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including a declaration sworn under penalty of perjury, that falsely represent that Cabrera was an
independent expert and that otherwise misrepresent the relationship between Cabrera and the
RICO Defendants.
369. Defendant Yanza has committed numerous mail and wire fraud violations,
including those identified in Appendix B in which Yanza used or caused to be used the mail or
wires in furtherance of the RICO Defendants' scheme to defraud. Yanza has committed wire
fraud and engaged in money laundering by knowingly causing funds to be transported,
transmitted, or transferred from the United States to Selva Viva, the Front, and other parties with
the intent that such payments would fund the RICO Defendants' criminal activity. Yanza has
also engaged in extortion of Chevron and fraudulent conduct by participating in a campaign of
public attacks based on false and misleading statements about Chevron and the Lago Agrio
Litigation (including in a letter to the U.S. Trade Representative), by manufacturing and causing
to be manufactured false evidence, and by applying pressure to Ecuadorian government officials
to procure baseless criminal charges against Chevron's attorneys. In addition, Yanza has
engaged in obstruction of justice by filing or causing to be filed in multiple U.S. courts
documents, including declarations sworn to under penalty of perjury, that falsely represent that
Cabrera was an independent expert and that otherwise misrepresent the RICO Defendants'
interactions with Cabrera.
370. Defendant the Front, through the actions of its agents Defendants Fajardo
and Yanza, among others, has committed numerous predicate acts, including mail and wire
fraud, money laundering, and extortion. The mail and wire fraud violations include those
identified in Appendix B in which the Front used or caused to be used the mail or wires in
furtherance of the RICO Defendants' scheme to defraud. The Front has also committed several
wire fraud violations and multiple acts of money laundering by causing funds to be transferred
by Kohn and/or Kohn Swift from the United States to Ecuador, acting as a conduit of those
funds, and then distributing those funds to finance the RICO Defendants' illegal scheme. In
addition, the Front has engaged in numerous acts of extortion of Chevron and fraudulent conduct
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