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237. The RICO Defendants' and their co-conspirators' deception of the national and
international media has gone beyond prompting the republication of lies about Cabrera's
independence. For example, Defendants Fajardo and Yanza were awarded the Goldman
Environmental Prize, "the world's largest prize program for grassroots environmental activists,"
and Fajardo was awarded the CNN "Heroes" award. The press release announcing the Goldman
Prize echoed the RICO Defendants' misstatements and half-truths, including those regarding
Cabrera's independence.
c. The RICO Defendants Make False Statements to U.S. State
and Federal Government Officials
238. The conspirators have sought to open as many fronts as possible in their
offensive against Chevron, pursuant to their strategy to generate maximum pressure on Chevron
to drive it into a coerced settlement. The RICO Defendants and their collaborators have made
false and misleading statements in the United States to state and federal officials, seeking to
enlist their (unknowing) aid in the fraudulent scheme through investigations and other official
acts. Since 2008, the RICO Defendants have continuously touted the findings in the so-called
"independent" Cabrera Report as evidence in support of their demands for official action.
239. The conspirators have engaged in a long-running campaign to convince the SEC
to investigate Chevron for allegedly violating disclosure obligations. They have attempted to
obscure their role in this campaign by using Amazon Watch as their front, but Donziger has
admitted that he wrote several of the letters which purportedly came from Amazon Watch. On
January 30, 2006, at the RICO Defendants' behest, Amazon Watch wrote Christopher Cox, then
Chairman of the SEC, requesting that he "open an investigation into the Chevron Corporation
(CVX) for violating SEC regulations governing disclosure obligations to shareholders in
reference to litigation against the company over an oil-related environmental catastrophe in
Ecuador." Relying on David Russell's $6 billion damages assessment (which he had already
disavowed), Amazon Watch accused Chevron offailing to inform its shareholders of its
"staggering potential liability." The letter went on to mischaracterize the lawsuit as a "class
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