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officials, and Chevron's shareholders, investors, analysts, and the media, and by the Lago Agrio
court by means of its acceptance of Defendants' and Cabrera's misrepresentations and omissions
and its failure to take meaningful corrective action.
393. As a direct, proximate, and foreseeable result of Defendants' fraud, Chevron has
been harmed, including significant pecuniary, reputational, and other damages. These injuries
include significant damage to Chevron's reputation and goodwill, and the attorneys' fees and
costs to defend itself in objectively baseless, improperly motivated sham litigation in Ecuador
and in related litigation in the U.S., including the attorneys' fees and costs associated with
exposing the Defendants' pervasive fraud in the Section 1782 proceedings.
394. Defendants have engaged in the malicious, willful, and fraudulent commission
of wrongful acts and, because of the reprehensible and outrageous nature of these acts, Chevron
is entitled to, and should be awarded, punitive damages against each of the Defendants.
395. 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-from 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.
FOURTH CLAIM FOR RELIEF
(Tortious Interference With Contract)
(Against All Defendants)
396. Chevron realleges and incorporates herein by reference each and every foregoing
paragraph of this Amended Complaint as if set forth in full.
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