Chevron Corp. v. Donziger

970 F. Supp. 2d 214, 2013 WL 4804192, 2013 U.S. Dist. LEXIS 128402
CourtDistrict Court, S.D. New York
DecidedSeptember 9, 2013
DocketNo. 11 Civ. 069(LAK)
StatusPublished
Cited by2 cases

This text of 970 F. Supp. 2d 214 (Chevron Corp. v. Donziger) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Chevron Corp. v. Donziger, 970 F. Supp. 2d 214, 2013 WL 4804192, 2013 U.S. Dist. LEXIS 128402 (S.D.N.Y. 2013).

Opinion

MEMORANDUM AND ORDER DENYING CONTINUANCE AND STAY OF PROCEEDINGS PENDING DISPOSITION OF MANDAMUS PETITION

LEWIS A. KAPLAN, District Judge.

Defendants now move to delay the October 15, 2018 trial (which was scheduled more than ten months ago) and, in addition, stay all other proceedings in this case pending the disposition by the Second Circuit of their petition for a writ of mandamus.

The motion to delay the trial is without merit, represents a radical change in defendants’ nominal position (though it is entirely consistent with a years-old strategy of delay wherever possible), and comes far too late.

The motion to delay the trial on the theory that it should await disposition of the mandamus petition, taken at face value, is entirely unpersuasive. The petition, even if granted, would not be case dispositive. It seeks to vacate a few interlocutory orders that relate principally to whether the defendants’ affirmative defense of collateral estoppel rests in part on the Ecuadorian judgment against Chevron (the “Judgment”) and, if so, whether defendants should have been permitted to withdraw it in this action without prejudice to asserting that Judgment elsewhere. A ruling vacating those orders would not significantly affect the scope or duration of the trial or of the preparation for it. In any event, as the collateral estoppel defense, if pressed, would be resolved either [216]*216by a special jury verdict or by the Court, any error with respect to the collateral estoppel defense — which would not even be material absent a plaintiffs verdict on liability — could be cured easily on direct appeal from a final judgment.

Defendants’ actions since the petition for mandamus was filed on March 5, 2013 effectively admit as much. They subsequently asserted their desire to proceed to trial on October 15 and initiated and participated in extensive discovery and motion practice — some within the last few weeks — without ever suggesting that a delay of the trial pending the outcome of the petition was necessary or appropriate.

Nor is there any merit to the suggestion that the trial should be delayed because defendants need more time to prepare. They repeatedly have been granted most of the extensions they have sought despite only the most tenuous reasons for them. Indeed, they recently moved for — and on September 4 substantially received — a thirty day extension of all outstanding deadlines, an extension they said was necessary to permit them to try the case on October 15. Interestingly, they did not wait for a ruling on that motion before following it up with the motion now before the Court.

The request to stay all proceedings other than the trial itself would lack merit even if the trial were delayed temporarily. There is much that should and can be done before this case is finally adjudicated and, in a few particulars, before trial commences. There is no reason why those tasks should not proceed in any event. To stay all proceedings — not just delay the start of the trial — pending the outcome of the mandamus petition would add needlessly to any delay that would be caused if the trial alone were deferred

Finally, this motion seeks to delay or avoid a trial of the fundamental dispute between the parties — whether the Judgment was procured by fraud. The reason for it is evident from defendants’ memorandum. Defendants now admit fear that “any rulings adverse to Defendants” would “prejudice[ ]” them in proceedings to enforce the Judgment elsewhere.1

Defendants have brought Judgment enforcement proceedings in Argentina, Brazil and Canada, as they have been free to do since the Naranjo decision in January 2012.2 Naranjo made clear also, however, that Chevron is equally free to pursue this action.3 The risk of a result in one of two or more parallel litigations that may have adverse implications for another is inherent in such situations.4 Indeed, all of the nations concerned — the United States included — have interests in their own courts adjudicating the cases before them in the ordinary course absent strong reasons for a different result.

This case now is ready for its long scheduled trial. The outcome of the mandamus petition either will not affect the trial at all or merely will eliminate the collateral estoppel defense that defendants wish to withdraw. The possibility of an adverse result on Chevron’s affirmative fraud claims that defendants fear might [217]*217impair their lawsuits in other countries is not a reason to stop the trial, even briefly.

Facts

The Original Schedule

A discussion of the relevant procedural history is useful to understand this motion and the context in which it is made.

The parties had nineteen months in which to conduct discovery in this case.5 On October 25, 2012, the Court set trial to commence on October 15, 2013.6 The joint pretrial order, requests to charge, and any motions for summary judgement were to have been filed no later than June 23, 2013, later extended, as will appear, at defendants’ request.7 In addition, the Court initially required submission by June 30, 2013 of requested jury instructions together with either an agreed proposed form of special verdict or, to the extent there was disagreement, a joint report summarizing their differences.8

The Filing of the Mandamus Petition

Defendants filed the mandamus petition in the Court of Appeals on March 5, 2013. They sought no stay of this action from this Court or the Court of Appeals. The proceedings in the District Court continued in this case as scheduled. As even the most cursory review of the docket sheet reveals, they have been extensive.

The Withdrawal of Some of Defendants’ Lawyers and Their Representations that the Schedule Would Not be Affected

On May 3, 2013, former counsel for the Donziger Defendants and some of the counsel for the LAP Representatives sought leave to withdraw as counsel on the ground of nonpayment of fees.9 They stated, however, that Mr. Donziger was prepared to represent himself and his law firm and that Mr. Gomez, who had been counsel of record for the LAP Representatives since virtually the commencement of the action, would continue to represent them. In addition, they represented that their withdrawal would not delay the case and that the parties were ready to proceed on the existing schedule.10 Neither the withdrawing counsel nor any of the parties so much as hinted that the case should be stayed by reason of the withdrawal of counsel — let alone stayed pending disposition of the mandamus petition. The Court, relying on counsels’ representations that the withdrawals would not cause delay, granted the motions to withdraw.11

Defendants Seek and Receive Numerous Extensions But Never Suggest a Delay Due to the Mandamus Petition

Immediately after those motions to withdraw were granted, Messrs. Gomez and Donziger began requesting that the special masters delay depositions and discovery [218]*218deadlines. But they sought no any delay of the trial.12 Mr.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Chevron Corp. v. Donziger
384 F. Supp. 3d 465 (S.D. Illinois, 2019)
Chevron Corporation v. Aaron Page
768 F.3d 332 (Fourth Circuit, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
970 F. Supp. 2d 214, 2013 WL 4804192, 2013 U.S. Dist. LEXIS 128402, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chevron-corp-v-donziger-nysd-2013.