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Boulder, Colorado; (ii) caused funds to be transferred within the United States and from the
United States to Ecuador in furtherance of the RICO Defendants' wrongful activities; (iii)
attended Chevron shareholder meetings to attempt to pressure Chevron's stockholders and board
of directors in furtherance of the conspiracy; (iv) solicited and received funds for the Lago Agrio
Litigation while in the United States and, on information and belief, in New York and from
persons in the United States and New York directly and through agents by other means for the
purpose of carrying out the conspiracy and fraud; (v) attempted to conceal the conspiracy and
fraud by making false and misleading statements in the United States and elsewhere; and (vi)
caused to be filed in the Southern District of New York the Yaiguaje action on behalf of the Lago
Agrio Plaintiffs to stay the Treaty Arbitration initiated by Chevron. Yanza has also engaged in
intentional, wrongful, illegal, and/or tortious acts the effects of which Yanza knew and intended
would be felt in the United States and New York. For example, Yanza has (i) directed
multitudes of phone calls, emails, and other forms of communication to his co-conspirators in the
United States and New York for the purpose of planning and carrying out their conspiracy and
fraud; and (ii) participated in and orchestrated campaigns in the United States and New York to
influence United States federal officials, State of New York officials, financial analysts,
investors, and stockholders for the purpose of extorting money from Chevron. Also, as set forth
more fully herein, Yanza's co-conspirators and agents have engaged in intentional, wrongful,
illegal, and/or tortious acts in the United States and New York. Yanza was aware of the effects
in the United States and New York of those acts, the activities ofYanza's co-conspirators and
agents were to the benefit ofYanza, and his co-conspirators and agents were working at the
direction, under the control, at the request, and/or on behalf of Yanza in committing those acts.
30. Exercise of jurisdiction over the Front is proper pursuant to 18 U .S.c. § 1965(b)
and N.Y. C.P.L.R. 301 and 302. The Front has been designated beneficiary and trustee in the
Lago Agrio Litigation and stands to benefit from the fraudulent judgment entered against
Chevron. Yanza is the Front's co-founder, Fajardo is a leader within the organization, and at all
times relevant herein Yanza and Fajardo were acting as the Front's co-conspirators, agents
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