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States or abroad, including any attempt to attach or seize any Chevron or Chevron subsidiary's or
co-venturer's assets, whether pre-judgment or otherwise, until this Court determines the merits
and enters judgment on Chevron's claims against the Defendants in this action.
WHEREFORE, Chevron prays for judgment as set forth below.
SIXTH CLAIM FOR RELIEF
(Unjust Enrichment)
(Against All Defendants)
410. Chevron realleges and incorporates herein by reference each and every foregoing
paragraph of this Amended Complaint as if set forth in full.
411. Defendants seek to obtain billions of dollars from Chevron through a fraudulent
judgment in the Lago Agrio Litigation. Defendants have been and will continue to be unjustly
enriched by benefits obtained due to the Judgment itself.
412. Any property that Defendants obtain from Chevron will be acquired as a result
of Defendants' tortious, illegal, and fraudulent conduct, as set forth herein, including the
prosecution of the Lago Agrio Litigation itself.
413. Principles of equity and good conscience mandate that this Court prevent
Defendants from reaping a multi-billion dollar windfall and any benefits arising out of the
fraudulent litigation by, among other things, issuing a preliminary and permanent injunction
against Defendants 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
States or abroad, including any attempt to attach or seize any Chevron or Chevron subsidiary's or
co-venturer's assets, whether pre-judgment or otherwise, until this Court determines the merits
and enters judgment on Chevron's claims against the Defendants in this action.
WHEREFORE, Chevron prays for judgment as set forth below.
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