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400 |
Filed: 2/14/2013, Entered: 2/14/2013 |
Memo Endorsement |
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399 |
Filed: 2/13/2013, Entered: 2/13/2013 |
Motion to Withdraw as Attorney |
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398 |
Filed: 9/7/2012, Entered: None |
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ENDORSED LETTER addressed to Judge Lewis A. Kaplan from Craig Smyser dated 9/6/12 re: Counsel for the defendants writes to request that Chevron's improper and unauthorized letter brief of today be stricken from the record due to Chevron's demonstrated disregard for the Court's Individual Practices for discovery motions. ENDORSEMENT: The request to strike is denied. Applicants may submit a surreply affidavit or declarations responding to Dr. Romero's on or before September 14, 2012. It shall not exceed 5 pages in length. (Signed by Judge Lewis A. Kaplan on 9/7/2012) (mro) (Entered: 09/07/2012)
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397 |
Filed: 6/20/2012, Entered: None |
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MEMO ENDORSEMENT on DEFENDANTS HUGO GERARDO CAMACHO NARANJO'S AND JAVIER PIAGUAJE PAYAGUAJE'S MOTION FOR CLARIFICATION OF THE SCOPE OF THE APRIL 2, 2012 MEMORANDUM OPINION EXONERATING AND DISCHARGING PRELIMINARY INJUNCTION BOND AND TO RESOLVE OUTSTANDING MOTION TO EXONERATE AND DISCHARGE SAME BOND [DI 381]. ENDORSEMENT: On March 7, 2012, the Court granted Chevron's motion for a preliminary injunction in Chevron Corp. v. Danziger, 11 Civ. 0691 (LAK), and conditioned that relief on the posting of a bond in the amount of $21.8 million. Chevron duly posted the bond, which was docketed as docket item 198 in 11 Civ. 0691. Following the appellate decision on appeals from that injunction, Chevron moved for an order exonerating the bond. Although the caption correctly entitled the case Chevron Corp. v. Danziger, it bore both the docket number of the case in which the bond was posted as well as the additional 11 Civ. 3718 (LAK) number. In any case, Chevron's motion was granted "in all respects" and the bond was "exonerated and discharged." 11 Civ. 0691 (LAK), DI 459. Defendants nevertheless move for "clarification" in No. 11 Civ. 3718 (LAK). The one and only bond ever required or posted in the controversies between any of these parties in this Court before the undersigned was exonerated and discharged on April2, 2012. There is not the slightest need for clarification of anything. Motion denied. Denying 393 Motion For Clarification of the Scope of the April 2, 2012 Memorandum Opinion Exonerating and Discharging Preliminary Injunction Bond. (Signed by Judge Lewis A. Kaplan on 6/20/2012) (rjm) (Entered: 06/21/2012)
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396 |
Filed: 6/18/2012, Entered: None |
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REPLY MEMORANDUM OF LAW in Support re: 393 MOTION For Clarification of the Scope of the April 2, 2012 Memorandum Opinion Exonerating and Discharging Preliminary Injunction Bond.. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio) (Entered: 06/18/2012)
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395 |
Filed: 6/7/2012, Entered: None |
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MEMORANDUM OF LAW in Opposition re: 393 MOTION For Clarification of the Scope of the April 2, 2012 Memorandum Opinion Exonerating and Discharging Preliminary Injunction Bond.. Document filed by Chevron Corporation. (Mastro, Randy) (Entered: 06/07/2012)
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394 |
Filed: 5/24/2012, Entered: None |
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DECLARATION of Julio C. Gomez in Support re: 393 MOTION For Clarification of the Scope of the April 2, 2012 Memorandum Opinion Exonerating and Discharging Preliminary Injunction Bond.. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Gomez, Julio) (Entered: 05/24/2012)
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Request |
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393 |
Filed: 5/24/2012, Entered: None |
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MOTION For Clarification of the Scope of the April 2, 2012 Memorandum Opinion Exonerating and Discharging Preliminary Injunction Bond. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(Gomez, Julio) (Entered: 05/24/2012)
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392 |
Filed: 5/22/2012, Entered: None |
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FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION For Clarification of the Scope of the April 2, 2012 Memorandum Opinion. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Attachments: # 1 Affidavit Declaration of Julio C. Gomez, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C)(Gomez, Julio) Modified on 5/24/2012 (db). (Entered: 05/22/2012)
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Request |
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391 |
Filed: 5/2/2012, Entered: None |
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FILING ERROR - NO ORDER SELECTED FOR APPEAL - NOTICE OF APPEAL. Document filed by Patton Boggs LLP. Filing fee $ 455.00, receipt number 0208-7433120. Form C and Form D are due within 14 days to the Court of Appeals, Second Circuit. (Young, S. Alyssa) Modified on 5/2/2012 (nd). (Entered: 05/02/2012)
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390 |
Filed: 4/2/2012, Entered: None |
Declaration in Support of Motion |
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DECLARATION of Randy M. Mastro in Support re: [381] MOTION for Order to Show Cause / [PROPOSED] ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT EXONERATE CHEVRON'S $21.8 MILLION BOND..
Document filed by Chevron Corporation. (Attachments: # (1) Exhibit 1,
# (2) Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4)(Mastro, Randy)
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389 |
Filed: 4/2/2012, Entered: None |
Reply Memorandum of Law in Support of Motion |
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REPLY MEMORANDUM OF LAW in Support re: [381] MOTION for Order to Show Cause / [PROPOSED] ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT EXONERATE CHEVRON'S $21.8 MILLION BOND.. Document filed by Chevron Corporation. (Mastro, Randy)
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388 |
Filed: 3/27/2012, Entered: None |
Joinder |
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JOINDER to join re: [386] Response in Opposition to Motion, PLAINTIFF CHEVRON CORPORATION'S MOTION TO EXONERATE CHEVRON'S $21.8 MILLION BOND. Document filed by Steven Donziger, Donziger & Associates PLLC, The Law Offices of Steven R. Donziger.(Keker, John)
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387 |
Filed: 3/27/2012, Entered: None |
Declaration in Opposition to Motion |
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DECLARATION of Craig Smyser in Opposition re: [381] MOTION for Order to Show Cause / [PROPOSED] ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT EXONERATE CHEVRON'S $21.8 MILLION BOND..
Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3)
Exhibit 3, # (4) Exhibit 4, # (5) Exhibit 5, # (6) Exhibit 6, # (7)
Exhibit 7)(Doyle, Tyler)
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386 |
Filed: 3/27/2012, Entered: None |
Response in Opposition to Motion |
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RESPONSE in Opposition re: [381] MOTION for Order to Show Cause / [PROPOSED] ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT EXONERATE CHEVRON'S $21.8 MILLION BOND.. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Doyle, Tyler)
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385 |
Filed: 3/15/2012, Entered: None |
Certificate of Service Other |
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CERTIFICATE OF SERVICE of
Memorandum Endorsed Order to Show Cause Why This Court Should Not
Exonerate Chevron's $21.8 Million Bond. Document filed by Chevron
Corporation. (Mastro, Randy)
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384 |
Filed: 3/13/2012, Entered: None |
Memo Endorsement |
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MEMO ENDORSEMENT on re: (423 in 1:11-cv-00691-LAK) MOTION for Order to Show Cause / [PROPOSED] ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT EXONERATE CHEVRON'S $21.8 MILLION BOND filed by Chevron Corporation, (381 in 1:11-cv-03718-LAK-JCF) MOTION for Order to Show Cause / [PROPOSED] ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT EXONERATE CHEVRON'S $21.8 MILLION BOND
filed by Chevron Corporation: Plaintiff has presented the Court with a
proposed order to show cause why the preliminary injunction bond posted
by Chevron in connection with the preliminary injunction entered in this
case should not be exonerated. Its papers, however, do not make the
requisite clear and specific showing of good and sufficient reasons why a
procedure other than notice of motion is necessary. See S.D.N.Y. Civ.
R. 6.1(d). Accordingly, the Court declines to sign the order to show
cause. As the order to show cause and supporting papers already have
been filed electronically, the proposed order to show cause is deemed to
be a notice of motion. The filing of answering and reply papers shall
be governed by the schedule establish by that Rule. (Signed by Judge
Lewis A. Kaplan on 3/13/2012) (lmb)
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383 |
Filed: 3/13/2012, Entered: None |
Declaration in Support of Motion |
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DECLARATION of Randy M. Mastro in Support re: [381] MOTION for Order to Show Cause / [PROPOSED] ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT EXONERATE CHEVRON'S $21.8 MILLION BOND..
Document filed by Chevron Corporation. (Attachments: # (1) Exhibit 1,
# (2) Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4, # (5) Exhibit 5, #
(6) Exhibit 6, # (7) Exhibit 7, # (8) Exhibit 8, # (9) Exhibit 9, # (10)
Exhibit 10, # (11) Exhibit 11, # (12) Exhibit 12, # (13) Exhibit 13, #
(14) Exhibit 14, # (15) Exhibit 15, # (16) Exhibit 16, # (17) Exhibit
17, # (18) Exhibit 18)(Mastro, Randy)
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Request |
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382 |
Filed: 3/13/2012, Entered: None |
Memorandum of Law in Support of Motion |
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MEMORANDUM OF LAW in Support re: [381] MOTION for Order to Show Cause / [PROPOSED] ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT EXONERATE CHEVRON'S $21.8 MILLION BOND.. Document filed by Chevron Corporation. (Mastro, Randy)
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381 |
Filed: 3/13/2012, Entered: None, Terminated: 3/13/2012 |
~Motion for Order to Show Cause |
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MOTION for Order to Show Cause / [PROPOSED] ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT EXONERATE CHEVRON'S $21.8 MILLION BOND. Document filed by Chevron Corporation.(Mastro, Randy)
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380 |
Filed: 2/21/2012, Entered: None |
Order on Motion for Recusal |
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ORDER granting [378] Motion for
Recusal; granting [379] Motion for Recusal; granting [379] Motion to
Withdraw. The motion [DI 379] to withdraw a motion for recusal [DI 378]
is granted. In conformity with the mandate of the Court of Appeals [DI
377], plaintiffs claim for injunctive and declaratory relief under the
Recognition Act is dismissed in its entirety. The Clerk shall terminate
all pending motions in this case. (Signed by Judge Lewis A. Kaplan on
2/21/2012) (ft)
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379 |
Filed: 2/17/2012, Entered: None, Terminated: 2/21/2012 |
Motion for Recusal |
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MOTION for Recusal (Notice of Withdrawal of Recusal Motion).,
MOTION to Withdraw [378] MOTION for Recusal.. Document filed by Steven
Donziger, Donziger & Associates PLLC, The Law Offices of Steven R.
Donziger.(Hirsch, Steven)
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378 |
Filed: 2/17/2012, Entered: None, Terminated: 2/21/2012 |
Motion for Recusal |
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MOTION for Recusal. Document
filed by Steven Donziger, Donziger & Associates PLLC, The Law
Offices of Steven R. Donziger.(Keker, John)
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377 |
Filed: 2/16/2012, Entered: None |
USCA Mandate |
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MANDATE of USCA (Certified Copy)
as to [98] Notice of Appeal filed by Javier Piaguaje Payaguaje, Hugo
Gerardo Camacho Naranjo. USCA Case Number 11-1150-cv(L),
11-1264-cv(con). Ordered, Adjudged and Decreed that the preliminary
injunction of the District Court is VACATED and REMANDED to the District
Court with instructions in accordance with the opinion of this Court.
Catherine O'Hagan Wolfe, Clerk USCA for the Second Circuit. Issued As
Mandate: 02/16/2012. (Original document entered in case number:
11cv0691, Doc # 390).(nd)
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Request |
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376 |
Filed: 1/27/2012, Entered: None |
USCA Order |
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TRUE COPY OPINION of USCA.....
USCA Case Number 11-1150-cv(L), 11-1264-cv(con). Accordingly, for the
foregoing reason and consistent with our September 19, 201 order, the
judgment of the District Court is REVERSED and the preliminary
injunction VACATED. WE REMAND to the District Court with the
instructions to DISMISS Chevron's claim for injunctive and declaratory
relief under the Recognition Act in its entirety. Catherine O'Hagan
Wolfe, Clerk USCA for the Second Circuit. Certified: 01/26/2012.
(Original document entered in case number: 11cv0691, Doc # 385).(nd)
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Request |
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375 |
Filed: 12/15/2011, Entered: None |
Memo Endorsement |
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MEMO ENDORSEMENT on Motion to
Withdraw as Attorney: Carlos A. Zelaya, II is no longer affiliated with
F. Gerald Maples, P.A., and therefore moves to withdraw his appearance
as counsel for Javier Piaguaje Payaguaje and Hugo Gerardo Camacho
Naranjo in the above-captioned action. Messrs. Piaguaje Payaguaje and
Camacho Naranjo continue to be represented by Gomez LLC, Smyser, Kaplan
&Veselka, and F. Gerald Maples, P.A., and this Notice is being
served on the parties through those counsel. This proceeding is
presently stayed. (Signed by Judge Lewis A. Kaplan on 12/15/2011) (ae)
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374 |
Filed: 12/13/2011, Entered: None |
Notice of Change of Address |
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NOTICE OF CHANGE OF ADDRESS by
James J. Rohn on behalf of Joseph C. Kohn, Kohn Swift & Graf, P.C..
New Address: Conrad O'Brien, PC, 1500 Market Street, Suite 3900, Centre
Square West, Philadelphia, Pennsylvania, USA 19102-2100, 215-864-8074.
(Rohn, James)
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373 |
Filed: 12/9/2011, Entered: None |
Notice of Change of Address |
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NOTICE OF CHANGE OF ADDRESS by
Patricia Mary Hamill on behalf of Joseph C. Kohn, Kohn Swift & Graf,
P.C.. New Address: Conrad O'Brien PC, 1500 Market Street, Centre
Square, West Tower, Ste. 3900, Philadelphia, PA, USA 19102,
215-864-9600. (Hamill, Patricia)
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372 |
Filed: 12/9/2011, Entered: None |
Notice of Change of Address |
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NOTICE OF CHANGE OF ADDRESS by
Joshua J. Voss on behalf of Joseph C. Kohn, Kohn Swift & Graf, P.C..
New Address: Conard O'Brien PC, 1500 Market Street, Centre Square, West
Tower, Ste. 3900, Philadelphia, PA, USA 19102, 215-864-9600. (Voss,
Joshua)
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371 |
Filed: 12/7/2011, Entered: None |
Order on Motion to Withdraw as Attorney |
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MEMO ENDORSEMENT on MOTION TO
WITHDRAW AS ATTORNEY. ENDORSEMENT: Granted. So ordered. Granting [369]
Motion to Withdraw as Attorney. Attorney Carlos A. Zelaya, II
terminated. (Signed by Judge Lewis A. Kaplan on 12/6/2011) (rjm)
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370 |
Filed: 12/6/2011, Entered: None |
Affidavit in Support of Motion |
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AFFIDAVIT of Carlos A. Zelaya,
II in Support re: [369] MOTION for Carlos A. Zelaya, II to Withdraw as
Attorney.. Document filed by Hugo Gerardo Camacho Naranjo, Javier
Piaguaje Payaguaje. (Zelaya, Carlos)
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369 |
Filed: 12/6/2011, Entered: None, Terminated: 12/7/2011 |
Motion to Withdraw as Attorney |
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MOTION for Carlos A. Zelaya,
II to Withdraw as Attorney. Document filed by Hugo Gerardo Camacho
Naranjo, Javier Piaguaje Payaguaje.(Zelaya, Carlos)
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368 |
Filed: 12/6/2011, Entered: None, Terminated: 12/6/2011 |
Motion to Withdraw as Attorney |
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FILING ERROR - DEFICIENT DOCKET
ENTRY - MOTION for Carlos A. Zelaya, II to Withdraw as Attorney.
Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Attachments: # (1) Affidavit In Support of Motion to
Withdraw)(Zelaya, Carlos) Modified on 12/6/2011 (db).
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Request |
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367 |
Filed: 11/30/2011, Entered: None |
Notice of Change of Address |
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NOTICE OF CHANGE OF ADDRESS by
Carlos A. Zelaya, II on behalf of Hugo Gerardo Camacho Naranjo, Javier
Piaguaje Payaguaje. New Address: Mumphrey Law Firm, L.L.C., 330 Oak
Harbor Blvd., Suite D, Slidell, LA, 70458, 985-649-0709. (Zelaya,
Carlos)
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366 |
Filed: 10/20/2011, Entered: None |
USCA Mandate |
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MANDATE of USCA (Certified Copy)
as to [98] Notice of Appeal filed by Javier Piaguaje Payaguaje, Hugo
Gerardo Camacho Naranjo USCA Case Number 11-1150-cv(L), 11-1264-cv(con),
11-2259-op(con), 11-2732-cv. Upon due consideration, it is hereby
ORDERED that the appeal docketed under 11-2732-cv is DISMISSED and the
Appellants' motion for consolidation is DENIED as moot. Catherine
O'Hagan Wolfe, Clerk USCA for the Second Circuit. Issued As Mandate:
10/20/2011. (nd)
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365 |
Filed: 10/20/2011, Entered: None |
USCA Mandate |
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MANDATE of USCA (Certified Copy)
as to [98] Notice of Appeal filed by Javier Piaguaje Payaguaje, Hugo
Gerardo Camacho Naranjo USCA Case Number 11-1150-cv(L), 11-1264-cv(con),
11-2259-op(con). Petitioners Hugo Gerardo Camacho Naranjo and Javier
Piaguaje, through counsel, petition this Court for a writ of mandamus,
seeking to compel the recusal of District Court Judge Lewis A. Kaplan.
Upon due consideration, it is hereby ORDERED that the mandamus petition
is DENIED. IT IS FURTHER ORDERED that the appeal from the issuance of a
preliminary injunction issued, docketed in this Court under 11-1150-cv,
the preliminary injunction issued by the District Court on March 7, 2011
is VACATED in its entirety upon entry of this Order. IT IS FURTHER
ORDERED that the motion for a stay of the District Court's proceedings
on Count 9 of the Complaint, renewed by counsel at oral argument before
this Court on September 16, 2011, is GRANTED. Catherine O'Hagan Wolfe,
Clerk USCA for the Second Circuit. Issued As Mandate: 10/20/2011. (nd)
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364 |
Filed: 9/27/2011, Entered: None |
Endorsed Letter |
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ENDORSED LETTER addressed to
Judge Lewis A. Kaplan from Randy M. Mastro dated 9/20/2011 re: counsel
for plaintiff seeks confirmation from the Court that yesterday's order
from the Second Circuit staying the Count Nine proceedings applies to
this Order. ENDORSEMENT: The matter is stayed as of now. (Signed by
Judge Lewis A. Kaplan on 9/27/2011) (pl)
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363 |
Filed: 9/21/2011, Entered: None |
Memo Endorsement |
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MEMO ENDORSEMENT on re: [348]
MOTION for Robert C. Blume, Oscar Garza, & Peter E. Seley to Appear
Pro Hac Vice, filed by Chevron Corporation. ENDORSEMENT: File unsigned.
(Signed by Judge Lewis A. Kaplan on 9/21/11) (laq)
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362 |
Filed: 9/21/2011, Entered: None |
Memo Endorsement |
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MEMO ENDORSEMENT on re: [346]
MOTION for John Timothy Byrd to Appear Pro Hac Vice, filed by Javier
Piaguaje Payaguaje, Hugo Gerardo Camacho Naranjo. ENDORSEMENT: File
unsigned. (Signed by Judge Lewis A. Kaplan on 9/21/11) (laq)
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360 |
Filed: 9/20/2011, Entered: None |
Order on Motion to Compel |
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MEMORANDUM AND ORDER granting
[264] Motion to Compel. The defendants' motion to compel (Docket no.
264) is granted to the extent that, by September 23, 2011, Chevron shall
identify individually each document withheld from discovery, including
(1) the type of document, (2) the general subject matter, (3) the date,
and (4) any other information necessary to identify the document and
evaluate the claim of privilege, including where appropriate, the author
and addressees, any other recipients, and the relationship among the
author and each recipient. (Signed by Magistrate Judge James C. Francis
on 9/19/2011) Copies Mailed By Chambers. (lmb)
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361 |
Filed: 9/19/2011, Entered: None |
USCA Order |
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TRUE COPY ORDER of USCA as to
[98] Notice of Appeal filed by Javier Piaguaje Payaguaje, Hugo Gerardo
Camacho Naranjo USCA Case Number 11-1150-cv(L); 11-1264-cv(con);
11-2259-cv(con). Upon due consideration, it is hereby ORDERED that the
mandamus petition, docketed under 11-2259-op is DENIED. IT IS FURTHER
ORDERED that in the appeal form the issuance of a preliminary injunction
issued in Chevron Corp v. Donziger, 768 F. Supp. 2d 58a, 660
(S.D.N.Y. 2011), docketed in this Court under 11-1150-cv, the
preliminary injunction issued by the District Court on Marcy 7, 2011 is
VACATED in its entirety upon entry of this Order. IT IS FURTHER ORDERED
that the motion for a stay of the District Court's proceedings on Count 9
of the Compliant, renewed by counsel at oral argument before this Court
on Sep. 16, 2011 is GRANTED. Catherine O'Hagan Wolfe, Clerk USCA for
the Second Circuit. Certified: 9/19/2011. (nd)
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359 |
Filed: 9/19/2011, Entered: None, Terminated: 2/21/2012 |
Motion to Compel |
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MOTION to Compel Andrew Woods
to give testimony. Document filed by Chevron Corporation. (Attachments:
# (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, #
(5) Exhibit E)(Mastro, Randy)
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Request |
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358 |
Filed: 9/19/2011, Entered: None |
Order on Motion to Appear Pro Hac Vice |
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ORDER granting [348] Motion for
Robert C. Blume, Oscar Garza and Peter E. Seley to Appear Pro Hac Vice.
ENDORSEMENT: Granted. (Signed by Judge Lewis A. Kaplan on 9/16/2011)
(lmb)
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Request |
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357 |
Filed: 9/19/2011, Entered: None |
Order on Motion to Appear Pro Hac Vice |
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ORDER granting [346] Motion for
John Timothy Byrd to Appear Pro Hac Vice. ENDORSEMENT: Granted. (Signed
by Judge Lewis A. Kaplan on 9/16/2011) (lmb) Modified on 9/19/2011
(lmb).
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Request |
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356 |
Filed: 9/19/2011, Entered: None |
Order |
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MEMORANDUM AND ORDER re: [198] MOTION to Continue Trial Setting
filed by Javier Piaguaje Payaguaje, Hugo Gerardo Camacho Naranjo.
Accordingly, the LAP Representatives promptly shall inform Chevron and
the Court whether the stipulation is offered on behalf of all of the
plaintiffs in the Lago Agrio case. Chevron then may address the
significance, if any, of the stipulation for the motion to continue the
trial, and the LAP Representatives may respond to Chevron's submission.
Chevron's submission shall be filed no later than three business days
following the receipt of the LAP Representatives advice as to whether
the stipulation is offered on behalf of all of the Lago Agrio
plaintiffs. The LAP Representatives' reply shall be filed no later than
three business days following the filing of Chevron's submission.
(Signed by Judge Lewis A. Kaplan on 9/19/2011) (tro)
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Request |
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353 |
Filed: 9/16/2011, Entered: None |
Notice of Filing Transcript |
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NOTICE OF FILING OF OFFICIAL
TRANSCRIPT Notice is hereby given that an official transcript of a
Conference proceeding held on 8/2/11 has been filed by the court
reporter/transcriber in the above-captioned matter. The parties have
seven (7) calendar days to file with the court a Notice of Intent to
Request Redaction of this transcript. If no such Notice is filed, the
transcript may be made remotely electronically available to the public
without redaction after 90 calendar days...(McGuirk, Kelly)
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Request |
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352 |
Filed: 9/16/2011, Entered: None |
Transcript |
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TRANSCRIPT of Proceedings re:
Conference held on 8/2/2011 before Judge Lewis A. Kaplan. Court
Reporter/Transcriber: Tara Jones, (212) 805-0300. Transcript may be
viewed at the court public terminal or purchased through the Court
Reporter/Transcriber before the deadline for Release of Transcript
Restriction. After that date it may be obtained through PACER.
Redaction Request due 10/10/2011. Redacted Transcript Deadline set for
10/20/2011. Release of Transcript Restriction set for
12/19/2011.(McGuirk, Kelly)
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Request |
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351 |
Filed: 9/16/2011, Entered: None |
Order |
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ORDER: that the LAP
Representatives shall serve and file, no later than 9/21/2011, one or
more detailed affidavits or declarations by persons with personal
knowledge setting forth, with respect to each of plaintiffs requests for
admission that defendants claimed they Jacked knowledge sufficient to
admit or deny, what efforts were made to enable them to obtain the
necessary knowledge and, if any efforts were made unsuccessfully, why
the efforts did not succeed. (Signed by Judge Lewis A. Kaplan on
9/16/2011) (ft)
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Request |
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350 |
Filed: 9/15/2011, Entered: None |
Memorandum of Law in Opposition to Motion |
|
MEMORANDUM OF LAW in
Opposition re: [339] MOTION to Compel LAURA GARR to GIVE TESTIMONY..
Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
349 |
Filed: 9/15/2011, Entered: None |
Response to Motion |
|
RESPONSE to Motion re: [338]
MOTION to Compel DEFENDANTS JAVIER PIAGUAJE PAYAGUAJE AND HUGO GERARDO
CAMACHO NARANJO to RESPONSES TO FIRST SUPPLEMENTAL SET OF REQUESTS FOR
ADMISSIONS AND FOR OTHER RELIEF.. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Doyle, Tyler)
|
|
Request |
 |
|
|
347 |
Filed: 9/15/2011, Entered: None |
Order |
|
ORDER: Plaintiff shall serve and
file its exhibit list no later than October 14, 2011. Defendants shall
serve and file their exhibit list no later than October 21, 2011. The
parties shall set forth any stipulation with respect to the authenticity
and admissibility of exhibits and indicate all objections to exhibits
and the grounds therefor no later than October 31, 2011. Plaintiff shall
serve and file its witness list no later than October 14, 2011.
