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Report, procuring baseless criminal charges against Chevron's attorneys in Ecuador, colluding
with Ecuadorian officials and pressuring the Lago Agrio court to ensure a negative outcome for
Chevron in the Lago Agrio Litigation, and threatening and causing threats to be made to Chevron
directly and through its shareholders. In addition, the Law Offices of Steven R. Donziger and
Donziger & Associates, PLLC have engaged in obstruction of justice by filing and/or causing to
be filed in multiple U.S. courts documents, including declarations sworn under penalty of
perjury, falsely representing that Cabrera was an independent expert and otherwise
misrepresenting the RICO Defendants' interactions with Cabrera. Also, the Law Offices of
Steven R. Donziger and Donziger & Associates, PLLC have committed wire fraud and engaged
in money laundering by knowingly causing funds to be transported, transmitted, or transferred
from the United States to Selva Viva, Yanza, the Front, and other parties with the intent that such
payments would fund the RICO Defendants' criminal activity. The Law Offices of Steven R.
Donziger has also engaged in witness tampering through Donziger's knowing intimidation,
threats, misleading conduct, and corrupt persuasion toward Dr. Calmbacher with the specific
intent to influence, delay, and prevent Dr. Calmbacher's testimony in the Northern District of
Georgia. In addition, the Law Offices of Steven R. Donziger also tampered with the testimony
of Mark Quarles by paying him for his affidavit and by concealing the RICO Defendants'
involvement with Cabrera and the Cabrera Report.
368. Defendant Fajardo has committed numerous mail and wire fraud
violations, including those identified in Appendix B in which Fajardo used or caused to be used
the mail or wires in furtherance ofthe RICO Defendants' scheme to defraud. Fajardo has also
engaged in extortion of Chevron and fraudulent conduct by participating in a campaign of public
attacks based on false and misleading statements about Chevron and the Lago Agrio Litigation
(including in a letter to the U.S. Trade Representative), by manufacturing and causing to be
manufactured false evidence, and by applying pressure to Ecuadorian government officials to
procure baseless criminal charges against Chevron's attorneys. In addition, Fajardo has engaged
in obstruction of justice by filing or causing to be filed in numerous U.S. courts documents,
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