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out in the courts of Ecuador, as well as in the global court of opinion." She went on to state,
"We don't make these suggestions lightly or symbolically."
223. The RICO Defendants and their co-conspirators use all available means to
publish their lies and half-truths in the "global court of opinion." They regularly disseminate
press releases over the Internet, through electronic mail, and on newswires. They appear on
television and radio broadcasts. Through various organizations they fund, the conspirators
operate or cause to be operated websites that attack Chevron at www.chevrontoxico.com.
www.texacotoxico.org, www.amazonwatch.org, www.chevroninecuador.com,
truecostofchevron.com, thechevronpit.blogspot.com, and www.changechevron.org. The
conspirators also promote their scheme through social media tools, sending messages to
supporters through Twitter (@changechevron) and Facebook, and by posting defamatory
comments and false statements (frequently using pseudonyms) in response to articles written on
the websites of newspapers, blogs and other commentators. They have helped fund at least one
book of photography and a documentary film, promoting misleading images of environmental
impact and poveliy. And the conspirators' attacks on Chevron have not been limited to words
and pictures: They have arranged or threatened marches and demonstrations at Chevron
shareholder meetings, places of business, and in front of the homes of individual Chevron
employees and board members.
224. The RICO Defendants' false statements are made in support of appeals for
funding, including through a link to make payments directly on their websites, at
http://chevrontoxico.com/take-action/donate.html and at
https://www.gifttool.com/donations/Donate?ID=38&VER=I& LNG=EN (via a link from
http://www.amazonwatch.org). Again, however, the RICO Defendants are careful to use the
supposedly independent Amazon Watch as a front for their efforts. At chevrontoxico.com, the
statements soliciting donations by mail request that they be sent to Amazon Watch at its address
in San Francisco, California. Kohn and Kohn Swift have made substantial donations to Amazon
Watch. In 2009, for example, Kohn reported that Kohn Swift had contributed over $184,000 to
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