From the Complaint:

“Plaintiffs Energy Transfer Equity, L.P., Energy Transfer Partners, L.P. (collectively

“Energy Transfer” or “Plaintiffs”), as and for their complaint against Greenpeace International (aka “Stichting Greenpeace Council”), Greenpeace, Inc. (“GP-Inc.”), Greenpeace Fund, Inc. (“GP-Fund”) (collectively, the “Greenpeace Defendants”), BankTrack (aka “Stichting BankTrack”), Earth First!, and John and Jane Does 1-20, allege as follows:

This case involves a network of putative not-for-profits and rogue eco-terrorist

groups who employ patterns of criminal activity and campaigns of misinformation to target legitimate companies and industries with fabricated environmental claims and other purported misconduct, inflicting billions of dollars in damage. The network’s pattern of criminal and other misconduct includes (i) defrauding charitable donors and cheating federal and state tax authorities with claims that they are legitimate tax-free charitable organizations; (ii) cyberattacks; (ii) intentional and malicious interference with their targeted victim’s business relationships; and (iv) physical violence, threats of violence and the purposeful destruction of private and federal property. Energy Transfer is the latest legitimate business targeted by this network. Over several decades, certain once-legitimate not-for-profit groups have been

corrupted by money raised from individuals and a network of foundations and special interests willing to ‘contribute’ to advance their own political or business agendas. More recently, many smaller more violent eco-terrorist organizations and radicalized individuals have begun exploiting the same lucrative business model using the proliferation of web-based fundraising tools to make money, much of which is diverted for personal gain and not used to further any environmental cause. In its simplest form, this model has two components: (1) manufacturing a media

spectacle based upon phony but emotionally charged hot-button issues, sensational lies, and intentionally incited physical violence, property destruction, and other criminal conduct; and (2) relentlessly publicizing these sensational lies, manufactured conflict and conflagration, and misrepresented ’causes’ to generate funding from individual donors, foundations, and corporate sponsors. These putative ‘environmental’ groups accept grants and other consideration from foundations and special business interests who use the groups’ environmental mantle to advance their own ulterior agendas.”

“41. Over the past several decades, numerous environmental non-governmental organizations (‘ENGO’s’) putatively focused on the environment have been corrupted and coopted by money and special interests. As a result of that corruption, these putative environmental organizations have abandoned legitimate environmental action and instead regularly manufacture sensational and grossly misrepresented causes designed exclusively to perpetuate and enrich those organizations and their executives, and serve the interests of a shadowy network of foundations and business special interests who funnel monies to these organizations to serve their own undisclosed agendas. The central element of the business plans for these corrupted charitable organizations is to aggressively disseminate sensational, phony, and unsupportable claims to manufacture sham causes on topical hot-button issues, and then use those sham causes to raise funds from donors and special interests who might otherwise benefit from those causes.”

“42. One of the ways the corrupt organizations conceal their true operations is to create

the illusion that their ‘campaigns’ and high-profile ‘events’ are grassroots actions by volunteers and local ‘victims’ who are spontaneously rallying together for the promoted cause. In fact, these events are organized, funded, and produced by these corrupt ENGOs to create sensational media attention and drive traffic and donors to their websites. Wolfpacks of corrupt ENGOs regularly collaborate on these manufactured attacks, including ‘old-line’ ENGOs like Greenpeace and radical and fringe eco-terrorists who engage in disguised direct actions involving violence, property, and business destruction, and fabricated claims and ‘evidence’ of misconduct by those targeted by the campaigns.”

“45. That none of these corrupt organizations were driven by genuine environmental

concerns, but solely by their desire for donation-driven publicity is demonstrated by their

endorsement of and encouragement for the reckless, criminal acts of Direct Climate Action

activists who illegally and dangerously stopped the flow of five oil pipelines carrying Canadian oil sands in October 2016 by shutting valves at pumping stations, despite the substantial risk that the pipelines would rupture or explode. In response, Greenpeace USA stated: ‘Greenpeace supports the brave activists’ who engaged in these extremely reckless acts and created a substantial and immediate risk of a major environmental disaster.”

