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corrective action. Further, the RICO Defendants' false and misleading statements have caused
Chevron substantial damages. Chevron has had to expend millions of dollars in attorneys' fees
and costs defending itself in the sham litigation the RICO Defendants and their co-conspirators
have prosecuted in Ecuador, and exposing the conspirators' pervasive fraud in the Section 1782
proceedings. On top of the attorneys' fees and expenses, Chevron's interest in executed
contracts, including the 1995 Settlement Agreement and 1998 Final Release, has also been
impaired as a result of the RICO Defendants' and their co-conspirators' collusion with the
Republic of Ecuador. In addition, many of the RICO Defendants' extortionate acts have
presented unfair and false representations of Chevron's business practices, harming Chevron's
reputation and goodwill. As alleged throughout, these harms represent the precise result
intended by the RICO Defendants' misconduct. And worse, it is clear from the RICO
Defendants' actions and words that they have no intention of stopping until Chevron surrenders
to their extortionate demands. Without the Court's intervention, Chevron will continue to suffer
significant harm at the hands of the RICO Defendants and their unlawful scheme.
338. The facts and evidence presented in this Amended Complaint are the result of
many thousands of hours of work by Chevron, its attorneys, and its investigators, and have been
assembled at extraordinary cost. As this Amended Complaint was being prepared for filing,
however, new evidence continued to emerge, and the true nature of the RICO Defendants'
criminal conduct becomes clearer and clearer. Just a few months ago, considering Chevron's
request to obtain discovery directly from the ringleader of this enterprise, Donziger, the United
States District Court for the Southern District of New York summarized the case as follows:
"[T]he name of the game is, arguably, to put a lot of pressure on the courts to feed them a record
in part false for the purpose of getting a big judgment or threatening a big judgment, which
conceivably might be enforceable in the U.S. or in Britain or some other such place, in order to
persuade Chevron to come up with some money. Now, do the phrases Hobbs Act, extortion,
RICO, have any bearing here?"
135