Case 1:10-mc-00002-LAK Document 194-31 Filed 04/26/11 Page 1 of 4

Exhibit 29
 Case 1:10-mc-00002-LAK Document 194-31 Filed 04/26/11 Page 2 of 4

Berkovits, Yonatan
From: Haggerty, Timothy [thaggerty@fklaw.com]
Sent: Wednesday, April 20, 2011 10:36 PM
To: mgitter@cgsh.com
Cc: jormand@cgsh.com; Mastro, Randy M.; Neuman, Andrea E.; bnarwold@motleyrice.com;
imoll@motleyrice.com; mjasinski@motleyrice.com; jabady@ecbalaw.com;
imaazel@ecbalaw.com; awilson@ecbalaw.com; arivero@riveromestre.com;
avinegrad@cov.com; Hendricks, Kristen; Kaplan, Bruce S.
Subject: Re: In re Application of Chevron, Case No. 10-mc-00002 (LAK) -- New email address

Follow Up Flag: Follow up

Flag Status: Completed

Dear Mr. Gitter:

We write with an update regarding the e-mail account sdonwon@gmail.com. I have tried the passwords on the master
password list that counsel for Chevron provided, and none of the passwords provided access to the account (I tried
uppercase and lowercase variations of the passwords). We have also spoken with Mr. Woods, who, like Mr. Donziger, is
not familiar with the account. I also went to the "password retrieval" utility on Gmail, and it provided the following "secret
question": 좋아하는 음식은? I do not speak or read Korean, and I understand that Messrs. Donziger and Woods do not
either, but when I pasted this question into "Google Translate," it autodetected the language as Korean and translated the
question as "favorite food?" Finally, I note again here, as we noted yesterday, that the e-mail service providers (including
Google) have told us that they have not identified e-mail accounts other than those that have been previously identified
and investigated in the course of these proceedings.

Respectfully,

Tim Haggerty

From: Haggerty, Timothy

To: 'mgitter@cgsh.com' <mgitter@cgsh.com>
Cc: jormand@cgsh.com <jormand@cgsh.com>; Mastro, Randy M. <RMastro@gibsondunn.com>; Neuman, Andrea E.
<ANeuman@gibsondunn.com>; bnarwold@motleyrice.com <bnarwold@motleyrice.com>; imoll@motleyrice.com
<imoll@motleyrice.com>; mjasinski@motleyrice.com <mjasinski@motleyrice.com>; jabady@ecbalaw.com
<jabady@ecbalaw.com>; imaazel@ecbalaw.com <imaazel@ecbalaw.com>; awilson@ecbalaw.com
<awilson@ecbalaw.com>; arivero@riveromestre.com <arivero@riveromestre.com>; avinegrad@cov.com
<avinegrad@cov.com>; Hendricks, Kristen <KHendricks@gibsondunn.com>; Kaplan, Bruce S.
Sent: Tue Apr 19 18:16:34 2011
Subject: RE: In re Application of Chevron, Case No. 10-mc-00002 (LAK) -- New email address

Dear Mr. Gitter:

I write on behalf of Bruce Kaplan and myself with an update regarding Mr. Donziger's email accounts.
After many conversations with the e-mail service providers, they all have reported that they are not able
to identify any e-mail accounts other than those we have already been aware of and investigated. In some
cases (sdonziger@aol.com, sdonziger2@yahoo.com, gringograndote@gmail.com), the e-mail service
providers cannot verify or provide information about the accounts listed in the subpoenas. All of the
service providers have noted that they have limitations in their ability to cross-reference backup e-mail
accounts and IP log information to identify primary e-mail addresses; generally, their systems are
designed so that they can access IP log information (as to which storage policies vary by e-mail service
provider, but none store IP log information indefinitely) and secondary e-mail accounts when they know
the primary e-mail account - not the other way around. They will be sending confirmatory letters to us
with these findings and conclusions, which they believe close out the subpoenas, shortly.

1
 Case 1:10-mc-00002-LAK Document 194-31 Filed 04/26/11 Page 3 of 4
As to the e-mail that Ms. Hendricks sent to us earlier today regarding the e-mail address
sdonwon@gmail.com, we have asked Mr. Donziger whether he recalls using this account, and he has
advised us that he does not. In light of this, it would be helpful if counsel for Chevron provide us with
some further information that might help us determine whether this account might be one used by Mr.
Donziger. Without further information that would tend to support a good faith conclusion that there is
a reasonable likelihood that the account might belong to Mr. Donziger, we are not entirely comfortable
attempting to access the account. Nevertheless, we will employ the password list since the chances are
remote that one of the passwords would succeed if the account were not Mr. Donziger's.

Respectfully,

Tim Haggerty

Timothy M. Haggerty
Friedman Kaplan Seiler & Adelman LLP
One Gateway Center, 25th Floor
Newark, NJ 07102-5311
Direct tel: 973-877-6451
Direct fax: 973-877-6452

New York Office:

7 Times Square
New York, NY 10036-6516
Direct tel: 212-833-1251
Direct fax: 212-833-1250

*********************************************

This transmission may be a confidential attorney-client communication or may otherwise be privileged or confidential. If you are not
the intended recipient, please do not read, copy, or re-transmit this communication. If you have received this communication in error,
please notify us by replying to the sender of this message, and delete this message (and your reply) and any attachments. Thank you
in advance for your cooperation and assistance.

*********************************************

From: Hendricks, Kristen [mailto:KHendricks@gibsondunn.com]

Sent: Tuesday, April 19, 2011 1:07 PM
To: Kaplan, Bruce S.; Haggerty, Timothy
Cc: Max GITTER; jormand@cgsh.com; Mastro, Randy M.; Neuman, Andrea E.; bnarwold@motleyrice.com;
imoll@motleyrice.com; mjasinski@motleyrice.com; jabady@ecbalaw.com; imaazel@ecbalaw.com; awilson@ecbalaw.com;
arivero@riveromestre.com; avinegrad@cov.com
Subject: In re Application of Chevron, Case No. 10-mc-00002 (LAK) -- New email address

Mr. Kaplan and Mr. Haggerty:

Just yesterday, we identified for the first time another email account that appears to have been used by Mr.
Donziger but was not previously identified by him. The email address is sdonwon@gmail.com. We request
that you ask Mr. Donziger whether he used this account, and then attempt to access the account using the
passwords identified in our prior emails on this subject. If unsuccessful in accessing the account using those

2
 Case 1:10-mc-00002-LAK Document 194-31 Filed 04/26/11 Page 4 of 4
passwords, we request that you issue another subpoena to google requesting immediate production of the
contents of this account, with Mr. Donziger's express consent.
Thank you,
Kristen

Kristen Hendricks

GIBSON DUNN
Gibson, Dunn & Crutcher LLP
200 Park Avenue, New York, NY 10166-0193
Tel +1 212.351.4051 • Fax +1 212.351.6339
KHendricks@gibsondunn.com • www.gibsondunn.com

________________________________
This message may contain confidential and privileged information. If it has been sent to you in error, please
reply to advise the sender of the error and then immediately delete this message.
________________________________