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In 2007, Ecuador submitted a declaration by Quarles regarding the "independence" of the
Cabrera Report in a proceeding pending in the Southern District of New York, using that
declaration to support Ecuador's contention that the Lago Agrio Litigation "has proceeded in
accordance with rules of procedure under Ecuador law." Quarles has recently admitted in sworn
testimony that Donziger paid him for this affidavit, and that he would not have signed the
affidavit if Donziger had told him the truth about the RICO Defendants' involvement with
Cabrera. By not disclosing the truth about the RICO Defendants' improper contact with Cabrera
and instead deliberately misleading Quarles, Donziger knowingly engaged in deceit with the
intent to deceive Quarles, this Court, and Chevron.
425. As a result of the deceitful and fraudulent conduct of Donziger, the Law Offices
of Steven R. Donziger, and Donziger & Associates, PLLC as described herein, Chevron has been
injured in an amount to be established at trial.
426. By reason of the foregoing, Chevron is entitled to monetary damages against
Donziger, the Law Offices of Steven R. Donziger, and Donziger & Associates, PLLC, treble
damages, and reasonable attorneys' fees pursuant to Judiciary Law § 487.
WHEREFORE, Chevron prays for judgment as set forth below.
NINTH CLAIM FOR RELIEF
(Request for Declaratory Judgment That the Judgment by the Lago Agrio Court Against
Chevron is Unenforceable and Non-Recognizable)
(Against the Front and the "Lago Agrio Plaintiffs")
427. Chevron realleges and incorporates herein by reference each and every foregoing
paragraph of this Amended Complaint as if set forth in full.
428. Chevron is entitled to a declaratory judgment that the judgment from the Lago
Agrio court is unenforceable and non-recognizable pursuant to the Declaratory Judgment Act, 28
U.S.c. § 2201(a).
429. A declaratory judgment will not improperly increase friction between sovereign
legal systems or encroach on the proper domain of a foreign court because no court has a right to
impose fraudulent judgments such as the judgment of the Lago Agrio court. And an injunction
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