“51. For example, Greenpeace is stubbornly opposed to “Golden Rice,” which is

genetically enhanced to address the vitamin A deficiency suffered by millions of rice-dependent people in poor countries, a deficiency that causes preventable blindness and death on a massive scale. Indeed, the World Health Organization notes that there are more than 100 million vitamin A deficient children around the world, and that 250,000 to 500,000 children become blind every year, with 50 percent of them dying from their deficiency. …”

“56. In 2015, Greenpeace and other ENGOs manufactured baseless claims about

Professor Anne Glover, the chief scientific adviser to the European Commission, to procure her termination because she recognizes the benefits and safety of GMOs. The ENGOs accused her of giving one-sided opinions on genetically modified crops and that she falsely claims that there is a scientific consensus about their safety, and succeeded in eliminating her position, prompting her resignation.”

“90. After Earthjustice commenced the campaign, other Enterprise members quickly

followed suit. No later than August 2016, radical eco-terrorist organizations manufactured an international #NODAPL movement based on the false narrative launched by Earthjustice, and expanded the campaign to direct action against DAPL. These groups immediately set up “resistance camps” near DAPL construction sites as a base for coordinating violent protests and fomenting public disorder to disrupt DAPL construction. They recruited new members through videos and social media, encouraging and even paying them to travel to the camps, before training them to engage in criminal trespass, violence, and property destruction. They supplied materials for and directed these attacks, and provided free legal representation and bail for those arrested for such illegal activities.”

“104. The [Racketeering] Enterprise’s conduct had its intended effect. On Saturday, September 3, 2016, gathering protestors, led and whipped into a frenzy by Red Warrior and the false report that construction crews had purposely accelerated construction to destroy putative newly discovered sacred sites revealed in 11th hour court filings the day before, marched along Highway 1806 and attacked DAPL construction crews working within the pre-existing pipeline right-of-way, and away from any cultural resources identified by Mentz. The protesters illegally blocked traffic, and quickly became violent, trampling a wire construction fence and stampeding with hundreds of protesters, horses, dogs, and vehicles onto land where construction was ongoing. Protesters threatened security personnel with knives, hit them with fence posts and flagpoles, and otherwise physically attacked private security personnel retained by Energy Transfer, resulting in multiple security guards and dogs being hospitalized.”

“105. Consistent with its playbook, the [Racketeering] Enterprise sought to capitalize on the violent clashes it had intentionally incited between the protesters and DAPL construction workers and security guards to further their false narrative that Energy Transfer responded to ‘peaceful’ protesters with excessive use of force, as a pretext for additional fundraising efforts. …”

“106. Not only did the [Racketeering] Enterprise incite violence, it also directly and indirectly funded and supported encampments for radical violent protestors at Standing Rock to ensure that attention grabbing clashes with workers on the pipeline and company security would continue. On September 8, 2016, Greenpeace announced that it was organizing and hosting supply drives to fund, feed and house Red Warrior Camp in 10 cities across the country.”

“152. USACE likewise documented protestor violence, including an instance of a

Colorado woman who was charged with attempted murder while participating in protests, and noted the strain the protests were placing on local law enforcement. USACE reported that ‘families of police officers are reportedly being threatened, followed home, and having their residence photographed and videotaped.'”

“153. Threats of violence by protesters were so severe that USACE instructed

employees to ‘consider not wearing USACE logos or paraphernalia to and from work; Military members should consider wearing civilian clothes to and from work and change into uniform at the office,’ and to ‘identify multiple routes to and from work; avoid protesters completely and do not attempt to cross through gatherings; protests may appear peaceful but can escalate quickly.’ Instructions included detailed de-escalation tactics, such as the use of active listening, expressions of empathy, and taking notes on protestor concerns, and ultimately advise employees to ‘remove yourself from the situation at the first opportunity.’”

The Complaint with the Attachments