Defendants shall serve and file their witness list no later than October
21, 2011. Plaintiff shall serve and file its witness designations no
later than October 21, 2011. Any objections to defendant's designation
shall be served and filed no later than November 1, 2011. Defendants
shall serve and file witness designations no later than October 26,
2011. Any objections to plaintiff's designations shall be served and
filed no later than October 27, 2011. (Signed by Judge Lewis A. Kaplan
on 9/15/2011) (rdz)
|
|
Request |
 |
|
|
348 |
Filed: 9/14/2011, Entered: None, Terminated: 9/19/2011 |
Motion to Appear Pro Hac Vice |
|
MOTION for Robert C. Blume,
Oscar Garza, & Peter E. Seley to Appear Pro Hac Vice. Document filed
by Chevron Corporation.(pgu)
|
|
Request |
 |
|
|
346 |
Filed: 9/14/2011, Entered: None, Terminated: 9/19/2011 |
Motion to Appear Pro Hac Vice |
|
MOTION for John Timothy Byrd to
Appear Pro Hac Vice. Document filed by Hugo Gerardo Camacho Naranjo,
Javier Piaguaje Payaguaje.(pgu)
|
|
Request |
 |
|
|
345 |
Filed: 9/14/2011, Entered: None |
Declaration in Opposition to Motion |
|
DECLARATION of Jarod Stewart in
Opposition re: [310] MOTION to Compel DEFENDANTS JAVIER PIAGUAJE
PAYAGUAJE AND HUGO GERARDO CAMACHO NARANJO to apear for depositions in
New York.. Document filed by Hugo Gerardo Camacho Naranjo, Javier
Piaguaje Payaguaje. (Doyle, Tyler)
|
|
Request |
 |
|
|
344 |
Filed: 9/14/2011, Entered: None |
Response in Opposition to Motion |
|
RESPONSE in Opposition re: [310]
MOTION to Compel DEFENDANTS JAVIER PIAGUAJE PAYAGUAJE AND HUGO GERARDO
CAMACHO NARANJO to apear for depositions in New York.. Document filed
by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.
(Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3) Exhibit 3, # (4)
Exhibit 4, # (5) Exhibit 5)(Doyle, Tyler)
|
|
Request |
 |
|
|
343 |
Filed: 9/14/2011, Entered: None |
Order |
|
ORDER: that motion [DI 328] is denied in all respects. (Signed by Judge Lewis A. Kaplan on 9/14/2011) (ft)
|
|
Request |
 |
|
|
342 |
Filed: 9/14/2011, Entered: None |
Reply to Response to Motion |
|
REPLY to Response to Motion re: [325] MOTION for Order to Show Cause Memorandum
of Law in Support of Application by Order to Show Cause Why Defendants
Motion to Compel Supplemental 30b6 Deposition Should Not be Granted..
Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Attachments: # (1) Exhibit Exhibit A to Reply)(Doyle,
Tyler)
|
|
Request |
 |
|
|
341 |
Filed: 9/14/2011, Entered: None |
Objection (non-motion) |
|
Objection re: [254] Objection (non-motion), Objection (non-motion) Response to Chevron's Limited Objections to Judge Francis's August 19, 2011 Order. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Doyle, Tyler)
|
|
Request |
 |
|
|
340 |
Filed: 9/14/2011, Entered: None |
Memorandum of Law in Opposition |
|
MEMORANDUM OF LAW in
Opposition re: [328] Order on Motion for Order to Show Cause,,,,,.
Document filed by Chevron Corporation. (Attachments: # (1) Exhibit A, #
(2) Exhibit B, # (3) Exhibit C)(Mastro, Randy)
|
|
Request |
 |
|
|
339 |
Filed: 9/13/2011, Entered: None, Terminated: 2/21/2012 |
Motion to Compel |
|
MOTION to Compel LAURA GARR to
GIVE TESTIMONY. Document filed by Chevron Corporation. (Attachments: #
(1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C)(Mastro, Randy)
|
|
Request |
 |
|
|
338 |
Filed: 9/13/2011, Entered: None, Terminated: 2/21/2012 |
Motion to Compel |
|
MOTION to Compel DEFENDANTS
JAVIER PIAGUAJE PAYAGUAJE AND HUGO GERARDO CAMACHO NARANJO to RESPONSES
TO FIRST SUPPLEMENTAL SET OF REQUESTS FOR ADMISSIONS AND FOR OTHER RELIEF.
Document filed by Chevron Corporation. (Attachments: # (1) Exhibit 1, #
(2) Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4, # (5) Exhibit 5, # (6)
Exhibit 6, # (7) Exhibit 7, # (8) Exhibit 8, # (9) Exhibit 9, # (10)
Exhibit 10, # (11) Exhibit 11, # (12) Exhibit 12, # (13) Exhibit
13)(Mastro, Randy)
|
|
Request |
 |
|
|
337 |
Filed: 9/13/2011, Entered: None |
Scheduling Order |
|
ORDER: Motions in limine due by
10/17/2011. Responses due by 10/24/2011 Replies due by 10/27/2011. Any
other aspects of motions in limine shall be governed the Court's
Individual Practices. (Signed by Judge Lewis A. Kaplan on 9/13/2011)
(ft)
|
|
Request |
 |
|
|
336 |
Filed: 9/13/2011, Entered: None |
Order on Motion for Order to Show Cause |
|
MEMO ENDORSEMENT granting [313]
Motion for Order to Show Cause. ENDORSEMENT: Plaintiff is deemed to have
moved for a protective order as set forth in the proposed order to show
cause. DI 313. That motion is granted. The depositions are
precluded. (See order for entire endorsement.) (Signed by Judge Lewis
A. Kaplan on 9/13/2011) (jar)
|
|
Request |
 |
|
|
335 |
Filed: 9/13/2011, Entered: None |
Order |
|
ORDER: For the reasons set forth
in this order, the objections set forth in the Defendants' Privilege
Logs are upheld. (Signed by Magistrate Judge James C. Francis on
9/13/2011) Copies Mailed By Chambers. (djc)
|
|
|
 |
|
|
334 |
Filed: 9/13/2011, Entered: None |
Brief |
|
FILING ERROR - WRONG DOCUMENT
TYPE SELECTED FROM MENU - BRIEF re: [254] Objection (non-motion),
Objection (non-motion) in Response to Chevron's Limited Objections to
Judge Francis's August 19, 2011 Order. Document filed by Hugo Gerardo
Camacho Naranjo, Javier Piaguaje Payaguaje.(Doyle, Tyler) Modified on
9/14/2011 (ka).
|
|
Request |
 |
|
|
333 |
Filed: 9/13/2011, Entered: None |
Certificate of Service Other |
|
CERTIFICATE OF SERVICE of Docket
#328 - Order served on Chevron on 09/13/2011 at 10:51 a.m.. Document
filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.
(Doyle, Tyler)
|
|
Request |
 |
|
|
332 |
Filed: 9/13/2011, Entered: None |
Notice of Filing Transcript |
|
NOTICE OF FILING OF OFFICIAL
TRANSCRIPT Notice is hereby given that an official transcript of a
Conference proceeding held on 8/2/11 has been filed by the court
reporter/transcriber in the above-captioned matter. The parties have
seven (7) calendar days to file with the court a Notice of Intent to
Request Redaction of this transcript. If no such Notice is filed, the
transcript may be made remotely electronically available to the public
without redaction after 90 calendar days...(McGuirk, Kelly)
|
|
Request |
 |
|
|
331 |
Filed: 9/13/2011, Entered: None |
Transcript |
|
TRANSCRIPT of Proceedings re:
Conference held on 8/2/2011 before Judge Lewis A. Kaplan. Court
Reporter/Transcriber: Tara Jones, (212) 805-0300. Transcript may be
viewed at the court public terminal or purchased through the Court
Reporter/Transcriber before the deadline for Release of Transcript
Restriction. After that date it may be obtained through PACER.
Redaction Request due 10/7/2011. Redacted Transcript Deadline set for
10/17/2011. Release of Transcript Restriction set for
12/15/2011.(McGuirk, Kelly)
|
|
Request |
 |
|
|
330 |
Filed: 9/13/2011, Entered: None |
Certificate of Service Other |
|
CERTIFICATE OF SERVICE of
Defendants Motion to Compel Supplemental Deposition of Chevron's 30b6
Witness served on all counsel of record on 09/13/2011. Document filed
by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Doyle,
Tyler)
|
|
Request |
 |
|
|
329 |
Filed: 9/13/2011, Entered: None |
Order on Motion for Order to Show Cause |
|
MEMO ENDORSEMENT denying [320]
Motion for Order to Show Cause. ENDORSEMENT: The movants are obliged by
the Court's previous order to appear for depositions in New York today
and tomorrow as scheduled. After 9 p.m. last evening, they
electronically filed an application for an order to show cause why a
protective order should not be granted and a stay of the depositions.
They claim that they cannot lawfully appear in New York for depositions
today and tomorrow because one of them lacks a passport and neither has a
visa, an argument that they did not make in resisting Chevron's
application to compel them to appear for examination in New York. [DI
219]. No support is offered for the proposition that a visa would be
required to enter this country. The Court sees no reason to stay the
depositions, as the proposed order to show cause seeks. The movants are
under an obligation to comply with this Court's order. If they do not
do so and Chevron seeks no relief based on that failure, there will be
nothing left to decide. If Chevron, on the other hand, seeks sanctions
or other relief based upon their failure to appear, the movants would be
permitted to argue that they could not lawfully enter the United States
in order to comply with the Court's order despite diligent efforts to
obtain any documents and visas that may be required. There is no
emergency here. The application for an order to show cause why a
protective order should not be granted [DI 320] is denied. (Signed by
Judge Lewis A. Kaplan on 9/13/2011) (mro)
|
|
Request |
 |
|
|
328 |
Filed: 9/13/2011, Entered: None |
Order on Motion for Order to Show Cause |
|
ORDER ON DEFENDANTS HUGO GERARDO
CAMACHO NARANJO'S AND JAVIER PIAGUAJE PYAGUAJE'S MEMORANDUM OF LAW IN
SUPPORT OF APPLICATION BY ORDER TO SHOW CAUSE WHY DEFENDANTS' MOTION TO
COMPEL THE SUPPLEMENTAL DEPOSITION OF CHEVRON'S 30(b)(6) WITNESS SHOULD
NOT BE GRANTED, OR IN THE ALTERNATIVE MOTION FOR LEAVE TO NOTICE
SUPPLEMENTAL DEPOSITION OF CHEVRON'S 30(b)(6) WITNESS re: [324] Motion
for Order to Show Cause. It is hereby: ORDERED that service of a copy
of this Order and of all of the papers submitted in support thereof, by
facsimile or email, upon counsel for Plaintiff Chevron Corporation, on
or before 11 a.m. on September 13, 2011, shall be deemed good and
sufficient service thereof; and it is further Ordered that Chevron show
cause why the Court should not grant the LAP representative's Motion to
Compel the Supplementary 30(b)(6) deposition scheduled to proceed on
September 15th, 2011. Answering papers, if any, shall be served and
filed electronically on or before 10:00 a.m. on September 14, 2011; and
it is further Ordered that reply papers, if any, shall be served and
filed electronically on or before 1 p.m. EDT on September 14, 2011, and
it is further Ordered, that counsel shall meet and confer forthwith with
respect to the proposed topics set out in the notice of deposition.
(Signed by Judge Lewis A. Kaplan on 9/13/2011) (mro)
|
|
Request |
 |
|
|
354 |
Filed: 9/12/2011, Entered: None |
Letter |
|
Letter addressed to Magistrate
Judge James C. Francis from Randy M. Mastro dated 9/7/2011 re: Counsel
of plaintiff requests the Court's permission to provide the materials on
a rolling basis over the next week from 9/9-16 given the practical
challenges of processing and delivering such a large volume of files.
(jfe)
|
|
Request |
 |
|
|
327 |
Filed: 9/12/2011, Entered: None |
Certificate of Service Other |
|
CERTIFICATE OF SERVICE of MOL
and Declaration on Show Cause for Motion to Compel 30b6 Deposition
served on all counsel of record on September 12, 2011. Document filed
by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Doyle,
Tyler)
|
|
Request |
 |
|
|
326 |
Filed: 9/12/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Christina Bryan in Support re: [325] MOTION for Order to Show Cause Memorandum
of Law in Support of Application by Order to Show Cause Why Defendants
Motion to Compel Supplemental 30b6 Deposition Should Not be Granted., [324] MOTION for Order to Show Cause Why Defendants Motion to Compel the Supplemental Deposition of Chevron 30b6 Witness Should not be Granted..
Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Attachments: # (1) Exhibit A Notice of Deposition, # (2)
Exhibit B Correspondence)(Doyle, Tyler)
|
|
Request |
 |
|
|
325 |
Filed: 9/12/2011, Entered: None, Terminated: 2/21/2012 |
~Motion for Order to Show Cause |
|
MOTION for Order to Show Cause Memorandum
of Law in Support of Application by Order to Show Cause Why Defendants
Motion to Compel Supplemental 30b6 Deposition Should Not be Granted. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(Doyle, Tyler)
|
|
Request |
 |
|
|
324 |
Filed: 9/12/2011, Entered: None, Terminated: 9/13/2011 |
~Motion for Order to Show Cause |
|
MOTION for Order to Show Cause Why Defendants Motion to Compel the Supplemental Deposition of Chevron 30b6 Witness Should not be Granted. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(Doyle, Tyler)
|
|
Request |
 |
|
|
323 |
Filed: 9/12/2011, Entered: None |
Certificate of Service Other |
|
CERTIFICATE OF SERVICE of Motion
for Show Cause of Defendants' Motion for Protective Order served on
Chevron on 09/12/2011. Document filed by Hugo Gerardo Camacho Naranjo,
Javier Piaguaje Payaguaje. (Doyle, Tyler)
|
|
Request |
 |
|
|
322 |
Filed: 9/12/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Larry R. Veselka in Support re: [320] MOTION for Order to Show Cause on Defendants' Motion for Protective Order to Extend the Time for Plaintiff Chevron to take Their Depositions..
Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3)
Exhibit 3, # (4) Exhibit 4, # (5) Exhibit 5, # (6) Exhibit 6)(Doyle,
Tyler)
|
|
Request |
 |
|
|
321 |
Filed: 9/12/2011, Entered: None |
Memorandum of Law in Support of Motion |
|
MEMORANDUM OF LAW in Support re: [320] MOTION for Order to Show Cause on Defendants' Motion for Protective Order to Extend the Time for Plaintiff Chevron to take Their Depositions.. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Doyle, Tyler)
|
|
Request |
 |
|
|
320 |
Filed: 9/12/2011, Entered: None, Terminated: 9/13/2011 |
~Motion for Order to Show Cause |
|
MOTION for Order to Show Cause on Defendants' Motion for Protective Order to Extend the Time for Plaintiff Chevron to take Their Depositions. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(Doyle, Tyler)
|
|
Request |
 |
|
|
319 |
Filed: 9/12/2011, Entered: None |
Order on Motion for Order to Show Cause |
|
MEMO ENDORSEMENT denying [316]
Motion for Order to Show Cause. ENDORSEMENT: Accordingly, the renewed
application (DI 316) is denied. (See order for complete endorsement).
(Signed by Judge Lewis A. Kaplan on 9/12/2011) (jar)
|
|
Request |
 |
|
|
318 |
Filed: 9/12/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Randy M. Mastro in Support re: [316] MOTION for Order to Show Cause
-- ORDER TO SHOW CAUSE WHY THE COURT SHOULD NOT STRIKE AND PRECLUDE THE
LAPs FROM OFFERING ON SUMMARY JUDGMENT OR AT TRIAL THE DEPOSITION
TESTIMONY OF DOUGLAS BELTMAN OR, IN THE ALTERNATIVE, WHY THE COURT
SHOULD NOT. Document filed by Chevron Corporation. (Attachments: # (1)
Exhibit 1, # (2) Exhibit 2)(Mastro, Randy)
|
|
Request |
 |
|
|
317 |
Filed: 9/12/2011, Entered: None |
Memorandum of Law in Support of Motion |
|
MEMORANDUM OF LAW in Support re: [316] MOTION for Order to Show Cause
-- ORDER TO SHOW CAUSE WHY THE COURT SHOULD NOT STRIKE AND PRECLUDE THE
LAPs FROM OFFERING ON SUMMARY JUDGMENT OR AT TRIAL THE DEPOSITION
TESTIMONY OF DOUGLAS BELTMAN OR, IN THE ALTERNATIVE, WHY THE COURT
SHOULD NOT. Document filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
316 |
Filed: 9/12/2011, Entered: None, Terminated: 9/12/2011 |
~Motion for Order to Show Cause |
|
MOTION for Order to Show Cause
-- ORDER TO SHOW CAUSE WHY THE COURT SHOULD NOT STRIKE AND PRECLUDE THE
LAPs FROM OFFERING ON SUMMARY JUDGMENT OR AT TRIAL THE DEPOSITION
TESTIMONY OF DOUGLAS BELTMAN OR, IN THE ALTERNATIVE, WHY THE COURT
SHOULD NOT GRANT CHEVRON LEAVE TO TAKE BELTMAN'S DEPOSITION AS A FACT
WITNESS ON SEPTEMBER 15 OR AS AN EXPERT WITNESS ON OR BEFORE SEPTEMBER
29 AS A PRE-CONDITION OF THE LAPs OFFERING HIS DEPOSITION TESTIMONY. Document filed by Chevron Corporation.(Mastro, Randy)
|
|
Request |
 |
|
|
315 |
Filed: 9/12/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Anne Champion in Support re: [313] MOTION for Order to Show Cause
-- ORDER TO SHOW CAUSE WHY A PROTECTIVE ORDER TO PRECLUDE DEFENDANTS
FROM TAKING THE DEPOSITIONS OF TWO OF CHEVRONS OUTSIDE ECUADORIAN
COUNSEL BY NOTICE TO CHEVRON ON LESS THAN FOUR FULL BUSINESS DAYS NOTICE
SHOULD N. Document filed by Chevron Corporation. (Attachments: # (1)
Exhibit 1, # (2) Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4)(Mastro,
Randy)
|
|
Request |
 |
|
|
314 |
Filed: 9/12/2011, Entered: None |
Memorandum of Law in Support of Motion |
|
MEMORANDUM OF LAW in Support re: [313] MOTION for Order to Show Cause
-- ORDER TO SHOW CAUSE WHY A PROTECTIVE ORDER TO PRECLUDE DEFENDANTS
FROM TAKING THE DEPOSITIONS OF TWO OF CHEVRONS OUTSIDE ECUADORIAN
COUNSEL BY NOTICE TO CHEVRON ON LESS THAN FOUR FULL BUSINESS DAYS NOTICE
SHOULD N. Document filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
313 |
Filed: 9/12/2011, Entered: None, Terminated: 9/13/2011 |
~Motion for Order to Show Cause |
|
MOTION for Order to Show Cause
-- ORDER TO SHOW CAUSE WHY A PROTECTIVE ORDER TO PRECLUDE DEFENDANTS
FROM TAKING THE DEPOSITIONS OF TWO OF CHEVRONS OUTSIDE ECUADORIAN
COUNSEL BY NOTICE TO CHEVRON ON LESS THAN FOUR FULL BUSINESS DAYS NOTICE
SHOULD NOT BE GRANTED. Document filed by Chevron Corporation.(Mastro, Randy)
|
|
Request |
 |
|
|
312 |
Filed: 9/12/2011, Entered: None |
Memo Endorsement |
|
MEMO ENDORSEMENT on ORDER TO
SHOW CAUSE WHY THE COURT SHOULD NOT STRIKE AND PRECLUDE THE LAPs FROM
OFFERING ON SUMMARY JUDGMENT OR AT TRIAL THE DEPOSITION TESTIMONY OF
DOUGLAS BELTMAN OR, IN THE ALTERNATIVE, WHY THE COURT SHOULD NOT GRANT
CHEVRON LEAVE TO TAKE BELTMAN'S DEPOSITION AS A FACT WITNESS ON
SEPTEMBER 15 OR AS AN EXPERT WITNESS ON OR BEFORE SEPTEMBER 29 AS A
PRE-CONDITION OF THE LAPs OFFERING HIS DEPOSITION TESTIMONY: Application
for order to show cause denied. Moving papers fail to comply with SDNY
Civ.R. 6.1(d). (Signed by Judge Lewis A. Kaplan on 9/12/2011) (ft)
|
|
Request |
 |
|
|
311 |
Filed: 9/12/2011, Entered: None |
Order |
|
ORDER re: [240] Order on Motion
for Order to Show Cause, [259] Declaration in Support of Motion, filed
by Javier Piaguaje Payaguaje, Hugo Gerardo Camacho Naranjo.
Accordingly, so much of the Order [DI 240] as held that the failure to
submit an adequate privilege log waived any claim of privilege with
respect to those documents set forth in the incomplete logs that were
submitted [DI 259, Exs. A, B] is vacated. The Order is affirmed in all
other respects. The matter is remanded to consider the objections
properly asserted on the incomplete logs. (Signed by Judge Lewis A.
Kaplan on 9/12/2011) (ft)
|
|
Request |
 |
|
|
310 |
Filed: 9/12/2011, Entered: None, Terminated: 2/21/2012 |
Motion to Compel |
|
MOTION to Compel DEFENDANTS
JAVIER PIAGUAJE PAYAGUAJE AND HUGO GERARDO CAMACHO NARANJO to apear for
depositions in New York. Document filed by Chevron Corporation.
(Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3) Exhibit 3)(Mastro,
Randy)
|
|
Request |
 |
|
|
309 |
Filed: 9/12/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Randy M. Mastro in Support re: [307] MOTION for Order to Show Cause --
ORDER TO SHOW CAUSE WHY THE COURT SHOULD NOT STRIKE AND PRECLUDE THE
LAPs FROM OFFERING ON SUMMARY JUDGMENT OR AT TRIAL THE DEPOSITION
TESTIMONY OF DOUGLAS BELTMAN OR, IN THE ALTERNATIVE, WHY THE COURT
SHOULD NOT G. Document filed by Chevron Corporation. (Attachments: #
(1) Exhibit 1, # (2) Exhibit 2)(Mastro, Randy)
|
|
Request |
 |
|
|
308 |
Filed: 9/12/2011, Entered: None |
Memorandum of Law in Support of Motion |
|
MEMORANDUM OF LAW in Support re: [307] MOTION for Order to Show Cause --
ORDER TO SHOW CAUSE WHY THE COURT SHOULD NOT STRIKE AND PRECLUDE THE
LAPs FROM OFFERING ON SUMMARY JUDGMENT OR AT TRIAL THE DEPOSITION
TESTIMONY OF DOUGLAS BELTMAN OR, IN THE ALTERNATIVE, WHY THE COURT
SHOULD NOT G. Document filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
307 |
Filed: 9/12/2011, Entered: None, Terminated: 9/12/2011 |
~Motion for Order to Show Cause |
|
MOTION for Order to Show Cause --
ORDER TO SHOW CAUSE WHY THE COURT SHOULD NOT STRIKE AND PRECLUDE THE
LAPs FROM OFFERING ON SUMMARY JUDGMENT OR AT TRIAL THE DEPOSITION
TESTIMONY OF DOUGLAS BELTMAN OR, IN THE ALTERNATIVE, WHY THE COURT
SHOULD NOT GRANT CHEVRON LEAVE TO TAKE BELTMAN'S DEPOSITION AS A FACT
WITNESS ON SEPTEMBER 15 OR AS AN EXPERT WITNESS ON OR BEFORE SEPTEMBER
29 AS A PRE-CONDITION OF THE LAPs OFFERING HIS DEPOSITION TESTIMONY. Document filed by Chevron Corporation.(Mastro, Randy)
|
|
Request |
 |
|
|
306 |
Filed: 9/9/2011, Entered: None |
Declaration in Opposition |
|
DECLARATION of Anne Champion in
Opposition re: [271] Brief,. Document filed by Chevron Corporation.
(Attachments: # (1) Exhibit A, # (2) Exhibit B)(Mastro, Randy)
|
|
Request |
 |
|
|
305 |
Filed: 9/9/2011, Entered: None |
Response |
|
RESPONSE re: [271] Brief, PLAINTIFF CHEVRON CORPORATION'S RESPONSE TO DEFENDANTS' LIMITED OBJECTIONS TO MAGISTRATE JUDGE FRANCIS' AUGUST 19, 2011 ORDER. Document filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
304 |
Filed: 9/9/2011, Entered: None |
Response |
|
RESPONSE re: [288] Objection (non-motion) CHEVRON
CORPORATION'S RESPONSE TO HUGO GERARDO CAMACHO NARANJO'S AND JAVIER
PIAGUAJE PAYAGUAJE'S OBJECTIONS TO THE AUGUST 23, 2011 ORDER OF
MAGISTRATE JUDGE FRANCIS. Document filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
355 |
Filed: 9/8/2011, Entered: None |
Letter |
|
Letter addressed to Magistrate
Judge James C. Francis from Julio C. Gomez dated 9/8/2011 re: Counsel of
defendants request this Court deny the relief sought by Chevron and
Order it to comply with the 9/7 Order.(jfe)
|
|
Request |
 |
|
|
303 |
Filed: 9/8/2011, Entered: None |
Order |
|
ORDER: that plaintiffs motion
for a protective order is denied without prejudiceto any and all
objections to the use of the depositions either at trial or in any other
respects. (Signed by Judge Lewis A. Kaplan on 9/8/2011) (ft)
|
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Request |
 |
|
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302 |
Filed: 9/8/2011, Entered: None |
Order on Motion for Order to Show Cause |
|
ORDER: denying [279] Motion for
Order to Show Cause. Plaintiffs motion for a protective order [DI 279,
DI 282] is denied without prejudice to any and all objections to the
use of the depositions either at trial or in any other respects.
(Signed by Judge Lewis A. Kaplan on 9/8/2011) (pl) Modified on 9/8/2011
(pl).
|
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Request |
 |
|
|
301 |
Filed: 9/8/2011, Entered: None, Terminated: 2/21/2012 |
Motion to Dismiss |
|
SUPPLEMENTAL MOTION to Dismiss
for Lack of Jurisdiction. Document filed by Hugo Gerardo Camacho
Naranjo, Javier Piaguaje Payaguaje.(Doyle, Tyler)
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Request |
 |
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|
Save 25% on a pre-paid one year subscription. |
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300 |
Filed: 9/8/2011, Entered: None |
Order |
|
ORDER: Chevron Corporation
("Chevron") having requested a modification of my Order dated September
7, 2011 (Letter of Randy M. Mastro dated Sept. 7, 2011), it is hereby
ORDERED that the application is granted to the following extent as set
forth in this Order. (Signed by Magistrate Judge James C. Francis on
9/8/2011) Copies Mailed By Chambers. (djc)
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Request |
 |
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299 |
Filed: 9/8/2011, Entered: None |
Order Referring Case to Magistrate Judge |
|
ORDER OF REFERENCE TO A
MAGISTRATE JUDGE. Order that case be referred to the Clerk of Court for
assignment to a Magistrate Judge for Specific Non-Dispositive
Motion/Dispute, Motion to compel Chevron to comply with Judge Francis's
order (#246). Referred to Magistrate Judge James C. Francis. Motions
referred to James C. Francis. (Signed by Judge Lewis A. Kaplan on
9/8/2011) (ft)
|
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Request |
 |
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298 |
Filed: 9/8/2011, Entered: None |
Order on Motion for Order to Show Cause |
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MEMO ENDORSEMENT terminating
[294] Motion for Order to Show Cause. ENDORSEMENT: In all the
circumstances, the Court declines to sign the order to show cause. In
the interests of avoiding unnecessary paperwork, the proposed order to
show cause is deemed to be a notice of motion filed electronically
today. (Signed by Judge Lewis A. Kaplan on 9/8/2011) (lmb)
|
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Request |
 |
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|
297 |
Filed: 9/7/2011, Entered: None |
Certificate of Service Other |
|
CERTIFICATE OF SERVICE of Motion
to Show Cause to Dismiss Count 9 served on all counsel of record on
September 7, 2011. Document filed by Hugo Gerardo Camacho Naranjo,
Javier Piaguaje Payaguaje. (Doyle, Tyler)
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Request |
 |
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296 |
Filed: 9/7/2011, Entered: None, Terminated: 9/8/2011 |
~Motion for Order to Show Cause |
|
MOTION for Order to Show Cause Declaration
of Craig Smyser in Support of Defendants Application by Order to Show
Cause Why Defendants Motion to Dismiss Plaintiff Declaratory Judgment
Claim for Want of Subject Matter Jurisdiction Should Not Be Granted. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(Doyle, Tyler)
|
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Request |
 |
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295 |
Filed: 9/7/2011, Entered: None, Terminated: 9/8/2011 |
~Motion for Order to Show Cause |
|
MOTION for Order to Show Cause Memorandum
of Law in Support of Application by Order To Show Cause Why Defendants
Motion to Dismiss Plaintiff Declaratory Judgment Claim for Want of
Subject Matter Jurisdiction Should Not Be Granted. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(Doyle, Tyler)
|
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Request |
 |
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294 |
Filed: 9/7/2011, Entered: None, Terminated: 9/8/2011 |
~Motion for Order to Show Cause |
|
MOTION for Order to Show Cause Why
Defendants Motion to Dismiss Plaintiff Chevron Declaratory Judgment
Claim for Want of Subject Matter Jurisdiction Should Not Be Granted. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(Doyle, Tyler)
|
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Request |
 |
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293 |
Filed: 9/7/2011, Entered: None |
Order on Motion to Preclude |
|
ORDER Accordingly, Chevron's
motion to preclude the Beltman deposition {DI 255} is denied. This
ruling affects only the question whether the deposition may go forward.
