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that the Lago Agrio Plaintiffs who signed the powers of attorney in November 2010 "affirmed
that as lead counsel I have the authority to make and sign contracts, hire and retain legal
consultants, and designate to others all or part of my power to represent the [Lago Agrio]
Plaintiffs." He also stated that he retained several u.s. law firms to assist with the representation
of the Lago Agrio Plaintiffs, including Patton Boggs, Emery Celli, and Motley Rice.
22. Whether or not the individual Lago Agrio Plaintiffs were or are aware of the
fraud that has been perpetrated by the RICO Defendants and their co-conspirators in their names,
the Lago Agrio Plaintiffs cannot benefit from the fraud and corrupt acts perpetrated ostensibly on
their behalf.
SUBJECT MATTER JURISDICTION AND VENUE
23. This Court has subject matter jurisdiction over Chevron's claims under
28 U.S.c. §§ 1331 and 1332, and under 18 U.S.C. § 1964(c). Chevron's first claim for relief
arises under 18 U .S.c. § 1961 et seq., as hereinafter more fully appears. There is also complete
diversity of citizenship between the parties, and the amount in controversy exceeds $75,000,
exclusive of interest and costs. Chevron's state law claims arise out of the same case or
controversy as its federal law claims, as all claims in this action arise out of a common nucleus
of operative facts. Thus, this Court also has supplemental jurisdiction over Chevron's state law
claims under 28 U.S.C. § 1367.
24. Venue is proper in this District under 28 U.S.c. § 1391 (b)(2), as a substantial
number of the events giving rise to this action occurred in this District, and also under 18 U.S.C.
§ 1965.
PERSONAL JURISDICTION
25. Exercise of jurisdiction over Defendant Donziger is reasonable and proper in this
District because Donziger is a citizen of the State of New York and because he conducts
extensive business activities within the State. Donziger is the sole proprietor ofthe Law Offices
of Steven R. Donziger, which is located and does business in New York. Through his activities
in New York, Donziger has served as the ringleader in the enterprise to defraud and extort
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