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Exhibit 29

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Berkovits, Yonatan

From: Haggerty, Timothy [thaggerty@fklaw.com]Sent: Wednesday, April 20, 2011 10:36 PMTo: mgitter@cgsh.comCc: 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 upFlag 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 masterpassword list that counsel for Chevron provided, and none of the passwords provided access to the account (I trieduppercase and lowercase variations of the passwords). We have also spoken with Mr. Woods, who, like Mr. Donziger, isnot familiar with the account. I also went to the "password retrieval" utility on Gmail, and it provided the following "secret

question":? 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 thequestion as "favorite food?" Finally, I note again here, as we noted yesterday, that the e-mail service providers (includingGoogle) have told us that they have not identified e-mail accounts other than those that have been previously identifiedand investigated in the course of these proceedings.

Respectfully,

Tim Haggerty

From: Haggerty, Timothy

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.Sent: Tue Apr 19 18:16:34 2011Subject: 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 somecases (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 theservice 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 aredesigned 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 uswith these findings and conclusions, which they believe close out the subpoenas, shortly.

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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 hasadvised 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 comfortableattempting 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: 973-877-6451Direct fax: 973-877-6452

New York Office:

7 Times SquareNew York, NY 10036-6516

Direct tel: 212-833-1251Direct 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 PMTo: Kaplan, Bruce S.; Haggerty, TimothyCc: 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.comSubject: 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 thepasswords identified in our prior emails on this subject. If unsuccessful in accessing the account using those

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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 LLP200 Park Avenue, New York, NY 10166-0193Tel +1 212.351.4051 Fax +1 212.351.6339KHendricks@gibsondunn.comwww.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.________________________________

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