It does not import any view on any other issue. (Signed by Judge Lewis
A. Kaplan on 9/7/11) (cd)
|
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Request |
 |
|
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292 |
Filed: 9/7/2011, Entered: None |
Response in Opposition to Motion |
|
RESPONSE in Opposition re: [279] MOTION for Order to Show Cause WHY A PROTECTIVE ORDER SHOULD NOT BE ENTERED CONCERNING FOREIGN DEPOSITIONS/EXAMINATIONS.....
Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3)
Exhibit 3, # (4) Exhibit 4, # (5) Exhibit 5, # (6) Exhibit 6, # (7)
Exhibit 7, # (8) Exhibit 8)(Doyle, Tyler)
|
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Request |
 |
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290 |
Filed: 9/7/2011, Entered: None |
Order |
|
ORDER: By close of business on
September 9. 2011, Chevron shall submit for in camera review all
documents at issue, labeled to correspond to their designation in the
privilege logs. Categorical privilege logs are generally appropriate,
but is is incumbent upon the Court to verify that this process has not
been abused. (Signed by Magistrate Judge James C. Francis on 9/7/2011)
(rdz)
|
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Request |
 |
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289 |
Filed: 9/7/2011, Entered: None |
Order |
|
ORDER: It is hereby Ordered that
the defendants motion (Docket No. 273) is determined as follows: To the
extent that the defendants or their attorneys or agents, including the
firm of Smyser Kaplan & Veselka, L.L.P. ("SKV"), have obtained
documents during the course of this case that relate to the Lago Agrio
Action, such documents are not immune from production merely because
they came into the possession of counsel in connection with this case.
SKV's time to comply with my August 23, 2011 Memorandum and Order is
extended to September 9, 2011. (Signed by Magistrate Judge James C.
Francis on 9/6/2011) (rdz) Modified on 9/7/2011 (rdz).
|
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Request |
 |
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|
291 |
Filed: 9/6/2011, Entered: None |
Order |
|
ORDER: The opinion issued on
8/17/2011 [DI 229] in this matter is corrected by substituting the
attached page 16 for the corresponding page in the opinion. (Signed by
Judge Lewis A. Kaplan on 9/6/2011) (tro)
|
|
Request |
 |
|
|
288 |
Filed: 9/6/2011, Entered: None |
Objection (non-motion) |
|
Objection re: [240] Order on
Motion for Order to Show Cause,,,,. Document filed by Hugo Gerardo
Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
287 |
Filed: 9/6/2011, Entered: None |
Certificate of Service Other |
|
CERTIFICATE OF SERVICE of Order
to Show Cause for Protective Order concerning Foreign
Depositions/Examinations dated September 6, 2011 (Document No. 282) and
supporting documents served on Defendants on 09/06/2011. Service was
made by electronic mail. Document filed by Chevron Corporation. (Mastro,
Randy)
|
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Request |
 |
|
|
286 |
Filed: 9/6/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of David J. Kerstein in Support re: [284] MOTION to Preclude -
CHEVRON CORPORATIONS NOTICE OF MOTION AND MOTION TO STRIKE THE EXPERT
REPORT AND DEPOSITION TESTIMONY OF ROBERTO MACLEAN AND PRECLUDE MACLEAN
FROM TESTIFYING AS AN EXPERT WITNESS.. Document filed by Chevron
Corporation. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3)
Exhibit 3, Part 1, # (4) Exhibit 3, Part 2, # (5) Exhibit 4, # (6)
Exhibit 5, # (7) Exhibit 6, # (8) Exhibit 7, # (9) Exhibit 8)(Mastro,
Randy)
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Request |
 |
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285 |
Filed: 9/6/2011, Entered: None |
Memorandum of Law in Support of Motion |
|
MEMORANDUM OF LAW in Support re: [284] MOTION to Preclude -
CHEVRON CORPORATIONS NOTICE OF MOTION AND MOTION TO STRIKE THE EXPERT
REPORT AND DEPOSITION TESTIMONY OF ROBERTO MACLEAN AND PRECLUDE MACLEAN
FROM TESTIFYING AS AN EXPERT WITNESS.. Document filed by Chevron Corporation. (Mastro, Randy)
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Request |
 |
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284 |
Filed: 9/6/2011, Entered: None, Terminated: 2/21/2012 |
Motion to Preclude |
|
MOTION to Preclude -
CHEVRON CORPORATIONS NOTICE OF MOTION AND MOTION TO STRIKE THE EXPERT
REPORT AND DEPOSITION TESTIMONY OF ROBERTO MACLEAN AND PRECLUDE MACLEAN
FROM TESTIFYING AS AN EXPERT WITNESS. Document filed by Chevron Corporation.(Mastro, Randy)
|
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Request |
 |
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283 |
Filed: 9/6/2011, Entered: None |
Order on Motion to Appear Pro Hac Vice |
|
ORDER granting [165] Motion for
Garland D. Murphy IV to Appear Pro Hac Vice. ENDORSEMENT: Granted.
(Signed by Judge Lewis A. Kaplan on 9/6/2011) (lmb)
|
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Request |
 |
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|
282 |
Filed: 9/6/2011, Entered: None |
Order to Show Cause  |
|
ORDER TO SHOW CAUSE WHY A
PROTECTIVE ORDER SHOULD NOT BE ENTERED CONCERNING FOREIGN
DEPOSITIONS/EXAMINATIONS NOTICED THIS PAST HOLIDAY WEEKEND FOR TESTIMONY
TO BE TAKEN FROM THREE WITNESSES COOPERATING WITH DEFENDANTS, INCLUDING
TWO WITNESSES SCHEDULED TO BE EXAMINED LATER THIS WEEK IN ECUADOR,
PURPORTEDLY TO PRESERVE THEIR TESTIMONY FOR TRIAL: Plaintiff Chevron
Corporation, submitted to this Court this Order to Show Cause why the
Court should not enter a protective order, pursuant to Federal Rule of
Civil Procedure 26(c)(l)(B), directing that (1) the notices issued by
the Lago Agrio Plaintiff Defendants (the "LAPs") to depose/examine
Donald Rafael Moncayo Jimenez, Jhinsop Martinez Erniez, and Santiago
Escobar (the "Deponents") are quashed or, alternatively, Chevron is
entitled to discovery depositions of the Deponents before the LAPs
attempt to preserve their testimony for trial through depositions or
other forms of examination (the "Depositions"); (2) the Depositions, if
they are to proceed at all, shall take place in New York, rather than
Ecuador, or in the alternative, the LAPs shall be precluded from using
testimony from the Depositions at trial; (3) the Depositions shall be
taken on a mutually acceptable date during the week of September 12,
2011, but by no later than September 15, 2011; and (4) regardless of the
location of the depositions, the LAPs must use a formally registered,
certified interpreter to translate questions and responses from English
into Spanish, and Spanish into English, as well as a certified court
reporter to transcribe the deposition; and WHEREAS, the Court has
considered the evidence, arguments, and law presented with this
application, and sufficient reason appearing for the LAPs to show cause
why such an order, in whole or in part, as requested by Chevron, should
not issue; It is hereby Ordered that the LAPs show cause why such an
Order, in whole or in part, as requested by Chevron, should not issue;
and it is hereby Ordered that Chevron shall serve the LAPs by hand or
email, with the Memorandum of Law, Declaration of Anne Champion in
Support of this Application, and this Order, on or before 6:00 p.m. EDT
on September 6, 2011; and it is further Ordered that papers in
opposition to the Application, if any, shall be served and filed
electronically on or before 1 p.m. EDT on September 7, 2011; and it is
further ORDERED that, unless otherwise ordered, the motion will be taken
on submission. Show Cause Response due by 9/7/2011. (Signed by Judge
Lewis A. Kaplan on 9/6/2011) (mro) Modified on 9/6/2011 (mro).
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Request |
 |
|
|
281 |
Filed: 9/6/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Anne Champion in Support re: [279] MOTION for Order to Show Cause WHY A PROTECTIVE ORDER SHOULD NOT BE ENTERED CONCERNING FOREIGN DEPOSITIONS/EXAMINATIONS.....
Document filed by Chevron Corporation. (Attachments: # (1) Exhibit 1,
# (2) Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4, # (5) Exhibit 5, #
(6) Exhibit 6, # (7) Exhibit 7, # (8) Exhibit 8, # (9) Exhibit 9, # (10)
Exhibit 10, # (11) Exhibit 11, # (12) Exhibit 12, # (13) Exhibit 13, #
(14) Exhibit 14)(Mastro, Randy)
|
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Request |
 |
|
|
280 |
Filed: 9/6/2011, Entered: None |
Memorandum of Law in Support of Motion |
|
MEMORANDUM OF LAW in Support re: [279] MOTION for Order to Show Cause WHY A PROTECTIVE ORDER SHOULD NOT BE ENTERED CONCERNING FOREIGN DEPOSITIONS/EXAMINATIONS..... Document filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
279 |
Filed: 9/6/2011, Entered: None, Terminated: 9/8/2011 |
~Motion for Order to Show Cause |
|
MOTION for Order to Show Cause WHY A PROTECTIVE ORDER SHOULD NOT BE ENTERED CONCERNING FOREIGN DEPOSITIONS/EXAMINATIONS.... Document filed by Chevron Corporation.(Mastro, Randy)
|
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Request |
 |
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|
276 |
Filed: 9/6/2011, Entered: None |
Order Referring Case to Magistrate Judge |
|
ORDER OF REFERENCE TO A
MAGISTRATE JUDGE. Order that case be referred to the Clerk of Court for
assignment to a Magistrate Judge for Specific Non-Dispositive
Motion/Dispute. Referred to Magistrate Judge James C. Francis. Motions
referred to James C. Francis. Motion to Compel Chevron to produce
documents identified in its privilege logs [DI 264]. (Signed by Judge
Lewis A. Kaplan on 9/6/2011) (mro)
|
|
Request |
 |
|
|
278 |
Filed: 9/2/2011, Entered: None |
Letter |
|
Letter addressed to Magistrate
Judge James C. Francis from Elliot R. Peters dated 8/29/11 re: Mr. Woods
requests that the Court not order him Woods further requests that the
Court admonish Chevron to double check the accuracy of its factual
allegations before accusing witnesses or their counsel of misconduct.
Document filed by Andrew Woods.(mro)
|
|
Request |
 |
|
|
277 |
Filed: 9/2/2011, Entered: None |
Letter |
|
Letter addressed to Magistrate
Judge James C. Francis from Randy M. Mastro dated 8/26/11 re: Chevron
requests that this Court order Woods to comply with its orders forthwith
and produce immediately to Chevron unredacted copies of the documents
listed on Woods' privilege logs listed herein. Document filed by Chevron
Corporation.(mro)
|
|
Request |
 |
|
|
275 |
Filed: 9/2/2011, Entered: None |
Oath |
|
OATH of Christina Bryan in
Support of Defendants Memorandum of Law in Support of its Motions on
Short Notice for Clarification and Request for Stay of This Court's
August 23, 2011 Memorandum and Order (Dkt. 240) Pending Decision on
Reconsideration and Clarification of Same. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(Doyle, Tyler)
|
|
Request |
 |
|
|
274 |
Filed: 9/2/2011, Entered: None |
Brief |
|
BRIEF re: [273] Notice (Other) Memorandum
of Law in Support of its Motion on Short Notice for Clarification and
Request for Stay of This Court's August 23, 2011 Memorandum and Order
Pending Decision on Reconsideration and Clarification of Same. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(Doyle, Tyler)
|
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Request |
 |
|
|
273 |
Filed: 9/2/2011, Entered: None |
~Notice (other) |
|
NOTICE of of Motion on Short
Notice of Defendants Motion in Further Support of Clarification re:
[240] Order on Motion for Order to Show Cause,,,,. Document filed by
Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Doyle, Tyler)
|
|
Request |
 |
|
|
272 |
Filed: 9/2/2011, Entered: None |
Response in Opposition to Motion |
|
RESPONSE in Opposition re: [264]
MOTION to Compel Chevron Corporation to Produce Documents Identified in
its Deficient Privilege Logs. - CHEVRON CORPORATION'S RESPONSE TO
DEFENDANTS HUGO GERARDO CAMACHO NARANJO AND JAVIER PIAGUAJE PAYAGUAJES
MOTION TO COMPEL PRODUCTION OF DOCUMENTS ON CHEVRON'S PRIVILEGE LOG. Document filed by Chevron Corporation. (Attachments: # (1) Exhibit A)(Mastro, Randy)
|
|
Request |
 |
|
|
271 |
Filed: 9/2/2011, Entered: None |
Brief |
|
BRIEF re: [233] Order on Motion to Compel,,, Defendants Limited Objection to Judge Francis's Order.
Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3) Exhibit
3, # (4) Exhibit 4)(Doyle, Tyler)
|
|
Request |
 |
|
|
270 |
Filed: 9/2/2011, Entered: None |
Order on Motion for Reconsideration |
|
ORDER denying [257] Motion for
Reconsideration. The defendants have not persuaded me that the August
23 Order merits reconsideration either because there has been an
intervening change in the law or because that order was clearly
erroneous. (Signed by Magistrate Judge James C. Francis on 9/2/2011)
Copies Mailed By Chambers. (jar) (jar).
|
|
Request |
 |
|
|
269 |
Filed: 9/2/2011, Entered: None |
Order |
|
ORDER: My Memorandum and Order
dated August 23, 2011 (Docket no. 240) incorrectly indicates at page 4
that the motion being resolved was Docket no. 203. the reference should
have been to Docket no. 178, and the August 23, 2011 Memorandum and
Order is hereby amended accordingly. So Ordered (Signed by Magistrate
Judge James C. Francis on 9/2/2011) Copies Mailed By Chambers. (js)
|
|
Request |
 |
|
|
268 |
Filed: 9/1/2011, Entered: None |
Declaration in Opposition to Motion |
|
DECLARATION of Anne Champion in
Opposition re: [257] MOTION for Reconsideration re; [240] Order on
Motion for Order to Show Cause,,,, on Short Notice and For Clarification.. Document filed by Chevron Corporation. (Attachments: # (1) Exhibit A, # (2) Exhibit B)(Mastro, Randy)
|
|
Request |
 |
|
|
267 |
Filed: 9/1/2011, Entered: None |
Memorandum of Law in Opposition to Motion |
|
MEMORANDUM OF LAW in Opposition re: [257] MOTION for Reconsideration re; [240] Order on Motion for Order to Show Cause,,,, on Short Notice and For Clarification.. Document filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
266 |
Filed: 9/1/2011, Entered: None |
Response in Opposition to Motion |
|
RESPONSE in Opposition re: [255] MOTION to Preclude -
PLAINTIFF CHEVRON CORPORATION'S MOTION TO PRECLUDE DEFENDANTS JAVIER
PIAGUAJE PAYAGUAJE AND HUGO GERARDO CAMACHO NARANJO FROM TAKING THE
DEPOSITION OF DOUGLAS BELTMAN.. Document filed by Hugo Gerardo
Camacho Naranjo, Javier Piaguaje Payaguaje. (Attachments: # (1) Exhibit
1, # (2) Exhibit 2, # (3) Exhibit 3)(Doyle, Tyler)
|
|
Request |
 |
|
|
265 |
Filed: 9/1/2011, Entered: None |
Memorandum and Opinion |
|
MEMORANDUM AND ORDER: that
Chevron's application is granted with respect to documents nos. 962,
970, 1545, and 1074 A1, and denied with respect to document no. 2317.
(Signed by Magistrate Judge James C. Francis on 9/1/2011) (ft)
|
|
|
 |
|
|
264 |
Filed: 8/31/2011, Entered: None, Terminated: 9/20/2011 |
Motion to Compel |
|
MOTION to Compel Chevron
Corporation to Produce Documents Identified in its Deficient Privilege
Logs. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit
C, # (4) Exhibit D, # (5) Exhibit E)(Gomez, Julio)
|
|
Request |
 |
|
|
263 |
Filed: 8/31/2011, Entered: None |
Declaration in Opposition to Motion |
|
DECLARATION of Christopher
Joralemon in Opposition re: [246] MOTION to Compel Chevron to Compliance
with Judge Francis Order.. Document filed by Chevron Corporation.
(Joralemon, Christopher)
|
|
Request |
 |
|
|
262 |
Filed: 8/31/2011, Entered: None |
Response in Opposition to Motion |
|
RESPONSE in Opposition re: [246]
MOTION to Compel Chevron to Compliance with Judge Francis Order..
Document filed by Chevron Corporation. (Attachments: # (1) Exhibit A, #
(2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D)(Mastro, Randy)
|
|
Request |
 |
|
|
261 |
Filed: 8/31/2011, Entered: None |
Memorandum and Opinion |
|
MEMORANDUM OPINION: #100732
Accordingly, to the extent that LAP Representatives motion for judgment
on the pleadings rests on their judicial estoppel claims, it must be
denied. (Signed by Judge Lewis A. Kaplan on 8/31/2011) (ab) Modified on
9/2/2011 (ajc).
|
|
Request |
 |
|
|
260 |
Filed: 8/31/2011, Entered: None |
Order on Motion for Judgment on the Pleadings |
|
ORDER denying [156] Motion for
Judgment on the Pleadings filed by Hugo Gerardo Camacho Naranjo and
Javier Piaguaje Payaguaje: For the reasons set forth above and those set
forth in the memorandum opinion of even date, the LAP Representatives
motion for judgment on the pleadings [DI 156] is denied in all respects.
(Signed by Judge Lewis A. Kaplan on 8/31/2011) (ab)
|
|
Request |
 |
|
|
259 |
Filed: 8/31/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Julio C. Gomez in
Support re: [257] MOTION for Reconsideration re; [240] Order on Motion
for Order to Show Cause,,,, on Short Notice and For Clarification..
Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3)
Exhibit C, # (4) Exhibit D (part 1), # (5) Exhibit D (part 2), # (6)
Exhibit E)(Gomez, Julio)
|
|
Request |
 |
|
|
258 |
Filed: 8/31/2011, Entered: None |
Memorandum of Law in Support of Motion |
|
MEMORANDUM OF LAW in Support re: [257] MOTION for Reconsideration re; [240] Order on Motion for Order to Show Cause,,,, on Short Notice and For Clarification.. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
257 |
Filed: 8/31/2011, Entered: None, Terminated: 9/2/2011 |
Motion for Reconsideration |
|
MOTION for Reconsideration re; [240] Order on Motion for Order to Show Cause,,,, on Short Notice and For Clarification. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(Gomez, Julio)
|
|
Request |
 |
|
|
256 |
Filed: 8/31/2011, Entered: None |
Order |
|
ORDER: The LAP Representatives,
Mr. Woods and Ms. Garr shall provide to the Court on or before September
12, 2011, copies of the privilege logs previously provided by Mr. Woods
and Ms. Garr, respectively, in this action, marked to indicate as to
each document whether it or at least one substantially identical copy
(differentiating between these two categories) previously has been
produced by Steven Donziger to Chevron in 10 MC 00002 (LAK). (Signed by
Judge Lewis A. Kaplan on 8/31/2011) (ab)
|
|
Request |
 |
|
|
255 |
Filed: 8/30/2011, Entered: None, Terminated: 9/7/2011 |
Motion to Preclude |
|
MOTION to Preclude -
PLAINTIFF CHEVRON CORPORATION'S MOTION TO PRECLUDE DEFENDANTS JAVIER
PIAGUAJE PAYAGUAJE AND HUGO GERARDO CAMACHO NARANJO FROM TAKING THE
DEPOSITION OF DOUGLAS BELTMAN. Document filed by Chevron
Corporation. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3)
Exhibit 3, # (4) Exhibit 4)(Mastro, Randy)
|
|
Request |
 |
|
|
254 |
Filed: 8/30/2011, Entered: None |
Objection (non-motion) |
|
Objection re: [233] Order on Motion to Compel,,, CHEVRON'S
LIMITED OBJECTIONS TO MAGISTRATE JUDGE FRANCIS'S AUGUST 19, 2011 ORDER
ADDRESSING DEFENDANTS' MOTION TO COMPEL INTERROGATORY RESPONSES. Document filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
253 |
Filed: 8/30/2011, Entered: None |
Notice of Filing Transcript |
|
NOTICE OF FILING OF OFFICIAL
TRANSCRIPT Notice is hereby given that an official transcript of a
CONFERENCE proceeding held on 7/19/11 has been filed by the court
reporter/transcriber in the above-captioned matter. The parties have
seven (7) calendar days to file with the court a Notice of Intent to
Request Redaction of this transcript. If no such Notice is filed, the
transcript may be made remotely electronically available to the public
without redaction after 90 calendar days...(Moya, Goretti)
|
|
Request |
 |
|
|
252 |
Filed: 8/30/2011, Entered: None |
Transcript |
|
TRANSCRIPT of Proceedings re:
CONFERECE held on 7/19/2011 before Magistrate Judge James C. Francis IV.
Court Reporter/Transcriber: Patricia Nilsen, (212) 805-0300.
Transcript may be viewed at the court public terminal or purchased
through the Court Reporter/Transcriber before the deadline for Release
of Transcript Restriction. After that date it may be obtained through
PACER. Redaction Request due 9/23/2011. Redacted Transcript Deadline
set for 10/3/2011. Release of Transcript Restriction set for
12/1/2011.(Moya, Goretti)
|
|
Request |
 |
|
|
251 |
Filed: 8/30/2011, Entered: None |
Letter |
|
Letter from Randy M. Mastro
dated 7/27/11 re: Counsel writes in response to the July 22 letters from
Elliot Peters and Patricia Hamill. Document filed by Chevron
Corporation.(mro)
|
|
Request |
 |
|
|
250 |
Filed: 8/30/2011, Entered: None |
Letter |
|
Letter from Elliot R. Peters
dated 7/22/11 re: Counsel renews their request made during the July 19
hearing that the Court stay its Order once it is formally issued so that
they can seek expedited relief from Judge Kaplan and, if necessary, the
Second Circuit Court of Appeals. Document filed by Laura J Garr, Andrew
Woods.(mro)
|
|
Request |
 |
|
|
249 |
Filed: 8/30/2011, Entered: None |
Letter |
|
Letter from Patricia M. Hamill
dated 7/22/11 re: Counsel writes to designate documents on KSG's
privilege logs pursuant to Magistrate Judge Francis's 7/19/11 Order.
Document filed by Joseph C. Kohn, Kohn Swift & Graf, P.C.(mro)
|
|
Request |
 |
|
|
248 |
Filed: 8/30/2011, Entered: None |
Declaration in Opposition to Motion |
|
DECLARATION of Randy M. Mastro in Opposition re: [237] MOTION for Extension of Time to Locate Technical Experts and Supplement to Motion to Continue Trial Setting., [198] MOTION to Continue Trial Setting..
Document filed by Chevron Corporation. (Attachments: # (1) Exhibit 1,
# (2) Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4, # (5) Exhibit 5, #
(6) Exhibit 6, # (7) Exhibit 7, # (8) Exhibit 8, # (9) Exhibit 9, # (10)
Exhibit 10, # (11) Exhibit 11, # (12) Exhibit 12, # (13) Exhibit 13, #
(14) Exhibit 14, # (15) Exhibit 15, # (16) Exhibit 16, # (17) Exhibit
17, # (18) Exhibit 18, # (19) Exhibit 19, # (20) Exhibit 20, # (21)
Exhibit 21, # (22) Exhibit 22)(Mastro, Randy)
|
|
Request |
 |
|
|
247 |
Filed: 8/29/2011, Entered: None |
Memorandum of Law in Opposition to Motion |
|
MEMORANDUM OF LAW in Opposition re: [237] MOTION for Extension of Time to Locate Technical Experts and Supplement to Motion to Continue Trial Setting., [198] MOTION to Continue Trial Setting. CHEVRON
CORPORATION'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANTS JAVIER
PIAGUAJE PAYAGUAJE AND HUGO GERARDO CAMACHO NARANJO'S (1) MOTION FOR
CONTINUANCE (DKT. 198) AND (2) MOTION TO EXTEND TIME TO LOCATE TECHNICAL
EXPERTS (DKT. 237). Document filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
246 |
Filed: 8/29/2011, Entered: None, Terminated: 2/21/2012 |
Motion to Compel |
|
MOTION to Compel Chevron to
Compliance with Judge Francis Order. Document filed by Hugo Gerardo
Camacho Naranjo, Javier Piaguaje Payaguaje. (Attachments: # (1) Exhibit 1
to Motion to Compel Compliance, # (2) Exhibit 2 to Motion to Compel
Compliance, # (3) Exhibit 3 to Motion to Compel Compliance)(Doyle,
Tyler)
|
|
Request |
 |
|
|
245 |
Filed: 8/26/2011, Entered: None |
Response in Opposition to Motion |
|
RESPONSE in Opposition re: [242]
MOTION to Compel DEFENDANTS JAVIER PIAGUAJE PAYAGUAJE AND HUGO GERADO
CAMACHO NARANJO to produce documents AND MEMORANDUM IN FURTHER SUPPORT OF CONTEMPT SANCTIONS.. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
244 |
Filed: 8/26/2011, Entered: None |
Reply Memorandum of Law in Support of Motion |
|
REPLY MEMORANDUM OF LAW in
Support re: [156] MOTION for Judgment on the Pleadings.. Document filed
by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Doyle,
Tyler)
|
|
Request |
 |
|
|
243 |
Filed: 8/24/2011, Entered: None |
Amended Answer to Complaints |
|
AMENDED ANSWER to with JURY DEMAND. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
242 |
Filed: 8/24/2011, Entered: None, Terminated: 2/21/2012 |
Motion to Compel |
|
MOTION to Compel DEFENDANTS JAVIER PIAGUAJE PAYAGUAJE AND HUGO GERADO CAMACHO NARANJO to produce documents AND MEMORANDUM IN FURTHER SUPPORT OF CONTEMPT SANCTIONS.
