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242. The RICO Defendants and their co-conspirators have made these same false
statements to other federal agencies. In a letter dated April 29, 2008, to the U.S. Trade
Representative, Defendants Yanza and Fajardo called Cabrera "an independent court-appointed
special master," and misstated that "the bulk of the evidence relied on by the special master,
Professor Richard Cabrera, was provided by Chevron itself via its own sampling evidence."
243. And in April 2009, Donziger made false statements concerning Cabrera's
purported "independence" in a statement before the U.S. House of Representatives. Donziger
falsely stated that "[t]he best and most recent independent estimate available of the human health
impact of this contamination is provided by the expert appointed by the court, Richard Cabrera."
(emphasis added). Donziger also testified that "[n]umerous qualified scientists have reviewed
this report and found its conclusions reasonable and the damages assessment consistent with the
costs of other large environmental cleanups." At no time did Donziger disclose the fact that the
"qualified scientists" were his co-conspirators Stratus, Beltman, Maest, and Chapman, who
planned and secretly wrote the "Cabrera" Report.
244. The RICO Defendants have also made false statements to individual members of
Congress. On December 19, 2008, Defendant Beltman provided United States Congressman Jim
McGovern's office "some talking points" for an interview with the Los Angeles Times, falsely
telling the Congressman's staff that "[t]he Court Expert reviewed available scientific data and
concluded that people in the area suffer from many illnesses caused by the contamination,
including cancer." On January 31,2009, Beltman forwarded Cabrera's reports, stating "[t]he
Court Expert's March 2008 report summary is attached," and that "[ a] Iso attached is the
November 2008 response to the [Lago Agrio] Plaintiffs questions that was written by the Court
Expert." Beltman failed to disclose that Stratus and the other RICO Defendants actually
ghostwrote the responses to the Lago Agrio Plaintiffs along with Cabrera's initial report.
245. In addition, the RICO Defendants have extended their campaign to state officials.
In 2009, the RICO Defendants made fraudulent allegations about Chevron to the New York
Attorney General, and provided that office with false information that Cabrera was a neutral
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