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is enforceable and recognizable, and is the best and most effective remedy for finalizing the
controversy between the parties as to this issue and for relieving Chevron from the expensive and
damaging uncertainty surrounding the pending enforcement and recognition of the fraudulent
judgment. Chevron is entitled to have the question of whether the Lago Agrio judgment is
enforceable and recognizable settled promptly so that it may continue conducting its business
without the threat of attachment, asset seizures, or other enforcement actions arising from the
massive fraudulent judgment.
433. Chevron is further entitled to, and should be awarded, a preliminary and
permanent injunction against the Front and the Lago Agrio Plaintiffs, their assignees and anyone
else acting in concert with them 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. Thus, even though they are
not named defendants in this Declaratory Judgment claim, the other RICO Defendants and their
co-conspirators, including the law firms of Emery Celli, Motley Rice and Patton Boggs, and H5
and financial backers such as Burford and Russell DeLeon, make themselves subject to any
injunction issued by this Court to the extent they act in concert with the defendants named in this
claim-the Lago Agrio Plaintiffs and the Front.
WHEREFORE, Chevron prays for judgment as set forth below.
PRAYER FOR RELIEF
On the First and Second Claims for Relief:
1. F or general damages according to proof at trial, trebled according to statute,
18 U.S.c. § 1964(c);
2. For pre-judgment interest according to statute; and
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