Document filed by Chevron Corporation. (Attachments: # (1) Exhibit 1, #
(2) Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4, # (5) Exhibit 5, # (6)
Exhibit 6, # (7) Exhibit 7, # (8) Exhibit 8, # (9) Exhibit 9, # (10)
Exhibit 10, # (11) Exhibit 11, # (12) Exhibit 12, # (13) Exhibit 13, #
(14) Exhibit 14, # (15) Exhibit 15)(Mastro, Randy)
|
|
Request |
 |
|
|
241 |
Filed: 8/24/2011, Entered: None |
Order |
|
ORDER: As set forth within, in
sum, nothing to which Donziger has pointed warrants reconsideration of
the Order. The motion (Dl 203, DI 209) is denied.(Signed by Judge Lewis
A. Kaplan on 8/23/2011) (laq)
|
|
Request |
 |
|
|
240 |
Filed: 8/23/2011, Entered: None |
Order on Motion for Order to Show Cause |
|
MEMORANDUM AND ORDER re: [178]
Motion for Order to Show Cause. In light of the defendants' failure to
comply with Judge Kaplan's order, Chevron's motion (Docket no. 178) is
determined as follows: Defendants shall produce all documents
encompassed within the 7/6/11 Order no later than September 2, 2011. Any
claim of attorney-client privilege or work product immunity has been
waived with respect to the documents referred to in paragraph 1 above by
virtue of the defendants' failure to produce an adequate privilege log
pursuant to the 7/6/11 Order. However, that waiver may be rescinded if
an adequate log is provided by September 2, 2011. Chevron's application
to hold the defendant's in contempt and its request for sanctions
including an adverse inference will be determined following the
defendants' compliance (or failure to comply) with this order. (Signed
by Magistrate Judge James C. Francis on 8/23/2011) Copies Mailed By
Chambers. (Signed by Magistrate Judge James C. Francis on 8/23/2011)
Copies Mailed By Chambers. (tro) Modified on 8/24/2011 (tro). Modified
on 9/2/2011 (ae). (Text modified pursuant to chambers' instructions -
This Order links up to doc. #178 not #203)
|
|
Request |
 |
|
|
239 |
Filed: 8/23/2011, Entered: None, Terminated: 8/24/2011 |
Motion for Reconsideration |
|
MOTION for Reconsideration re; [238] Order on Motion for Reconsideration,, UNREDACTED. Document filed by Andrew Woods.(Little, Jan)
|
|
Request |
 |
|
|
238 |
Filed: 8/22/2011, Entered: None |
Order on Motion for Reconsideration |
|
MEMORANDUM AND ORDER: For the
reasons discussed, Mr. Woods' motion for reconsideration Docket no.
[234] is granted in part and denied part, as set forth above. This
order and the August 16, 2011 order are stayed until 5:00 p.m. EDT on
August 25, 2011. Mr. Woods shall file forthwith an unredacted copy of
the memorandum in support of his motion for consideration, as the
redacted material does not disclose any protectible, confidential
information. (Signed by Magistrate Judge James C. Francis on 8/22/2011)
(laq) COPIES MAILED BY CHAMBERS.
|
|
Request |
 |
|
|
237 |
Filed: 8/22/2011, Entered: None, Terminated: 2/21/2012 |
Motion for Extension of Time |
|
MOTION for Extension of Time to Locate Technical Experts and Supplement to Motion to Continue Trial Setting. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(Doyle, Tyler)
|
|
Request |
 |
|
|
236 |
Filed: 8/22/2011, Entered: None |
~Notice (other) |
|
NOTICE of Joinder re: [234] MOTION for Reconsideration re; [227] Order,,,, [REDACTED].. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
235 |
Filed: 8/19/2011, Entered: None |
Memorandum of Law in Opposition to Motion |
|
MEMORANDUM OF LAW in
Opposition re: [156] MOTION for Judgment on the Pleadings.. Document
filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
234 |
Filed: 8/19/2011, Entered: None, Terminated: 8/22/2011 |
Motion for Reconsideration |
|
MOTION for Reconsideration re; [227] Order,,,, [REDACTED]. Document filed by Andrew Woods.(Little, Jan)
|
|
Request |
 |
|
|
233 |
Filed: 8/19/2011, Entered: None |
Order on Motion to Compel |
|
MEMORANDUM AND ORDER re: [195]
Motion to Compel Chervon Corporation to Response to Interrogatories.
Document filed by Hugo Gerardo Camacho Naranjo and Javier Piaguaje
Payaguaje: I will address each dispute as it relates to the modified
interrogatories. In addition, my determinations are guided by the
Memorandum Opinion of the Honorable Lewis A. Kaplan, U.S.D.J., dated
August 17, 2011 (the 8/17/11 Op.), which defines the scope of certain
claims and defenses. The outstanding disputes are resolved as set forth
on this Order. To the extent Chevron is required by this order to answer
interrogatories, it shall do so by August 25, 2011. This order resolves
Docket no. 195. (Signed by Magistrate Judge James C. Francis on
8/19/2011) Copies Mailed By Chambers. (ab)
|
|
|
 |
|
|
232 |
Filed: 8/18/2011, Entered: None |
Reply Memorandum of Law in Support |
|
REPLY MEMORANDUM OF LAW in Support re: [201] Memorandum of Law in Support,
of Renwed Application by Order to Show Cause Why This Court Should Not
Reconsider Its May 31, 2011 Order on Donziger's Application to
Intervene, and Grant Donziger Full Intervention in Claim Nine. Document filed by Steven Donziger, Donziger & Associates PLLC, The Law Offices of Steven R. Donziger. (Little, Jan)
|
|
Request |
 |
|
|
231 |
Filed: 8/17/2011, Entered: None |
Declaration in Opposition |
|
DECLARATION of Kristen L.
Hendricks in Opposition re: [209] Order,,,,,. Document filed by Chevron
Corporation. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3)
Exhibit 3)(Mastro, Randy)
|
|
Request |
 |
|
|
230 |
Filed: 8/17/2011, Entered: None |
Memorandum of Law in Opposition |
|
MEMORANDUM OF LAW in Opposition re: [209] Order,,,,,. Document filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
229 |
Filed: 8/17/2011, Entered: None |
Memorandum and Opinion |
|
MEMORANDUM OPINION re: #100685
(49 in 1:11-cv-03718-LAK -JCF) MOTION to Strike CHEVRON CORPORATION'S
NOTICE OF MOTION AND MOTION FOR PARTIAL JUDGMENT ON THE PLEADINGS
REGARDING CERTAIN DEFENSES ASSERTED BY DEFENDANTS STEVEN DONZIGER, THE
LAW OFFICES OF STEVEN DONZIGER, DONZIGER & ASSOCIATES, PLLC, HUGO G
filed by Chevron Corporation, (42 in 1:11-cv-03718-LAK -JCF) MOTION for
Leave to File Amended Answer to Amended Complaint, Separate Defenses and
Jury Trial Demand filed by Javier Piaguaje Payaguaje, Hugo Gerardo
Camacho Naranjo. For the foregoing reasons, (1) the LAP Representatives
amended answer to the amended complaint, improperly filed without leave
of Court [DI 63] is stricken; (2) the LAP Representatives motion for
leave to file an amended answer to the amended complaint [DI 42] is
granted. Chevrons motion for judgment on the pleadings dismissing
certain defenses of the LAPs answer to the amended complaint or for
other relief [DI 49] is deemed applicable to the amended answer to the
amended complaint and granted to the extent that the twenty-eighth and
thirty-first defenses and so much of the thirtieth defense as is (a)
based upon anything other than the points noted in the text and (b)
addressed to anything other than Chevrons claim for injunctive is
granted. The latter motion is otherwise denied. These rulings are made
only with respect to Action No. 2 and thus do not resolve this motion
with respect to Donzigers defenses because he is not a party to this
action. To the extent, if any, that these issues are pertinent to Action
No. 1, the Court reserves decision. (Signed by Judge Lewis A. Kaplan
on 8/17/2011) (mro) Modified on 8/23/2011 (ajc).
|
|
|
 |
|
|
228 |
Filed: 8/16/2011, Entered: None |
Declaration in Support |
|
DECLARATION of Kristen L.
Hendricks in Support re: [178] Order to Show Cause,,. Document filed by
Chevron Corporation. (Attachments: # (1) Exhibit 24, # (2) Exhibit 25,
# (3) Exhibit 26, # (4) Exhibit 27, # (5) Exhibit 28, # (6) Exhibit 29,
# (7) Exhibit 30, # (8) Exhibit 31, # (9) Exhibit 32, # (10) Exhibit
33, # (11) Exhibit 34, # (12) Exhibit 35, # (13) Exhibit 36)(Mastro,
Randy)
|
|
Request |
 |
|
|
227 |
Filed: 8/16/2011, Entered: None |
Order |
|
MEMORANDUM AND ORDER, regarding
an Memorandum and Order issued on August 3, 2011. I ordered that Mr.
Woods produce for in camera inspection all documents responsive to
Chevrons subpoena created after October 20, 2010, so that I could
determine which ones might be subject to the crime-fraud exception or
otherwise discoverable.Mr. Woods turned over approximately 4,250
electronic files in Tagged Image File (TIF) format. On the basis of a
review of those documents, I can now rule on the discoverability of
each. My rulings with respect to each individual document are set forth
in the attached Appendix. Within three days of the date of this
Memorandum and Order, Mr. Woods shall produce to Chevron the documents
as to which his objections have been overruled. However, this Order is
stayed until 5:00 p.m. on August 22, 2011 to provide any party the
opportunity to appeal. Additional relief as set forth in this Order.
(Signed by Magistrate Judge James C. Francis on 8/16/11) Copies Mailed
By Chambers. (pl) Modified on 8/16/2011 (pl).
|
|
Request |
 |
|
|
226 |
Filed: 8/16/2011, Entered: None |
Reply Memorandum of Law in Support |
|
REPLY MEMORANDUM OF LAW in Support re: [178] Order to Show Cause,,. Document filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
225 |
Filed: 8/16/2011, Entered: None |
Order on Motion to Compel |
|
ORDER granting in part and
denying in part [210] Motion to Compel. Accordingly, Chevron's motion
to compel the LAP Representatives to appear fordepositions in New York
and to produce expert witnesses for depositions in New York [DI 210] is
granted to the extent that Messrs. Piaguaje Payaguaje and Camacho
Naranjo shall (1) appear for and submit to depositions in New York, (2)
produce for depositions in New York their proposed expertwitnesses Dr.
Hector Cabrera Suarez, Dr. Jose Julio Benitez Astudilo, and Dr. Efrain
Novilo Guzman, provided that Chevron shall reimburse the LAP
Representatives for the reasonable transportation, lodging and
subsistence expenses of the foregoing persons in coming to New York for
their depositions. It is denied in all other respects. The depositions
of Dr. Roberto MacLean and Professor Joseph L. Staats shall be conducted
in Houston, Texas, unless the parties otherwise agreed in writing.
(Signed by Judge Lewis A. Kaplan on 8/16/11) (cd)
|
|
Request |
 |
|
|
224 |
Filed: 8/16/2011, Entered: None |
Order |
|
ORDER the stay of Magistrate
Judge Francis' order, dated 8/3/11, is extended pending further order of
this Court. (Signed by Judge Lewis A. Kaplan on 8/16/11) (cd)
|
|
Request |
 |
|
|
223 |
Filed: 8/15/2011, Entered: None |
Order Referring Case to Magistrate Judge |
|
ORDER REFERRING CASE TO
MAGISTRATE JUDGE. Order that case be referred to the Clerk of Court for
assignment to a Magistrate Judge for Specific Non-Dispositive
Motion/Dispute: Order to show cause why the Court should not (a) find
defendants in contempt (b) order complete production of responsive
documents and (c) in the even of non-compliance further sanctions.
Referred to Magistrate Judge James C. Francis. Motions referred to
James C. Francis. (Signed by Judge Lewis A. Kaplan on 8/15/2011) (tro)
|
|
Request |
 |
|
|
222 |
Filed: 8/15/2011, Entered: None |
Response |
|
RESPONSE re: [192] Objection (non-motion), Objection (non-motion) Ecuadorian
Plaintiffs' Response to Chevron Corporation's Objections to the
Memorandum and Order (Dkt. 180) of the Honorable James C. Francis, IV,
U.S.M.J., dated August 3, 2011. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
221 |
Filed: 8/15/2011, Entered: None |
Declaration in Support |
|
DECLARATION of JAN NIELSEN
LITTLE in Support re: [220] Response,. Document filed by Laura J Garr,
Andrew Woods. (Attachments: # (1) Exhibit A, # (2) Exhibit B)(Little,
Jan)
|
|
Request |
 |
|
|
220 |
Filed: 8/15/2011, Entered: None |
Response |
|
RESPONSE re: [192] Objection (non-motion), Objection (non-motion)
Third-Parties Andrew Woods' and Laura J. Garr's Response to Chevron's
August 8 and August 11, 2011 Submissions Regarding Judge James C.
Francis's August 3, 2011 Order Re: Chevron's Motions to Compel the
Production of Documents. Document filed by Laura J Garr, Andrew Woods. (Little, Jan)
|
|
Request |
 |
|
|
219 |
Filed: 8/15/2011, Entered: None |
Response to Motion |
|
RESPONSE to Motion re: [210]
MOTION to Compel DEFENDANTS JAVIER PIAGUAJE PAYAGUAJE AND HUGO GERARDO
CAMACHO NARANJO AND THEIR EXPERT WITNESSES to appear for depositions in
New York.. Document filed by Hugo Gerardo Camacho Naranjo, Javier
Piaguaje Payaguaje. (Attachments: # (1) Exhibit)(Doyle, Tyler)
|
|
Request |
 |
|
|
218 |
Filed: 8/15/2011, Entered: None |
Notice of Filing Transcript |
|
NOTICE OF FILING OF OFFICIAL
TRANSCRIPT Notice is hereby given that an official transcript of a
Conference proceeding held on 8/2/11 has been filed by the court
reporter/transcriber in the above-captioned matter. The parties have
seven (7) calendar days to file with the court a Notice of Intent to
Request Redaction of this transcript. If no such Notice is filed, the
transcript may be made remotely electronically available to the public
without redaction after 90 calendar days...(McGuirk, Kelly)
|
|
Request |
 |
|
|
217 |
Filed: 8/15/2011, Entered: None |
Transcript |
|
TRANSCRIPT of Proceedings re:
Conference held on 8/2/2011 before Judge Lewis A. Kaplan. Court
Reporter/Transcriber: Tara Jones, (212) 805-0300. Transcript may be
viewed at the court public terminal or purchased through the Court
Reporter/Transcriber before the deadline for Release of Transcript
Restriction. After that date it may be obtained through PACER.
Redaction Request due 9/8/2011. Redacted Transcript Deadline set for
9/19/2011. Release of Transcript Restriction set for
11/17/2011.(McGuirk, Kelly)
|
|
Request |
 |
|
|
216 |
Filed: 8/12/2011, Entered: None |
Declaration in Opposition |
|
DECLARATION of Julio C. Gomez in
Opposition re: [215] Response to Order to Show Cause. Document filed
by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.
(Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3) Exhibit 3, # (4)
Exhibit 4, # (5) Exhibit 5, # (6) Exhibit 6, # (7) Exhibit 7, # (8)
Exhibit 8, # (9) Exhibit 9, # (10) Exhibit 10, # (11) Exhibit 11, # (12)
Exhibit 12, # (13) Exhibit 13, # (14) Exhibit 14, # (15) Exhibit 15, #
(16) Exhibit 16, # (17) Exhibit 17, # (18) Exhibit 18, # (19) Exhibit
19, # (20) Exhibit 20, # (21) Exhibit 21, # (22) Exhibit 22, # (23)
Exhibit 23, # (24) Exhibit 24, # (25) Exhibit 25)(Gomez, Julio)
|
|
Request |
 |
|
|
215 |
Filed: 8/12/2011, Entered: None |
Response to Order to Show Cause |
|
RESPONSE TO ORDER TO SHOW CAUSE
re: [178] Order to Show Cause,,. Document filed by Hugo Gerardo Camacho
Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
214 |
Filed: 8/12/2011, Entered: None |
Order Referring Case to Magistrate Judge |
|
ORDER OF REFERENCE TO A
MAGISTRATE JUDGE: Order that case be referred to the Clerk of Court for
assignment to a Magistrate Judge for Specific Non-Dispositive
Motion/Dispute - Motion to Compel Cherron Response to Interrogatories.
Referred to Magistrate Judge James C. Francis. Motions referred to
James C. Francis. (Signed by Judge Lewis A. Kaplan on 8/12/2011) (ab)
|
|
Request |
 |
|
|
213 |
Filed: 8/12/2011, Entered: None |
Reply to Response to Motion |
|
REPLY to Response to Motion re:
[195] MOTION to Compel Chervon Corporation to Response to
Interrogatories.. Document filed by Hugo Gerardo Camacho Naranjo,
Javier Piaguaje Payaguaje. (Doyle, Tyler)
|
|
Request |
 |
|
|
212 |
Filed: 8/11/2011, Entered: None |
Response in Opposition to Motion |
|
RESPONSE in Opposition re: [195]
MOTION to Compel Chervon Corporation to Response to Interrogatories..
Document filed by Chevron Corporation. (Attachments: # (1) Exhibit A, #
(2) Exhibit B)(Mastro, Randy)
|
|
Request |
 |
|
|
211 |
Filed: 8/11/2011, Entered: None |
Certificate of Service Other |
|
CERTIFICATE OF SERVICE of
Supporting Papers for Order to Show Cause Why This Court Should Not
Reconsider its May 31, 2011 Order on Donziger Defendants' Renewed
Application to Intervene served on Plaintiff Chevron Corporation on
August 11, 2011. Service was made by by Electronic Mail. Document filed
by Steven Donziger, Donziger & Associates PLLC, The Law Offices of
Steven R. Donziger. (Keker, John)
|
|
Request |
 |
|
|
210 |
Filed: 8/11/2011, Entered: None, Terminated: 8/16/2011 |
Motion to Compel |
|
MOTION to Compel DEFENDANTS
JAVIER PIAGUAJE PAYAGUAJE AND HUGO GERARDO CAMACHO NARANJO AND THEIR
EXPERT WITNESSES to appear for depositions in New York. Document filed
by Chevron Corporation. (Attachments: # (1) Exhibit A)(Mastro, Randy)
|
|
Request |
 |
|
|
209 |
Filed: 8/11/2011, Entered: None |
Order |
|
ORDER TO SHOW CAUSE WHY THIS
COURT SHOULD NOT RECONSIDER ITS MAY 31, 2011 ORDER ON DONZIGER
DEFENDANTS' RENEWED APPLICATION TO INTERVENE. Upon the application of
Defendants Steven Donziger, Law Offices of Steve R. Donziger, and
Donziger & Associates, PLLC's ("Donziger") Memorandum of Law in
Support of Renewed Application By Order to Show Cause Why This Court
Should Not Reconsider its May 31, 2011 Order on Donziger's Application
to Intervene; and the Declaration of Jan Nielsen Little dated August 9,
2011, it is hereby: ORDERED, that service of a copy of this Order and
of all the papers submitted in support thereof, by hand, facsimile or
email, upon counsel for Plaintiff Chevron Corporation, on or before 6
p.m. EDT on Thursday, 8/11/11, shall be deemed good and sufficient
service thereof; ORDERED that papers in opposition to Donziger's Renewed
Application to intervene, if any, shall be served and filed
electronically on or before 4 p.m. EDT on Wednesday, August 17, 2011;
ORDERED that reply papers, if any, shall be served and filed
electroniclly on or before 4 p.m. EDT on August 18, 2011, and it is
further ORDERED, that no response is necessary to the argument set forth
in Section II.F of the moving memorandum. (Signed by Judge Lewis A.
Kaplan on 8/11/11) (djc) Modified on 8/11/2011 (djc).
|
|
Request |
 |
|
|
208 |
Filed: 8/11/2011, Entered: None |
Order on Motion for Miscellaneous Relief |
|
ORDER. The Court treats
Danziger's so-called Motion for Relief From Improper Subpoena [DI 194]
as the motion to quash that it really is. The subpoena is addressed to a
so-called the "Entity" which, notwithstanding the broadscope of the
word "person" in Rule 30, is defined in overly broad and perhaps
ambiguous terms - so much so that it would be difficult or impossible to
determine with certainty all of the individuals and entities who fall
within it. Accordingly, the motion to quash [DI 194] is granted. (RE:
[194] Motion for MOTION TO QUASH). (Signed by Judge Lewis A. Kaplan on
8/11/11) (djc)
|
|
Request |
 |
|
|
207 |
Filed: 8/11/2011, Entered: None |
Notice of Filing Transcript |
|
NOTICE OF FILING OF OFFICIAL
TRANSCRIPT Notice is hereby given that an official transcript of a
Conference proceeding held on 8/2/11 has been filed by the court
reporter/transcriber in the above-captioned matter. The parties have
seven (7) calendar days to file with the court a Notice of Intent to
Request Redaction of this transcript. If no such Notice is filed, the
transcript may be made remotely electronically available to the public
without redaction after 90 calendar days...(McGuirk, Kelly)
|
|
Request |
 |
|
|
206 |
Filed: 8/11/2011, Entered: None |
Transcript |
|
TRANSCRIPT of Proceedings re:
Conference held on 8/2/2011 before Judge Lewis A. Kaplan. Court
Reporter/Transcriber: Tara Jones, (212) 805-0300. Transcript may be
viewed at the court public terminal or purchased through the Court
Reporter/Transcriber before the deadline for Release of Transcript
Restriction. After that date it may be obtained through PACER.
Redaction Request due 9/5/2011. Redacted Transcript Deadline set for
9/15/2011. Release of Transcript Restriction set for
11/14/2011.(McGuirk, Kelly)
|
|
Request |
 |
|
|
205 |
Filed: 8/11/2011, Entered: None |
Response to Motion |
|
RESPONSE to Motion re: [194]
MOTION Relief From Improper Subpoena To Testify At Deposition In A Civil
Action.. Document filed by Chevron Corporation. (Attachments: # (1)
Exhibit 1)(Mastro, Randy)
|
|
Request |
 |
|
|
204 |
Filed: 8/11/2011, Entered: None |
Response |
|
RESPONSE re: [190] Objection
(non-motion), Objection (non-motion), [186] Objection (non-motion),
Objection (non-motion). Document filed by Chevron Corporation. (Mastro,
Randy)
|
|
Request |
 |
|
|
203 |
Filed: 8/11/2011, Entered: None, Terminated: 8/23/2011 |
~Motion for Order to Show Cause |
|
MOTION for Order to Show Cause [PROPOSED
ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT RECONSIDER ITS MAY 31,
2011 ORDER ON DONZIGER DEFENDANTS' RENEWED APPLICATION TO INTERVENE]. Document filed by Steven Donziger, Donziger & Associates PLLC, The Law Offices of Steven R. Donziger.(Keker, John)
|
|
Request |
 |
|
|
202 |
Filed: 8/11/2011, Entered: None |
Declaration in Support |
|
DECLARATION of JAN NIELSEN
LITTLE in Support re: [201] Memorandum of Law in Support,. Document
filed by Steven Donziger, Donziger & Associates PLLC, The Law
Offices of Steven R. Donziger. (Attachments: # (1) Exhibit A to
Declaration of Jan Nielsen Little, # (2) Exhibit B to Declaration of Jan
Nielsen Little)(Keker, John)
|
|
Request |
 |
|
|
201 |
Filed: 8/11/2011, Entered: None |
Memorandum of Law in Support |
|
MEMORANDUM OF LAW in Support OF
THEIR RENEWED APPLICATION BY ORDER TO SHOW CAUSE WHY THIS COURT SHOULD
NOT RECONSIDER ITS MAY 31, 2011 ORDER ON DONZIGER'S APPLICATION TO
INTERVENE, AND GRANT DONZIGER FULL INTERVENTION IN CLAIM NINE. Document filed by Steven Donziger, Donziger & Associates PLLC, The Law Offices of Steven R. Donziger. (Keker, John)
|
|
Request |
 |
|
|
Save 25% on a pre-paid one year subscription. |
|
|
200 |
Filed: 8/11/2011, Entered: None |
Order |
|
ORDER: The stay of compliance
with Judge Francis' order of August 3, 2011 until 3 p.m. today is
further extended to and including August 16, 2011 at 3 p.m. in order to
afford the Court further time for consideration. This does not imply any
view with respect to whether the considerations pertinent to stay
applications generally have been satisfied. (Signed by Judge Lewis A.
Kaplan on 8/11/2011) (ae)
|
|
Request |
 |
|
|
199 |
Filed: 8/10/2011, Entered: None |
Certificate of Service Other |
|
CERTIFICATE OF SERVICE of Motion
for Continuance served on all counsel of record on 8-10-11. Document
filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.
(Doyle, Tyler)
|
|
Request |
 |
|
|
198 |
Filed: 8/10/2011, Entered: None, Terminated: 2/21/2012 |
Motion to Continue |
|
MOTION to Continue Trial Setting.
Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Attachments: # (1) Exhibit List Chevron 1782
Depositions)(Doyle, Tyler)
|
|
Request |
 |
|
|
197 |
Filed: 8/10/2011, Entered: None |
Response |
|
RESPONSE to Chevron's Objections to Magistrate Judge Francis's August 3, 2011 Order. Document filed by Joseph C. Kohn, Kohn Swift & Graf, P.C.. (Hamill, Patricia)
|
|
Request |
 |
|
|
196 |
Filed: 8/9/2011, Entered: None |
Certificate of Service Other |
|
CERTIFICATE OF SERVICE of Motion
to Compel served on all counsel of record on 08/09/2011. Document
filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.
