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WHEREFORE, Chevron prays for judgment as set forth below.
EIGHTH CLAIM FOR RELIEF
(Violations of New York JUdiciary Law § 487)
(Against Defendants Donziger, the Law Offices of Steven R. Donziger and Donziger &
Associates, PLLC)
420. Chevron realleges and incorporates herein by reference each and every foregoing
paragraph of this Amended Complaint as ifset forth in full.
421. New York Judiciary Law § 487 provides, in pertinent part, as follows: "An
attorney or counselor who ... [i]s guilty of any deceit or collusion, or consents to any deceit or
collusion, with intent to deceive the court or any party ... [i]s guilty of a misdemeanor, and in
addition to the punishment prescribed therefore by the penal law, he forfeits to the party injured
treble damages, to be recovered in a civil action."
422. As set forth above, Donziger, the Law Offices of Steven R. Donziger, and
Donziger & Associates, PLLC engaged in an intentional pattern of collusion, wrongdoing, and
deceit with the intent to deceive both Chevron and multiple federal courts, including the United
States District Court for the Southern District of New York and the United States Court of
Appeals for the Second Circuit.
423. Donziger, the Law Offices of Steven R. Donziger, and Donziger & Associates,
PLLC actively participated in the preparation and filing of multiple court submissions to the
United States District Court for the Southern District of New York, which included false and
misleading statements about the Lago Agrio Litigation and the Cabrera Report. Defendants
Donziger and the Law Offices of Steven R. Donziger knowingly caused these misstatements to
be filed with the intent of deceiving this Court and Chevron. As described in paragraphs 304-10,
supra, these misstatements were filed in opposition to Chevron's requests for discovery under 28
U.S.c. § 1782 and in support of the Lago Agrio Plaintiffs' and the Republic of Ecuador's actions
against Chevron seeking to terminate arbitration proceedings.
424. Donziger and the Law Offices of Steven R. Donziger tampered with the
testimony of environmental consultant Mark Quarles in furtherance of the Enterprise's scheme.
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