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y participating in a campaign of public attacks based on false and misleading statements about
Chevron and the Lago Agrio Litigation through a website the Front maintains as well as
numerous press releases and by manufacturing and causing to be manufactured false evidence.
371. Defendant Selva Viva, through the actions of its agents Defendants Yanza
and Donziger, among others, has 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. Through the actions of its agents Defendants
Yanza and Donziger, among others, Selva Viva has also engaged in numerous acts of extortion
of Chevron and fraudulent conduct by manufacturing and causing to be manufactured false
evidence.
372. Defendant Stratus, through the actions of its agents Defendants Beltman,
Maest, and other individuals, has committed numerous predicate acts, including mail and wire
fraud, extortion, obstruction of justice, and witness tampering. The mail and wire fraud
violations include those identified in Appendix B in which Stratus used or caused to be used the
mail or wires in furtherance ofthe RICO Defendants' scheme to defraud. Stratus also has
engaged in extortion of Chevron and fraudulent conduct by manufacturing false evidence, in the
form of the Cabrera Report and its annexes, used extensively by the RICO Defendants in the
Lago Agrio Litigation and more generally in furtherance of their illegal scheme. In addition,
Stratus has engaged in extortion and fraudulent conduct by disseminating false statements about
Chevron through its authorship of the Cabrera Report and through its later "evaluation" of that
report. Stratus also has engaged in extortion and fraudulent conduct by participating in a
campaign of public attacks based on false and misleading statements about Chevron and the
Lago Agrio Litigation. Finally, Stratus has engaged in obstruction of justice by misrepresenting
to the United States District Court for the District of Colorado that Cabrera was an independent
expert, that it was "astonished" to see "similarities" between its own work product and the
Cabrera Report when Stratus actually drafted the majority of the Cabrera Report, and otherwise
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