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CLAIMS FOR RELIEF
FIRST CLAIM FOR RELIEF
(Violations of RICO, 18 U.S.c. § 1962(c))
(Against All RICO Defendants)
339. Chevron realleges and incorporates herein by reference each and every foregoing
paragraph of this Amended Complaint as if set forth in full.
340. At all relevant times, Chevron is a person within the meaning of 18 U.S.C.
§§ 1961(3) and 1962(c).
341. At all relevant times, each RICO Defendant is a person within the meaning of 18
U.S.C. §§ 1961(3) and 1962(c).
The RICO Enterprise
342. The RICO Defendants and their co-conspirators are a group of persons associated
together in fact for the common purpose of carrying out an ongoing criminal enterprise, as
described in the foregoing paragraphs of this Amended Complaint; namely, through a multi­
faceted campaign of lies, fraud, threats and official corruption, to coerce Chevron into paying
billions of dollars to the RICO Defendants and their co-conspirators. These RICO Defendants
and their co-conspirators have organized their operation into a cohesive group with specific and
assigned responsibilities and a command structure, operating in the United States and Ecuador,
funded primarily from the United States, and directed mainly from the United States. Over the
years they have adapted their scheme to changing circumstances, recruiting new members to
their operation, and expanding the scope and nature of their activities. While the organization of
the criminal enterprise has changed over time, and its members may have held different roles at
different times, the criminal enterprise has generally been structured to operate as a unit in order
to accomplish the goals of their criminal scheme:
a. Defendants Donziger, the Law Offices of Steven R. Donziger, and
Donziger & Associates, PLLC have been responsible for oversight of the
scheme to defraud and extort Chevron, and have directed other
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