(Doyle, Tyler)
|
|
Request |
 |
|
|
195 |
Filed: 8/9/2011, Entered: None, Terminated: 8/19/2011 |
Motion to Compel |
|
MOTION to Compel Chervon
Corporation to Response to Interrogatories. Document filed by Hugo
Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Attachments: # (1)
Exhibit 1, # (2) Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4, # (5)
Exhibit 5, # (6) Exhibit 6)(Doyle, Tyler)
|
|
Request |
 |
|
|
194 |
Filed: 8/9/2011, Entered: None, Terminated: 8/11/2011 |
Motion for Miscellaneous Relief |
|
MOTION Relief From Improper
Subpoena To Testify At Deposition In A Civil Action. Document filed by
Steven Donziger, Donziger & Associates PLLC, The Law Offices of
Steven R. Donziger.(Little, Jan)
|
|
Request |
 |
|
|
193 |
Filed: 8/9/2011, Entered: None |
Declaration in Support |
|
DECLARATION of Anne Chamoion in
Support re: [180] Order,,,. Document filed by Chevron Corporation.
(Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4)
Exhibit D, # (5) Exhibit E)(Mastro, Randy)
|
|
Request |
 |
|
|
192 |
Filed: 8/9/2011, Entered: None |
Objection (non-motion) |
|
Objection re: [180] Order,,, CHEVRON'S
OBJECTIONS TO MAGISTRATE JUDGE FRANCIS'S AUGUST 3, 2011 ORDER REGARDING
CHEVRON'S MOTIONS TO COMPEL PRODUCTION OF DOCUMENTS FROM ANDREW WOODS,
LAURA GARR AND JOSEPH KOHN. Document filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
191 |
Filed: 8/8/2011, Entered: None |
Declaration in Support |
|
DECLARATION of Julio C. Gomez in
Support re: [190] Objection (non-motion), Objection (non-motion).
Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3)
Exhibit 3, # (4) Exhibit 4)(Gomez, Julio)
|
|
Request |
 |
|
|
190 |
Filed: 8/8/2011, Entered: None |
Objection (non-motion) |
|
Objection re: [180] Order,,, Ecuadorian Plaintiffs' Objections to Judge Francis's August 3, 2011 Order and, in the Alternative, Request for Protective Order. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
189 |
Filed: 8/8/2011, Entered: None |
Order |
|
ORDER: The stay of compliance
with Judge Francis' order of August 3, 2011 until 5 p.m. today is
extended to and including August 11, 2011 at 3 p.m. in order to afford
the Court further time for consideration. This does not imply any view
with respect to whether the considerations pertinent to stay
applications generally have been satisfied. The Court may consider any
failure of the LAP Representatives to file objections to that order
reasonably in advance of that time in determining whether to grant
further relief, as the precise nature of the objections may be pertinent
to a decision. (Signed by Judge Lewis A. Kaplan on 8/8/2011) (mro)
|
|
Request |
 |
|
|
188 |
Filed: 8/8/2011, Entered: None |
Letter |
|
Letter addressed to Judge Lewis
A. Kaplan from Randy M. Mastro dated 8/4/11 re: Counsel for the
plaintiff submits this letter narrowing its list of designated experts.
Counsel is withdrawing 10 of them, more than one-third reduction.
Document filed by Chevron Corporation.(mro)
|
|
Request |
 |
|
|
187 |
Filed: 8/8/2011, Entered: None |
Order |
|
ORDER: The LAP Representatives'
motion for an order striking 26 of Chevron's proposed expert witnesses
and limiting the scope of the proceedings or, alternatively, for an
extension of time within which to designate rebuttal witnesses (DI 132,
134) is granted to the extent that the LAP Representatives' time to
designate experts in rebuttal to the proposed testimony of those of
plaintiff's 16 disputed proposed experts that remain and provide Rule 26
disclosures regarding the LAP Representatives' experts in rebuttal
thereto is extended to and including August 22, 2011, and denied in all
other respects. In view of the extended period afforded to them, the
LAP Representatives shall make such disclosures on a rolling basis as
promptly as possible. The Time for completion of expert discovery is
extended from September 15, 2011 to and including September 29, 2011,
provided, however, that the date for completion of all fact discovery
remains September 15, 2011, and all other aspects of the scheduling
order remain unchanged. (Signed by Judge Lewis A. Kaplan on 8/8/2011)
(mro)
|
|
Request |
 |
|
|
186 |
Filed: 8/5/2011, Entered: None |
Objection (non-motion) |
|
Objection re: [180] Order,,, [Third-Parties
Andrew Woods' and Laura J. Garr's Objections to Judge Francis's August
3, 2011 Order and Request for A Stay of Judge Francis's Order Past 5
p.m. on August 8, 2011]. Document filed by Laura J Garr, Andrew Woods. (Little, Jan)
|
|
Request |
 |
|
|
185 |
Filed: 8/5/2011, Entered: None |
Certificate of Service Other |
|
CERTIFICATE OF SERVICE of Notice
in Response to August 1 Order served on all counsel on August 5, 2011.
Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Doyle, Tyler)
|
|
Request |
 |
|
|
184 |
Filed: 8/5/2011, Entered: None |
Response |
|
EMERGENCY RESPONSE re: [182]
Endorsed Letter,,,,,,,. Document filed by Hugo Gerardo Camacho Naranjo,
Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
183 |
Filed: 8/5/2011, Entered: None |
~Notice (other) |
|
NOTICE of in Response to August 1
2011 Order re: [167] Order,. Document filed by Hugo Gerardo Camacho
Naranjo, Javier Piaguaje Payaguaje. (Doyle, Tyler)
|
|
Request |
 |
|
|
182 |
Filed: 8/5/2011, Entered: None |
Endorsed Letter |
|
ENDORSED LETTER addressed to
Judge Lewis A. Kaplan from Gomez LLC, Attorney at Law dated 8/4/2011 re:
I write now to respectfully as that the Court grant a short extension
of Judge Francis' stay so that it encompasses any ensuring time
necessary for the Court to rule upon the objection. ENDORSEMENT:
Magistrate Judge James C. Francis IV on 8/3/2011 issued a 48-page
memorandum and order in which he overruled various attorney-client
privilege and work product objection to subpoenas served upon non-party
witnesses and directed production of most of the documents in question.
DI 180. He stayed most aspects of is order until 5 p.m. on 8/8/2011 in
order to permit the filing before me of objection to his ruling. The LAP
Representatives this morning have submitted a letter requesting a short
extension of the stay "so that it encompasses any ensuring time for the
Court to rule upon the objections". As of this writing, no objections
to Judge Francis' decision have been filed. The grounds of any such
objections, save one mentioned in the LAP Representatives acknowledge
that courts, in ruling on stay applications, consider the likelihood of
success on the merits, the risk of irreparable harm to movants absent a
stay the rick of substantial harm to respondents from the grant of stay,
and considerations of public policy, they have made only the most
cursory effort to address these factors and certainly have not
established a likelihood of success on the merits. Accordingly, the
application is premature and without merit and therefore is denied. This
ruling however, is without prejudice to the filing, prior to the
expiration of Judge Francis' stay, of a renewed stay application
provided that all objections by parties and non-parties and any papers
supporting such objections have been filed with or before the filing of
any such renewed application. (Signed by Judge Lewis A. Kaplan on
8/5/2011) (mbe)
|
|
Request |
 |
|
|
181 |
Filed: 8/4/2011, Entered: None |
Order |
|
ORDER: In light of Magistrate
Judge Francis's order dated August 3, 2011 [DI 180], which orders
production to Chevron of all of the documents listed in Garr's privilege
log and many of those listed in Woods's log, the Court has determined
that it would be more efficient to refer to Judge Francis for
disposition the remainder of the subset of yellow-highlighted documents.
Accordingly, all remaining aspects of Chevron's motion [DI 100] are
referred to Magistrate Judge Francis. (Signed by Judge Lewis A. Kaplan
on 8/4/2011) (ab)
|
|
Request |
 |
|
|
180 |
Filed: 8/3/2011, Entered: None |
Order |
|
MEMORANDUM AND ORDER: For the
reasons discussed, Ms. Garr's objection to Chevron's subpoena based on
the attorney-client privilege and the work products doctrine are
overruled, and she shall produce each of the documents on her privilege
log forthwith. Mr. Woods' objections are overruled except to the extent
that they relate to documents which were created after 10/20/2010 but
which are encompassed by the crime-fraud exception as described above.
Mr. Woods shall produce all documents for which his objections have been
overruled and shall submit for in camera review on 8/8/2011 all other
documents identified in his privilege log and as set forth on this
order. This memorandum and order resolves the motions identified as
docket Nos. 25, 35, and 100. (Signed by Magistrate Judge James C.
Francis on 8/3/2011) Copies Mailed By Chambers. (mbe)
|
|
Request |
 |
|
|
179 |
Filed: 8/3/2011, Entered: None |
Certificate of Service Other |
|
CERTIFICATE OF SERVICE of Motion
and Notice for Extension; Rule 26 Disclosures served on all counsel on
8/1/11. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Doyle, Tyler)
|
|
Request |
 |
|
|
178 |
Filed: 8/2/2011, Entered: None |
Order to Show Cause  |
|
ORDER TO SHOW CAUSE filed by
Chevron Corporation. Defendants Javier Piaguaje Payaguaje and Hugo
Gerardo Camacho Naranjo shall show cause as to why the Court should not:
(A) find Defendants Javier Piaguaje Payaguaje and Hugo Gerardo Camacho
Naranjo in contempt; (B) order complete production of all responsive
documents within one week; and (C) in the event that Defendants Piaguaje
and Camacho do not comply, enter an appropriate sanctions, including an
adverse inference remedy. ENDORSEMENT: Unless otherwise ordered, the
motion will be taken on submission. Show Cause Response due by
8/12/2011. Reply papers due by 8/16/2011. (Signed by Judge Lewis A.
Kaplan on 8/2/2011) (jar)
|
|
Request |
 |
|
|
177 |
Filed: 8/2/2011, Entered: None |
Order on Motion for Extension of Time |
|
MEMO ENDORSEMENT denying [174]
Motion for Extension of Time. ENDORSEMENT: As the conference call made
clear, the Court takes seriously the difficulties that may have been
created by Chevron's designation of the 26 experts who are the subject
of the LAP Representatives' motion to strike or for an extension to meet
their proposed testimony. But those concerns have no bearing at all on
the matter of expert testimony with respect to the 5304(a), subd. 1
issue. The LAP Representatives have been aware of the issue for some
time. They have not shown that they acted with due diligence in the
intervening period. Their failure to designate experts and make
disclosures on that issue by July 1 was questionable at best. They have
not shown that there is any good reason for their failure to have done
so by August 1. They have not shown that cause for modification of the
scheduling order insofar as it applies to disclosures concerning experts
directed at the 5304(a), subd. 1 issue. The motion for an extension to
designate rebuttal experts on the 5304(a), subd. 1 issue (DI 175) is
denied. (Signed by Judge Lewis A. Kaplan on 8/2/2011) (mro) Modified on
8/3/2011 (mro).
|
|
Request |
 |
|
|
176 |
Filed: 8/2/2011, Entered: None |
Rule 26 Disclosure |
|
FILING ERROR - WRONG DOCUMENT
TYPE SELECTED FROM MENU(CERTIFICATE OF SERVICE) - RULE 26
DISCLOSURE.Document filed by Hugo Gerardo Camacho Naranjo, Javier
Piaguaje Payaguaje.(Doyle, Tyler) Modified on 8/3/2011 (ka).
|
|
Request |
 |
|
|
175 |
Filed: 8/1/2011, Entered: None |
~Notice (other) |
|
NOTICE of Motion for Extension to Designate Rebuttal Experts re: [174] MOTION for Extension of Time for Designation of Rebuttal Experts.. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Doyle, Tyler)
|
|
Request |
 |
|
|
174 |
Filed: 8/1/2011, Entered: None, Terminated: 8/2/2011 |
Motion for Extension of Time |
|
MOTION for Extension of Time for Designation of Rebuttal Experts. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(Doyle, Tyler)
|
|
Request |
 |
|
|
173 |
Filed: 8/1/2011, Entered: None |
Endorsed Letter |
|
ENDORSED LETTER addressed to
Judge Lewis A. Kaplan from Randy M. Mastro dated 7/29/2011 re: request
that the Court extend chevron's deadline to designate rebuttal expert
witnesses and make rebuttal expert disclosures to 8/15. ENDORSEMENT:
Time extended to 8/4/2011 pending conference call tomorrow. (Signed by
Judge Lewis A. Kaplan on 8/1/2011) (jar)
|
|
Request |
 |
|
|
172 |
Filed: 8/1/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Kristen L. Hendricks in Support re: [170] MOTION for Order to Show Cause
- [PROPOSED] ORDER TO SHOW CAUSE WHY THE COURT SHOULD NOT (A) FIND
DEFENDANTS JAVIER PIAGUAJE PAYAGUAJE AND HUGO GERARDO CAMACHO NARANJO IN
CONTEMPT; (B) ORDER COMPLETE PRODUCTION OF ALL RESPONSIVE DOCUMENTS
WITHIN O MOTION for Order to Show Cause - [PROPOSED] ORDER TO SHOW
CAUSE WHY THE COURT SHOULD NOT (A) FIND DEFENDANTS JAVIER PIAGUAJE
PAYAGUAJE AND HUGO GERARDO CAMACHO NARANJO IN CONTEMPT; (B) ORDER
COMPLETE PRODUCTION OF ALL RESPONSIVE DOCUMENTS WITHIN O. Document
filed by Chevron Corporation. (Attachments: # (1) Exhibit 1, # (2)
Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4, # (5) Exhibit 5, # (6)
Exhibit 6, # (7) Exhibit 7, # (8) Exhibit 8, # (9) Exhibit 9, # (10)
Exhibit 10, # (11) Exhibit 11, # (12) Exhibit 12, # (13) Exhibit 13, #
(14) Exhibit 14, # (15) Exhibit 15, # (16) Exhibit 16, # (17) Exhibit
17, # (18) Exhibit 18, # (19) Exhibit 19, # (20) Exhibit 20, # (21)
Exhibit 21, # (22) Exhibit 22 - Part 1, # (23) Exhibit 22 - Part 2, #
(24) Exhibit 22 - Part 3, # (25) Exhibit 23)(Mastro, Randy) Modified on
8/2/2011 (db). Modified on 8/2/2011 (db).
|
|
Request |
 |
|
|
171 |
Filed: 8/1/2011, Entered: None |
Memorandum of Law in Support of Motion |
|
MEMORANDUM OF LAW in Support re: [170] MOTION for Order to Show Cause
- [PROPOSED] ORDER TO SHOW CAUSE WHY THE COURT SHOULD NOT (A) FIND
DEFENDANTS JAVIER PIAGUAJE PAYAGUAJE AND HUGO GERARDO CAMACHO NARANJO IN
CONTEMPT; (B) ORDER COMPLETE PRODUCTION OF ALL RESPONSIVE DOCUMENTS
WITHIN O MOTION for Order to Show Cause - [PROPOSED] ORDER TO SHOW
CAUSE WHY THE COURT SHOULD NOT (A) FIND DEFENDANTS JAVIER PIAGUAJE
PAYAGUAJE AND HUGO GERARDO CAMACHO NARANJO IN CONTEMPT; (B) ORDER
COMPLETE PRODUCTION OF ALL RESPONSIVE DOCUMENTS WITHIN O. Document
filed by Chevron Corporation. (Mastro, Randy) Modified on 8/2/2011 (db).
Modified on 8/2/2011 (db).
|
|
Request |
 |
|
|
170 |
Filed: 8/1/2011, Entered: None, Terminated: 2/21/2012 |
~Motion for Order to Show Cause |
|
MOTION for Order to Show Cause
- [PROPOSED] ORDER TO SHOW CAUSE WHY THE COURT SHOULD NOT (A) FIND
DEFENDANTS JAVIER PIAGUAJE PAYAGUAJE AND HUGO GERARDO CAMACHO NARANJO IN
CONTEMPT; (B) ORDER COMPLETE PRODUCTION OF ALL RESPONSIVE DOCUMENTS
WITHIN ONE WEEK; AND (C) IN THE EVENT THAT DEFENDANTS PIAGUAJE AND
CAMACHO DO NOT COMPLY, ENTER SANCTIONS, INCLUDING AN APPROPRIATE ADVERSE
INFERENCE REMEDY. Document filed by Chevron Corporation.(Mastro, Randy) Modified on 8/2/2011 (db). Modified on 8/2/2011 (db).
|
|
Request |
 |
|
|
169 |
Filed: 8/1/2011, Entered: None |
Notice of Filing Transcript |
|
NOTICE OF FILING OF OFFICIAL
TRANSCRIPT Notice is hereby given that an official transcript of a
Conference proceeding held on 7/19/11 has been filed by the court
reporter/transcriber in the above-captioned matter. The parties have
seven (7) calendar days to file with the court a Notice of Intent to
Request Redaction of this transcript. If no such Notice is filed, the
transcript may be made remotely electronically available to the public
without redaction after 90 calendar days...(McGuirk, Kelly)
|
|
Request |
 |
|
|
168 |
Filed: 8/1/2011, Entered: None |
Transcript |
|
TRANSCRIPT of Proceedings re:
Hearing held on 7/19/2011 before Magistrate Judge James C. Francis IV.
Court Reporter/Transcriber: Patricia Nilsen, (212) 805-0300. Transcript
may be viewed at the court public terminal or purchased through the
Court Reporter/Transcriber before the deadline for Release of Transcript
Restriction. After that date it may be obtained through PACER.
Redaction Request due 8/25/2011. Redacted Transcript Deadline set for
9/5/2011. Release of Transcript Restriction set for 11/3/2011.(McGuirk,
Kelly)
|
|
Request |
 |
|
|
167 |
Filed: 8/1/2011, Entered: None |
Order |
|
ORDER. Accordingly, on or before
August 8, 2011, the LAP Representatives shall file a notice stating
whether they wish to have the declaration and exhibits considered in the
disposition of the motion and, if so, a statement conforming to
S.D.N.Y. Civ. R. 56.1. Plaintiff's papers in opposition to the motion
shall be filed within fourteen days following the filing of that notice.
(Signed by Judge Lewis A. Kaplan on 8/1/11) (rjm)
|
|
Request |
 |
|
|
166 |
Filed: 7/29/2011, Entered: None |
Notice of Change of Address |
|
NOTICE OF CHANGE OF ADDRESS by
Elliot Remsen Peters on behalf of Steven Donziger, Donziger &
Associates PLLC, The Law Offices of Steven R. Donziger. New Address:
Keker & Van Nest LLP, 633 Battery Street, San Francisco, California,
U.S.A. 94111, 415-391-5400. (Peters, Elliot)
|
|
Request |
 |
|
|
164 |
Filed: 7/29/2011, Entered: None |
Order |
|
ORDER: Accordingly, Donziger's
motion [DI 128, 129] is denied in all respects. (Signed by Judge Lewis
A. Kaplan on 7/29/2011) (tro)
|
|
Request |
 |
|
|
163 |
Filed: 7/28/2011, Entered: None |
Order on Motion for Order to Show Cause |
|
ORDER: Defendants have moved for
an order striking 26 of Chevron's proposed expert witnesses and
limiting the scope of the proceedings or, alternatively, for an
extension of time within which to designate rebuttal witnesses. DI 132,
134. The motion is granted to the limited extent that defendants' time
to designate rebuttal expert witnesses with respect to the 26 Chevron
experts at issue on the defendants' motion is extended to and including
August 15, 2011. The Court reserves decision on all other aspects of the
motion, including the question whether any additional time should be
afforded. (Signed by Judge Lewis A. Kaplan on 7/28/2011) (ab).
|
|
Request |
 |
|
|
162 |
Filed: 7/28/2011, Entered: None |
Reply Memorandum of Law in Support of Motion |
|
REPLY MEMORANDUM OF LAW in Support re: [128] MOTION for Order to Show Cause [PROPOSED
ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT RECONSIDER ITS MAY 31,
2011 ORDER ON DONZIGER DEFENDANTS' APPLICATION TO INTERVENE]. MOTION for Order to Show Cause [PROPOSED
ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT RECONSIDER ITS MAY 31,
2011 ORDER ON DONZIGER DEFENDANTS' APPLICATION TO INTERVENE].. Document filed by Steven Donziger, Donziger & Associates PLLC, The Law Offices of Steven R. Donziger. (Keker, John)
|
|
Request |
 |
|
|
161 |
Filed: 7/28/2011, Entered: None |
Endorsed Letter |
|
ENDORSED LETTER addressed to
Magistrate Judge James C. Francis IV from Elliot R. Peters dated 7/25/11
re: We respectfully request that Your Honor either (a) Order Chevron to
return Woods entire hard drive to Woods as further specified in this
letter, or (b) Order Chevron within five (5) business days to make a
partial image of the hard drive containing only documents related to the
Ecuadorean litigation, retain that partial image, and return the entire
hard drive to Mr. Woods and as further specified in this letter.
ENDORSEMENT: Chevron shall promptly delete from the Woods Hard Drive any
files identified by Mr. Woods or his counsel as containing personal
information. To the extent that Chevron believes that any file so
identified contains information relevant to its discovery requests,
counsel shall meet and confer and, if they are unable to agree on the
disposition of the information, shall submit the dispute to me. So
ordered. (Signed by Magistrate Judge James C. Francis on 7/28/11) (rjm)
|
|
Request |
 |
|
|
160 |
Filed: 7/28/2011, Entered: None |
Reply Memorandum of Law |
|
REPLY MEMORANDUM OF LAW re: [134] Order to Show Cause,,., REPLY MEMORANDUM OF LAW in Support of Application by Order to Show Cause Why Chevron's Irrelevent Expert Witnesses Should Not Be Stricken, and other relief. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
159 |
Filed: 7/28/2011, Entered: None |
Certificate of Service Other |
|
CERTIFICATE OF SERVICE of
Ecuadorian Plaintiffs Motion for Judgment on the Pleadings and documents
in support of same served on Plaintiff Chevron Corporation on July 27,
2011. Service was accepted by Telles Milliga, Gibson Dunn &
Crutcher LLP. Document filed by Hugo Gerardo Camacho Naranjo, Javier
Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
165 |
Filed: 7/27/2011, Entered: None, Terminated: 9/6/2011 |
Motion to Appear Pro Hac Vice |
|
MOTION for Garland D. Murphy IV
to Appear Pro Hac Vice. Document filed by Hugo Gerardo Camacho Naranjo,
Javier Piaguaje Payaguaje.(pgu)
|
|
Request |
 |
|
|
158 |
Filed: 7/27/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Julio C. Gomez in
Support re: [156] MOTION for Judgment on the Pleadings.. Document
filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.
(Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C Part 1, #
(4) Exhibit C Part 2, # (5) Exhibit C Part 3, # (6) Exhibit C Part 4, #
(7) Exhibit D, # (8) Exhibit E Part 1, # (9) Exhibit E Part 2, # (10)
Exhibit F Part 1, # (11) Exhibit F Part 2, # (12) Exhibit G, # (13)
Exhibit H, # (14) Exhibit I, # (15) Exhibit J, # (16) Exhibit K, # (17)
Exhibit L, # (18) Exhibit M, # (19) Exhibit N, # (20) Exhibit O, # (21)
Exhibit P, # (22) Exhibit Q, # (23) Exhibit R Part 1, # (24) Exhibit R
Part 2, # (25) Exhibit R Part 3, # (26) Exhibit R Part 4, # (27) Exhibit
R Part 5, # (28) Exhibit R Part 6)(Gomez, Julio)
|
|
Request |
 |
|
|
157 |
Filed: 7/27/2011, Entered: None |
Memorandum of Law in Support of Motion |
|
MEMORANDUM OF LAW in Support
re: [156] MOTION for Judgment on the Pleadings.. Document filed by Hugo
Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
156 |
Filed: 7/27/2011, Entered: None, Terminated: 8/31/2011 |
Motion for Judgment on the Pleadings |
|
MOTION for Judgment on the
Pleadings. Document filed by Hugo Gerardo Camacho Naranjo, Javier
Piaguaje Payaguaje.(Gomez, Julio)
|
|
Request |
 |
|
|
155 |
Filed: 7/27/2011, Entered: None |
Order on Motion for Order to Show Cause |
|
MEMO ENDORSEMENT on Rejected
Order to Show Cause Why Defendants' denying [152] Motion for Order to
Show Cause Why Defendants' Motion for Judgment on the Pleadings Should
Not Be Granted. Endorsement (conclusion; see order for entire
endorsement): In short, there is no "go and sufficient reason" why a
procedure other than notice of motion is necessary. The application for
an order to show cause is denied without prejudice to defendants' right
to proceed by notice of motion. (Signed by Judge Lewis A. Kaplan on
7/27/2011) (jar)
|
|
Request |
 |
|
|
154 |
Filed: 7/27/2011, Entered: None |
Endorsed Letter |
|
ENDORSED LETTER addressed to
Judge Lewis A. Kaplan from Craig Smyser dated 7/27/2011 re: Counsel
request that the Court enforce its riles regarding briefs and motion
papers, require Chevron to withdraw its non-complaint brief and refile a
complaint paper, and permit the Ecuadorian plaintiffs to respond to the
complaint brief on whatever timetable the Court deems appropriate.
