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conspirators to take actions necessary to accomplish the overall aims of
the criminal enterprise-namely, manufacturing evidence of Chevron's
liability, procuring sham criminal charges against Chevron's attorneys,
conducting a massive public pressure campaign designed to spread false
and misleading information about Chevron and the Lago Agrio Litigation,
and obstructing Chevron's efforts at uncovering the truth in various U.S.
court proceedings.
b. Defendant Fajardo has been primarily responsible for prosecuting the
sham litigation in the Ecuadorian courts, has served as one of the heads of
the criminal enterprise in the U.S. and Ecuadorian media, and has planned
and coordinated the ghostwriting of the Cabrera Report.
c. Defendants Yanza and the Front have been primarily responsible for
managing the RICO Defendants' "private army," exerting influence over
and colluding with Ecuadorian government and court officials, and serving
as media representatives for the criminal enterprise in which they have
made false statements to Chevron stockholders, financial analysts,
investors, and/or state and federal agencies. Yanza arranged for funding
from Kohn and/or Kohn Swift for the RICO Defendants' activities in
Ecuador, and frequently caused money to be transferred out of the United
States for this purpose.
d. Defendant Selva Viva has served as a conduit for funding and otherwise
furthering the RICO Defendants' criminal enterprise.
e. Defendants Stratus, Beltman, and Maest have been responsible for
coordinating the drafting of and actually ghostwriting the Cabrera Report
and other submissions to the Lago Agrio court, and for the false promotion
ofthe Cabrera Report as independent in the media and to U.S. courts.
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