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y Donziger, was to cause a "mass sell-off of billions in [Chevron] stock." In furtherance of
their scheme, the conspirators have staged protests at Chevron's shareholder meetings and at the
homes of members of Chevron's Board of Directors, and have issued false and misleading
propaganda to Chevron's shareholders about its liability in the Lago Agrio Litigation. In each
instance, they have argued that the $27 billion damages assessment is independent and
legitimate, and thus represents a major risk to Chevron's share value. Donziger described these
pressure tactics on shareholders as one of the "key cards we can play."
247. The RICO Defendants' strategy of targeting Chevron's shareholders is stated in
their public comments and on the websites they operate, which contain material aimed directly at
investors. At the website changechevron.org/for-investors, operated by co-conspirator RAN, the
conspirators claim "Chevron's current brand of operations exposes the company (and its
investors) to great financial, reputational, and environmental risks." In reference to the damages
assessed in Cabrera's repoli, the conspirators refer to "staggering liabilities," and suggest that
Chevron has not "adequately warned shareholders about the financial risks the company faces in
the Ecuador lawsuit." The conspirators describe these activities on their website: "To pressure
Chevron to do the right thing in Ecuador, we engage in a variety of tactics. In the past few years
we have ... [a]lerted Chevron's shareholders to the company's lies and omissions regarding the
case in Ecuador, a case in which a ruling against Chevron would dramatically threaten the value
of those shareholders' investments." And in August 2008, Donziger commissioned a detailed
analysis of "various options for a more proactive and engaged strategy to put pressure on
Chevron via public markets."
248. For example, shortly after Cabrera filed his initial report, on or about May 31,
2008, Kohn appeared on a Fox News segment touting the "independent" Cabrera Report as a
reason for Chevron shareholders to be concerned. [n that interview, Kohn insinuated that
Chevron was hiding information regarding Cabrera's "independent" damage assessment, stating
"shareholders were [recently] informed for the first time of even the existence of the case
although the original case was filed in the u.s. in the 90s." He then warned that "shareholders
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