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and misleading statements as part of the RICO Defendants' extortionate scheme.
Kohn and Kohn Swift are significant financial supporters of Amazon Watch.
g. Atossa Soltani ("Soltani") is the founder and executive director of Amazon Watch
and, in that capacity, Soltani repeatedly distributed false and misleading
statements about Chevron and the Lago Agrio Litigation as part of the RICO
Defendants' extortionate scheme. She has also worked with Donziger, Yanza and
other RICO Defendants to coordinate the public pressure campaign against
Chevron, and to develop the RICO Defendants' strategy of manipulating the Lago
Agrio court through intimidation and collusion with the Republic of Ecuador.
Soltani is a resident of California.
h. Rainforest Action Network ("RAN") is a "non-profit" organization with its main
office at 221 Pine Street, San Francisco, California 94104. The organization
specializes in boycotts, demonstrations, and other high-profile means of exerting
pressure on corporations that it perceives threaten the world's rainforests. In
close concert with Amazon Watch (with which it shares a headquarters location),
RAN has organized demonstrations and boycotts against Chevron and distributed
false and misleading statements about Chevron and the Lago Agrio Litigation.
RAN also maintains at least one of the websites, changechevron.org, through
which the RICO Defendants distribute false and misleading statements.
i. Richard Stalin Cabrera Vega ("Cabrera") is a mining engineer and court expert in
the Lago Agrio Litigation and a resident of Ecuador. The RICO Defendants
secured his appointment as a purportedly independent court expert in the Lago
Agrio Litigation. He was paid by the RICO Defendants and their co-conspirators
for his cooperation in signing a fraudulent report ghostwritten by the RICO
Defendants and their co-conspirators and he has repeatedly misrepresented his
independence.
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