hRb7u

Chevron, working closely with the other RICO Defendants in this action. For Chevron's claims
for violations of 18 U .S.C. § 1962 and New York state law, exercise of jurisdiction over
Donziger is proper pursuant to 18 U.S.C. § 1965(a) and N.Y. C.P.L.R. 301.
26. Exercise of jurisdiction over the Law Offices of Steven R. Donziger and
Donziger & Associates, PLLC is reasonable and proper in this District because the Law Offices
of Steven R. Donziger and Donziger & Associates, PLLC are citizens of New York, and because
they conduct extensive business activities in the State. Further, by and through the activities of
Donziger described above, the Law Offices of Steven R. Donziger and Donziger & Associates
PLLC have served as key players in the conspiracy against Chevron. For Chevron's claims for
violations of 18 U .S.C. § 1962 and New York state law, exercise of jurisdiction over the Law
Offices of Steven R. Donziger and Donziger & Associates, PLLC is proper pursuant to 18 U .S.c.
§ 1965(a) and N.Y. C.P.L.R. 301.
27. Defendants Stratus, Beltman, and Maest are all residents of the United States.
For Chevron's claims for violations of 18 u.s.c. § 1962, the exercise of jurisdiction over each of
these defendants is proper in this District pursuant to 18 U.S.C. § 1965(b). The ends of justice
require application of the nationwide service provisions of 18 U.S.c. § 1965(b) because there is
no district in which all of the RICO Defendants could otherwise be tried together. For Chevron's
claims under New York state law, exercise of jurisdiction over Defendants Stratus, Beitman, and
Maest is proper pursuant to N.Y. C.P.L.R. 301 and 302. Through their agents and co­
conspirators, Defendants Stratus, Beltman, and Maest have transacted and continue to transact
business in the State of New York, and there is a substantial nexus between Defendants Stratus,
Beltman, and Maest's purposeful availment of the New York forum and Chevron's claims.
28. Exercise of jurisdiction over Fajardo is proper pursuant to 18 U .S.c. § 1965(b)
and N.Y. C.P.L.R. 301 and 302. Fajardo has transacted business and engaged in tortious conduct
in the United States and New York which gives rise in part to Chevron's claims. Among other
things, Fajardo (i) met with his co-conspirators in the United States multiple times to plan the
ghostwriting of the Cabrera Report, including trips to New York to meet with Donziger and to
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