ENDORSEMENT: De minimis non-curet lex. So Ordered. (Signed by Judge
Lewis A. Kaplan on 7/27/2011) (jfe) Modified on 8/2/2011 (jfe).
|
|
Request |
 |
|
|
153 |
Filed: 7/27/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Craig Smyser in Support re: [152] MOTION for Order to Show Cause WHY DEFENDANTS' MOTION FOR JUDGMENT ON THE PLEADINGS SHOULD NOT BE GRANTED.. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
152 |
Filed: 7/27/2011, Entered: None, Terminated: 7/27/2011 |
~Motion for Order to Show Cause |
|
MOTION for Order to Show Cause WHY DEFENDANTS' MOTION FOR JUDGMENT ON THE PLEADINGS SHOULD NOT BE GRANTED. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(Gomez, Julio)
|
|
Request |
 |
|
|
151 |
Filed: 7/27/2011, Entered: None |
Declaration in Support |
|
DECLARATION of Julio C. Gomez in
Support re: [150] Memorandum of Law in Support,. Document filed by
Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Attachments: #
(1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C Part 1, # (4) Exhibit C
Part 2, # (5) Exhibit C Part 3, # (6) Exhibit C Part 4, # (7) Exhibit
D, # (8) Exhibit E Part 1, # (9) Exhibit E Part 2, # (10) Exhibit F Part
1, # (11) Exhibit F Part 2, # (12) Exhibit G, # (13) Exhibit H, # (14)
Exhibit I, # (15) Exhibit J, # (16) Exhibit K, # (17) Exhibit L, # (18)
Exhibit M, # (19) Exhibit N, # (20) Exhibit O, # (21) Exhibit P, # (22)
Exhibit Q, # (23) Exhibit R Part 1, # (24) Exhibit R Part 2, # (25)
Exhibit R Part 3, # (26) Exhibit R Part 4, # (27) Exhibit R Part 5, #
(28) Exhibit R Part 6)(Gomez, Julio)
|
|
Request |
 |
|
|
150 |
Filed: 7/27/2011, Entered: None |
Memorandum of Law in Support |
|
MEMORANDUM OF LAW in Support OF DEFENDANTS HUGO GERARDO CAMACHO NARANJO'S AND JAVIER PIAGUAJE PAYAGUAJE'S MOTION FOR JUDGMENT ON THE PLEADINGS. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
149 |
Filed: 7/26/2011, Entered: None |
Declaration in Opposition to Motion |
|
DECLARATION of Randy M. Mastro
in Opposition re: [132] MOTION for Order to Show Cause.. Document filed
by Chevron Corporation. (Attachments: # (1) Exhibit 15, # (2) Exhibit
16)(Mastro, Randy)
|
|
Request |
 |
|
|
148 |
Filed: 7/26/2011, Entered: None |
Declaration in Opposition to Motion |
|
DECLARATION of Randy M. Mastro
in Opposition re: [132] MOTION for Order to Show Cause.. Document filed
by Chevron Corporation. (Attachments: # (1) Exhibit 2, # (2) Exhibit 3
- Part 1, # (3) Exhibit 3 - Part 2, # (4) Exhibit 3 - Part 3, # (5)
Exhibit 4, # (6) Exhibit 5, # (7) Exhibit 6, # (8) Exhibit 7, # (9)
Exhibit 8, # (10) Exhibit 9, # (11) Exhibit 10, # (12) Exhibit 11, #
(13) Exhibit 12, # (14) Exhibit 13, # (15) Exhibit 14 - Part 1, # (16)
Exhibit 14 - Part 2)(Mastro, Randy)
|
|
Request |
 |
|
|
147 |
Filed: 7/26/2011, Entered: None |
Declaration in Opposition to Motion |
|
DECLARATION of Randy M. Mastro
in Opposition re: [132] MOTION for Order to Show Cause.. Document filed
by Chevron Corporation. (Attachments: # (1) Exhibit 1 - Part 1, # (2)
Exhibit 1 - Part 2, # (3) Exhibit 1 - Part 3, # (4) Exhibit 1 - Part 4, #
(5) Exhibit 1 - Part 5, # (6) Exhibit 1 - Part 6, # (7) Exhibit 1 -
Part 7, # (8) Exhibit 1 - Part 8, # (9) Exhibit 1 - Part 9, # (10)
Exhibit 1 - Part 10, # (11) Exhibit 1 - Part 11, # (12) Exhibit 1 - Part
12, # (13) Exhibit 1 - Part 13, # (14) Exhibit 1 - Part 14, # (15)
Exhibit 1 - Part 15)(Mastro, Randy)
|
|
Request |
 |
|
|
146 |
Filed: 7/26/2011, Entered: None |
Memorandum of Law in Opposition to Motion |
|
MEMORANDUM OF LAW in
Opposition re: [132] MOTION for Order to Show Cause.. Document filed by
Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
145 |
Filed: 7/26/2011, Entered: None |
Letter |
|
Letter addressed to Judge Lewis A
Kaplan from Randy Mastro dated 7/22/11 re: Request for an informal
conference. Document filed by Chevron Corporation.(cd)
|
|
Request |
 |
|
|
144 |
Filed: 7/26/2011, Entered: None |
Letter |
|
Letter addressed to Judge Lewis A
Kaplan from Craig Smyser dated 7/22/11 re: Chevron's 7/22/11 letter and
that the court has set the schedule for response to discovery. Document
filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(cd)
|
|
Request |
 |
|
|
143 |
Filed: 7/26/2011, Entered: None |
Order |
|
ORDER The framework and schedule
proposed by plaintiff in counsel's letter of July 22,2011 for
responding to the LAP Representatives' written discovery requests is
approved and adopted save that (a) the parties shall meet and confer no
later than July 29,2011, (b) Chevron shall provide written responses and
objections to the requests no later than August 3, 2011, (c) Chevron
will produce responsive materials and information on a rolling basis
commencing no later than August 3, 2011 and shall complete its
production within 14 days thereafter (subject to the resolution of
objections to the nature and scope of the LAP Representatives'
requests). (Signed by Judge Lewis A. Kaplan on 7/26/11) (cd)
|
|
Request |
 |
|
|
142 |
Filed: 7/26/2011, Entered: None |
Declaration in Opposition to Motion |
|
DECLARATION of Randy M. Mastro in Opposition re: [128] MOTION for Order to Show Cause [PROPOSED
ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT RECONSIDER ITS MAY 31,
2011 ORDER ON DONZIGER DEFENDANTS' APPLICATION TO INTERVENE]. MOTION for Order to Show Cause [PROPOSED
ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT RECONSIDER ITS MAY 31,
2011 ORDER ON DONZIGER DEFENDANTS' APPLICATION TO INTERVENE]..
Document filed by Chevron Corporation. (Attachments: # (1) Exhibit 1, #
(2) Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4, # (5) Exhibit 5, # (6)
Exhibit 6, # (7) Exhibit 7)(Mastro, Randy)
|
|
Request |
 |
|
|
141 |
Filed: 7/26/2011, Entered: None |
Memorandum of Law in Opposition to Motion |
|
MEMORANDUM OF LAW in Opposition re: [128] MOTION for Order to Show Cause [PROPOSED
ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT RECONSIDER ITS MAY 31,
2011 ORDER ON DONZIGER DEFENDANTS' APPLICATION TO INTERVENE]. MOTION for Order to Show Cause [PROPOSED
ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT RECONSIDER ITS MAY 31,
2011 ORDER ON DONZIGER DEFENDANTS' APPLICATION TO INTERVENE].. Document filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
140 |
Filed: 7/26/2011, Entered: None |
Order on Motion to Appear Pro Hac Vice |
|
MEMO ENDORSEMENT re: [125]
Motion for Craig Smyser to Appear Pro Hac Vice. ENDORSEMENT: Granted. So
ordered. (Signed by Judge Lewis A. Kaplan on 7/26/2011) (mro)
|
|
Request |
 |
|
|
139 |
Filed: 7/26/2011, Entered: None |
Order on Motion to Appear Pro Hac Vice |
|
MEMO ENDORSEMENT re: [124]
Motion for Larry R. Veselka to Appear Pro Hac Vice. ENDORSEMENT:
Granted. So ordered. (Signed by Judge Lewis A. Kaplan on 7/26/2011)
(mro)
|
|
Request |
 |
|
|
138 |
Filed: 7/26/2011, Entered: None |
Order on Motion to Appear Pro Hac Vice |
|
MEMO ENDORSEMENT re: [123]
Motion for Christina A. Bryan to Appear Pro Hac Vice. ENDORSEMENT:
Granted. So Ordered. (Signed by Judge Lewis A. Kaplan on 7/26/2011)
(mro)
|
|
Request |
 |
|
|
137 |
Filed: 7/22/2011, Entered: None |
Declaration in Support |
|
DECLARATION of Julio C. Gomez in
Support re: [136] Response. Document filed by Hugo Gerardo Camacho
Naranjo, Javier Piaguaje Payaguaje. (Attachments: # (1) Exhibit 1, #
(2) Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4, # (5) Exhibit 5)(Gomez,
Julio)
|
|
Request |
 |
|
|
136 |
Filed: 7/22/2011, Entered: None |
Response |
|
RESPONSE re: Discovery Hearing. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
135 |
Filed: 7/22/2011, Entered: None |
Certificate of Service Other |
|
CERTIFICATE OF SERVICE of
Discovery Requests Propounded by the Ecuadorian Plaintiffs on Chevron
served on All Counsel of Record on 07/21/11. Service was made by
Electronic Mail. Document filed by Hugo Gerardo Camacho Naranjo, Javier
Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
134 |
Filed: 7/22/2011, Entered: None |
Order to Show Cause  |
|
ORDER TO SHOW CAUSE filed by
Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. Chevron
Corporation shall show cause as to why Chevron's irrelevant expert
witnesses should not be stricken, the scope of proceedings should not be
limited, or, in the alternative, additional time for designation of
rebuttal expert witness should not be granted. Show Cause Response due
by 7/26/2011. Reply papers, if any, shall be served and filed
electronically on or before 5:00 p.m. Thursday, 7/26/2011. Unless
otherwise ordered, the motion shall be taken under submission. (Signed
by Judge Lewis A. Kaplan on 7/22/2011) (ae)
|
|
Request |
 |
|
|
133 |
Filed: 7/21/2011, Entered: None |
Certificate of Service Other |
|
CERTIFICATE OF SERVICE of ORDER
TO SHOW CAUSE WHY THIS COURT SHOULD NOT RECONSIDER ITS MAY 31, 2011
ORDER ON DONZIGER DEFENDANTS' APPLICATION TO INTERVENE AND PAPERS
SUBMITTED IN SUPPORT THEREOF served on CHEVRON CORPORATION on 7/21/2011.
Document filed by Steven Donziger, Donziger & Associates PLLC, The
Law Offices of Steven R. Donziger. (Little, Jan)
|
|
Request |
 |
|
|
132 |
Filed: 7/21/2011, Entered: None, Terminated: 7/28/2011 |
~Motion for Order to Show Cause |
|
MOTION for Order to Show Cause. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(Gomez, Julio)
|
|
Request |
 |
|
|
131 |
Filed: 7/21/2011, Entered: None |
Declaration in Support |
|
DECLARATION of Craig Smyser in
Support re: [130] Memorandum of Law in Support,. Document filed by Hugo
Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Attachments: #
(1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5)
Exhibit E, # (6) Exhibit F, # (7) Exhibit G, # (8) Exhibit H, # (9)
Exhibit I, # (10) Exhibit J, # (11) Exhibit K, # (12) Exhibit L, # (13)
Exhibit M, # (14) Exhibit N, # (15) Exhibit O, # (16) Exhibit P, # (17)
Exhibit Q, # (18) Exhibit R, # (19) Exhibit S, # (20) Exhibit T, # (21)
Exhibit U, # (22) Exhibit V, # (23) Exhibit W, # (24) Exhibit X, # (25)
Exhibit Y, # (26) Exhibit Z)(Gomez, Julio)
|
|
Request |
 |
|
|
130 |
Filed: 7/21/2011, Entered: None |
Memorandum of Law in Support |
|
MEMORANDUM OF LAW in Support OF
APPLICATION BY ORDER TO SHOW CAUSE WHY CHEVRON'S IRRELEVANT EXPERT
WITNESSES SHOULD NOT BE STRICKEN, THE SCOPE OF PROCEEDINGS SHOULD NOT BE
LIMITED, OR, IN THE ALTERNATIVE, ADDITIONAL TIME FOR DESIGNATION OF
REBUTTAL EXPERT WITNESSES SHOULD NOT BE GRANTED. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
129 |
Filed: 7/21/2011, Entered: None |
Order to Show Cause  |
|
ORDER TO SHOW CAUSE WHY THIS
COURT SHOULD NOT RECONSIDER ITS MAY 31, ORDER ON DONZIGER DEFENDANTS'
APPLICATION TO INTERVENE: Upon sufficient cause appearing from
Defendants Steven Donziger, Law Offices of Steve R. Donziger, and
Donziger & Associates, PLLC's ("Donziger") Memorandum of Law in
Support of Application By Order to Show Cause Why This Court Should Not
Reconsider its 5/31/2011 Order on Donziger's Application to Intervene;
and the Declaration of Jan Nielsen Little dated 7/20/2011, it is hereby
ORDERED that service of a copy of this Order and all of the papers
submitted in support thereof, by hand, facsimile or email, upon counsel
for Plaintiff Chevron Corporation, on or before 8:30 a.m. on Friday,
7/22/2011, shall be deemed good and sufficient service thereof; and it
is further ORDERED that papers in opposition to Donziger's Application
to Intervene, if any, shall be served and filed electronically on or
before 5:00 p.m. on Tuesday, 7/26/2011; ORDERED that reply papers, if
any, shall be served and filed electronically on or before 4:00 p.m. on
Thursday, 7/28/2011. shall show cause as to why this Court should not
reconsider its 5/31/2011 Order on Donziger's Application to Intervene;
and the Declaration of Jan Nielsen Little dated 7/20/2011. (Responses
due by 7/26/2011, Replies due by 7/28/2011.) Motions terminated: [128]
MOTION for Order to Show Cause [PROPOSED ORDER TO SHOW CAUSE WHY THIS
COURT SHOULD NOT RECONSIDER ITS MAY 31, 2011 ORDER ON DONZIGER
DEFENDANTS' APPLICATION TO INTERVENE] MOTION for Order to Show Cause [PROPOSED
ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT RECONSIDER ITS MAY 31,
2011 ORDER ON DONZIGER DEFENDANTS' APPLICATION TO INTERVENE] filed
by Donziger & Associates PLLC, The Law Offices of Steven R.
Donziger, Steven Donziger. (Signed by Judge Lewis A. Kaplan on
7/21/2011) (tro)
|
|
Request |
 |
|
|
128 |
Filed: 7/20/2011, Entered: None, Terminated: 7/21/2011 |
~Motion for Order to Show Cause |
|
MOTION for Order to Show Cause [PROPOSED
ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT RECONSIDER ITS MAY 31,
2011 ORDER ON DONZIGER DEFENDANTS' APPLICATION TO INTERVENE].
Document filed by Steven Donziger, Donziger & Associates PLLC, The
Law Offices of Steven R. Donziger.(Keker, John) Modified on 7/21/2011
(db).
|
|
Request |
 |
|
|
127 |
Filed: 7/20/2011, Entered: None |
Declaration in Support |
|
DECLARATION of JAN NIELSEN
LITTLE in Support re: [126] Memorandum of Law in Support,. Document
filed by Steven Donziger, Donziger & Associates PLLC, The Law
Offices of Steven R. Donziger. (Attachments: # (1) Exhibit A)(Little,
Jan)
|
|
Request |
 |
|
|
126 |
Filed: 7/20/2011, Entered: None |
Memorandum of Law in Support |
|
MEMORANDUM OF LAW in Support
OF THEIR APPLICATION BY ORDER TO SHOW CAUSE WHY THIS COURT SHOULD NOT
RECONSIDER ITS MAY 31, 2011 ORDER ON DONZIGER'S APPLICATION TO
INTERVENE, AND GRANT DONZIGER FULL INTERVENTION IN CLAIM NINE. Document filed by Steven Donziger, Donziger & Associates PLLC, The Law Offices of Steven R. Donziger. (Keker, John)
|
|
Request |
 |
|
|
125 |
Filed: 7/19/2011, Entered: None |
Motion to Appear Pro Hac Vice |
|
MOTION for Craig Smyser to
Appear Pro Hac Vice. Document filed by Hugo Gerardo Camacho Naranjo,
Javier Piaguaje Payaguaje.(pgu)
|
|
Request |
 |
|
|
124 |
Filed: 7/19/2011, Entered: None |
Motion to Appear Pro Hac Vice |
|
MOTION for Larry R. Veselka to
Appear Pro Hac Vice. Document filed by Hugo Gerardo Camacho Naranjo,
Javier Piaguaje Payaguaje.(pgu)
|
|
Request |
 |
|
|
123 |
Filed: 7/19/2011, Entered: None |
Motion to Appear Pro Hac Vice |
|
MOTION for Christina A. Bryan
to Appear Pro Hac Vice. Document filed by Hugo Gerardo Camacho Naranjo,
Javier Piaguaje Payaguaje.(pgu)
|
|
Request |
 |
|
|
122 |
Filed: 7/15/2011, Entered: None |
Endorsed Letter |
|
ENDORSED LETTER addressed to
Magistrate Judge James C. Francis from Elliot R. Peters dated 7/15/11
re: counsel for defendants write that we just received Mr. Mastro's
letter to the Court regarding a proposed audio-visual display at
Tuesday's hearing on the Motion to Compel, I write to observe that such
histrionics are unlikely to shed light on any of the privilege
questions before the Court, and to request that if Chevron is
nonetheless permitted to show video or photographs at the hearing, that
we be furnished no later than 9 a.m. New York time on Monday with copies
of whatever they plan to use so that we may be prepared to object or
respond. ENDORSEMENT: Application granted to the extent that by 12:00
noon EDT on Monday, July 18, 2011, Chevon shall provide to counsel for
all other parties (including non-parties subject to subpoena) any
photographs or videotapes that it intends to introduce at the hearing
the following day. (Signed by Magistrate Judge James C. Francis on
7/15/11) (pl) Modified on 7/18/2011 (pl). Modified on 8/1/2011 (pl).
|
|
Request |
 |
|
|
121 |
Filed: 7/15/2011, Entered: None |
Endorsed Letter |
|
ENDORSED LETTER addressed to
Judge Lewis A. Kaplan from Elliot R. Peters dated 7/14/2011 re: Counsel
requests a conference call at Your Honor's convenience or relief from
today's Order, and the opportunity to discuss this issue with Magistrate
Judge Francis on July 19 at the already scheduled hearing. ENDORSEMENT:
The time to respond is extended to 5 p.m. on July 19, 2011. (Signed by
Judge Lewis A. Kaplan on 7/15/2011) (tro)
|
|
Request |
 |
|
|
120 |
Filed: 7/15/2011, Entered: None, Terminated: 9/8/2011 |
Motion to Quash |
|
MOTION to Quash and Objections
to subpoena to produce documents, information, or objects in a civil
action and MOTION for Protective Order. Document filed by non-party
HomeTown Bank, N.A.(mro)
|
|
Request |
 |
|
|
119 |
Filed: 7/14/2011, Entered: None |
Order on Motion to Appear Pro Hac Vice |
|
MEMO ENDORSEMENT granting [115]
Motion for James J. Rohn, Patricia M. Hamill, and Joshua J. Voss to
Appear Pro Hac Vice. ENDORSEMENT: Granted. (Signed by Judge Lewis A.
Kaplan on 7/14/2011) (tro)
|
|
Request |
 |
|
|
118 |
Filed: 7/14/2011, Entered: None |
Endorsed Letter |
|
ENDORSED LETTER addressed to
Judge Lewis A. Kaplan from Randy M. Mastro dated 7/13/2011 re: Counsel
for Plaintiff Chevron Corporation writes to clarify an important fact
regarding the privilege logs of Andrew Woods and Laura Garr.
ENDORSEMENT: In its motion to compel of July 5, 2011 (DI 100), Chevron
sought, among other things, the production of exchanges with third
parties enumerated on the privilege log, which it stated were
"highlighted in yellow." Having determined that there are approximately
300 documents highlighted in yellow on the privilege log, the Court, in
order to save time, directed the submission of those documents to it for
in camera inspection while referring the balance of the motion to
Magistrate Judge Francis. DI 117. The Court subsequently received from
Chevron a letter stating that there are an additional 400 documents
listed on the privilege log that it claims also were exchanges with
third parties, but that were highlighted in pink. It seeks an order
directing the submission of those documents as well for in camera
inspection by this Court rather than by Magistrate Judge Francis in the
first instance. The Court will leave any in camera inspection of those
additional documents to Magistrate Judge Francis should he think such
inspection appropriate. In order to facilitate any such inspection, two
copies of each of those documents shall be submitted to Magistrate Judge
Francis' chambers no later than 4 p.m. on July 15, 2011 for such use as
he may deem appropriate in resolving the motions now before him.
(Signed by Judge Lewis A. Kaplan on 7/14/2011) (tro)
|
|
Request |
 |
|
|
117 |
Filed: 7/12/2011, Entered: None |
Order |
|
ORDER: Regarding Plaintiff
Chevron Corporation's motion to compel Andrew Woods and Laura Garr to
produce individual documents listed on their privilege logs and the
referral of this motion to Magistrate Judge Francis in all other
aspects. (Signed by Judge Lewis A. Kaplan on 7/12/2011) (ae)
|
|
Request |
 |
|
|
116 |
Filed: 7/12/2011, Entered: None |
Order Referring Case to Magistrate Judge |
|
ORDER REFERRING CASE TO
MAGISTRATE JUDGE. Order that case be referred to the Clerk of Court for
assignment to a Magistrate Judge for Specific Non-Dispositive
Motion/Dispute. Part of Motion to Compel Woods and Garr to produce
individual docs listed on their privilege logs. Referred to Magistrate
Judge James C. Francis. Motions referred to James C. Francis. (Signed
by Judge Lewis A. Kaplan on 7/12/2011) (ae)
|
|
Request |
 |
|
|
115 |
Filed: 7/8/2011, Entered: None |
Motion to Appear Pro Hac Vice |
|
MOTION for James J. Rohn,
Patricia M. Hamill, and Joshua J. Voss to Appear Pro Hac Vice. Document
filed by Joseph C. Kohn, Kohn Swift & Graf, P.C.(pgu)
|
|
Request |
 |
|
|
114 |
Filed: 7/8/2011, Entered: None |
Declaration in Opposition to Motion |
|
DECLARATION of Carlos A. Zelaya,
II in Opposition re: [25] MOTION to Compel Laura J. Garr and Andrew
Woods to produce documents.. Document filed by Hugo Gerardo Camacho
Naranjo, Javier Piaguaje Payaguaje. (Attachments: # (1) Exhibit A, #
(2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6)
Exhibit F, # (7) Exhibit G, # (8) Exhibit H)(Gomez, Julio)
|
|
Request |
 |
|
|
113 |
Filed: 7/8/2011, Entered: None |
Reply Memorandum of Law in Oppisition to Motion |
|
REPLY MEMORANDUM OF LAW in Opposition re: [25] MOTION to Compel Laura J. Garr and Andrew Woods to produce documents. Sur-Reply Memorandum of Law. Document filed by Maria Victoria Aguinda Salazar, Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
112 |
Filed: 7/8/2011, Entered: None |
Reply Memorandum of Law in Oppisition to Motion |
|
THIRD PARTY REPLY MEMORANDUM OF
LAW in Opposition re: [25] MOTION to Compel Laura J. Garr and Andrew
Woods to produce documents. [SUR-REPLY IN OPPOSITION]. Document filed by Laura J Garr, Andrew Woods. (Peters, Elliot)
|
|
Request |
 |
|
|
111 |
Filed: 7/7/2011, Entered: None |
Response in Opposition to Motion |
|
RESPONSE in Opposition re: [100]
MOTION to Compel ANDREW WOODS AND LAURA GARR to PRODUCE INDIVIDUAL
DOCUMENTS LISTED ON THEIR PRIVILEGE LOGS.. Document filed by Hugo
Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Attachments: # (1)
Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5)
Exhibit E, # (6) Exhibit F)(Gomez, Julio)
|
|
Request |
 |
|
|
110 |
Filed: 7/7/2011, Entered: None |
Memorandum of Law in Opposition to Motion |
|
MEMORANDUM OF LAW in
Opposition re: [100] MOTION to Compel ANDREW WOODS AND LAURA GARR to
PRODUCE INDIVIDUAL DOCUMENTS LISTED ON THEIR PRIVILEGE LOGS.. Document
filed by Laura J Garr, Andrew Woods. (Peters, Elliot)
|
|
Request |
 |
|
|
109 |
Filed: 7/7/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Carlos A. Zelaya,
II in Support re: [42] MOTION for Leave to File Amended Answer to
Amended Complaint, Separate Defenses and Jury Trial Demand.. Document
filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.
(Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C)(Gomez,
Julio)
|
|
Request |
 |
|
|
108 |
Filed: 7/7/2011, Entered: None |
Reply Memorandum of Law in Support of Motion |
|
REPLY MEMORANDUM OF LAW in
Support re: [42] MOTION for Leave to File Amended Answer to Amended
Complaint, Separate Defenses and Jury Trial Demand.. Document filed by
Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
107 |
Filed: 7/7/2011, Entered: None |
Reply Memorandum of Law in Support of Motion |
|
FILING ERROR - DEFICIENT DOCKET ENTRY - (SEE DOCUMENT # 108) - REPLY MEMORANDUM OF LAW in Support re: [49] MOTION to Strike CHEVRON
CORPORATION'S NOTICE OF MOTION AND MOTION FOR PARTIAL JUDGMENT ON THE
PLEADINGS REGARDING CERTAIN DEFENSES ASSERTED BY DEFENDANTS STEVEN
DONZIGER, THE LAW OFFICES OF STEVEN DONZIGER, DONZIGER & ASSOCIATES,
PLLC, HUGO G. Document filed by Hugo Gerardo Camacho Naranjo, Javier
Piaguaje Payaguaje. (Gomez, Julio) Modified on 7/13/2011 (lb).
|
|
Request |
 |
|
|
106 |
Filed: 7/7/2011, Entered: None |
Endorsed Letter |
|
ENDORSED LETTER addressed to
Judge Lewis A. Kaplan from Carlos A. Zelaya, II dated 7/6/2011 re:
Plaintiffs respectfully ask that the Court strike Chevron's Motion.
ENDORSEMENT: The application to strike Chevron's motion is denied. So
Ordered. (Signed by Judge Lewis A. Kaplan on 7/7/2011) (jfe)
|
|
Request |
 |
|
|
105 |
Filed: 7/6/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Anne Champion in
Support re: [35] MOTION to Compel Joseph C. Kohn and Kohn, Swift &
Graf P.C. to produce documents.. Document filed by Chevron Corporation.
(Attachments: # (1) Exhibit 38, # (2) Exhibit 39, # (3) Exhibit 40, #
(4) Exhibit 41, # (5) Exhibit 42, Part 1, # (6) Exhibit 42, Part 2, #
(7) Exhibit 43, # (8) Exhibit 44, # (9) Exhibit 45)(Mastro, Randy)
|
|
Request |
 |
|
|
104 |
Filed: 7/6/2011, Entered: None |
Reply Memorandum of Law in Support of Motion |
|
REPLY MEMORANDUM OF LAW in
Support re: [35] MOTION to Compel Joseph C. Kohn and Kohn, Swift &
Graf P.C. to produce documents.. Document filed by Chevron Corporation.
(Mastro, Randy)
|
|
Request |
 |
|
|
103 |
Filed: 7/6/2011, Entered: None |
Certificate of Service Other |
|
CERTIFICATE OF SERVICE of Expert
Disclosures served on Defendants and Intervenors on 7/1/2011. Service
was made by Electronic Mail. Document filed by Chevron Corporation.
