jjR0b

350. The RICO Defendants' actions are intended to induce fear in Chevron that
the RICO Defendants will, among other things: (1) continue to pursue a scheme of
misrepresentation to the great harm and public denigration of Chevron, unless and until Chevron
"settles" the Lago Agrio Litigation; (2) continue to conspire with Ecuadorian officials to have
Chevron's attorneys criminally prosecuted on trumped up charges; and (3) secure a fraudulent
multi-billion dollar judgment against Chevron and file lawsuits in the United States and in other
foreign jurisdictions seeking recognition and enforcement of the judgment. These actions, as
described herein, have created a reasonable fear of harm on the part of Chevron, including fear of
economic loss.
351. Accordingly, the RICO Defendants have unlawfully obstructed, delayed,
and affected-and attempted to obstruct, delay, and affect-commerce as that term is defined in
18 U .S.C. § 1951, and the movement of articles and commodities in such commerce, by
extortion, as that term is defined in § 1951, in that the RICO Defendants attempted to induce
Chevron to consent to relinquish property through the wrongful use of actual and threatened
force, violence, and fear-including fear of economic harm.
Pattern of Racketeering Activity: Extortion in Violation of New York Penal Law
§§JJO.OO.155.05(2)(e),155.42
352. Similarly, the RICO Defendants' wrongful attempts to appropriate
Chevron's property by instilling fear that ifthe property is not delivered the RICO Defendants
would perform an act calculated to harm Chevron materially with respect to its business,
financial condition, and reputation violates New York Penal Law §§ 110.00, 155.05(2)(e),
155.42.
Pattern o[RacketeeringActivity: Multiple Instances o[Mail Fraud and Wire Fraud in
Violation o(J8 u.s.c. §§ 1341,1343
353. As described herein, the RICO Defendants engaged in a wide-ranging
scheme or artifice to defraud Chevron, various courts of law, and the greater public concerning
Chevron's purported liability for environmental harm in Ecuador by manufacturing evidence,
colluding with the court expert Cabrera to submit the RICO Defendants' manufactured evidence,
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