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and/or alter egos in perpetrating the conspiracy and fraud against Chevron. By and through its
co-conspirators, agents and/or alter egos Yanza and Fajardo, the Front has transacted business
and engaged in tortious conduct in the United States and New York which give rise in part to
Chevron's claims, as set forth more fully above. The Front has also engaged in intentional,
wrongful, illegal, and/or tortious acts the effects of which the Front knew and intended would be
felt in the United States and New York. Among other things, the Front: (i) directed multitudes of
phone calls, emails, and other forms of communication to its co-conspirators in the United States
and New York for the purpose of planning and carrying out their conspiracy and fraud; (ii)
maintains or causes to be maintained a website intentionally directed towards a U.S.-based
audience called www.texacotoxico.org through which the Front has attempted to conceal the
conspiracy and fraud by making false and misleading statements and, on information and belief,
raised funds from the United States and New York for the purpose of carrying out the conspiracy
and fraud; (iii) solicited and received funds 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; (iv) used Amazon Watch as its public relations firm in the United States to publish false
and misleading statements to conceal the conspiracy and fraud; and (v) hired a Washington,
D.C.-based lobbyist to pursue its and its co-conspirators' interests before the U.S. Congress.
Also, as set forth more fully herein, the Front's co-conspirators and agents have engaged in
intentional, wrongful, illegal, and/or tortious acts in the United States and New York. The Front
was aware of the effects in the United States and New York of those acts, the activities of the
Front's co-conspirators and agents were to the benefit of the Front, and its co-conspirators and
agents were working at the direction, under the control, at the request, and/or on behalf of the
Front in committing those acts.
31. Exercise of jurisdiction over Selva Viva is proper pursuant to 18 U .S.c.
§ 1965(b) and N.Y. C.P.L.R. 301 and 302. Donziger is or has been the President of Selva Viva,
Yanza is or was the General Manager of Selva Viva, and at all times relevant herein Donziger,
Yanza and Fajardo were acting as Selva Viva's co-conspirators, agents and/or alter egos in
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