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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.
FIFTH CLAIM FOR RELIEF
(Trespass to Chattels)
(Against All Defendants)
403. Chevron realleges and incorporates herein by reference each and every foregoing
paragraph of this Amended Complaint as if set forth in full.
404. As set forth above, the RICO Defendants have engaged in a pattern of extortion,
collusion, wrongdoing, and deceit with an intent to interfere with Chevron's property, and the
Lago Agrio Plaintiffs have benefited and will continue to benefit from the RICO Defendants'
criminal scheme through a fraudulent judgment. Through these actions, and by prosecuting a
fraudulent lawsuit, manufacturing false evidence, tampering with testimony, disseminating
misleading statements to courts, the public, and U.S. government officials, and otherwise
engaging in the pressure campaign described in the foregoing paragraphs of this Amended
Complaint, Defendants have intentionally, and without justification or consent, interfered and
intermeddled with Chevron's use and enjoyment of its funds that were intended for Chevron's
business purposes and of its business reputation and goodwill.
405. Chevron has been harmed and the use of its property has been interfered with
and disturbed when its property, resources, and funds were necessarily redirected from their
intended uses to defend against Defendants' fraudulent litigation and misleading media
campaign. For example, Chevron has been forced by the RICO Defendants' intentional and
wrongful conduct to expend funds and resources defending against fraudulent submissions in the
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