| Court: | nysd |
| Docket #: | 1:11-cv-03718 |
| Case Name: | Chevron Corporation v. Salazar et al |
| PACER case #: | 379973 |
| Date filed: | 2011-06-01 |
| Date of last filing: | 2013-02-14 |
| Assigned to: | Judge Lewis A. Kaplan |
| Referred to: | Magistrate Judge James C. Francis |
| Case Cause: | 28:1331 Fed. Question |
| Nature of Suit: | 150 Contract: Recovery/Enforcement |
| Jury Demand: | Defendant |
| Jurisdiction: | Federal Question |
| Represented Party | Attorney & Contact Info |
| Chevron Corporation Plaintiff |
Andrea Ellen Neuman Kristen Luise Hendricks Oscar Garza Peter E. Seley Randy M. Mastro Robert C. Blume William Edward Thomson |
| Maria Aguinda Salazar Defendant |
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| Alfredo Donaldo Payaguaje Payaguaje Defendant |
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| Angel Justino Piaguaje Lucitante Defendant |
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| Armando Wilfrido Piaguaje Payaguaje Defendant |
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| Beatriz Mercedes Grefa Tanguila Defendant |
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| Benancio Freddy Chimbo Grefa Defendant |
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| Bertha Antonia Yumbo Tanguila Defendant |
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| Carlos Grega Huatatoca Defendant |
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| Catalina Antonia Aguinda Salazar Defendant |
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| Celia Irene Viveros Cusangua Defendant |
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| Clide Ramiro Aguinda Aguinda Defendant |
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| Emilio Martin Lusitande Yaiguaje Defendant |
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| Delfin Leonidas Payaguaje Payaguaje Defendant |
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| Elias Roberto Piyahuaje Payahuaje Defendant |
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| Francisco Alvarado Yumbo Defendant |
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| Francisco Matias Alvarado Yumbo Defendant |
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| Gloria Lucrecia Tanguila Grefa Defendant |
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| Francisco Victor Tanguila Grefa Defendant |
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| Guillermo Vicente Payaguaje Lusitante Defendant |
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| Heleodoro Pataron Guaraca Defendant |
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| Hugo Gerardo Camacho Naranjo Defendant |
Tyler Geoffrey Doyle Christina A Bryan Craig Smyser F. Gerald Maples Garland D Murphy , IV John Timothy Byrd Julio Cesar Gomez Larry R Veselka |
| Javier Piaguaje Payaguaje Defendant |
Tyler Geoffrey Doyle Christina A Bryan Craig Smyser F. Gerald Maples Garland D Murphy , IV John Timothy Byrd Julio Cesar Gomez Larry R Veselka |
| Jose Gabriel Revelo Llore Defendant |
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| Jose Miguel Ipiales Chicaiza Defendant |
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| Lidia Alexandra Aguinda Aguinda Defendant |
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| Lorenzo Jose Alvarado Yumbo Defendant |
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| Lourdes Beatriz Chimbo Tanguila Defendant |
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| Lucio Enrique Grefa Tanguila Defendant |
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| Luis Austin Payaguaje Piaguaje Defendant |
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| Luis Armando Chimbo Yumbo Defendant |
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| Luisa Delia Tanguila Narvaez Defendant |
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| Maria Victoria Aguinda Salazar Defendant |
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| Maria Clelia Reascos Revelo Defendant |
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| Maria Hortencia Viveros Cusangua Defendant |
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| Maria Magdalena Rodriguez Barcenes Defendant |
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| Miguel Mario Payaguaje Payaguaje Defendant |
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| Narcisa Aida Tanguila Narvaez Defendant |
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| Octavio Ismael Cordova Huanca Defendant |
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| Olga Gloria Grefa Cerda Defendant |
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| Patricio Alberto Chimbo Yumbo Defendant |
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| Patricio Wuilson Aguinda Aguinda Defendant |
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| Reinaldo Lusitande Yaiguaje Defendant |
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| Rosa Teresa Chimbo Tanguila Defendant |
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| Segundo Angel Amanta Milan Defendant |
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| Simon Lusitande Yaiguaje Defendant |
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| Teodoro Gonzalo Piaguaje Payaguaje Defendant |
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| Daniel Carlos Lusitande Yaiguaje Defendant |
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| Fermin Piaguaje Payaguaje Defendant |
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| Andrew Woods Miscellaneous |
Elliot Remsen Peters Jan Nielsen Little |
| Laura J Garr Miscellaneous |
Elliot Remsen Peters |
| Joseph C. Kohn Miscellaneous |
James J. Rohn Joshua J. Voss Patricia Mary Hamill Seth D. Ard Stephen D. Susman |
| Kohn Swift & Graf, P.C. Miscellaneous |
