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should be concerned about the image of Chevron." At no point did Kohn explain that his co­
conspirators had actually ghostwritten Cabrera's supposedly independent report.
249. In the face of allegations that the RICO Defendants colluded with Cabrera, in a
press release issued by the Front on February 13,2009, Fajardo is quoted as saying that such
allegations were '''false and defamatory'" and claimed that it would '''expose Chevron
shareholders to additional liability. '" And in an April 2008 press release issued by the Amazon
Defense Front, Fajardo accused Chevron offailing to disclose to shareholders that Ecuador's
Attorney General had filed a formal complaint to the U.S. Department of Justice, and that "[t]his
is part of[a] conscious strategy to try to discredit a trial process that Chevron knows it is losing
because of the evidence." And as recently as December 21, 2010, the Front issued a press
release quoting Fajardo as saying, "Chevron's Board of Directors cannot continue to ignore the
mounting evidence of illegal activity and fraud on the part of the company's legal team in the
United States and in Ecuador. ... We intend to seek full redress of the harm that has been done
in the name of Chevron's shareholders and to hold accountable all individuals in Chevron who
have participated in this unlawful scheme."
250. The conspirators have also communicated directly with Chevron shareholders
and influential analysts on numerous occasions. On May 25,2009, Amazon Watch sent a letter
signed by Soltani to Chevron shareholders, asserting that Chevron had made "false, misleading,
or incomplete" filings with the SEC, and quoted analysts from Barclays and Potomac Research
stating that the litigation was hurting Chevron's stock price. As with most of the conspirators'
public statements since April 2008, the letter relied upon an "independent court damages
assessment," but did not disclose that the RICO Defendants and their co-conspirators themselves
had secretly written that "assessment."
251. Donziger and his co-conspirators have also personally lobbied analysts,
including in personal meetings, and made fraudulent misrepresentations with the intent that their
misrepresentations would be reported as fact by these analysts, and that these reports would
decrease Chevron's stock price. On May 11,2009, for example, Donziger and his co-
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