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397. Defendants are and have been aware of valid and enforceable contracts between
TexPet and the Republic of Ecuador, including the 1995 Settlement Agreement and the 1998
Final Release. These contracts, in exchange for TexPet's remedial actions, released TexPet,
Texaco, and their employees, successors, principals and subsidiaries from liability relating to
environmental damage in Ecuador.
398. Defendants have intentionally caused and continued to cause the Republic of
Ecuador to repeatedly breach the 1995 Settlement Agreement and the 1998 Final Release.
Defendants have, through improper influence and the fabricated Cabrera Report, persuaded the
Republic of Ecuador to refuse to defend Chevron's rights and those of its subsidiaries under the
contracts, to improperly dictate to the judiciary that Chevron be held liable in the Lago Agrio
Litigation, and to bring criminal charges against Chevron's employees.
399. The judgment from the Lago Agrio court also constitutes a severe and
qualitatively different breach ofthe 1995 Settlement Agreement and the 1998 Final Release.
Defendants have intentionally caused the Republic of Ecuador to take actions necessary to secure
this fraudulent judgment.
400. As a direct, proximate, and foreseeable result of Ecuador's breaches of the 1995
Settlement Agreement and the 1998 Final Release, Chevron has been forced to defend itself
against claims for which TexPet had already secured a release, which has caused significant
pecuniary, reputational, and other damages. These injuries include significant damage to
Chevron's reputation, and attorneys' fees and costs to defend itself and its subsidiaries against
previously released claims in Ecuador, in related litigation to attempt to enforce these contracts
in international arbitration, and in recognition and enforcement efforts around the world.
401. Defendants have engaged in the malicious, willful, and fraudulent commission
of wrongful acts and, because ofthe reprehensible and outrageous nature ofthese acts, Chevron
is entitled to, and should be awarded, punitive damages against each of the Defendants.
402. Chevron is further entitled to, and should be awarded, a preliminary and
permanent injunction that enjoins Defendants, their assignees, and anyone else acting in concert
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