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Plaintiff
PARTIES AND RELEV ANT NON-PARTIES
6. Plaintiff Chevron Corporation ("Chevron") is a Delaware corporation with its
principal place of business located at 6001 Bollinger Canyon Road, San Ramon, California
94583. Chevron is therefore a citizen of Delaware and California.
RICO Defendants
7. The defendants listed in paragraphs 8 through 17 are the individuals who have
conspired to engage in a pattern of racketeering activity, have each committed numerous
criminal acts as part of their scheme to defraud and extort Chevron, and have each participated in
the operation or management of the criminal enterprise. These defendants shall be referred to
herein as the "RICO Defendants."
8. Defendant Steven Donziger ("Donziger") is currently a "consulting" attorney for
the Amazon Defense Front in the Lago Agrio Litigation and, as he described himself, "the
person primarily responsible for putting [the Lago Agrio] team together and supervising it."
Donziger is an individual residing in New York, New York, with an intention to reside there
indefinitely, and is therefore a citizen of the State of New York. Exercise of jurisdiction over
Donziger is reasonable and proper in this District for the reasons set forth in paragraph 25, infra.
9. Defendant the Law Offices of Steven R. Donziger is a sole proprietorship
located at 245 W. 104th Street, #70, New York, New York 10025, and is therefore a citizen of
the State of New York. Exercise of jurisdiction over the Law Offices of Steven R. Donziger is
reasonable and proper in this District for the reasons set forth in paragraph 26, infra.
10. Defendant Donziger & Associates, PLLC is a professional limited liability
corporation located at 245 W. 104th Street, #70, New York, New York 10025, and is therefore a
citizen of the State of New York. Exercise of jurisdiction over Donziger & Associates, PLLC is
reasonable and proper in this District for the reasons set forth in paragraph 26, infra.
II. Defendant Pablo Fajardo Mendoza ("Fajardo") is counsel of record for the
Amazon Defense Front as well as purportedly counsel of record for the named plaintiffs in the
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