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tactic." Increasing the pressure involves maximizing publicity, and Donziger always "does his
best to arrange a good show."
216. To that end, Donziger recruited Karen Hinton, a public relations specialist, to
create and manage the RICO Defendants' and their co-conspirators' campaign of false and
misleading public statements, and to coordinate the efforts to co-opt the media and well-meaning
private citizens in the conspirators' pressure campaign. Stratus contributed to the effort as well,
developing what Stratus referred to as a "comprehensive press kit." And political and
communications consultant Chris Lehane was brought on board to help the RICO Defendants
"leverage the criminal investigation of the Chevron executives" through extensive public
relations efforts. In addition to recruiting reporters to cover the story, Lehane and the
conspirators planned to "[b ]uild[] off the initial activity, we will want to consider several
targeted specific mini-campaigns all designed to create pressure points on Chevron's
economics." These "mini-campaigns" included filing a shareholder lawsuit against Chevron "for
failure to disclose information," contacting the New York Attorney General "to see whether we
can get Spitzer into the game," and manipulating students at a "major university that is invested
in Chevron for a divestment campaign." In an email about hiring a new team member in
Ecuador, Donziger described the ideal candidate as someone who would "raise some hell in
Ecuador," and that the "job entails f1**]king up every machine you see that has
ChevronTexaco's name on it. ... Being able to manufacture reality a plus."
217. The conspirators also maintain relationships, in part through the provision of
financial support, with various organizations that distribute false and misleading public
statements to increase the public pressure on Chevron. Some of these organizations are
dedicated to the fraud while others have broader functions, but all are knowing or unknowing
accomplices ofthe RICO Defendants and their co-conspirators. Foremost among these are
Amazon Watch, RAN, and Defendant the Front, organizations that knowingly operate and
control significant aspects of the pressure campaign and overarching conspiracy to extort a
payment from Chevron.
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