincial Court of Justice in Nueva Loja, Ecuador, April 2008. Informe a la Corte Superior de Nueva Loja, Pruebas del Fraude de Chevron, Aguinda, et al. v. Chevron Corp., Sucumbios Provincial Court of Justice in Nueva Loja, Ecuador, November 2006. Di Paolo, William and Hall, Laura B., Rebuttal of the Methodology Used by Mr. Cabrera to Determine the Number and Size of Pits in the Petroecuador-Texaco Concession, Aguinda, et al. v. Chevron Corp., Sucumbios Provincial Court of Justice in Nueva Loja, Ecuador, 2008. Aerial Photographs Included In: Reports by Experts Nominated on Behalf of Chevron, Aguinda, et al. v. Chevron Corp., Sucumbios Provincial Court of Justice in Nueva Loja, Ecuador, Judicial Inspections, 20042009. Reports by Court Experts, Aguinda, et al. v. Chevron Corp., Sucumbios Provincial Court of Justice in Nueva Loja, Ecuador, Judicial Inspections, 2007-2009. Connor, John A., Expert Opinion of John A. Connor, P.E., P.G., B.C.E.E., Regarding Remediation Activities and Environmental Conditions in the Former PetroEcuador-Texaco Concession, Oriente Region, Ecuador, Aguinda, et al. v. Chevron Corp., Sucumbios Provincial Court of Justice in Nueva Loja, Ecuador, September 2010. Other Documents Aerial photographs of well sites in the former Concession area (IGM, 1985). Court Documents Sentencia, Aguinda, et al. v. Chevron Corp., Sucumbios Provincial Court of Justice in Nueva Loja, Ecuador, February 14, 2011. Clarification, Aguinda, et al. v. Chevron Corp., Sucumbios Provincial Court of Justice in Nueva Loja, Ecuador, March 4, 2011.

* Documents on this list are available upon request. 18

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