James J. Rohn Joshua J. Voss Patricia Mary Hamill Seth D. Ard Stephen D. Susman |
| Steven Donziger Intervenor |
Elliot Remsen Peters Jan Nielsen Little John W. Keker Steven Arthur Hirsch |
| The Law Offices of Steven R. Donziger Intervenor |
Christopher J. Young Elliot Remsen Peters Jan Nielsen Little John W. Keker Matthew M. Werdegar Nikki H. Vo Paula Lenore Blizzard Steven Arthur Hirsch William S. Hicks |
| Donziger & Associates PLLC Intervenor |
Christopher J. Young Elliot Remsen Peters Jan Nielsen Little John W. Keker Matthew M. Werdegar Nikki H. Vo Paula Lenore Blizzard Steven Arthur Hirsch William S. Hicks |
| Patton Boggs LLP Interested Party |
| Date Filed | Document # | Attachment # | Short Description | Long Description | Upload date | SHA1 hash |
| 2011-06-01 | 1 | 0 | Order | 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). | ||
| 2011-06-01 | 2 | 0 | Order | 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) | ||
| 2011-06-02 | 3 | 0 | Letter | 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) | ||
| 2011-06-02 | 4 | 0 | Order to Show Cause | 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) | ||
| 2011-06-02 | 5 | 0 | Order | 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) | ||
| 2011-06-03 | 6 | 0 | Memorandum of Law in Support | 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) | ||
| 2011-06-03 | 7 | 0 | Declaration in Support | 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) | ||
| 2011-06-03 | 8 | 0 | Certificate of Service Other | 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) | ||
| 2011-06-06 | 9 | 0 | Memorandum of Law in Opposition | MEMORANDUM OF LAW in Opposition re: [4] Order to Show Cause, Set Deadlines,,,,,,. Document filed by Chevron Corporation. (Mastro, Randy) | ||
| 2011-06-06 | 10 | 0 | Declaration in Opposition | 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) | ||
| 2011-06-03 | 11 | 0 | Notice of Case Assignment/Reassignment | NOTICE OF CASE ASSIGNMENT to Judge Lewis A. Kaplan. Judge Unassigned is no longer assigned to the case. (sjo) | ||
| 2011-06-07 | 12 | 0 | Order to Show Cause | 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) | ||
| 2011-06-07 | 13 | 0 | Order | 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) | ||
| 2011-06-07 | 14 | 0 | Motion for Order to Show Cause | 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). | ||
| 2011-06-07 | 15 | 0 | Declaration in Support of Motion | 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). | ||
| 2011-06-07 | 16 | 0 | 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) | ||
| 2011-06-07 | 17 | 0 | Notice of Appearance | NOTICE OF APPEARANCE by William Edward Thomson on behalf of Chevron Corporation (Thomson, William) | ||
| 2011-06-08 | 18 | 0 | 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) | ||
| 2011-06-08 | 19 | 0 | 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) | ||
| 2011-06-08 | 20 | 0 | 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) | ||
| 2011-06-08 | 21 | 0 | 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) | ||
| 2011-06-08 | 22 | 0 | 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) | ||
| 2011-06-09 | 23 | 0 | 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). | ||
| 2011-06-10 | 24 | 0 | 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) | ||
| 2011-06-10 | 25 | 0 | Motion to Compel | MOTION to Compel Laura J. Garr and Andrew Woods to produce documents. Document filed by Chevron Corporation.(Mastro, Randy) | ||
| 2011-06-10 | 26 | 0 | 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) | ||
| 2011-06-10 | 27 | 0 | 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) | ||
| 2011-06-13 | 28 | 0 | 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) | ||
| 2011-06-13 | 29 | 0 | 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) | ||
| 2011-06-13 | 30 | 0 | 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) | ||
| 2011-06-14 | 31 | 0 | 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) | ||
| 2011-06-14 | 32 | 0 | 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) | ||
| 2011-06-14 | 33 | 0 | 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) | 2011-07-16 21:14:14 | c99cdecf3c9ed12e1c8de0831c517fa41e74eb88 |
| 2011-06-15 | 34 | 0 | 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) | ||
| 2011-06-15 | 35 | 0 | 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) | ||
| 2011-06-15 | 36 | 0 | 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) | ||
| 2011-06-15 | 37 | 0 | 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) | ||
| 2011-06-15 | 38 | 0 | 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) | ||
| 2011-06-15 | 39 | 0 | 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) | ||
| 2011-06-15 | 40 | 0 | 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) | ||
| 2011-06-15 | 41 | 0 | 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) | ||
| 2011-06-15 | 42 | 0 | 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) | ||
| 2011-06-15 | 43 | 0 | 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) | ||
| 2011-06-15 | 44 | 0 | 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) | ||
| 2011-06-16 | 45 | 0 | 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) | ||
| 2011-06-16 | 46 | 0 | 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) | ||
| 2011-06-16 | 47 | 0 | 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). | ||
| 2011-06-14 | 48 | 0 | 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) | ||
| 2011-06-17 | 49 | 0 | 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) | ||
| 2011-06-17 | 50 | 0 | 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) | ||
| 2011-06-17 | 51 | 0 | 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) | ||