(Mastro, Randy)
|
|
Request |
 |
|
|
102 |
Filed: 7/6/2011, Entered: None |
Endorsed Letter |
|
ENDORSED LETTER addressed to
Magistrate Judge James C. Francis from Randy M. Mastro dated 6/28/11 re:
Accordingly, while Chevron opposes additional briefing by the
Defendants alone, it respectfully requests that Your Honor permit all
parties to simultaneously submit supplemental briefs to address any
remaining issues, to be limited to no more than five pages and to be
submitted by no later than this Friday, July 1. ENDORSEMENT: Application
denied. All issues may be fully aired at the hearing that is now
scheduled. SO ORDERED. (Signed by Magistrate Judge James C. Francis on
7/6/11) (djc)
|
|
Request |
 |
|
|
101 |
Filed: 7/6/2011, Entered: None |
Order on Motion to Compel |
|
ORDER. Accordingly, plaintiff's
motion to compel production of documents pursuant to its Rule 34 request
is granted to the extent that defendants Camacho Naranjo and Piaguaje
Payaguaje shall comply fully with all requests on or before July 15,
2011, save that (a) the objections with respect to Request Nos. 16, 31,
36 and 46 are sustained, (b) these defendants by that date shall comply
fully with Request Nos. 12 and 18 as modified above, and (c) in lieu of
producing documents as to which these defendants claim privilege, these
defendants may produce, on or before July 13, 2011, a privilege log
fully compliant with S.D.N.Y. Civ. R. 26.2. Granting in part and denying
in part [77] Motion to Compel. (Signed by Judge Lewis A. Kaplan on
7/6/2011) (rjm)
|
|
Request |
 |
|
|
Save 25% on a pre-paid one year subscription. |
|
|
100 |
Filed: 7/5/2011, Entered: None, Terminated: 8/3/2011 |
Motion to Compel |
|
MOTION to Compel ANDREW WOODS
AND LAURA GARR to PRODUCE INDIVIDUAL DOCUMENTS LISTED ON THEIR PRIVILEGE
LOGS. Document filed by Chevron Corporation. (Attachments: # (1)
Exhibit 1, # (2) Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4, # (5)
Exhibit 5, # (6) Exhibit 6)(Mastro, Randy)
|
|
Request |
 |
|
|
99 |
Filed: 7/1/2011, Entered: None |
Certificate of Service Other |
|
CERTIFICATE OF SERVICE of Notice
of Defendants Hugo Gerardo Camacho Naranjo and Javier Piaguaje
Payaguaje and accompanying Exhibits 1-6 served on Chevron Corporation on
July 1, 2011. Service was made by Email. Document filed by Hugo
Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
98 |
Filed: 6/30/2011, Entered: None |
Notice of Appeal |
|
NOTICE OF APPEAL from [1]
Order,. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. Filing fee $ 455.00, receipt number 465401010548. (nd)
|
|
Request |
 |
|
|
97 |
Filed: 6/30/2011, Entered: None |
Order |
|
ORDER. Accordingly, the
definitions of the words "communication," "document," and "person" in
the interrogatories are modified to conform to the definitions of those
words in S.D.N.Y. 26.3. The motion to compel full and complete responses
to the interrogatories [DI 72] is granted. Defendants shall (a) answer
the interrogatories and (b) serve a complete privilege log compliant
withS.D.N.Y. Civ. R. 26.2 with respect to any document or oral
communication as to which they claim privilege, in each case on or
before July 11, 2011. Failure to serve a log as here directed may result
in the waiver of any claim of privilege.(Signed by Judge Lewis A.
Kaplan on 6/30/11) (djc)
|
|
Request |
 |
|
|
96 |
Filed: 6/30/2011, Entered: None |
Memorandum of Law in Opposition to Motion |
|
MEMORANDUM OF LAW in
Opposition re: [77] MOTION to Compel Defendants Javier Piaguaje
Payaguaje and Hugo Gerardo Camacho Naranjo to Produce Documents..
Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
95 |
Filed: 6/30/2011, Entered: None |
Order on Motion to Compel |
|
ORDER. The objections to the
requests for admissions all are overruled. The motion to compel
responses [DI 71] is granted in all respects. Defendants shall respond
fully to the requests in accordance with Rule 36 and this order no later
than July 8, 2011. In the event they fail to do so, the matters in
respect of which admissions are sought may be deemed admitted.(granting
[71] Motion to Compel). (Signed by Judge Lewis A. Kaplan on 6/30/11)
(djc)
|
|
Request |
 |
|
|
94 |
Filed: 6/30/2011, Entered: None |
Order |
|
ORDER. ORDERED, as follows: 1.
The time within which any party served with discovery requests pursuant
to Fed. R. Civ. P. 33, 34 and 36 must respond shall be seven days unless
the Court by order approves a different time period.2. Any motion to
quash or modify a subpoena shall be served and filed no laterthan seven
days after service of the subpoena unless the return date of the
subpoena is less than seven days from the date of service, in which case
such a motion shall be served prior to the return date. A copy of this
Order shall be served with any subpoena henceforth served on any
non-party. 3. S.D.N.Y. Civ. R. 33.3(a) and 33.3(c) shall have no
further application in this action absent further order of the Court.
(Signed by Judge Lewis A. Kaplan on 6/30/11) (djc)
|
|
Request |
 |
|
|
93 |
Filed: 6/29/2011, Entered: None |
Declaration in Opposition to Motion |
|
DECLARATION of Carlos A. Zelaya,
II in Opposition re: [35] MOTION to Compel Joseph C. Kohn and Kohn,
Swift & Graf P.C. to produce documents.. Document filed by Hugo
Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Attachments: # (1)
Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5)
Exhibit E, # (6) Exhibit F, # (7) Exhibit G, # (8) Exhibit H, # (9)
Exhibit I, # (10) Exhibit J, # (11) Exhibit K, # (12) Exhibit L, # (13)
Exhibit M, # (14) Exhibit N, # (15) Exhibit O, # (16) Exhibit P, # (17)
Exhibit Q, # (18) Exhibit R, # (19) Exhibit S, # (20) Exhibit T, # (21)
Exhibit U)(Gomez, Julio)
|
|
Request |
 |
|
|
92 |
Filed: 6/29/2011, Entered: None |
Memorandum of Law in Opposition to Motion |
|
MEMORANDUM OF LAW in
Opposition re: [35] MOTION to Compel Joseph C. Kohn and Kohn, Swift
& Graf P.C. to produce documents.. Document filed by Hugo Gerardo
Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
91 |
Filed: 6/29/2011, Entered: None |
Response to Motion |
|
RESPONSE to Motion re: [71]
MOTION to Compel Defendants Javier Piaguaje Payaguaje and Hugo Gerardo
Camacho Naranjo to respond to requests for admissions, dated May 20,
2011.. Document filed by Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
90 |
Filed: 6/29/2011, Entered: None |
Response to Motion |
|
RESPONSE to Motion re: [72]
MOTION to Compel Defendants Javier Piaguaje Payaguaje and Hugo Gerardo
Camacho Naranjo to respond to interrogatories, dated May 20, 2011..
Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
89 |
Filed: 6/29/2011, Entered: None |
Declaration in Opposition to Motion |
|
DECLARATION of Seth Ard in
Opposition re: [35] MOTION to Compel Joseph C. Kohn and Kohn, Swift
& Graf P.C. to produce documents.. Document filed by Joseph C.
Kohn, Kohn Swift & Graf, P.C.. (Attachments: # (1) Exhibit A, Part
1, # (2) Exhibit A, Part 2, # (3) Exhibit A, Part 3, # (4) Exhibit B, #
(5) Exhibit C, # (6) Exhibit D, # (7) Exhibit E, # (8) Exhibit F, # (9)
Exhibit G, # (10) Exhibit H, # (11) Exhibit I, # (12) Exhibit J, # (13)
Exhibit K, # (14) Exhibit L, # (15) Exhibit M, # (16) Exhibit N, # (17)
Exhibit O, # (18) Exhibit P, # (19) Exhibit Q, # (20) Exhibit R)(Ard,
Seth)
|
|
Request |
 |
|
|
88 |
Filed: 6/29/2011, Entered: None |
Memorandum of Law in Opposition to Motion |
|
MEMORANDUM OF LAW in
Opposition re: [35] MOTION to Compel Joseph C. Kohn and Kohn, Swift
& Graf P.C. to produce documents.. Document filed by Joseph C.
Kohn, Kohn Swift & Graf, P.C.. (Susman, Stephen)
|
|
Request |
 |
|
|
87 |
Filed: 6/29/2011, Entered: None |
Notice of Appearance |
|
NOTICE OF APPEARANCE by Stephen D. Susman on behalf of Joseph C. Kohn, Kohn Swift & Graf, P.C. (Susman, Stephen)
|
|
Request |
 |
|
|
86 |
Filed: 6/29/2011, Entered: None |
Endorsed Letter |
|
ENDORSED LETTER addressed to
Judge Lewis A. Kaplan from Carlos A. Zelaya dated 6/28/2011 re: request
extension of time until 7/1/2011 to oppose Chevron's Motion to Compel.
ENDORSEMENT: The Court previously extended the time to 6/30 at 4:00 p.m.
and declines to extend it further. (Signed by Judge Lewis A. Kaplan on
6/29/2011) (jar)
|
|
Request |
 |
|
|
85 |
Filed: 6/28/2011, Entered: None |
Notice of Appearance |
|
NOTICE OF APPEARANCE by Seth D. Ard on behalf of Joseph C. Kohn, Kohn Swift & Graf, P.C. (Ard, Seth)
|
|
Request |
 |
|
|
84 |
Filed: 6/28/2011, Entered: None |
Memorandum and Opinion |
|
MEMORANDUM OPINION #100479 re:
(40 in 1:11-cv-03718-LAK -JCF) MOTION to Compel Pablo Fajardo Mendoza,
Juan Pablo Senz, Julio Prieto Mndez, and Luis Yanza to appear for
deposition filed by Chevron Corporation. For the foregoing reasons,
plaintiff's motion to compel [DI 40] is denied. (Signed by Judge Lewis
A. Kaplan on 6/28/2011) (tro) Modified on 6/30/2011 (ajc).
|
|
Request |
 |
|
|
83 |
Filed: 6/28/2011, Entered: None |
Endorsed Letter |
|
ENDORSED LETTER addressed to
Judge Lewis A. Kaplan from Carlos A. Zelaya, II dated 6/27/11 re: I
write to respectfully request an extension until and including Friday,
July 1, 2011, to respond to Chevron Corporation's ("Chevron") Motion to
Compel Requests for Admissions and Chevron's Motion to Compel Responses
to Interrogatories from Defendants Javier Piaguaje Payaguaje and Hugo
Gerardo Camacho Naraqjo ENDORSEMENT: The Court previously extended the
time to 6/29/11 and declines to extend it further. Denied. (Signed by
Judge Lewis A. Kaplan on 6/28/11) (djc)
|
|
Request |
 |
|
|
82 |
Filed: 6/28/2011, Entered: None |
Order Referring Case to Magistrate Judge |
|
ORDER REFERRING CASE TO
MAGISTRATE JUDGE. Order that case be referred to the Clerk of Court for
assignment to a Magistrate Judge for Specific Non-Dispositive
Motion/Dispute: *Motion to Compel Kohn &Kohn, Swift & Graf.
Referred to Magistrate Judge James C. Francis. Motions referred to
James C. Francis. (Signed by Judge Lewis A. Kaplan on 6/28/11) (djc)
Modified on 7/6/2011 (djc).
|
|
Request |
 |
|
|
81 |
Filed: 6/28/2011, Entered: None |
Endorsed Letter |
|
ENDORSED LETTER addressed to
Magistrate Judge James C. Francis from Elliot R. Peters dated 6/27/2011
re: Accordingly, Mr. Woods and Ms. Garr hereby join in defendants
Camacho's and Piaguaje's request that the Court strike the last two,
single-spaced pages of Chevron's reply brief, as well as the twenty-four
new exhibits submitted by Chevron on reply. ENDORSEMENT: Defendants and
third-parties Woods and Garr may each submit a surreply of no more than
seven (7) pages by July 8, 2011. A hearing will be scheduled
thereafter so that these issues may be fully briefed. (Signed by
Magistrate Judge James C. Francis on 6/28/2011) (tro)
|
|
Request |
 |
|
|
80 |
Filed: 6/28/2011, Entered: None |
Order |
|
ORDER: Among the motions now
pending in this action are motions by plaintiff to compel defendants
Camacho Naranjo and Piaguaje Payaguaje to respond to requests for
admissions (DI 71) and interrogatories (Dl 72), both filed on June 24,
2011, and to produce documents (DI 77), filed June 27, 2011. In order to
avoid any claim of misunderstanding, (a) any papers in opposition to DI
71 and 72 motions shall be filed no later than June 29, 2011, (b) any
papers in opposition to DI 77 shall be filed no later than June 30, 2011
at 4 p.m., and (c) any papers in response to any other discovery
related motion in this case shall be filed no later than two business
days following the date on which the motion was filed. This affords
brief extensions of the time within which any papers in opposition to DI
71, DI 72 and DI 77 must be filed. Set Deadlines/Hearing as to [77]
MOTION to Compel Defendants Javier Piaguaje Payaguaje and Hugo Gerardo
Camacho Naranjo to Produce Documents. ( Responses due by 6/30/2011)
(Signed by Judge Lewis A. Kaplan on 6/28/2011) (ae)
|
|
Request |
 |
|
|
79 |
Filed: 6/27/2011, Entered: None |
Reply Memorandum of Law in Support of Motion |
|
REPLY MEMORANDUM OF LAW in Support re: [49] MOTION to Strike CHEVRON
CORPORATION'S NOTICE OF MOTION AND MOTION FOR PARTIAL JUDGMENT ON THE
PLEADINGS REGARDING CERTAIN DEFENSES ASSERTED BY DEFENDANTS STEVEN
DONZIGER, THE LAW OFFICES OF STEVEN DONZIGER, DONZIGER & ASSOCIATES,
PLLC, HUGO G. Document filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
78 |
Filed: 6/27/2011, Entered: None |
Memorandum of Law in Opposition to Motion |
|
MEMORANDUM OF LAW in
Opposition re: [42] MOTION for Leave to File Amended Answer to Amended
Complaint, Separate Defenses and Jury Trial Demand.. Document filed by
Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
77 |
Filed: 6/27/2011, Entered: None, Terminated: 7/6/2011 |
Motion to Compel |
|
MOTION to Compel Defendants
Javier Piaguaje Payaguaje and Hugo Gerardo Camacho Naranjo to Produce
Documents. Document filed by Chevron Corporation. (Attachments: # (1)
Exhibit 1, # (2) Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4, # (5)
Exhibit 5, # (6) Exhibit 6, # (7) Exhibit 7)(Mastro, Randy)
|
|
Request |
 |
|
|
76 |
Filed: 6/24/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Kristen L.
Hendricks in Support re: [25] MOTION to Compel Laura J. Garr and Andrew
Woods to produce documents.. Document filed by Chevron Corporation.
(Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3) Exhibit 3, # (4)
Exhibit 4, # (5) Exhibit 5, # (6) Exhibit 6, # (7) Exhibit 7, # (8)
Exhibit 8, # (9) Exhibit 9, # (10) Exhibit 10, # (11) Exhibit 11, # (12)
Exhibit 12, # (13) Exhibit 13, Part 1, # (14) Exhibit 13, Part 2, #
(15) Exhibit 14, # (16) Exhibit 15, # (17) Exhibit 16, # (18) Exhibit
17, # (19) Exhibit 18, # (20) Exhibit 19, # (21) Exhibit 20, # (22)
Exhibit 21, # (23) Exhibit 22, # (24) Exhibit 23, # (25) Exhibit
24)(Mastro, Randy)
|
|
Request |
 |
|
|
75 |
Filed: 6/24/2011, Entered: None |
Reply Memorandum of Law in Support of Motion |
|
REPLY MEMORANDUM OF LAW in
Support re: [25] MOTION to Compel Laura J. Garr and Andrew Woods to
produce documents.. Document filed by Chevron Corporation. (Mastro,
Randy)
|
|
Request |
 |
|
|
74 |
Filed: 6/24/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Anne Champion in
Support re: [40] MOTION to Compel Pablo Fajardo Mendoza, Juan Pablo
Senz, Julio Prieto Mndez, and Luis Yanza to appear for deposition..
Document filed by Chevron Corporation. (Attachments: # (1) Exhibit 49, #
(2) Exhibit 50, # (3) Exhibit 51)(Mastro, Randy)
|
|
Request |
 |
|
|
73 |
Filed: 6/24/2011, Entered: None |
Reply Memorandum of Law in Support of Motion |
|
REPLY MEMORANDUM OF LAW in
Support re: [40] MOTION to Compel Pablo Fajardo Mendoza, Juan Pablo
Senz, Julio Prieto Mndez, and Luis Yanza to appear for deposition..
Document filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
72 |
Filed: 6/24/2011, Entered: None, Terminated: 6/30/2011 |
Motion to Compel |
|
MOTION to Compel Defendants
Javier Piaguaje Payaguaje and Hugo Gerardo Camacho Naranjo to respond to
interrogatories, dated May 20, 2011. Document filed by Chevron
Corporation. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3)
Exhibit 3, # (4) Exhibit 4)(Mastro, Randy)
|
|
Request |
 |
|
|
71 |
Filed: 6/24/2011, Entered: None, Terminated: 6/30/2011 |
Motion to Compel |
|
MOTION to Compel Defendants
Javier Piaguaje Payaguaje and Hugo Gerardo Camacho Naranjo to respond to
requests for admissions, dated May 20, 2011. Document filed by Chevron
Corporation. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3)
Exhibit 3, # (4) Exhibit 4)(Mastro, Randy)
|
|
Request |
 |
|
|
70 |
Filed: 6/24/2011, Entered: None |
Order |
|
MEMORANDUM AND ORDER denying in all respects [4] Order to Show Cause. (Signed by Judge Lewis A. Kaplan on 6/23/11) (cd)
|
|
Request |
 |
|
|
69 |
Filed: 6/24/2011, Entered: None |
Order Referring Case to Magistrate Judge |
|
ORDER REFERRING CASE TO
MAGISTRATE JUDGE. Order that case be referred to the Clerk of Court for
assignment to a Magistrate Judge for Specific Non-Dispositive
Motion/Dispute. Referred to Magistrate Judge James C. Francis. Motion
to compel production from Laura Garr and Andrew Woods referred to James
C. Francis. (Signed by Judge Lewis A. Kaplan on 6/24/11) (cd)
|
|
Request |
 |
|
|
68 |
Filed: 6/23/2011, Entered: None |
Memorandum of Law in Opposition to Motion |
|
MEMORANDUM OF LAW in Opposition re: [25] MOTION to Compel Laura J. Garr and Andrew Woods to produce documents. [CORRECTED] Memorandum of Law. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
67 |
Filed: 6/23/2011, Entered: None |
Declaration in Opposition to Motion |
|
DECLARATION of Julio C. Gomez in
Opposition re: [25] MOTION to Compel Laura J. Garr and Andrew Woods to
produce documents.. Document filed by Hugo Gerardo Camacho Naranjo,
Javier Piaguaje Payaguaje. (Attachments: # (1) Exhibit A, # (2) Exhibit
B)(Gomez, Julio)
|
|
Request |
 |
|
|
66 |
Filed: 6/22/2011, Entered: None |
Memorandum of Law in Opposition to Motion |
|
FILING ERROR - DEFICIENT DOCKET
ENTRY (SEE [68] MEMORANDUM) - MEMORANDUM OF LAW in Opposition re: [25]
MOTION to Compel Laura J. Garr and Andrew Woods to produce documents..
Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Gomez, Julio) Modified on 6/23/2011 (db).
|
|
Request |
 |
|
|
65 |
Filed: 6/21/2011, Entered: None |
Declaration in Opposition to Motion |
|
DECLARATION of Julio C. Gomez in
Opposition re: [40] MOTION to Compel Pablo Fajardo Mendoza, Juan Pablo
Senz, Julio Prieto Mndez, and Luis Yanza to appear for deposition..
Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Attachments: # (1) Exhibit A, # (2) Exhibit B)(Gomez,
Julio)
|
|
Request |
 |
|
|
64 |
Filed: 6/21/2011, Entered: None |
Memorandum of Law in Opposition to Motion |
|
MEMORANDUM OF LAW in
Opposition re: [40] MOTION to Compel Pablo Fajardo Mendoza, Juan Pablo
Senz, Julio Prieto Mndez, and Luis Yanza to appear for deposition..
Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
62 |
Filed: 6/21/2011, Entered: None |
Order on Motion to Amend/Correct |
|
MEMO ENDORSED denying [54] Motion to Amend/Correct, (Signed by Judge Lewis A. Kaplan on 6/21/11) (cd)
|
|
Request |
 |
|
|
61 |
Filed: 6/17/2011, Entered: None |
Joinder |
|
JOINDER to join re: [60] Memorandum of Law in Opposition to Motion CORRECTED. Document filed by Steven Donziger, Donziger & Associates PLLC, The Law Offices of Steven R. Donziger.(Peters, Elliot)
|
|
Request |
 |
|
|
60 |
Filed: 6/17/2011, Entered: None |
Memorandum of Law in Opposition to Motion |
|
MEMORANDUM OF LAW in Opposition re: [25] MOTION to Compel Laura J. Garr and Andrew Woods to produce documents. CORRECTED. Document filed by Laura J Garr, Andrew Woods. (Peters, Elliot)
|
|
Request |
 |
|
|
59 |
Filed: 6/17/2011, Entered: None |
Joinder |
|
JOINDER to join re: [56]
Memorandum of Law in Opposition to Motion. Document filed by Steven
Donziger, Donziger & Associates PLLC, The Law Offices of Steven R.
Donziger.(Peters, Elliot)
|
|
Request |
 |
|
|
58 |
Filed: 6/17/2011, Entered: None |
Declaration in Opposition to Motion |
|
DECLARATION of Laura J. Garr in
Opposition re: [25] MOTION to Compel Laura J. Garr and Andrew Woods to
produce documents.. Document filed by Laura J Garr, Andrew Woods.
(Peters, Elliot)
|
|
Request |
 |
|
|
57 |
Filed: 6/17/2011, Entered: None |
Declaration in Opposition to Motion |
|
DECLARATION of Andrew Woods in
Opposition re: [25] MOTION to Compel Laura J. Garr and Andrew Woods to
produce documents.. Document filed by Laura J Garr, Andrew Woods.
(Peters, Elliot)
|
|
Request |
 |
|
|
56 |
Filed: 6/17/2011, Entered: None |
Memorandum of Law in Opposition to Motion |
|
MEMORANDUM OF LAW in
Opposition re: [25] MOTION to Compel Laura J. Garr and Andrew Woods to
produce documents.. Document filed by Laura J Garr, Andrew Woods.
(Peters, Elliot)
|
|
Request |
 |
|
|
55 |
Filed: 6/17/2011, Entered: None |
Endorsed Letter |
|
ENDORSED LETTER addressed to
Judge Lewis A. Kaplan from Julio C. Gomez dated 6/15/2011 re: Requesting
an extension to and including June 22, 2011 to respond to Chevron
Corporation's motion to compel the production of documents. ENDORSEMENT:
The time of defendants Camacho and Piaguve to respond to the motion is
extended to and including June 22, 2011, provided, however, that this
does not alter the date by which Ms. Garr and Mr. Woods must respond.
Chevron's reply papers are due on June 24, 2011. (Signed by Judge Lewis
A. Kaplan on 6/17/2011) (jpo)
|
|
Request |
 |
|
|
54 |
Filed: 6/17/2011, Entered: None, Terminated: 6/21/2011 |
Motion to Amend/Correct |
|
MOTION to Amend/Correct [33] Order, Motion
to Correct Misstatements Contained in June 14, 2011 Order (DI 33)
Denying Stay Application by Defendants Steven Donziger, The Law Offices
of Steven R. Donziger, and Donziger & Associates, PLLC. Document filed by Steven Donziger, Donziger & Associates PLLC, The Law Offices of Steven R. Donziger.(Peters, Elliot)
|
|
Request |
 |
|
|
53 |
Filed: 6/17/2011, Entered: None |
Endorsed Letter |
|
ENDORSED LETTER: addressed to
Judge Lewis A. Kaplan from Julio C. Gomez dated 6/16/2011 re: Counsel
for defendant respectfully request that this Court deny Chevron's
request to expedite briefing on Chevron's motion to compel documents
from Joseph Kohn and Kohn, Swift & Graf P.c., and instead grant the
Ecuadorian Plaintiffs at least three weeks time to respond to Chevron's
motion.ENDORSEMENT: Papers in opposition to the motion shall be filed no
later then June 29, 2011, reply papers shall be filed no later then
July 6, 2011. So Ordered. (Signed by Judge Lewis A. Kaplan on 6/17/11)
(js)
|
|
Request |
 |
|
|
52 |
Filed: 6/17/2011, Entered: None |
Endorsed Letter |
|
ENDORSED LETTER: addressed to
Judge Lewis A. Kaplan from Julio C. Gomez dated 6/16/2011 re: I
therefore respectfully request that this Court extend the time to
respond to Chevron's motion to compel Messrs. Camacho and Piaguaje to
physically produce individuals located in another country by two days,
to and including, Wednesday, June 22, 2011. Undersigned counsel
attempted to reach Chevron counsel in advance of submitting this request
to the Court (and proposed as well that Chevron's reply time be
extended by two more days), but was unsuccessful in contacting opposing
counsel. This is the first extension request my client' have made with
respect to this motion. ENDORSEMENT: The argument for an extension is
grossly exaggerated. Nonetheless, the time to respond is extended to and
including June 21, 2011. reply papers shall be filed by June 25, 2011.
So Ordered. (Signed by Judge Lewis A. Kaplan on 6/17/11) (js)
|
|
Request |
 |
|
|
51 |
Filed: 6/17/2011, Entered: None |
Letter |
|
LETTER: addressed to judge Lewis
A. Kaplan from Randy M. Mastro dated 6/16/2011 re: Chevron has no
objection to the LAP Representatives' request for this brief extension
of their time to oppose Chevron's motion, so long as Chevron's time to
file reply papers to any opposition is extended to and including Friday,
June 24th, at which time Chevron will file a single reply to any
opposition papers filed by any parties (e.g., Laura Garr, Andrew Woods,
and/or the LAP Representatives). Any accommodation of the LAP
Representatives' request, however, should not result in any further
extension of the deadline for submission of opposition papers by Laura
Garr and Andrew Woods, who agreed to do so by this Friday, June 17th
consistent with the June 3 Stipulation.Document filed by Chevron
Corporation.(js)
|
|
Request |
 |
|
|
50 |
Filed: 6/17/2011, Entered: None |
Memorandum of Law in Support of Motion |
|
MEMORANDUM OF LAW in Support re: [49] MOTION to Strike CHEVRON
CORPORATION'S NOTICE OF MOTION AND MOTION FOR PARTIAL JUDGMENT ON THE
PLEADINGS REGARDING CERTAIN DEFENSES ASSERTED BY DEFENDANTS STEVEN
DONZIGER, THE LAW OFFICES OF STEVEN DONZIGER, DONZIGER & ASSOCIATES,
PLLC, HUGO G. Document filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
49 |
Filed: 6/17/2011, Entered: None, Terminated: 8/17/2011 |
Motion to Strike |
|
MOTION to Strike CHEVRON
CORPORATION'S NOTICE OF MOTION AND MOTION FOR PARTIAL JUDGMENT ON THE
PLEADINGS REGARDING CERTAIN DEFENSES ASSERTED BY DEFENDANTS STEVEN
DONZIGER, THE LAW OFFICES OF STEVEN DONZIGER, DONZIGER & ASSOCIATES,
PLLC, HUGO GERARDO CAMACHO NARANJO, AND JAVIER PIAGUAJE PAYAGUAJE OR,
IN THE ALTERNATIVE, TO STRIKE THOSE DEFENSES. Document filed by Chevron Corporation.(Mastro, Randy)
|
|
Request |
 |
|
|
47 |
Filed: 6/16/2011, Entered: None |
Notice of Appearance |
|
NOTICE OF APPEARANCE by Elliot
Remsen Peters on behalf of Andrew Woods, Laura J Garr (Peters, Elliot)
Modified on 6/17/2011 (jar).
|
|
Request |
 |
|
|
46 |
Filed: 6/16/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Kristen L.
