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"court-appointed expert" and that the RICO Defendants had played no part in creating the
exorbitant $27 billion figure. Their intention was to generate an official inquiry or investigation,
which would itself bring direct pressure on Chevron, and which the RICO Defendants could use
to reinforce their own pressure campaign. On May 4,2009, in reliance upon the RICO
Defendants' false statements, the New York Attorney General did just that, sending Chevron a
letter inquiring about Chevron's disclosures related to the Lago Agrio Litigation and requesting a
"written response" to several questions within a week. In the letter's first paragraph, the New
York Attorney General stated, "As I understand the allegations, a technical expert has estimated
that if the plaintiffs prevail in the litigation, damages assessed against Chevron may be as high as
$27 billion." The RICO Defendants seized on this outcome, referring to the letter in mUltiple
press releases as an "investigation." In a May 25, 2009 letter to Chevron shareholders ostensibly
from Atossa Soltani and other members of Amazon Watch, the conspirators claimed that "New
York State Attorney General Andrew Cuomo has opened a probe ofthe company," and
"Chevron is now the target of an official fraud investigation by the New York State Attorney
General." And, precisely as the RICO Defendants had intended, the New York Attorney
General's letter was noted in the press, and it generated media coverage suggesting that Chevron
had "mishandled" the matter. Industry publication Oilgram news stated that the campaign was
having the intended effect, reporting, in reference to the May 4 letter: "Analysts seem mixed on
what the Ecuador fallout ultimately may mean to Chevron but appear to agree there will be at
least a short-term knock to the stock price." It quoted an analyst with OppenheimerFunds, Inc.
stating, "I would settle and cut my losses."
d. The Conspirators Attempt to Manipulate Chevron's Stock
Price to Coerce a Favorable Settlement
246. To increase financial and public pressure on Chevron to pay off the RICO
Defendants through an extorted settlement of the Lago Agrio Litigation, the conspirators have
sought to manipulate and depress Chevron's stock price by targeting Chevron's shareholders,
potential investors, and stock analysts with their lies and half-truths. The objective, as expressed
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