| 2011-06-17 | 52 | 0 | 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) | ||
| 2011-06-17 | 53 | 0 | 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) | ||
| 2011-06-17 | 54 | 0 | 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) | ||
| 2011-06-17 | 55 | 0 | 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) | ||
| 2011-06-17 | 56 | 0 | 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) | ||
| 2011-06-17 | 57 | 0 | 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) | ||
| 2011-06-17 | 58 | 0 | 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) | ||
| 2011-06-17 | 59 | 0 | 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) | ||
| 2011-06-17 | 60 | 0 | 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) | ||
| 2011-06-17 | 61 | 0 | 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) | ||
| 2011-06-21 | 62 | 0 | 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) | ||
| 2011-06-21 | 64 | 0 | 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) | ||
| 2011-06-21 | 65 | 0 | 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) | ||
| 2011-06-22 | 66 | 0 | 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). | ||
| 2011-06-23 | 67 | 0 | 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) | ||
| 2011-06-23 | 68 | 0 | 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) | ||
| 2011-06-24 | 69 | 0 | 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) | ||
| 2011-06-24 | 70 | 0 | Order | MEMORANDUM AND ORDER denying in all respects [4] Order to Show Cause. (Signed by Judge Lewis A. Kaplan on 6/23/11) (cd) | ||
| 2011-06-24 | 71 | 0 | 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) | ||
| 2011-06-24 | 72 | 0 | 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) | ||
| 2011-06-24 | 73 | 0 | 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) | ||
| 2011-06-24 | 74 | 0 | 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) | ||
| 2011-06-24 | 75 | 0 | 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) | ||
| 2011-06-24 | 76 | 0 | 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) | ||
| 2011-06-27 | 77 | 0 | 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) | ||
| 2011-06-27 | 78 | 0 | 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) | ||
| 2011-06-27 | 79 | 0 | 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) | ||
| 2011-06-28 | 80 | 0 | 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) | ||
| 2011-06-28 | 81 | 0 | 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) | ||
| 2011-06-28 | 82 | 0 | 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). | ||
| 2011-06-28 | 83 | 0 | 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) | ||
| 2011-06-28 | 84 | 0 | Memorandum & 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). | ||
| 2011-06-28 | 85 | 0 | Notice of Appearance | NOTICE OF APPEARANCE by Seth D. Ard on behalf of Joseph C. Kohn, Kohn Swift & Graf, P.C. (Ard, Seth) | ||
| 2011-06-29 | 86 | 0 | 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) | ||
| 2011-06-29 | 87 | 0 | Notice of Appearance | NOTICE OF APPEARANCE by Stephen D. Susman on behalf of Joseph C. Kohn, Kohn Swift & Graf, P.C. (Susman, Stephen) | ||
| 2011-06-29 | 88 | 0 | 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) | ||
| 2011-06-29 | 89 | 0 | 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) | ||
| 2011-06-29 | 90 | 0 | 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) | ||
| 2011-06-29 | 91 | 0 | 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) | ||
| 2011-06-29 | 92 | 0 | 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) | ||
| 2011-06-29 | 93 | 0 | 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) | ||
| 2011-06-30 | 94 | 0 | 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) | ||
| 2011-06-30 | 95 | 0 | 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) | ||
| 2011-06-30 | 96 | 0 | 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) | ||
| 2011-06-30 | 97 | 0 | 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) | ||
| 2011-06-30 | 98 | 0 | 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) | ||
| 2011-07-01 | 99 | 0 | 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) | ||
| 2011-07-05 | 100 | 0 | 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) | ||
| 2011-07-06 | 101 | 0 | 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) | ||
| 2011-07-06 | 102 | 0 | 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) | ||
| 2011-07-06 | 103 | 0 | 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) | ||
| 2011-07-06 | 104 | 0 | 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) | ||
| 2011-07-06 | 105 | 0 | 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) | ||
| 2011-07-07 | 106 | 0 | 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) | ||
| 2011-07-07 | 107 | 0 | 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). | ||
| 2011-07-07 | 108 | 0 | 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) | ||
| 2011-07-07 | 109 | 0 | 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) | ||
| 2011-07-07 | 110 | 0 | 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) | ||
| 2011-07-07 | 111 | 0 | 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) | ||
| 2011-07-08 | 112 | 0 | 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) | ||
| 2011-07-08 | 113 | 0 | 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) | ||
| 2011-07-08 | 114 | 0 | 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) | ||
| 2011-07-08 | 115 | 0 | 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) | ||
| 2011-07-12 | 116 | 0 | 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) | ||
| 2011-07-12 | 117 | 0 | 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) | ||
| 2011-07-14 | 118 | 0 | 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) | ||
