hRb7u

Lago Agrio Litigation, pursuing relief in the Treaty Arbitration, uncovering the RICO
Defendants' fraud through discovery in the United States (discovery with which the RICO
Defendants have continually interfered and which they have unduly extended, as described
herein), responding to false and misleading reports in major media publications and broadcasts
which have been induced by the RICO Defendants, and maintaining an ongoing effort to provide
accurate information about the Cabrera Report and other aspects of the RICO Defendants' fraud
to the media and directly to the pUblic.
406. Chevron also has been harmed in that Defendants' conduct has damaged
Chevron's reputation, thus interfering with Chevron's interest in the public goodwill toward it.
Public awareness of and positive associations with the Chevron and Texaco brand names, and
Chevron's other brand assets are among Chevron's most valuable assets, and Chevron has
invested substantial resources into those brand names. The RICO Defendants have intentionally
sought to reduce the value of those assets as part oftheir extortionate scheme. As Donziger has
expressly stated, a key element of the RICO Defendants' strategy is to impose upon Chevron,
"the cost of their sullied reputation, you know, in the media."
407. The harms suffered by Chevron are the direct, proximate, and reasonably
foreseeable results ofthe Defendants' acts of intentional interference with Chevron's funds and
goodwill.
408. Defendants have engaged in the malicious, willful, and fraudulent commission
of wrongful acts and, because of the reprehensible and outrageous nature of these acts, Chevron
is entitled to, and should be awarded, punitive damages against each of the Defendants.
409. Chevron is further entitled to, and should be awarded, a preliminary and
permanent injunction that enjoins Defendants, their assignees, and anyone else acting in concert
with them-including the law firms of Emery Celli, Motley Rice and Patton Boggs, and H5 and
financial backers such as Burford and Russell DeLeon-from commencing, prosecuting, or
advancing in any way-directly or indirectly-any attempt to recognize or enforce the Lago
Agrio judgment in any court, tribunal, or administrative agency in any jurisdiction, in the United
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