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SEVENTH CLAIM FOR RELIEF
(Civil Conspiracy)
(Against All Defendants)
414. Chevron realleges and incorporates herein by reference each and every foregoing
paragraph of this Amended Complaint as if set forth in full.
415. As set forth above, Defendants have committed torts against Chevron, including
acts of racketeering giving rise to violations of RICO, fraud, tortious interference with contract,
trespass to chattels, and unjust enrichment.
416. Defendants agreed to participate in a common scheme against Chevron.
Defendants intentionally participated in the furtherance of a plan or purpose to obtain property
from Chevron. In furtherance of this plan or purpose, Defendants committed overt and unlawful
acts, including acts of racketeering as alleged herein.
417. As a direct and proximate result of Defendants' conspiracy, the overt acts
committed in furtherance of that conspiracy, and the torts committed against Chevron, Chevron
has been damaged in its business and property, and further damage to Chevron's business and
property is threatened and imminent.
418. 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.
419. 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 !-I5 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.
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