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damages has had its desired effect on Chevron's share price: "The possibility that ajudge may
later this year demand damages as high as $27.5 billion, roughly one-fifth of Chevron's market
capitalization, appears to have spooked some investors."
257. The Front and Hinton have touted negative analyst reports regarding Chevron on
the website, chevrontoxico.com. For example, on May 26,2009, the conspirators published an
article stating that "Oppenheimer, in a report dated May 4th [2009], said the $27 billion claim
from Ecuador' could depress the stock until a settlement is reached ... the sooner [the case] is
removed, the better off shareholders will be'" and that "Barclay's called the Ecuador case a
'drag' on Chevron's stock value."
258. And on August 24,2010, FOXBusiness reported that, "the oil company has lost
much of its gains over the past few weeks as it continues to fight a lawsuit in Ecuador that
alleges Texaco, acquired by Chevron in 2001, wrecked portions of a jungle while drilling for oil
in the 1970s and 1980s." The conspirators published this article in its entirety the next day at the
chevronpit.blogspot.com.
259. Above all, however, the RICO Defendants' and their co-conspirators' false
statements, harassing conduct, and lobbying efforts with media, government, shareholders and
private individuals are all aimed at one ultimate objective-forcing Chevron to pay the RICO
Defendants and their co-conspirators billions of dollars to make them stop.
e. The RICO Defendants Falsely Accuse Chevron of Murder to
Generate Outrage and Force Chevron to Pay
260. The conspirators have made numerous public statements stating or implying that
Chevron is guilty of murder. This claim is false and has been made intentionally and without
any basis whatsoever. The RICO Defendants and their co-conspirators' intent in spreading this
lie is to generate great outrage and disgust among the public and activists and in the media, all in
furtherance of their extortionate conspiracy.
261. Defendant Fajardo and his co-conspirators have attempted to capitalize on the
violent murder of Fajardo's brother, Wilson Fajardo. They have repeatedly implied that Chevron
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