jjR0b

were to agree to [force Chevron to post a bond in order to appeal the Lago Agrio judgment], then
we would try to start seizing assets in other countries." According to Donziger, "If we get a
judgment out of the trial court, we're coming back immediately, - soon as we can, -to get that
judgment enforced. We are not waiting for the appeals process." And Donziger has threatened
that "Chevron operates in more than 100 countries and has numerous oil tankers that troll the
world's waterways and dock in any number of ports .... This could end up being one of the
biggest forced asset seizures in history and it could have a significant disruptive impact on the
company's operations." In an interview broadcast as part of a 60 Minutes segment on the Lago
Agrio Litigation, Donziger, in response to the observation that Chevron has no assets in Ecuador,
stated, "At the end of the day, it might be a situation where a U.S. court enforces the judgment
and the marshals have to go to Chevron and seize their assets." These threats continue unabated.
Just months before this Amended Complaint was filed, Donziger, in a speech to law students,
told them that he was assembling a legal team "to execute whatever judgment comes out of
Ecuador effectively, in whatever forum might-forum might be appropriate, including multiple
places that, you know, you could file suits, you could seize assets, seize boats."
333. Through statements made to this Court, Defendants have also made clear their
intent to enforce the judgment immediately. When asked by Judge Sand ofthe Southern District
of New York whether the Lago Agrio Plaintiffs in their action to stay the Treaty Arbitration were
"willing to stipulate that [they would] take no efforts to enforce the judgment until ... the
arbitration is completed," their counsel refused to agree to stay enforcement: "No, your honor.
We would not and cannot do that."
334. Indeed, since the issuance of the Lago Agrio judgment, Defendants have only
accelerated their plan to pressure Chevron by using the fraudulent judgment to institute
attachment proceedings and other enforcement actions, in defiance of a temporary restraining
order issued by this Court. On February 14,2011, Fajardo stated that "we're going to
immediately ask any country where Chevron has assets ... that Chevron's assets be attached."
And a day later, referring to this Court's issuance of a temporary restraining order, Fajardo stated
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