Hendricks in Support re: [35] MOTION to Compel Joseph C. Kohn and Kohn,
Swift & Graf P.C. to produce documents.. Document filed by Chevron
Corporation. (Attachments: # (1) Exhibit AA-AZ, # (2) Exhibit BA-BB, #
(3) Exhibit BC-BZ, # (4) Exhibit CA-CZ, # (5) Exhibit DA-DM, # (6)
Exhibit DN, # (7) Exhibit DO-DZ, # (8) Exhibit EA-EO, # (9) Exhibit
EP-EZ)(Mastro, Randy)
|
|
Request |
 |
|
|
45 |
Filed: 6/16/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Kristen L.
Hendricks in Support re: [35] MOTION to Compel Joseph C. Kohn and Kohn,
Swift & Graf P.C. to produce documents.. Document filed by Chevron
Corporation. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3)
Exhibit C - Part 1, # (4) Exhibit C - Part 2, # (5) Exhibit C - Part 3, #
(6) Exhibit C - Part 4, # (7) Exhibit C - Part 5, # (8) Exhibit C -
Part 6, # (9) Exhibit D-Z)(Mastro, Randy)
|
|
Request |
 |
|
|
44 |
Filed: 6/15/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Anne Champion
(continued) in Support re: [40] MOTION to Compel Pablo Fajardo Mendoza,
Juan Pablo Senz, Julio Prieto Mndez, and Luis Yanza to appear for
deposition.. Document filed by Chevron Corporation. (Attachments: #
(1) Exhibit 29, # (2) Exhibit 30, # (3) Exhibit 31, # (4) Exhibit 32, #
(5) Exhibit 33, # (6) Exhibit 34, # (7) Exhibit 35, # (8) Exhibit 36, #
(9) Exhibit 37, # (10) Exhibit 38, # (11) Exhibit 39, # (12) Exhibit 40,
# (13) Exhibit 41, # (14) Exhibit 42, Part 1, # (15) Exhibit 42, Part
2, # (16) Exhibit 43, # (17) Exhibit 44, # (18) Exhibit 45, # (19)
Exhibit 46, # (20) Exhibit 47, # (21) Exhibit 48)(Mastro, Randy)
|
|
Request |
 |
|
|
43 |
Filed: 6/15/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Anne Champion in
Support re: [40] MOTION to Compel Pablo Fajardo Mendoza, Juan Pablo
Senz, Julio Prieto Mndez, and Luis Yanza to appear for deposition..
Document filed by Chevron Corporation. (Attachments: # (1) Exhibit 1,
Part 1, # (2) Exhibit 1, Part 2, # (3) Exhibit 2, # (4) Exhibit 3, # (5)
Exhibit 4, # (6) Exhibit 5, # (7) Exhibit 6, # (8) Exhibit 7, # (9)
Exhibit 8, # (10) Exhibit 9, # (11) Exhibit 10, # (12) Exhibit 11, #
(13) Exhibit 12, # (14) Exhibit 13, # (15) Exhibit 14, # (16) Exhibit
15, # (17) Exhibit 16, # (18) Exhibit 17, # (19) Exhibit 18, # (20)
Exhibit 19, # (21) Exhibit 20, # (22) Exhibit 21, # (23) Exhibit 22, #
(24) Exhibit 23, # (25) Exhibit 24, # (26) Exhibit 25, # (27) Exhibit
26, # (28) Exhibit 27, # (29) Exhibit 28)(Mastro, Randy)
|
|
Request |
 |
|
|
42 |
Filed: 6/15/2011, Entered: None, Terminated: 8/17/2011 |
Motion for Leave to File Document |
|
MOTION for Leave to File
Amended Answer to Amended Complaint, Separate Defenses and Jury Trial
Demand. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje
Payaguaje. (Attachments: # (1) Proposed Amended Answer to Amended
Complaint, Separate Defenses and Jury Trial Demand)(Gomez, Julio)
|
|
Request |
 |
|
|
41 |
Filed: 6/15/2011, Entered: None |
Memorandum of Law in Support of Motion |
|
MEMORANDUM OF LAW in Support
re: [40] MOTION to Compel Pablo Fajardo Mendoza, Juan Pablo Senz, Julio
Prieto Mndez, and Luis Yanza to appear for deposition.. Document filed
by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
40 |
Filed: 6/15/2011, Entered: None, Terminated: 6/28/2011 |
Motion to Compel |
|
MOTION to Compel Pablo Fajardo
Mendoza, Juan Pablo Senz, Julio Prieto Mndez, and Luis Yanza to appear
for deposition. Document filed by Chevron Corporation.(Mastro, Randy)
|
|
Request |
 |
|
|
39 |
Filed: 6/15/2011, Entered: None |
Declaration in Support |
|
DECLARATION of Julio C. Gomez in
Support re: [38] Memorandum of Law in Opposition,. Document filed by
Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Attachments: #
(1) Exhibit Ex. A, # (2) Exhibit Ex. B, # (3) Exhibit Ex. C, # (4)
Exhibit Ex. D, # (5) Exhibit Ex. E)(Gomez, Julio)
|
|
Request |
 |
|
|
38 |
Filed: 6/15/2011, Entered: None |
Memorandum of Law in Opposition |
|
MEMORANDUM OF LAW in Opposition to
Chevron Corporations Motion For Partial Judgment On The Pleadings
Regarding Certain Defenses Or In The Alternative To Strike Those
Defenses, And In Support Of Hugo Gerardo Camacho Naranjo's and Javier
Piaguaje Payaguaje's Cross-Motion To Amend Certain Affirmative Defenses
If Deemed Necessary By The Court. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
37 |
Filed: 6/15/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Anne Champion in
Support re: [35] MOTION to Compel Joseph C. Kohn and Kohn, Swift &
Graf P.C. to produce documents.. Document filed by Chevron Corporation.
(Attachments: # (1) Exhibit 1 - 2, # (2) Exhibit 3, Part 1, # (3)
Exhibit 3, Part 2, # (4) Exhibit 4 - 5, # (5) Exhibit 6, Part A, # (6)
Exhibit 6, Part B, # (7) Exhibit 6, Part C1-1, # (8) Exhibit 6, Part
C1-2, # (9) Exhibit 6, Part C2, # (10) Exhibit 7 - 23, # (11) Exhibit 24
- 33, # (12) Exhibit 34 - 38)(Mastro, Randy)
|
|
Request |
 |
|
|
36 |
Filed: 6/15/2011, Entered: None |
Memorandum of Law in Support of Motion |
|
MEMORANDUM OF LAW in Support
re: [35] MOTION to Compel Joseph C. Kohn and Kohn, Swift & Graf P.C.
to produce documents.. Document filed by Chevron Corporation. (Mastro,
Randy)
|
|
Request |
 |
|
|
35 |
Filed: 6/15/2011, Entered: None, Terminated: 8/3/2011 |
Motion to Compel |
|
MOTION to Compel Joseph C.
Kohn and Kohn, Swift & Graf P.C. to produce documents. Document
filed by Chevron Corporation.(Mastro, Randy)
|
|
Request |
 |
|
|
34 |
Filed: 6/15/2011, Entered: None |
Response |
|
RESPONSE Intervenors
Response To Chevron Corporation's Motion For Partial Judgment on the
Pleadings Regarding Certain Defenses or, in the Alternative, to Strike
Those Defenses. Document filed by Steven Donziger, Donziger & Associates PLLC, The Law Offices of Steven R. Donziger. (Keker, John)
|
|
Request |
 |
|
|
48 |
Filed: 6/14/2011, Entered: None |
Memorandum of Law in Support |
|
MEMORANDUM OF LAW in Support of
their application by order to show cause why discovery should not be
stayed pending the court's decision on Donziger's application to
intervene. Document filed by Steven Donziger, Donziger & Associates
PLLC, The Law Offices of Steven R. Donziger. (mbe)
|
|
Request |
 |
|
|
33 |
Filed: 6/14/2011, Entered: None |
Order |
|
MEMORANDUM AND ORDER.
Accordingly, Donzigers motion [DI 12] is denied in all respects. The
Clerk shall terminate also DI 14, Donzigers memorandum of law, which
incorrectly was docketed as a separate motion. (Signed by Judge Lewis
A. Kaplan on 6/14/11) (rjm)
|
|
|
 |
|
|
32 |
Filed: 6/14/2011, Entered: None |
Endorsed Letter |
|
ENDORSED LETTER addressed to
Judge Lewis A. Kaplan from Randy M. Mastro dated 6/10/11 re: We request
that Chevron be permitted to submit a moving brief of up to 25 pages,
that Kohn be permitted to file an opposition brief of up to that same
length, and that Chevron be permitted to submit a reply brief of up to
15 pages. ENDORSEMENT: Expanded page limits granted to all concerned.
Schedule will be set when motion is filed. (Signed by Judge Lewis A.
Kaplan on 6/13/11) (rjm)
|
|
Request |
 |
|
|
31 |
Filed: 6/14/2011, Entered: None |
Memorandum of Law in Support |
|
STEVEN DONZIGER, THE LAW OFFICES
OF STEVEN R. DONZIGER, AND DONZIGER & ASSOCIATES, PLLC'S MEMORANDUM
OF LAW IN SUPPORT OF THEIR APPLICATION BY ORDER TO SHOW CAUSE WHY
DISCOVERY SHOULD NOT BE STAYED PENDING THIS COURT'S DECISION ON
DONZIGER'S APPLICATION TO INTERVENE. Document filed by Steven Donziger,
Donziger & Associates PLLC, The Law Offices of Steven R. Donziger.
(rjm)
|
|
Request |
 |
|
|
30 |
Filed: 6/13/2011, Entered: None |
Endorsed Letter |
|
ENDORSED LETTER addressed to
Judge Lewis A. Kaplan from Randy M. Mastro dated 6/9/2011 re: I write on
behalf of Plaintiff Chevron Corporation to advise Your Honor that
counsel for third parties Laura J. Garr and Andrew Woods and counsel for
defendants Hugo Camacho Naranjo and Javier Piaguaje Payaguaje (the "LAP
Representatives") consent to the proposals set forth in our letters of
earlier today requesting the Court's permission to treat certain motions
as traditional motions rather than motions pertaining to a "discovery
dispute."; Representatives similarly consent to treating the motion as a
traditional motion, with page limits of 15 pages for the opening and
opposition briefs, and 10 pages for the reply brief. ENDORSEMENT:
Increased page limits approved. The motion is to be filed by 6/15/2011.
Answering papers are to be filed by 6/20/2011. Any reply shall be filed
by 6/22/2011. ( Motions due by 6/15/2011. Responses due by 6/20/2011,
Replies due by 6/22/2011.) (Signed by Judge Lewis A. Kaplan on
6/13/2011) (ae)
|
|
Request |
 |
|
|
29 |
Filed: 6/13/2011, Entered: None |
Stipulation and Order |
|
STIPULATION AND ORDER: Chevron
shall file and serve a motion to compel and for declaratory relief
relating to the objections served by Donziger, Garr, and Woods, seeking
the Court's assistance in resolving any disagreements over such
objections, including any privilege assertions made therein, no later
than Friday. June 10, 2011; Papers in opposition to Chevron's June 10
Motion shall be filed and served no later than Friday, June 17, 2011;
Reply papers, if any, shall be served no later than Tuesday, June 21,
2011. (Signed by Judge Lewis A. Kaplan on 6/13/2011) (jpo)
|
|
Request |
 |
|
|
28 |
Filed: 6/13/2011, Entered: None |
Reply Memorandum of Law in Support |
|
REPLY MEMORANDUM OF LAW in
Support re: [12] Order to Show Cause,,,. Document filed by Steven
Donziger, Donziger & Associates PLLC, The Law Offices of Steven R.
Donziger. (Keker, John)
|
|
Request |
 |
|
|
27 |
Filed: 6/10/2011, Entered: None |
Declaration in Support of Motion |
|
DECLARATION of Kristen L.
Hendricks in Support re: [25] MOTION to Compel Laura J. Garr and Andrew
Woods to produce documents.. Document filed by Chevron Corporation.
(Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3) Exhibit 3, # (4)
Exhibit 4, # (5) Exhibit 5, # (6) Exhibit 6, # (7) Exhibit 7, # (8)
Exhibit 8, # (9) Exhibit 9, # (10) Exhibit 10, # (11) Exhibit 11, # (12)
Exhibit 12, # (13) Exhibit 13, # (14) Exhibit 14, # (15) Exhibit 15, #
(16) Exhibit 16, # (17) Exhibit 17, # (18) Exhibit 18, # (19) Exhibit
19, # (20) Exhibit 20, # (21) Exhibit 21, # (22) Exhibit 22, # (23)
Exhibit 23, # (24) Exhibit 24, # (25) Exhibit 25, # (26) Exhibit 26, #
(27) Exhibit 27, # (28) Exhibit 28, # (29) Exhibit 29, # (30) Exhibit
30, # (31) Exhibit 31, # (32) Exhibit 32, # (33) Exhibit 33, # (34)
Exhibit 34, # (35) Exhibit 35, # (36) Exhibit 36, # (37) Exhibit 37, #
(38) Exhibit 38)(Mastro, Randy)
|
|
Request |
 |
|
|
26 |
Filed: 6/10/2011, Entered: None |
Memorandum of Law in Support of Motion |
|
MEMORANDUM OF LAW in Support
re: [25] MOTION to Compel Laura J. Garr and Andrew Woods to produce
documents.. Document filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
25 |
Filed: 6/10/2011, Entered: None, Terminated: 8/3/2011 |
Motion to Compel |
|
MOTION to Compel Laura J. Garr and Andrew Woods to produce documents. Document filed by Chevron Corporation.(Mastro, Randy)
|
|
Request |
 |
|
|
24 |
Filed: 6/10/2011, Entered: None |
Memorandum of Law in Opposition |
|
MEMORANDUM OF LAW in Opposition re: [12] Order to Show Cause,,, CHEVRON
CORPORATION'S MEMORANDUM OF LAW IN OPPOSITION TO STEVEN DONZIGER, THE
LAW OFFICES OF STEVEN R. DONZIGER, AND DONZIGER & ASSOCIATES, PLLCS
APPLICATION BY ORDER TO SHOW CAUSE WHY PROCEEDING SHOULD NOT BE STAYED
PENDING THE APPEAL OF THIS COURT'S ORDER ON THEIR APPLICATION TO
INTERVENE. Document filed by Chevron Corporation. (Mastro, Randy)
|
|
Request |
 |
|
|
23 |
Filed: 6/9/2011, Entered: None |
Endorsed Letter |
|
ENDORSED LETTER addressed to
Judge Lewis A. Kaplan from Randy M. Mastro dated 6/9/11 re: counsel for
plaintiff writes to follow up on the stipulation and proposed order that
was submitted by e-mail to the Orders and Judgments clerk on June 3,
2011, providing for an expedited briefing schedule for Plaintiff s
forthcoming motion related to subpoenas that were served on third
parties Laura J. Garr and Andrew Woods, both associates with Steven
Donziger's law firm. Given the multitude of factual and legal arguments
to be addressed in light of the objections that were served last
night, Chevron respectfully requests the Court's permission to treat
the motion as a traditional motion under the "Briefs and Motion
Papers" section of Your Honor's individual Motion Rules and
Procedures, rather than a "Discovery Dispute and also request that
Chevron be permitted to submit a moving brief of up to 15 pages, that
any opposition be permitted of up to that same length, and that
Chevron be permitted to submit a reply brief of up to 10 pages.
ENDORSEMENT: Granted on Consent. So Ordered. (Signed by Judge Lewis A.
Kaplan on 6/9/11) (pl) Modified on 6/9/2011 (pl).
|
|
Request |
 |
|
|
22 |
Filed: 6/8/2011, Entered: None |
Declaration in Support |
|
DECLARATION of John W. Keker in
Support re: [15] Declaration in Support of Motion. Document filed by
Steven Donziger, Donziger & Associates PLLC, The Law Offices of
Steven R. Donziger. (Keker, John)
|
|
Request |
 |
|
|
21 |
Filed: 6/8/2011, Entered: None |
Memorandum of Law in Support |
|
MEMORANDUM OF LAW in Support Steven
Donziger, The Law Offices of Steven R. Donziger, and Donziger &
Associates, PLLC's Application by Order to Show Cause Why Proceedings
Should Not Be Stayed Pending the Appeal of this Court's Order on their
Application to Intervene. Document filed by Steven Donziger, Donziger & Associates PLLC, The Law Offices of Steven R. Donziger. (Keker, John)
|
|
Request |
 |
|
|
20 |
Filed: 6/8/2011, Entered: None |
Declaration in Support |
|
DECLARATION of Julio C. Gomez in
Support re: [19] Reply Memorandum of Law. Document filed by Hugo
Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Attachments: # (1)
Exhibit Ex. 1, # (2) Exhibit Ex. 2, # (3) Exhibit Ex. 3, # (4) Exhibit
Ex. 4)(Gomez, Julio)
|
|
Request |
 |
|
|
19 |
Filed: 6/8/2011, Entered: None |
Reply Memorandum of Law |
|
REPLY MEMORANDUM OF LAW re:
[4] Order to Show Cause, Set Deadlines,,,,,,. Document filed by Hugo
Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
|
|
Request |
 |
|
|
18 |
Filed: 6/8/2011, Entered: None |
Rule 7.1 Corporate Disclosure Statement |
|
RULE 7.1 CORPORATE DISCLOSURE
STATEMENT. No Corporate Parent. Document filed by Steven Donziger,
Donziger & Associates PLLC, The Law Offices of Steven R.
Donziger.(Werdegar, Matthew)
|
|
Request |
 |
|
|
17 |
Filed: 6/7/2011, Entered: None |
Notice of Appearance |
|
NOTICE OF APPEARANCE by William Edward Thomson on behalf of Chevron Corporation (Thomson, William)
|
|
Request |
 |
|
|
16 |
Filed: 6/7/2011, Entered: None |
Certificate of Service Other |
|
CERTIFICATE OF SERVICE of
[Proposed] Order to Show Cause Why Proceedings Should Not Be Stayed
Pending the Appeal of This Court's Order on the Donziger Defendants'
Application To Intervene; Memorandum of Law by Steven Donziger, The Law
Offices of Steven R. Donziger, and Donziger & Associates, PLLC in
Support of their Application by Order to Show Cause, etc.; Declaration
of John W. Keker in support of Application by Order to Show Cause on
June 7, 2011. Service was made by EMAIL per Order of 6/7/11. Document
filed by Steven Donziger, Donziger & Associates PLLC, The Law
Offices of Steven R. Donziger. (Keker, John)
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Request |
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15 |
Filed: 6/7/2011, Entered: None |
Declaration in Support of Motion |
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DECLARATION of John Keker in
Support. Document filed by Steven Donziger, Donziger & Associates
PLLC, The Law Offices of Steven R. Donziger. (Keker, John) Modified on
6/8/2011 (ldi).
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Request |
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14 |
Filed: 6/7/2011, Entered: None, Terminated: 6/7/2011 |
~Motion for Order to Show Cause |
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MOTION for Order to Show Cause (Memorandum
of Law Submitted by Steven Donziger, The Law Offices of Steven R.
Donziger, and Donziger & Associates, PLLC in Support of their
Application by Order to Show Cause Why Proceedings Should Not Be Stayed
Pending the Appeal of this Court's Order on Their Application to
Intervene). Document filed by Steven Donziger, Donziger &
Associates PLLC, The Law Offices of Steven R. Donziger.(Keker, John)
Modified on 6/8/2011 (ldi). Modified on 6/8/2011 (dlw). Modified on
7/19/2011 (kkc).
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Request |
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13 |
Filed: 6/7/2011, Entered: None |
Order |
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ORDER - Until further notice,
the procedure for applications for orders to show cause in these actions
shall be as follows: 1) The proposed order to show cause and all papers
in support of the order to show cause (including without limitation
affidavits, declarations, exhibits and memoranda of law) shall be filed
electronically through the ECF system, and the movant shall notify
chambers of the filing by telephone. The filer shall use the Motion to
Show Cause event code for the proposed order to show cause itself. 2)
The movant shall deliver the originals and two copies of the proposed
order to show cause and supporting papers to chambers at substantially
the same time. (Signed by Judge Lewis A. Kaplan on 6/7/2011) (ab)
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Request |
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12 |
Filed: 6/7/2011, Entered: None |
Order to Show Cause  |
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ORDER TO SHOW CAUSE WHY
PROCEEDINGS SHOULD NOT BE STAYED PENDING THE APPEAL OF THIS COURT'S
ORDER ON THE DONZIGER DEFENDANT'S APPLICATION TO INTERVENE; Defendant
shall show cause as to why proceedings should not be stayed pending the
appeal of this Court's Order on the Donziger Defendants' Application to
Intervene; Service of a copy of this Order and all of the papers
submitted in support thereof, by hand, facsimile or email, upon counsel
for Plaintiff Chevron Corporation, on or before 2:00 p.m. on Tuesday,
6/7/2011, shall be deemed good and sufficient service thereof; Papers in
Opposition to Donziger's Application to Intervene, if any shall be
served and filed electronically on or before 5:00 p.m. on Friday,
6/10/2011; and that reply papers, if any shall be served and filed
electronically on or before 11:00 a.m. on Monday, 6/13/2011. (Signed by
Judge Lewis A. Kaplan on 6/7/2011) (ae)
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Request |
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10 |
Filed: 6/6/2011, Entered: None |
Declaration in Opposition |
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DECLARATION of Randy M. Mastro
in Opposition re: [4] Order to Show Cause, Set Deadlines,,,,,,.
Document filed by Chevron Corporation. (Attachments: # (1) Exhibit 1, #
(2) Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4, # (5) Exhibit 5, # (6)
Exhibit 6, # (7) Exhibit 7, # (8) Exhibit 8, # (9) Exhibit 9, # (10)
Exhibit 10, # (11) Exhibit 11, # (12) Exhibit 12, # (13) Exhibit 13, #
(14) Exhibit 14, # (15) Exhibit 15)(Mastro, Randy)
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Request |
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9 |
Filed: 6/6/2011, Entered: None |
Memorandum of Law in Opposition |
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MEMORANDUM OF LAW in
Opposition re: [4] Order to Show Cause, Set Deadlines,,,,,,. Document
filed by Chevron Corporation. (Mastro, Randy)
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Request |
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11 |
Filed: 6/3/2011, Entered: None |
Notice of Case Assignment/Reassignment |
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NOTICE OF CASE ASSIGNMENT to Judge Lewis A. Kaplan. Judge Unassigned is no longer assigned to the case. (sjo)
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Request |
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8 |
Filed: 6/3/2011, Entered: None |
Certificate of Service Other |
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CERTIFICATE OF SERVICE of
Supporting Papers for Order to Show Cause Why All Discovery in this
Proceeding Should Not Be Stayed Pending the Completion of Merits
Briefing to the United States Court of Appeals for the Second Circuit
served on Plaintiff Chevron Corporation on 06/03/11. Service was made
by Electronic Mail. Document filed by Hugo Gerardo Camacho Naranjo,
Javier Piaguaje Payaguaje. (Gomez, Julio)
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Request |
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7 |
Filed: 6/3/2011, Entered: None |
Declaration in Support |
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DECLARATION of Julio C. Gomez in
Support re: [4] Order to Show Cause, Set Deadlines,,,,,,. Document
filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.
(Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3) Exhibit 3, # (4)
Exhibit 4, # (5) Exhibit 5, # (6) Exhibit 6, # (7) Exhibit 7, # (8)
Exhibit 8, # (9) Exhibit 9, # (10) Exhibit 10, # (11) Exhibit 11, # (12)
Exhibit 12)(Gomez, Julio)
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Request |
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6 |
Filed: 6/3/2011, Entered: None |
Memorandum of Law in Support |
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MEMORANDUM OF LAW in Support
re: [4] Order to Show Cause, Set Deadlines,,,,,,. Document filed by
Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio)
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Request |
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5 |
Filed: 6/2/2011, Entered: None |
Order |
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MEMORANDUM AND ORDER: Insofar as
the LAP Representatives seek a stay of discovery in this action pending
the hearing and determination of their motion for such a stay, the
application is denied. The Court will enter an order to show cause
bringing on their motion on an expedited basis. (Signed by Judge Lewis
A. Kaplan on 6/2/2011) (tro)
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Request |
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4 |
Filed: 6/2/2011, Entered: None |
Order to Show Cause  |
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ORDER TO SHOW CAUSE WHY ALL
DISCOVERY IN THE PROCEEDINGS SHOULD NOT BE STAYED PENDING THE COMPLETION
OF MERITS BRIEFING TO THE UNITED STATES COURT OF APPEALS FOR THE SECOND
CIRCUIT: that service of a copy of this Order and of all of the papers
submitted in support thereof, by hand, facsimile, or email, upon counsel
for Plaintiff Chevron Corporation on or before 11a.m. on 6/3/2011,
shall be deemed good and sufficient service thereof. Papers in
opposition to Defendants' motion for a stay, if any, shall be served and
filed electronically on or before 5:00p.m. EDT on 6/6/2011. Reply
papers, if any, shall be served and filed electronically on or before
4:00 p.m. on 6/8/2011. ( Responses due by 6/3/2011, Replies due by
6/8/2011.) (Signed by Judge Lewis A. Kaplan on 6/2/2011) (tro)
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Request |
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3 |
Filed: 6/2/2011, Entered: None |
Letter |
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Letter addressed to Judge Lewis
A. Kaplan from Randy M. Mastro dated 6/2/11 re: The application
apparently filed yesterday by the LAP Representatives, just two days
before the deadline for objections and responses to the subpoenas served
on several third parties, as wen as the date scheduled for the
deposition of Pablo Fajardo, one of the LAP Representatives' lawyers and
agents, is consistent with their pattern of seeking to delay and
prevent the parties from completing discovery within the time set by
this Court in its April 15 Scheduling Order. Under that Order, the
discovery period ends on September 15, barely three months from today.
No further delay is warranted, and the LAP Representatives' meritless
application should be denied. Document filed by Chevron Corporation.
(djc)
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Request |
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2 |
Filed: 6/1/2011, Entered: None |
Order |
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ORDER: The filing fee for the
previously ordered [DI 328] separate docket number for the Count 9
Action is hereby waived. (Signed by Judge Lewis A. Kaplan on 5/31/11)
(rdz)
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Request |
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1 |
Filed: 6/1/2011, Entered: None |
Order |
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ORDER: Count 9 of the Amended
Complaint is hereby severed from the remainder of the action and shall
proceed as a separate action. The Clerk shall assign a separate docket
number to the Count 9 Action, the caption of which shall include the
parties listed in paragraph 1 of this Order. (Signed by Judge Lewis A.
Kaplan on 5/31/2011) (rdz) (ae).
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Request |
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