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§ 1964(c).
3. For Chevron's reasonable attorneys' fees and costs according to statute, 18 U.S.c.
On the First through Seventh Claims for Relief:
4. For general damages according to proof at trial;
5. For equitable relief as appropriate pursuant to applicable law, including but not
limited to issuing a temporary restraining order, a preliminary injunction and a permanent
injunction that bars Defendants, their assignees and anyone else acting in concert with them­
including potentially 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; and
6. Only for the third, fourth, fifth, and seventh claims for relief, punitive damages in
an amount to be proven at trial.
On the Eighth Claim for Relief:
7. For general damages according to proof at trial, trebled according to statute,
Judiciary Law § 487; and
8. For Chevron's reasonable attorneys' fees and costs according to statute,
Judiciary Law § 487.
On the Ninth Claim for Relief:
9. For a declaration that the judgment against Chevron in the Lago Agrio Litigation
is non-recognizable and unenforceable for each and everyone of the reasons set forth herein; and
10. For equitable relief as appropriate pursuant to applicable law, including but not
limited to issuing a temporary restraining order, a preliminary injunction and a permanent
injunction that bars the Front, the Lago Agrio Plaintiffs, their assignees and anyone else acting in
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