| 2011-07-14 | 119 | 0 | 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) | ||
| 2011-07-15 | 120 | 0 | 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) | ||
| 2011-07-15 | 121 | 0 | 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) | ||
| 2011-07-15 | 122 | 0 | 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). | ||
| 2011-07-19 | 123 | 0 | 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) | ||
| 2011-07-19 | 124 | 0 | 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) | ||
| 2011-07-19 | 125 | 0 | 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) | ||
| 2011-07-20 | 126 | 0 | 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) | ||
| 2011-07-20 | 127 | 0 | 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) | ||
| 2011-07-20 | 128 | 0 | 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). | ||
| 2011-07-21 | 129 | 0 | 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) | ||
| 2011-07-21 | 130 | 0 | 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) | ||
| 2011-07-21 | 131 | 0 | 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) | ||
| 2011-07-21 | 132 | 0 | Motion for Order to Show Cause | MOTION for Order to Show Cause. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(Gomez, Julio) | ||
| 2011-07-21 | 133 | 0 | 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) | ||
| 2011-07-22 | 134 | 0 | 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) | ||
| 2011-07-22 | 135 | 0 | 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) | ||
| 2011-07-22 | 136 | 0 | Response | RESPONSE re: Discovery Hearing. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio) | ||
| 2011-07-22 | 137 | 0 | 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) | ||
| 2011-07-26 | 138 | 0 | 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) | ||
| 2011-07-26 | 139 | 0 | 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) | ||
| 2011-07-26 | 140 | 0 | 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) | ||
| 2011-07-26 | 141 | 0 | 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) | ||
| 2011-07-26 | 142 | 0 | 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) | ||
| 2011-07-26 | 143 | 0 | 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) | ||
| 2011-07-26 | 144 | 0 | 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) | ||
| 2011-07-26 | 145 | 0 | 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) | ||
| 2011-07-26 | 146 | 0 | 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) | ||
| 2011-07-26 | 147 | 0 | 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) | ||
| 2011-07-26 | 148 | 0 | 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) | ||
| 2011-07-26 | 149 | 0 | 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) | ||
| 2011-07-27 | 150 | 0 | 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) | ||
| 2011-07-27 | 151 | 0 | 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) | ||
| 2011-07-27 | 152 | 0 | 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) | ||
| 2011-07-27 | 153 | 0 | 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) | ||
| 2011-07-27 | 154 | 0 | 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). | ||
| 2011-07-27 | 155 | 0 | 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) | ||
| 2011-07-27 | 156 | 0 | Motion for Judgment on the Pleadings | MOTION for Judgment on the Pleadings. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(Gomez, Julio) | ||
| 2011-07-27 | 157 | 0 | 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) | ||
| 2011-07-27 | 158 | 0 | 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) | ||
| 2011-07-28 | 159 | 0 | 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) | ||
| 2011-07-28 | 160 | 0 | 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) | ||
| 2011-07-28 | 161 | 0 | 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) | ||
| 2011-07-28 | 162 | 0 | 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) | ||
| 2011-07-28 | 163 | 0 | 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). | ||
| 2011-07-29 | 164 | 0 | 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) | ||
| 2011-07-27 | 165 | 0 | 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) | ||
| 2011-07-29 | 166 | 0 | 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) | ||
| 2011-08-01 | 167 | 0 | 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) | ||
| 2011-08-01 | 168 | 0 | 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) | ||
| 2011-08-01 | 169 | 0 | 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) | ||
| 2011-08-01 | 170 | 0 | 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). | ||
| 2011-08-01 | 171 | 0 | 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). | ||
| 2011-08-01 | 172 | 0 | 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). | ||
| 2011-08-01 | 173 | 0 | 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) | ||
| 2011-08-01 | 174 | 0 | 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) | ||
| 2011-08-01 | 175 | 0 | 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) | ||
| 2011-08-02 | 176 | 0 | 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). | ||
| 2011-08-02 | 177 | 0 | 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). | ||
| 2011-08-02 | 178 | 0 | 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) | ||
| 2011-08-03 | 179 | 0 | 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) | ||
| 2011-08-03 | 180 | 0 | 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) | ||
| 2011-08-04 | 181 | 0 | 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) | ||
| 2011-08-05 | 182 | 0 | 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) | ||
| 2011-08-05 | 183 | 0 | 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) | ||
