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218. The RICO Defendants and their co-conspirators funnel a substantial portion of
their public attacks on Chevron through Amazon Watch, which presents itself to the public as an
independent organization. Donziger has explained the crucial role of this element of the pressure
campaign:
[They have] played an absolutely critical role in this. .. [I]f it weren't for them,
we would just be a legal case, but because of the work of people who care, you
know, especially Amazon Watch, we're a campaign that has a legal case. And I
think ... that, um, the pain Amazon Watch can cause Chevron in many respects is
greater than the pain we can cause ....
The RICO Defendants coordinate their efforts with Rainforest Action Network, whose "direct
action" campaigns Donziger describes as "[b ]rutally personal."
219. Amazon Watch dutifully plays its role, fully understanding that "the target of
many of the ... campaign releases is Chevron itself rather than the media" and working to "get
under Chevron management's skin" as much as possible. In a proposal seeking $1 million in
funding from the RICO Defendants and their co-conspirators, Amazon Watch described the
Lago Agrio Litigation as nothing less than a chance to "change how the oil industry operates,"
and offered to join what it saw as "an existing and well-developed campaign structure based in
the U.S." Amazon Watch described its goal as putting Chevron's management and board, "in a
position where, to survive intact in American society as a reputable company with a competitive
edge, they will be forced to settle the lawsuit." It then set forth how they would "threaten" the
"personal comfort levels" of Chevron management, who currently "live in the Bay Area with
impunity," how Chevron's directors "are particularly vulnerable to direct pressure and pressure
via secondary targets," and how Amazon Watch would create a "task force" that will be "a
constant and daily source of friction for Chevron[.]" Amazon Watch also prepared a visual
representation of their strategy, a chart describing various pressure tactics, including the use of
government agencies, all in a circle surrounding "Chevron."
220. Amazon Watch's proposal is in line with Donziger's strategy to "keep attacking,
keep pressure on, etc." Donziger has further explained his "cost-benefit" calculation of the
pressure campaign: "I also think that if you run ... the costs in terms of the hassle, the
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