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incorporated in Colorado with its main office at 1881 Ninth Street, Suite 201, Boulder, Colorado
80302, and is therefore a citizen of Colorado. Exercise of jurisdiction over Stratus is reasonable
and proper in this District for the reasons set forth in paragraph 27, infra.
16. Defendant Douglas Beltman ("Beltman") is an Executive Vice President of
Stratus. Beltman is an individual residing in Colorado, with an intention to reside there
indefinitely, and is therefore a citizen of Colorado. Exercise of jurisdiction over Beltman is
reasonable and proper in this District for the reasons set forth in paragraph 27, infra.
17. Defendant Ann Maest ("Maest") is a Managing Scientist at Stratus. Maest is an
individual residing in Colorado, with an intention to reside there indefinitely, and is therefore a
citizen of Colorado. Exercise of jurisdiction over Maest is reasonable and proper in this District
for the reasons set forth in paragraph 27, infra.
Non-Party Co-Conspirators
18. Certain other non-party individuals and business entities played roles, direct or
indirect, in the scheme to defraud and extort Chevron. Foremost among these individuals and
business entities are the following:
a. Joseph Kohn ("Kohn") of the law firm Kohn Swift & Graf P.c. is an attorney
who was a "consulting" attorney for the Amazon Defense Front in the Lago Agrio
Litigation, and a primary source of funds for that litigation and for many ofthe
illegal activities described in this Amended Complaint. Kohn is a resident of
Pennsylvania.
b. Kohn Swift & GrafP.C. ("Kohn Swift") is a professional corporation located at
One South Broad Street, Suite 2100, Philadelphia, Pennsylvania 19107. Kohn
Swift has bankrolled the Lago Agrio Litigation as one of its "flagship cases" and
funded the co-conspirators' other illegal activities.
c. Joshua Lipton ("Lipton") is the President of Stratus and is a resident of Colorado.
Together with the RICO Defendants, Lipton coordinated and oversaw the use of
Stratus and other resources by the RICO Defendants to ghostwrite the Cabrera
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