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253. The conspirators have also staged protests at several of Chevron's annual
shareholder meetings. As shown in the film Crude, these protests, while designed to appear to
be grassroots, community events, are actually carefully planned and literally scripted by
Donziger and his co-conspirators.
254. In addition, the conspirators have lobbied large institutional investors to support
Chevron shareholder resolutions designed to bring support for the conspirators' lies and to add
additional pressure on Chevron. For example, Stratus and Amazon Watch were involved in
drafting a 2009 shareholder resolution, offered by the Office of the Comptroller of New York
City as the custodian and trustee of certain pension funds. On December 1, 2008, Mitchell
Anderson of Amazon Watch emailed Beltman of Stratus with the subject line "2009 Shareholder
Resolution - Urgent Update" and stated that "[ w]e need to make some changes quickly to the
below paragraph, given the new figures released by the cOUli appointed expert." Beltman
provided the higher numbers from Cabrera's revised report, which were then included verbatim
in the shareholder resolution proposed by the funds the next day. That resolution provides that a
"court-appointed expert in the Ecuadorian litigation has recommended that Chevron be held
liable for up to $27.3 billion in damages," but fails to explain that Stratus and the other RICO
Defendants and their co-conspirators secretly drafted the "court-appointed expert's" report
fInding Chevron liable.
255. The conspirators have promoted their involvement in drafting shareholder
resolutions that seek to draw attention to Cabrera's finding of liability, but, again, without
disclosing the RICO Defendants' and their co-conspirators' roles in drafting his report. For
example, on April 8, 2009, after the SEC declined to issue a no-action letter to Chevron
regarding one of the conspirators' shareholder resolutions, Hinton and Amazon Watch issued a
press release describing the resolution as, "a high-profile resolution that threatens to focus
attention on the company's record-breaking $27 billion environmental liability in Ecuador."
256. The Wall Street Journal has reported that the RICO Defendants' statements
about the Lago Agrio Litigation, and, specifically, Cabrera's assessment of $27 billion in
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