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job." And when the RICO Defendants heard that the Republic of Ecuador might be considering
negotiating with Chevron directly, they pushed to have those conversations shut down, urging
that no "representative ofthe Ecuadorian government ... meet face to face with a representative
of Chevron at this j uncture[.]"
67. The Lago Agrio complaint does not name the entity that has been responsible for
environmental harm in the Oriente region since at least 1992: Petroecuador. Pursuant to their
agreement not to bring any claims against Petroecuador or the Republic of Ecuador itself, the
Lago Agrio Plaintiffs' U.S. representatives caused Chevron to be named as the only defendant in
the Lago Agrio Litigation, despite the fact that Chevron has never operated in Ecuador. (Years
after TexPet ceased operations in Ecuador, one of Chevron's subsidiaries merged with Texaco,
TexPet's ultimate parent company. Chevron thereby became an indirect shareholder ofTexPet.)
B. The Conspirators Are Corrupting the Judicial Process to Extort a Payment
From Chevron
68. The support of the Republic of Ecuador, the manipulation of the EMA, and the
filing of the Lago Agrio Litigation provided the U.S. lawyers with the foundation for their
criminal scheme. Through the conduct oftheir criminal enterprise, the conspirators set about to
manufacture false evidence and a fake "history" that they would repeat in every media outlet,
before Congress, in front of state and federal investigative and administrative agencies, and with
which they would seek to scare and mislead Chevron shareholders and investors. All of this was
done in furtherance oftheir scheme to coerce Chevron into making a massive payoff to the
criminal enterprise. As part ofthis scheme, the conspirators keep "jack[ing] up," in Donziger's
words, their demand. In 2003, they thought $6 billion was an aggressive number. In 2008, they
raised the stakes to $16 billion, then to $27 billion, and finally, to an outrageous $113 billion,
before ultimately obtaining an $18.2 billion judgment in Lago Agrio.
69. The RI CO Defendants' criminal scheme has three main lines of attack: One,
intimidate or corrupt the Lago Agrio court and obtain a fraudulent judgment against Chevron
based on manufactured evidence of liability. Two, collude with the Republic of Ecuador to
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