| 2011-08-05 | 184 | 0 | Response | EMERGENCY RESPONSE re: [182] Endorsed Letter,,,,,,,. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio) | ||
| 2011-08-05 | 185 | 0 | 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) | ||
| 2011-08-05 | 186 | 0 | 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) | ||
| 2011-08-08 | 187 | 0 | 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) | ||
| 2011-08-08 | 188 | 0 | 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) | ||
| 2011-08-08 | 189 | 0 | 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) | ||
| 2011-08-08 | 190 | 0 | 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) | ||
| 2011-08-08 | 191 | 0 | 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) | ||
| 2011-08-09 | 192 | 0 | 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) | ||
| 2011-08-09 | 193 | 0 | 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) | ||
| 2011-08-09 | 194 | 0 | 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) | ||
| 2011-08-09 | 195 | 0 | 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) | ||
| 2011-08-09 | 196 | 0 | 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) | ||
| 2011-08-10 | 197 | 0 | 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) | ||
| 2011-08-10 | 198 | 0 | 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) | ||
| 2011-08-10 | 199 | 0 | 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) | ||
| 2011-08-11 | 200 | 0 | 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) | ||
| 2011-08-11 | 201 | 0 | 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) | ||
| 2011-08-11 | 202 | 0 | 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) | ||
| 2011-08-11 | 203 | 0 | 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) | ||
| 2011-08-11 | 204 | 0 | Response | RESPONSE re: [190] Objection (non-motion), Objection (non-motion), [186] Objection (non-motion), Objection (non-motion). Document filed by Chevron Corporation. (Mastro, Randy) | ||
| 2011-08-11 | 205 | 0 | 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) | ||
| 2011-08-11 | 206 | 0 | 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) | ||
| 2011-08-11 | 207 | 0 | 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) | ||
| 2011-08-11 | 208 | 0 | 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) | ||
| 2011-08-11 | 209 | 0 | 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). | ||
| 2011-08-11 | 210 | 0 | 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) | ||
| 2011-08-11 | 211 | 0 | 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) | ||
| 2011-08-11 | 212 | 0 | 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) | ||
| 2011-08-12 | 213 | 0 | 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) | ||
| 2011-08-12 | 214 | 0 | 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) | ||
| 2011-08-12 | 215 | 0 | 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) | ||
| 2011-08-12 | 216 | 0 | 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) | ||
| 2011-08-15 | 217 | 0 | 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) | ||
| 2011-08-15 | 218 | 0 | 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) | ||
| 2011-08-15 | 219 | 0 | 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) | ||
| 2011-08-15 | 220 | 0 | 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) | ||
| 2011-08-15 | 221 | 0 | 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) | ||
| 2011-08-15 | 222 | 0 | 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) | ||
| 2011-08-15 | 223 | 0 | 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) | ||
| 2011-08-16 | 224 | 0 | 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) | ||
| 2011-08-16 | 225 | 0 | 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) | ||
| 2011-08-16 | 226 | 0 | 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) | ||
| 2011-08-16 | 227 | 0 | 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). | ||
| 2011-08-16 | 228 | 0 | 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) | ||
| 2011-08-17 | 229 | 0 | Memorandum & 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). | 2011-09-05 16:18:18 | 7870d9b88e87b87895677d577814e5cd32c74019 |
| 2011-08-17 | 230 | 0 | Memorandum of Law in Opposition | MEMORANDUM OF LAW in Opposition re: [209] Order,,,,,. Document filed by Chevron Corporation. (Mastro, Randy) | ||
| 2011-08-17 | 231 | 0 | 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) | ||
| 2011-08-18 | 232 | 0 | 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) | ||
| 2011-08-19 | 233 | 0 | 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) | 2011-08-22 01:46:15 | 0faa2f0d084f4094cca5c646bb5bf0b55857b23d |
| 2011-08-19 | 234 | 0 | Motion for Reconsideration | MOTION for Reconsideration re; [227] Order,,,, [REDACTED]. Document filed by Andrew Woods.(Little, Jan) | ||
| 2011-08-19 | 235 | 0 | 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) | ||
| 2011-08-22 | 236 | 0 | 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) | ||
| 2011-08-22 | 237 | 0 | 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) | ||
| 2011-08-22 | 238 | 0 | 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. | ||
| 2011-08-23 | 239 | 0 | Motion for Reconsideration | MOTION for Reconsideration re; [238] Order on Motion for Reconsideration,, UNREDACTED. Document filed by Andrew Woods.(Little, Jan) | ||
| 2011-08-23 | 240 | 0 | 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) | ||
| 2011-08-24 | 241 | 0 | 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) | ||
| 2011-08-24 | 242 | 0 | 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) | ||
| 2011-08-24 | 243 | 0 | Amended Answer to Complaints | AMENDED ANSWER to with JURY DEMAND. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje. (Gomez, Julio) | ||
