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377. Further, these injuries to Chevron were a direct, proximate, and reasonably
foreseeable result of the violation of 18 U.S.c. § 1962. Chevron is the ultimate victim of the
RICO Defendants' unlawful Enterprise. Chevron has been and will continue to be injured in its
business and property in an amount to be determined at trial.
378. Pursuant to 18 U .S.c. § 1964( c), Chevron is entitled to recover treble damages
plus costs and attorneys' fees from the RICO Defendants.
379. 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
with them-including the law firms of Emery Celli, Motley Rice and Patton Boggs, and H5 and
financial backers such as Burford and Russell DeLeon-from commencing, prosecuting, or
advancing in any way-directly or indirectly-any attempt to recognize or enforce the Lago
Agrio judgment in any court, tribunal, or administrative agency in any jurisdiction, in the United
States or abroad, including any attempt to attach or seize any Chevron or Chevron subsidiary's or
co-venturer's assets, whether pre-judgment or otherwise, until this Court determines the merits
and enters judgment on Chevron's claims against the Defendants in this action.
WHEREFORE, Chevron prays for judgment as set forth below.
SECOND CLAIM FOR RELIEF
(Conspiracy to Violate RICO, Violation of 18 U.S.c. § 1962(d))
(Against All RICO Defendants)
380. Chevron rea lieges and incorporates herein by reference each and every foregoing
paragraph of this Amended Complaint as if set forth in full.
381. The RICO Defendants have unlawfully, knowingly and willfully combined,
conspired, confederated and agreed together and with others to violate 18 U.S.c. § 1962(c) as
described above, in violation of 18 U.S.C. § 1962(d).
382. Upon information and belief, the RICO Defendants knew that they were engaged
in a conspiracy to commit the predicate acts, and they knew that the predicate acts were part of
such racketeering activity, and the participation and agreement of each of them was necessary to
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