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Lago Agrio Litigation. Fajardo is an individual residing in Ecuador, with an intention to reside
there indefinitely, and is therefore a citizen of Ecuador. Exercise of jurisdiction over Fajardo is
reasonable and proper in this District for the reasons set forth in paragraph 28, infra.
12. Defendant Luis Yanza ("Yanza") is the co-founder of the Amazon Defense
Front and is or has been the General Manager for Defendant Selva Viva. Yanza is an individual
residing in Ecuador, with an intention to reside there indefinitely, and is therefore a citizen of
Ecuador. Exercise of jurisdiction over Yanza is reasonable and proper in this District for the
reasons set forth in paragraph 29, infra.
13. Defendant Frente de Defensa de la Amazonia, a/k/a the Amazon Defense Front
or Amazon Defense Coalition (the "Frente" or the "Front"), is a "non-profit" organization
purporting to represent the "plaintiffs" in the Lago Agrio Litigation. The Front is the designated
"beneficiary" and "trustee" of a trust ordered by the judgment in the Lago Agrio Litigation (the
"Judgment Trust"), and intends to administer the proceeds from the judgment entered against
Chevron. The Front is a non-profit organization registered under the laws of Ecuador with
offices located in the town of Nueva Loja (Lago Agrio) in the province of Sucumbios, Ecuador.
The Front is therefore a citizen of Ecuador. Exercise of jurisdiction over the Front is reasonable
and proper in this District for the reasons set forth in paragraph 30, infra.
14. Defendant Selva Viva, a/k/a Selva Viva Selviva CIA, Uda. ("Selva Viva") is or
was an Ecuadorian limited liability company with an office located at 1240 Shirys Street,
Tumbaco, Ecuador. Selva Viva is therefore a citizen of Ecuador. Defendant the Front created
Selva Viva to administer funds for the litigation. Defendant the Front controls Selva Viva,
Defendant Donziger is or has been the President of Selva Viva, and Defendant Yanza is or has
been the General Manager of Selva Viva. Exercise of jurisdiction over Selva Viva is reasonable
and proper in this District for the reasons set forth in paragraph 31, infra.
15. Defendant Stratus Consulting, Inc. ("Stratus") provided various environmental
consulting services to the RICO Defendants, and was involved in producing the purportedly
"independent" expert report filed in the Lago Agrio Litigation. Stratus is a private corporation
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