| 2011-08-26 | 244 | 0 | 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) | ||
| 2011-08-26 | 245 | 0 | 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) | ||
| 2011-08-29 | 246 | 0 | 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) | ||
| 2011-08-29 | 247 | 0 | 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) | ||
| 2011-08-30 | 248 | 0 | 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) | ||
| 2011-08-30 | 249 | 0 | 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) | ||
| 2011-08-30 | 250 | 0 | 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) | ||
| 2011-08-30 | 251 | 0 | 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) | ||
| 2011-08-30 | 252 | 0 | 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) | ||
| 2011-08-30 | 253 | 0 | 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) | ||
| 2011-08-30 | 254 | 0 | 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) | ||
| 2011-08-30 | 255 | 0 | 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) | ||
| 2011-08-31 | 256 | 0 | 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) | ||
| 2011-08-31 | 257 | 0 | 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) | ||
| 2011-08-31 | 258 | 0 | 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) | ||
| 2011-08-31 | 259 | 0 | 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) | ||
| 2011-08-31 | 260 | 0 | 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) | ||
| 2011-08-31 | 261 | 0 | Memorandum & 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). | ||
| 2011-08-31 | 262 | 0 | 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) | ||
| 2011-08-31 | 263 | 0 | 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) | ||
| 2011-08-31 | 264 | 0 | 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) | ||
| 2011-09-01 | 265 | 0 | Memorandum & 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) | 2011-10-15 06:37:31 | 752af0a3b517474c00b7ba6bf24a96a16c485299 |
| 2011-09-01 | 266 | 0 | 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) | ||
| 2011-09-01 | 267 | 0 | 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) | ||
| 2011-09-01 | 268 | 0 | 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) | ||
| 2011-09-02 | 269 | 0 | 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) | ||
| 2011-09-02 | 270 | 0 | 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). | ||
| 2011-09-02 | 271 | 0 | 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) | ||
| 2011-09-02 | 272 | 0 | 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) | ||
| 2011-09-02 | 273 | 0 | 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) | ||
| 2011-09-02 | 274 | 0 | 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) | ||
| 2011-09-02 | 275 | 0 | 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) | ||
| 2011-09-06 | 276 | 0 | 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) | ||
| 2011-09-02 | 277 | 0 | 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) | ||
| 2011-09-02 | 278 | 0 | 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) | ||
| 2011-09-06 | 279 | 0 | 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) | ||
| 2011-09-06 | 280 | 0 | 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) | ||
| 2011-09-06 | 281 | 0 | 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) | ||
| 2011-09-06 | 282 | 0 | 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). | ||
| 2011-09-06 | 283 | 0 | 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) | ||
| 2011-09-06 | 284 | 0 | 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) | ||
| 2011-09-06 | 285 | 0 | 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) | ||
| 2011-09-06 | 286 | 0 | 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) | ||
| 2011-09-06 | 287 | 0 | 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) | ||
| 2011-09-06 | 288 | 0 | 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) | ||
| 2011-09-07 | 289 | 0 | 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). | ||
| 2011-09-07 | 290 | 0 | 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) | ||
| 2011-09-06 | 291 | 0 | 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) | ||
| 2011-09-07 | 292 | 0 | 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) | ||
| 2011-09-07 | 293 | 0 | 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) | ||
| 2011-09-07 | 294 | 0 | 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) | ||
| 2011-09-07 | 295 | 0 | 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) | ||
| 2011-09-07 | 296 | 0 | 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) | ||
| 2011-09-07 | 297 | 0 | 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) | ||
| 2011-09-08 | 298 | 0 | Order on Motion for Order to Show Cause | 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) | ||
| 2011-09-08 | 299 | 0 | 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) | ||
| 2011-09-08 | 300 | 0 | 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) | ||
| 2011-09-08 | 301 | 0 | Motion to Dismiss/Lack of Jurisdiction | SUPPLEMENTAL MOTION to Dismiss for Lack of Jurisdiction. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(Doyle, Tyler) | ||
| 2011-09-08 | 302 | 0 | 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). | ||
| 2011-09-08 | 303 | 0 | 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) | ||
| 2011-09-09 | 304 | 0 | 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) | ||
| 2011-09-09 | 305 | 0 | 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) | ||
| 2011-09-09 | 306 | 0 | 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) | ||
| 2011-09-12 | 307 | 0 | 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) | ||
| 2011-09-12 | 308 | 0 | 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) | ||
