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Remaining Defendants
20. The Lago Agrio Litigation was ostensibly brought on behalf of forty-eight
named individual Ecuadorians,2 referred to herein as the Lago Agrio Plaintiffs. At all relevant
times, the Lago Agrio Plaintiffs have been individuals residing in the Republic of Ecuador. The
Lago Agrio Plaintiffs are those individuals identified in Appendix A to this Amended Complaint,
which is incorporated by reference as if set forth herein in its entirety.
21. The Lago Agrio Plaintiffs' Complaint seeks no individual damages in the Lago
Agrio Litigation, and the signatures for twenty of the Lago Agrio Plaintiffs on the power of
attorney form submitted along with the complaint in the Lago Agrio Litigation are the product of
forgery. Defendant Fajardo, in a sworn declaration submitted to this Court in January 20 11, has
affirmed that he represents the Lago Agrio Plaintiffs as their attorney in the Lago Agrio
Litigation and is authorized to pursue and defend their interests in other domestic and foreign
courts. According to Fajardo, the Lago Agrio Plaintiffs gave him "the power to represent them"
in the Lago Agrio Litigation in 2006. At that time, they purportedly signed documents
appointing him as their "Common Attorney," which required him "to undertake all appropriate
legal action to defend the[ir] rights" and authorized him "to appear on their behalf in connection
with the Lago Agrio Litigation and if necessary to delegate this power to others." Subsequently,
in November 2010, "at least forty-one (41)" of the Lago Agrio Plaintiffs allegedly signed
notarized powers of attorney "affirming" Fajardo's "powers to represent them in pursuit and
defense of their interests before the courts in Ecuador and in all other countries, including the
United States." Moreover, in these powers of attorney, the Lago Agrio Plaintiffs purportedly
"ratified and approved each and every action to date performed by [Fajardo] or by any other
persons authorized by [Fajardo] to act in defense of the [Lago Agrio] Plaintiffs' interests in the
Lago Agrio Litigation and in all other related actions." In his declaration, Fajardo represented
2 One of these individuals, Esteban Lusitante Yaiguaje, is now deceased and thus is not named
as a defendant in this case.
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