hLpb5

misrepresenting the relationship between Cabrera and the RICO Defendants. Finally, Stratus has
engaged in witness tampering by repeatedly and intentionally misleading numerous of its
employees regarding Cabrera's independence, and omitting facts about its true role in drafting
the Cabrera Report, with the intent that its employees would then fail to testify truthfully if called
to testify as to these subjects.
373. Defendant Beltman has committed numerous mail and wire fraud
violations, including those identified in Appendix B in which Beltman used or caused to be used
the mail or wires in furtherance of the RICO Defendants' scheme to defraud. Beltman also has
engaged in extortion of Chevron and fraudulent conduct by manufacturing false evidence, in the
form of the Cabrera Report and its annexes, used extensively by the RICO Defendants in the
Lago Agrio Litigation and more generally in furtherance of their illegal scheme. In addition,
Beltman has engaged in extortion and fraudulent conduct by disseminating false statements
about Chevron through his role in drafting both the Cabrera Report and his later "evaluation" of
that report. Beltman also has engaged in extortion of Chevron and fraudulent conduct by
disseminating and causing to be disseminated false statements to the public and to a member of
Congress regarding Chevron, the Lago Agrio Litigation, and Cabrera's independence. Beltman
also engaged in obstruction of justice by causing misrepresentations to be made to the United
States District Court for the District of Colorado that Cabrera was an independent expert, that
Stratus was "astonished" to see "similarities" between its own work product and the Cabrera
Report when it actually drafted the majority of the Cabrera Report, and otherwise
misrepresenting the relationship between Cabrera and the RICO Defendants. Finally, Beltman
has engaged in witness tampering by repeatedly and intentionally misleading numerous Stratus
employees regarding Cabrera's independence, and omitting facts about Stratus's true role in
drafting the Cabrera Report, with the intent that its employees would then fail to testify truthfully
if called to testify as to these subjects.
374. Defendant Maest has committed numerous mail and wire fraud violations,
including those identified in Appendix B in which Maest used or caused to be used the mail or
149