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concession area. See Yaiguaje, No. 10 CV 316 (LBS) (S.D.N.Y. Jan. 14,2010), Transcript of
Hearing, Mar. 10-11,2010. The Lago Agrio Plaintiffs have also intervened in Chevron's 28
U.S.C. § 1782 proceedings in this Court (and in other federal district courts) by filing various
motions and briefs as "interested parties." The Lago Agrio Plaintiffs' involvement in the 1782
proceedings in this Court caused Judge Kaplan to specifically find that "they [have] subjected
themselves to the personal jurisdiction of this Court." In re Application a/Chevron, 10 MC
00001 (LAK) (S.D.N.Y. July 22, 2010), 9/7/2010 Order at 23. There is a substantial nexus
between the Lago Agrio Plaintiffs' purposeful availment of the New York forum and Chevron's
claims under New York state law. For such claims, exercise of jurisdiction over the Lago Agrio
Plaintiffs is therefore proper pursuant to N.Y. C.P.L.R. 301-02.
A. Background
FACTUAL BASIS FOR CLAIMS
33. This Amended Complaint details how a group of U.S. plaintiffs' lawyers,
together with U.S. and Ecuadorian co-conspirators, set about fraudulently exploiting images of
environmental degradation in rural Ecuador to extort money from a U.S. company in a criminal
scheme. Many ofthe quotations included in this Amended Complaint were captured in video
footage in the making of Crude: The Real Price a/Oil, a film commissioned by the RICO
Defendants and their co-conspirators in furtherance of their criminal scheme. Others come
directly from the RICO Defendants' own emails, letters and other documents.
1. TexPet Participates in Ecuador's State Oil Consortium and Negotiates
Release From Liability in Return for Specified Remediation
34. In 1964, Ecuador granted oil exploration and production rights (known as a
"concession") in a designated part ofthe Oriente region of Ecuador to Texaco Petroleum
Company ("TexPet") and the Ecuadorian Gulf Oil Company ("Gulf'), which then formed what
came to be known as the consortium. Ecuador's state-owned oil company, Petroecuador
(formerly known as Corporaci6n Estatal Petro I era Ecuatoriana or CEPE), became a stakeholder
in the consortium in 1974 and, on December 31, 1976, it became the 62.5% majority stakeholder.
19