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wires in furtherance of the RICO Defendants' scheme to defraud. Maest also has engaged in
extortion of Chevron and fraudulent conduct by manufacturing false evidence, in the form ofthe
Cabrera Report and its annexes, used extensively by the RICO Defendants in the Lago Agrio
Litigation and more generally in furtherance of their illegal scheme. In addition, Maest has
engaged in extortion and fraudulent conduct by disseminating false statements about Chevron
through her role in drafting both the Cabrera Report and Cabrera's later "evaluation" of that
report. Maest also has engaged in extortion of Chevron and fraudulent conduct by disseminating
and causing to be disseminated false statements to the public regarding Chevron, the Lago Agrio
Litigation, and Cabrera's independence. Finally, Maest has engaged in obstruction of justice by
causing misrepresentations to be made to the United States District Court for the District of
Colorado that Cabrera was an independent expert, that Stratus was "astonished" to see
"similarities" between its own work product and the Cabrera Report when it actually drafted the
majority of the Cabrera Report, and otherwise misrepresenting the relationship between Cabrera
and the RICO Defendants.
375. Each of the RICO Defendants has engaged in multiple predicate acts, as described
in paragraphs 366-74, supra. The conduct of each of the RICO Defendants described in
paragraphs 345-74, supra, constitutes a pattern of racketeering activity within the meaning of 18
U.S.c. § 1961(5).
376. Chevron was injured in its business and property by reason of the RICO
Defendants' violations of 18 U.S.c. § 1962(c). The injuries to Chevron caused by reason of the
violations of 18 U.S.c. § 1962(c) include but are not limited to damage to Chevron's reputation
and goodwill; the impairment of Chevron's interest in executed contracts, including the 1995
Settlement Agreement and 1998 Final Release; and the attorneys' fees and costs to defend itself
in objectively baseless, improperly motivated sham litigation in Ecuador and in related litigation
in the U.S., including the attorneys' fees and costs associated with exposing the RICO
Defendants' pervasive fraud in the Section 1782 proceedings.
150