hLpb5

343. The RICO Defendants and their co-conspirators constitute an association-in-fact
enterprise within the meaning of 18 U .S.C. §§ 1961 (4) and 1962( c), referred to hereinafter as the
"Enterprise." Each of the RICO Defendants participated in the operation or management of the
Enterprise.
344. At all relevant times, the Enterprise was engaged in, and its activities affected
interstate and foreign commerce within the meaning of 18 U.S.c. § 1962( c).
Pattern of Racketeering Activity
345. The RICO Defendants conducted or participated, directly or indirectly, in the
conduct, management, or operation of the Enterprise's affairs through a "pattern of racketeering
activity" within the meaning of 18 U .S.c. § 1961 (5) and in violation of 18 U .S.c. § 1962( c), to
wit:
Pattern of Racketeering Activity: Extortion in Violation of Hobbs Act, 18 U.S.C )\ 1951
346. At all times material to this Amended Complaint, Chevron was engaged in
interstate and foreign commerce and in an industry that affects interstate and foreign commerce.
347. As described herein, the RICO Defendants have engineered a wide­
ranging campaign of public attacks based on false and misleading statements, trumped up
criminal charges, a threatened and actual fraudulent civil judgment, investigations by
government agencies, and ongoing harassment and disruptions of business operations, and have
demanded the payment of billions of dollars before these activities will cease, all with the intent
and effect of causing a reasonable fear of economic loss on the part of Chevron.
348. As described herein, the RICO Defendants manufactured false evidence
against Chevron and are relying on that false evidence in the sham Lago Agrio Litigation with
the intent and effect of causing a reasonable fear of economic loss on the part of Chevron.
349. As described herein, the RICO Defendants conspired with the Republic of
Ecuador to advance baseless criminal charges against two Chevron lawyers responsible for
executing the 1998 Final Release in order to extort a payment from Chevron.
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