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conspirators met in New York with the Managing Director of Oil & Gas Equity research at UBS,
and provided him with copies of the Cuomo letter, the Cabrera report and supplemental report,
and the fraudulent "review" of that report by Stratus, all intended to convey the impression that
Cabrera's report was independent and valid. Also involved in this effort was co-conspirator
Daniel Orlow, described by the RICO Defendants as "an investment advisor who works with the
legal team that represents the Amazonian communities," who made repeated public statements
shortly after the UBS meeting on behalf of the RICO Defendants such as: "The pressure is
increasing on Chevron's management over the uncertainty surrounding a very significant
potential environmental liability in Ecuador," and "Our team is being contacted repeatedly by
shareholders and analysts who are concerned that Chevron management is not fully and honestly
disclosing the company's exposure in Ecuador .... There is a real concern that Chevron is not
playing it straight and that it might have overpaid for Texaco."
252. In another effort to influence Chevron's share price, the conspirators have
instituted a "Buy Freeze" campaign in which they have contacted investors directly and, relying
on false and misleading statements about the results of the site inspections and the criminal
prosecutions and government inquiries that the conspirators have instigated, urged the investors
not to buy Chevron stock. Amazon Watch describes the campaign as follows:
Amazon Watch is contacting institutional and individual shareholders - in
particular, socially responsible investment community (SRls) and public
employees, teachers and university pension funds to urge them to join the buy
freeze. The trial court in Lago Agrio, Ecuador, has found shocking levels of lifethreatening
toxins at dozens of former Chevron production sites in Ecuador ....
Now Chevron is being accused of fraud in Ecuador for lying about the results of a
limited remediation it did in the mid-1990s ....
As a result, Ecuador's Attorney General has asked the U.S. Department of Justice
to investigate Chevron's alleged fraud. The Securities and Exchange Commission
already is probing the company for failing to disclose the potential liability to
shareholders.
Amazon Watch concealed the fact that it was the RICO Defendants and their co-conspirators
who actually wrote the Ecuadorian Attorney General's report.
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