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management time, reputational ... [h]arm, dealing with the board, looking bad, having your kids
... in school, have friends who say, hey, what'd your daddy do in Ecuador? .... I think all of
that factors into it in an af-extremely significant way, much more than th-the hard-core costs,
... out-of-pocket expenses and stuff-I think that's where they're most vulnerable."
221. The RICO Defendants rely on Amazon Watch to carry out many of the public
attacks against Chevron, and the RICO Defendants closely monitor, frequently revise, and
sometimes entirely ghostwrite, the press releases and letters that Amazon Watch issues. When
an Amazon Watch representative complained to Donziger that Amazon Watch was "not here to
simply rubber-stamp press releases," and dared to tell him that prior experience showed that
Amazon Watch "needs to carefully fact-check your press releases in order to safeguard our own
credibility," Donziger replied sharply. He stated that he and the other lawyers were "the final
authority," and that, "We can be collaborators, but we are not equal partners." The issue that set
off Donziger's tirade is particularly telling: Amazon Watch had wanted to provide Cabrera's
educational credentials in a press release about him. Donziger's response: "The issue about
Cabrera's qualifications is a good example. He doesn't have a doctorate. I don't want to
highlight that. So I don't mention what degree he has in the press release. Obviously ifhe had a
doctorate it would be in there, don't u think?" In response, the Amazon Watch representative
called Donziger's tactic an "unsubtle and unnecessary obfuscation" and "[b ]ombast and
hoodwink."
222. By using Amazon Watch as their proxy, the RICO Defendants and their co-
conspirators can also deliver their extortionate threats to Chevron using more direct language
than they are willing to use themselves-at least publicly. In "turn[ing] up the heat on Chevron,"
the RICO Defendants and their co-conspirators have made their extortionate demands explicit in
direct communications with Chevron. For example, on December 17, 2009, Soltani wrote a
letter "on behalf of Amazon Watch" to then-incoming Chief Executive Officer John Watson in
which she cited the fraudulent $27 billion damages assessment from the Cabrera Report, and
threatened, "Until Chevron takes meaningful steps to resolve this case, it will continue to play
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