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Plaintiff Chevron Corporation ("Chevron") for its Amended Complaint against the
Defendants listed below alleges as follows:
INTRODUCTION
1. Over the course of several years, defendant Steven Donziger and his co-
defendants and co-conspirators have sought to extort, defraud, and otherwise tortiously injure
plaintiff Chevron by means of a plan they conceived and substantially executed in the United
States. It has been carried out by a U.S.-based enterprise comprised of, among others, U.S.
plaintiffs' lawyers led by Donziger; U.S. environmental consultants, led by Stratus Consulting,
Inc., Ann Maest, and Doug Beltman; their Ecuadorian colleagues, led by Pablo Fajardo and Luis
Yanza; and their front organizations, the Amazon Defense Front and Selva Viva. These
conspirators are collectively referred to herein as the "RICO Defendants."! Their co-
conspirators in the enterprise include, among others, U.S. law firms and attorneys, such as
Joseph Kohn ofKohn Swift & Graf, P.c., Emery Celli Brinckerhoff & Abady LLP, Motley Rice
LLC and Patton Boggs LLP; U.S. environmental "activists," such as Atossa Soltani, Amazon
Watch, and Rainforest Action Network; U.S. public relations consultants, such as Karen Hinton;
and additional financiers, such as Russell DeLeon and the Burford Group.
2. The enterprise's ultimate aim is to create enough pressure on Chevron in the
United States to extort it into paying to stop the campaign against it. The RICO Defendants have
sought to inflict maximum "damage to [Chevron's] reputation," to put "personal psychological
Forty-seven of the 48 Ecuadorian individuals who are named in the caption of the Lago
Agrio complaint are also named as defendants here (the exception being one who is now
deceased). Whether or not these 47 individuals were actively involved with the corrupt acts
described in this Amended Complaint, or knew or should have known about them, the Lago
Agrio Litigation and multiple acts in United States courts have been undertaken in their
names, as well as in the name of the Amazon Defense Front, by the other defendants or those
acting in concert with them on their behalves. Thus, they are vicariously liable for the torts
of their agents undertaken on their behalves, can in no way benefit from a corruptly obtained
judgment, and any relief Chevron procures by means of this action or other legal avenues
applies equally to these 47 Ecuadorian individuals, who necessarily would thereby be acting
in concert with their corrupt agents.