| 2011-09-12 | 309 | 0 | 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) | ||
| 2011-09-12 | 310 | 0 | 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) | ||
| 2011-09-12 | 311 | 0 | 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) | ||
| 2011-09-12 | 312 | 0 | 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) | ||
| 2011-09-12 | 313 | 0 | 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) | ||
| 2011-09-12 | 314 | 0 | 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) | ||
| 2011-09-12 | 315 | 0 | 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) | ||
| 2011-09-12 | 316 | 0 | 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) | ||
| 2011-09-12 | 317 | 0 | 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) | ||
| 2011-09-12 | 318 | 0 | 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) | ||
| 2011-09-12 | 319 | 0 | 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) | ||
| 2011-09-12 | 320 | 0 | 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) | ||
| 2011-09-12 | 321 | 0 | 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) | ||
| 2011-09-12 | 322 | 0 | 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) | ||
| 2011-09-12 | 323 | 0 | 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) | ||
| 2011-09-12 | 324 | 0 | 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) | ||
| 2011-09-12 | 325 | 0 | 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) | ||
| 2011-09-12 | 326 | 0 | 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) | ||
| 2011-09-12 | 327 | 0 | 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) | ||
| 2011-09-13 | 328 | 0 | 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) | ||
| 2011-09-13 | 329 | 0 | 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) | ||
| 2011-09-13 | 330 | 0 | 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) | ||
| 2011-09-13 | 331 | 0 | 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) | ||
| 2011-09-13 | 332 | 0 | 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) | ||
| 2011-09-13 | 333 | 0 | 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) | ||
| 2011-09-13 | 334 | 0 | 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). | ||
| 2011-09-13 | 335 | 0 | 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) | 2011-10-15 06:54:23 | b0d75d5b864fac043f80f5e67587313ef995aaeb |
| 2011-09-13 | 336 | 0 | 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) | ||
| 2011-09-13 | 337 | 0 | 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) | ||
| 2011-09-13 | 338 | 0 | 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) | ||
| 2011-09-13 | 339 | 0 | 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) | ||
| 2011-09-14 | 340 | 0 | 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) | ||
| 2011-09-14 | 341 | 0 | 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) | ||
| 2011-09-14 | 342 | 0 | 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) | ||
| 2011-09-14 | 343 | 0 | Order | ORDER: that motion [DI 328] is denied in all respects. (Signed by Judge Lewis A. Kaplan on 9/14/2011) (ft) | ||
| 2011-09-14 | 344 | 0 | 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) | ||
| 2011-09-14 | 345 | 0 | 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) | ||
| 2011-09-14 | 346 | 0 | 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) | ||
| 2011-09-15 | 347 | 0 | 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) | ||
| 2011-09-14 | 348 | 0 | 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) | ||
| 2011-09-15 | 349 | 0 | 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) | ||
| 2011-09-15 | 350 | 0 | 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) | ||
| 2011-09-16 | 351 | 0 | Order | 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) | ||
| 2011-09-16 | 352 | 0 | 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 10/10/2011. Redacted Transcript Deadline set for 10/20/2011. Release of Transcript Restriction set for 12/19/2011.(McGuirk, Kelly) | ||
| 2011-09-16 | 353 | 0 | 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) | ||
| 2011-09-12 | 354 | 0 | 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) | ||
| 2011-09-08 | 355 | 0 | 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) | ||
| 2011-09-19 | 356 | 0 | Order | 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) | ||
| 2011-09-19 | 357 | 0 | Order on Motion to Appear Pro Hac Vice | 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). | ||
| 2011-09-19 | 358 | 0 | Order on Motion to Appear Pro Hac Vice | 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) | ||
| 2011-09-19 | 359 | 0 | Motion to Compel | 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) | ||
| 2011-09-20 | 360 | 0 | Order on Motion to Compel | 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) | 2011-09-21 04:01:35 | e8c2380a3c98cd19cbafd1275e87453e54cafc17 |
| 2011-09-19 | 361 | 0 | USCA Order | 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) | 2011-09-21 04:03:31 | 6d0d57f9c5b25df52f02e714af08d4ccd0774925 |
| 2011-09-21 | 362 | 0 | Memo Endorsement | 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) | 2011-09-23 04:40:07 | bb04984fc43dbd40fc2d977ce241f940185d0272 |
| 2011-09-21 | 363 | 0 | Memo Endorsement | 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) | 2011-09-23 04:42:30 | f2acb26928830919aac86c11d686a4d6bd05ed40 |
| 2011-09-27 | 364 | 0 | Endorsed Letter | 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) | 2011-09-28 04:42:43 | c57263cf85773c739d6b383d9170e7f8cf73e39b |
| 2011-10-20 | 365 | 0 | USCA Mandate | 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) | 2011-10-24 02:16:29 | 1e678e3b33720f2588a4ea722b990738db084a54 |
| 2011-10-20 | 366 | 0 | USCA Mandate | 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) | 2011-10-24 02:18:34 | 61b612d153a4d46a747bad8e792390549899cbdd |
