jjR0b

that the order would not prevent Defendants' attempts to enforce and recognize the judgment
outside ofthe United States: "The judge cannot order and require something that is outside of
United States territory, as such. Therefore, that injunction is completely, uh, it's unenforceable,
inapplicable for countries other than the United States."
335. The judgment of the Lago Agrio court, procured by the RICO Defendants' and
their co-conspirators' fraud-in addition to related attachment and enforcement efforts and the
specter of billions of dollars in liability-threatens to disrupt Chevron's business operations,
sully its reputation, and otherwise cause Chevron to suffer irreparable harm. In the RICO
Defendants' "Invictus" memorandum, outlining their plans to use the Lago Agrio judgment to
extract payments from Chevron, Patton Boggs also proposes initiating a shareholder derivative
action against Chevron in the United States, "as a point of leverage with respect to settlement
[and] as a fruitful basis for discovery into the machinations of Chevron management vis a vis the
Ecuadorian litigation." And that memo also reveals that the RICO Defendants do not intend to
wait for judgments in their proposed enforcement proceedings: "Consistent with their aggressive
approach, Plaintiffs' Team will look for ways to proceed against Chevron on a pre-judgment
basis, largely as a means of attaining a favorable settlement at an early stage. Various laws and
procedures within and outside the United States may permit attachment of Chevron's assets prior
to successful recognition of the Ecuadorian judgment."
336. Nor are the RICO Defendants limiting their operations to the Lago Agrio
Litigation. Donziger has stated that their intention is to "take legal fees we can earn from this
case and, do more cases like this in different places with, you know, the same team, if possible."
337. The RICO Defendants' extensive and wide-ranging scheme to defraud and extort
Chevron, as described in this Amended Complaint, has already had a lasting and irreparable
effect on Chevron. The RICO Defendants' false and misleading statements have been relied on
by the U.S. courts, U.S. state and federal government agencies, Chevron's shareholders,
investors, analysts, the media, and by the Lago Agrio court by means of its acceptance of
Defendants' and Cabrera's misrepresentations and omissions and its failure to take meaningful
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