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Case 1:14-cr-00263-JEI Document 165-2 Filed 03/25/15 Page 1 of 3 PageID: 2421

quin 1 C11

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WRITER'S DIRECT DIAL No.


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williamburck@quinnemanuel.com

March 20, 2015


VIA EMAIL AND U.S. MAIL

Patrick Stokes, Esquire


Daniel Kahn, Esquire
Tarek Helou, Esquire
U.S. Department of Justice
Criminal Division, Fraud Section
1400 New York Ave. NW
Washington, DC 20005
Zach Intrater, Esquire
United States Attorney's Office
970 Broad Street, Suite 700
Newark, NJ 07102
Re:

Expert disclosures

Dear Patrick, Dan, Tarek, and Zach:


Pursuant to Federal Rule of Criminal Procedure 16(b)(1)(C), we write to disclose the
expert witness testimony of the four witnesses named below.

I.

Justice Carlos G. Arrieta

Mr. Sigelman intends to call Justice Carlos G. Arrieta to provide testimony pursuant to
Federal Rule of Evidence 702. We anticipate that Justice Arrieta will offer testimony regarding
Ecopetrol, including the functions it performed between 2009 and 2010 and its relationship with
the Republic of Colombia ("Colombia") during that period. This testimony is expected to
include Ecopetrol's history, the laws and regulations bearing on its functions and its relationship
with Colombia, Ecopetrol's internal governance and operations, and the role of Ecopetrol's
employees. Justice Arrieta has already provided one declaration in this matter, see Declaration

quInn emanuel urquhait & sullivan, lip


LOS ANGELES
MUNICH

NEW YORK

SYDNEY

SAN FRANCISCO

HONG KONG

BRUSSELS

SILICON VALLEY

CHICAGO

HOUSTON

LONDON

TOKYO

MANNHEIM

MOSCOW

HAMBURG

PARIS

Case 1:14-cr-00263-JEI Document 165-2 Filed 03/25/15 Page 2 of 3 PageID: 2422

of Carlos Gustavo Arrieta Padilla, ECF No. 112-1, and we expect that his testimony at trial will
be consistent with and supplemental to that declaration.
Justice Arrieta is qualified to offer this testimony on the basis of his education,
professional training, academic research, and experience in administrative law. His extensive
judicial experience includes terms as Justice on Colombia's State Council (Colombia's highest
court for administrative law disputes) and as adjunct Justice on Colombia's Constitutional Court
(Colombia's highest court for constitutional law matters). In addition, he served for four years as
Colombia's Attorney Inspector General. Justice Arrieta's private practice experience includes
litigation and client advisory services related to administrative law issues prevalent in the oil and
gas industry. He also acts as an arbitrator in disputes arising from public and commercial
contracts. Additionally, Justice Arrieta was a professor of law at the Los Andes School of Law in
Bogota, Colombia, for many years and served as the school's Dean from 1986-89.

II.

Professor David R. Mares

Mr. Sigelman intends to call Professor David R. Mares to provide testimony pursuant to
Federal Rule of Evidence 702. We anticipate that Professor Mares will offer testimony
regarding the characteristics and relative autonomy of various nationally-owned and private oil
and gas companies, including Ecopetrol. Professor Mares is also expected to provide testimony
regarding the political, social, and economic factors influencing the creation and/or privatization
of national oil companies.
Professor Mares is qualified to offer this testimony on the basis of his extensive academic
research of Latin American energy issues. In addition to his current teaching position at the
University of California, San Diego, Professor Mares is the Baker Institute Scholar for Latin
American Energy Studies at Rice University. Professor Mares has also held teaching posts at El
Colegio de Mexico; the Universidad de Chile; FLACSO Ecuador; Harvard University; Stanford
University; and a fellowship at the Oxford Institute for Energy Studies. In the course of his
scholarship, Professor Mares has written or edited nine books, as well as hundred journal
articles, book chapters, and reports. Professor Mares's teaching includes classes on energy
politics.

III.

Justice Jorge A. Gomez

Mr. Sigelman intends to call Justice Jorge A. Gomez to provide testimony pursuant to
Federal Rule of Evidence 702. We anticipate that Justice Gomez will offer testimony regarding
Colombia's criminal laws and procedure, including the effects of certain criminal penalties.
Justice Gomez is expected to provide testimony as to the penalty of debarment from performing
public functions as well as to the effect of such penalty on crimes against the public
administration of Colombia, such as bribery.
Justice Gomez is qualified to offer this testimony on the basis of his education,
professional training, academic research, and experience. His professional background includes
extensive judicial experience, including terms on the Criminal Section of Colombia's Supreme
Court of Justice (Colombia's highest court for criminal matters) as well as appellate and trial

Case 1:14-cr-00263-JEI Document 165-2 Filed 03/25/15 Page 3 of 3 PageID: 2423

courts with jurisdiction over criminal matters. In addition, Justice Gomez's private practice
experience focuses on criminal law matters. He has taught Colombian criminal law at several
universities and published academic articles in Colombian legal journals.
IV. Louis G. Dudney, CPA, CFF
Mr. Sigelman intends to call Louis G. Dudney to provide testimony pursuant to Federal
Rule of Evidence 702. We anticipate that Mr. Dudney will offer testimony regarding the funds,
capital, and other contributions provided to PetroTiger Ltd. and/or its affiliates or subsidiaries
(collectively "PetroTiger") by its founders and/or subsequent investors from 2007 to 2011. We
also expect that Mr. Dudney will provide analysis of financial records reflecting the flow of
funds between PetroTiger and Mr. Sigelman.
Mr. Dudney is qualified to offer this opinion on the basis of his education, professional
training, and experience. Mr. Dudney possesses broad professional experience in business
accounting. He a Certified Public Accountant and holds additional professional credentials in
financial forensics.

We have provided this disclosure based on the information we have reviewed to date.
Please note that we expressly reserve the right to supplement this disclosure. If you have any
questions regarding the foregoing, please do not hesitate to contact us.
Sincerely,

William A. Burck & Juan P. Morillo