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corrective action. Further, the RICO Defendants' false and misleading statements have caused
Chevron substantial damages.
Pattern of Racketeering Activity: Money Laundering in Violation 0[18 u.s. C.
§ 1956(a)(2){A)
358. Defendants Yanza, Donziger, the Law Offices of Steven R. Donziger, and
Donziger & Associates, PLLC, have on multiple occasions, acting in their individual capacities
and as agents for Selva Viva and/or the Front have knowingly caused the transportation,
transmission, and/or transfer offunds to or from the United States to themselves and to
Defendants Selva Viva, the Front, and other entities with the intent that those funds be used to
promote the carrying on of unlawful activity, including but not limited to violations of 18 U.S.c.
§§ 1341, 1343 and 1951, such as the secret preparation of the Cabrera Report, payment to
Cabrera for his complicity and silence as to the report's authorship, the funding of the RICO
Defendants' pressure campaigns against the Lago Agrio court and against Chevron, and
collusion with the Republic of Ecuador.
Pattern of Racketeering Activity: Obstruction of Justice in Violation 0[18 u.s. C. § 1503
359. Faced with implacable denials in Ecuador from Cabrera and the RICO
Defendants about the authorship of the Cabrera Report, Chevron turned to U.S. courts to pursue
discovery directly from the Enterprise through proceedings under 28 U.S.c. § 1782, which
authorizes "[t]he district court of the district in which a person resides or is found [to] order him
to give his testimony or statement or to produce a document or other thing for use in a
proceeding in a foreign or international tribunal."
360. In a concerted effort to thwart Chevron's attempts to uncover the truth and
avoid discovery, the RICO Defendants, and their counsel, have habitually filed or caused to be
filed documents, including declarations sworn to under penalty of perjury, that falsely represent
that Cabrera was an independent expert and that otherwise misrepresent the RICO Defendants'
interactions with Cabrera. They have done so with the full knowledge that these statements were
false, as evidenced by their own internal correspondence. By making these deliberate and
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