| 2011-11-30 | 367 | 0 | Notice of Change of Address | 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) | 2011-12-01 00:36:21 | dee5d7b18d8b444b21f9c3bdf77671e6c2e51896 |
| 2011-12-06 | 368 | 0 | Motion to Withdraw as Attorney | 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). | ||
| 2011-12-06 | 369 | 0 | Motion to Withdraw as Attorney | MOTION for Carlos A. Zelaya, II to Withdraw as Attorney. Document filed by Hugo Gerardo Camacho Naranjo, Javier Piaguaje Payaguaje.(Zelaya, Carlos) | 2011-12-07 02:00:57 | 24d9a8f5b67317632d7d68ee28d76eda0cf0541a |
| 2011-12-06 | 370 | 0 | Affidavit in Support of Motion | 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) | 2011-12-07 02:03:25 | 399bfc64db605a8012d3943e689fb02994718eb5 |
| 2011-12-07 | 371 | 0 | Order on Motion to Withdraw as Attorney | 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) | 2011-12-08 02:21:30 | 04e951345846c2bbb258f022f268621030f58ae0 |
| 2011-12-09 | 372 | 0 | Notice of Change of Address | 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) | 2011-12-12 02:59:37 | f9934676a4f0edf5de0e31cfe47c0e73256eb447 |
| 2011-12-09 | 373 | 0 | Notice of Change of Address | 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) | 2011-12-12 03:00:31 | cf90877ef74a9a6124e46c0b3a266c2a4625c554 |
| 2011-12-13 | 374 | 0 | Notice of Change of Address | 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) | 2011-12-14 02:48:38 | 60b029c66885b6d61c781fa1a7ebad3b08206ca3 |
| 2011-12-15 | 375 | 0 | Memo Endorsement | 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) | 2011-12-16 03:51:22 | 2c5663e7a0b66b01e1d3d2ac2455db834ce9eb78 |
| 2012-01-27 | 376 | 0 | USCA Order | 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) | ||
| 2012-02-16 | 377 | 0 | USCA Mandate | 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) | ||
| 2012-02-17 | 378 | 0 | Motion for Recusal | MOTION for Recusal. Document filed by Steven Donziger, Donziger & Associates PLLC, The Law Offices of Steven R. Donziger.(Keker, John) | 2012-02-18 02:58:06 | b03e1d1afb3caa23e19fc8729fab2d24d6d58b82 |
| 2012-02-17 | 379 | 0 | Motion for Recusal | 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) | 2012-02-18 03:03:00 | 5a95d5d42801b43e8021dbba18e85ac86acd6432 |
| 2012-02-21 | 380 | 0 | Order on Motion for Recusal | 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) | 2012-02-22 02:27:45 | db09f990306e9aa53a11e857d11d405744669a7a |
| 2012-03-13 | 381 | 0 | Motion for Order to Show Cause | 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) | 2012-03-14 04:38:19 | 9178b5072cb200bd973495f2d54e1f9cd66a88ca |
| 2012-03-13 | 382 | 0 | Memorandum of Law in Support of Motion | 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) | 2012-03-14 04:38:17 | dc5018dae1348e3d8f7a60b8486bfb7e61c3d07c |
| 2012-03-13 | 383 | 0 | Declaration in Support of Motion | 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) | ||
| 2012-03-13 | 384 | 0 | Memo Endorsement | 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) | 2012-03-14 04:39:33 | f234f33d0a3f607bcde66552a30a4d09b49157fe |
| 2012-03-15 | 385 | 0 | Certificate of Service Other | 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) | 2012-03-16 03:18:25 | edc0f49424a0d31b3f1807b109a68336434ed5cf |
| 2012-03-27 | 386 | 0 | Response in Opposition to Motion | 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) | 2012-03-28 04:20:51 | e7dad63a5dc17d44f28851af957fcb9064c85aff |
| 2012-03-27 | 387 | 0 | Declaration in Opposition to Motion | 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) | 2012-03-28 04:21:12 | b2be671f410a64c5835a354a47d2fe8e43d425d4 |
| 2012-03-27 | 388 | 0 | Joinder | 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) | 2012-03-28 04:21:39 | 74320325835b8ac82e2c75905fa3b6b9fea2f51b |
| 2012-04-02 | 389 | 0 | Reply Memorandum of Law in Support of Motion | 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) | 2012-04-03 03:39:07 | 769762f0948eed65bc2c6ffabcc14c5739a1bdb2 |
| 2012-04-02 | 390 | 0 | Declaration in Support of Motion | 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) | 2012-04-03 03:42:29 | 738bee266b50c6942fc78c47926b4a5804de6d7f |
| 2012-05-02 | 391 | 0 | Notice of Appeal | 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). | 2012-05-03 04:27:32 | 7977e197f1c4aa4daa3e315074075deb3376818c |
| 2012-05-22 | 392 | 0 | Motion for Miscellaneous Relief | 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). | ||
| 2012-05-24 | 393 | 0 | Motion for Miscellaneous Relief | 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) | 2012-05-25 03:36:29 | 305f298d493253ee2e947497c00a7a2422f0944c |
| 2012-05-24 | 394 | 0 | Declaration in Support of Motion | 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) | ||
| 2012-06-07 | 395 | 0 | Memorandum of Law in Opposition to Motion | 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) | 2012-06-08 05:24:03 | 0b5c7a05be343b9f33b259186e2fcab385e1d1d6 |
| 2012-06-18 | 396 | 0 | Reply Memorandum of Law in Support of Motion | 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) | 2012-06-19 03:15:14 | 2824ac43aeddc77b7056256676bb032ff75543cc |
| 2012-06-20 | 397 | 0 | Order on Motion for Miscellaneous Relief | 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) | 2012-06-22 04:36:37 | bdbe2783a6039f77598df214253fa8edf2f4e279 |
| 2012-09-07 | 398 | 0 | Endorsed Letter | 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) | 2012-09-10 04:26:33 | 3aef8f7d28fed6f06ba558403850c333a5716962 |
| 2013-02-13 | 399 | 0 | Motion to Withdraw as Attorney | 2013-02-14 02:09:34 | d1eba6b07ecca0bcb31c42241ee2a700d1d50d45 | |
| 2013-02-14 | 400 | 0 | Memo Endorsement | 2013-02-15 02:04:03 | abf1df291d85721033c91750bdfe515d193fcc24 |