FILED

Case 2:15-cv-00506-RDP Document 121-2 Filed 12/08/16 Page 1 of 4

2016 Dec-08 PM 08:03

U.S. DISTRICT COURT
N.D. OF ALABAMA

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ALABAMA
SOUTHERN DIVISION
DRUMMOND COMPANY, INC.; and
DRUMMOND LTD.
Plaintiffs,
v.
TERRENCE P. COLLINGSWORTH
individually and as agent of Conrad & Scherer
LLP, International Rights Advocates, Inc., and
Albert van Bilderbeek; CONRAD & SCHERER
LLP; WILLIAM R. SCHERER, JR., individually
and as agent of Conrad & Scherer, LLP;
INTERNATIONAL RIGHTS ADVOCATES
INC.; IVAN ALFREDO OTERO MENDOZA
FRANCISCO RAMIREZ CUELLAR; and
ALBERT van BILDERBEEK
Defendants.

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DECLARATION OF TERRENCE P. COLLINGSWORTH

1.

My name is Terrence P. Collingsworth. I am an adult resident of Washington,

D.C., and am competent to testify to the matters contained in this declaration. I make this
declaration based on my personal knowledge, except where otherwise indicated.
2.

I am Executive Director of the International Rights Advocates, and I am a

Defendant in the captioned case as well as in Drummond Co., Inc. v. Collingsworth, et al., No.
2:11-cv-3695-RDP (N.D. Ala. filed Oct. 21, 2011).
3.

I was hired by Albert van Bilderbeek to investigate and explore the options for his

company, Llanos Oil, to bring a case against Drummond based on Drummonds possible role in

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the wrongful appropriation the Llanos Oil concession in Colombia. As Drummond was
operating under Llanos Oils environmental permit, there was a substantial basis to think a claim
could be brought. The representation was solely based on a contingency fee agreement for that
possible case, and I was never otherwise compensated by Llanos Oil and acquired no interest,
contingent or otherwise, in any other case brought by Llanos Oil or Albert van Bilderbeek. This
work for Mr. van Bilderbeek had an obvious and substantial overlap with my work for the
human rights plaintiffs in my cases, as both cases require evidence of Drummonds unlawful acts
and improper relationship with the Colombian government during the Uribe administration.
Drummond has put the facts of what happened to Llanos Oil in Colombia at issue in the RICO
and libel cases by stating falsely and without any factual basis that Llanos Oil and I have
conspired to damage Drummonds business.
4.

In around 2010, Albert van Bilderbeek arranged for me to meet with some

investment bankers in Zurich, Switzerland to allow me to present a proposal to obtain a loan to

finance our Drummond litigation. I met with two gentlemen at their offices in Zurich. I do not
recall their names or the name of their company. At the conclusion of our discussion, the
investment bankers declined to provide any financing, stating that they did not understand U.S.
litigation and could not objectively assess the risk to their investment.
5.

I drafted the two letters which were to be provided to the Dutch government. I

received some minor assistance from Albert van Bilderbeek in finalizing the two letters. He
mainly provided me with the names and correct spelling of the appropriate officials in the Dutch
government who were to receive the letters. I was the sole author of the text of the letters, and
the assertions therein were based on my knowledge and belief as to the facts of Drummonds
unlawful conduct in Colombia.

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6.

Without waiving attorney-client privilege, I can say that I informed Albert van

Bilderbeek about Jaime Blanco Maya. I told Mr. van Bilderbeek that Blanco had contacts and
technical information that could help van Bilderbeek investigate his claims regarding the
wrongful termination of his oil leases in Colombia.
7.

Mr. van Bilderbeek never met with, and as far as I know, spoke directly to Jamie

Blanco, who comes from a prominent Colombian family. Instead, van Bilderbeeks Colombian
lawyer, Gloria Alzate, met Blanco, who was being housed in the political wing of the Picoto
prison in Bogota, Colombia. Blanco had many contacts and technical information that van
Bilderbeeks attorney viewed as helpful to their case.
8.

Once van Bilderbeek and his local lawyer were satisfied that Blanco had given

them the information and contacts they sought, he arranged for Ivan Otero, my Colombian
attorney, to receive funds to pay Mr. Blanco for his services.
9.

Van Bilderbeeks arrangement with Blanco was based on information he needed

for his litigation in the Netherlands against Ecopetrol and was not to assist the human rights
litigation going on in Birmingham. I know that all or part of the funds that Blanco earned from
his services to van Bilderbeek were used by Blanco to pay his criminal attorney in Colombia
because he was changing his plea in his criminal case and exposing himself to criminal liability
as he planned to tell the truth about his role, and Drummonds role, in the murder of the
Drummond union leaders.
10.

At the time I introduced Blanco to van Bilderbeeks Colombian lawyer, I had

interviewed Blanco at least three times, was aware of his truthful testimony about Drummonds
role in the union murders, and that he was concerned only about admitting to his part in the
conspiracy with Drummond to murder the union leaders without having proper legal

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representation in his criminal case. Mr. van Bilderbeeks assistance did not in any way change
the testimony I had already heard from Blanco.
11.

Van Bilderbeek has never provided payments to any witnesses to secure

testimony against Drummond in any Alabama litigation.

12.

I have never conducted business on behalf of van Bilderbeek in Alabama.

13.

In the past, I have told van Bilderbeek that I would like to see Drummond shut

down. Van Bilderbeek took my statement jokingly amidst all frustrations of our lengthy cases
against Drummond. Van Bilderbeeks only goal is recovering the profits and royalties Llanos Oil
lost when the Colombian government cancelled its oil lease and transferred the rights under the
lease to Drummond.
I declare under penalty of perjury that the foregoing is true and correct to the best of my
knowledge and belief.
Executed on this the 8th day of December, 2016

By:_________________________________
Terrence P. Collingsworth