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. Emery Celli Brinckerhoff & Abady LLP ("Emery Celli") is a law firm located at
75 Rockefeller Plaza, 20th Floor, New York, New York 10019. Emery Celli has
spearheaded the RICO Defendants' obstruction and cover-up efforts in the United
States, making numerous meritless filings in opposition to Chevron's discovery
proceedings in U.S. courts in an express effort to delay those proceedings and
"buy time" for the RICO Defendants' criminal scheme.
s. Patton Boggs LLP ("Patton Boggs") is a law firm with its principal office at 2550
M Street, NW, Washington, D.C. 20037. Patton Boggs has developed the RICO
Defendants' strategy for pursuing the assets of Chevron and its subsidiaries
around the world on the basis of the fraudulent judgment in Ecuador, and has also
been instrumental in the cover-up and obstruction of Chevron's U.S. discovery
proceedings.
t. Motley Rice LLC ("Motley Rice") is a law firm with an office located at One
Corporate Center, 20 Church St., Hartford, Connecticut 06103. Motley Rice has
participated in the obstruction of Chevron's U.S. discovery efforts.
u. H5 is a California corporation with its principal office at 71 Stevenson St., San
Francisco, California 94105. H5 has participated in planning and implementing
the RICO Defendants' scheme, including the "cleansing" of the Cabrera Report
and the obstruction of Chevron's U.S. discovery efforts.
19. At all relevant times, each and every non-party named in paragraph 18 was
acting in concert with, or as an agent for, one or more of the RICO Defendants and, further, as
described in more detail below, conspired with one or more ofthe other RICO Defendants to
perform the acts averred herein.
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