JODY DWAYNE KOPNICKY VERSUS CITGO PETROLEUM CORPORATION Consolidated With JONATHAN WIELEY ALEX VERSUS CITGO PETROLEUM CORPORATION

CourtLouisiana Court of Appeal
DecidedMay 7, 2008
DocketCW-0007-1483
StatusUnknown

This text of JODY DWAYNE KOPNICKY VERSUS CITGO PETROLEUM CORPORATION Consolidated With JONATHAN WIELEY ALEX VERSUS CITGO PETROLEUM CORPORATION (JODY DWAYNE KOPNICKY VERSUS CITGO PETROLEUM CORPORATION Consolidated With JONATHAN WIELEY ALEX VERSUS CITGO PETROLEUM CORPORATION) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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JODY DWAYNE KOPNICKY VERSUS CITGO PETROLEUM CORPORATION Consolidated With JONATHAN WIELEY ALEX VERSUS CITGO PETROLEUM CORPORATION, (La. Ct. App. 2008).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

NO. CW 07-1483

JODY DWAYNE KOPNICKY

VERSUS

CITGO PETROLEUM CORPORATION, ET AL.

CONSOLIDATED WITH

JONATHAN ALEX, ET AL.

REHEARING GRANTED

This matter first came before this court when CITGO Petroleum Corporation

(CITGO) filed an application for supervisory writs, seeking to have a trial court

judgment finding it in contempt of court set aside. The underlying litigation arises

from a June 2006 chemical spill that occurred at the CITGO facility in Calcasieu

Parish, Louisiana. The plaintiffs in these consolidated cases seek to recover damages

they claim to have sustained as a result of the chemical spill. The issues now before

this court relate to matters that occurred in the discovery process. By a judgment

dated January 8, 2008, this court vacated the trial court’s order finding CITGO in

contempt of court and set aside the order compelling specific attorneys to provide

their clients’ names. The matter is now before us on an application for rehearing filed

by the plaintiffs. For the following reasons, we grant the plaintiffs’ motion for

rehearing, vacate our prior judgment, and enter a new judgment as explained below.

1 On April 16, 2007, the plaintiffs served CITGO with a notice of corporate

deposition, listing twenty-five items or areas for examination. The notice further

requested that, pursuant to La.Code Civ.P. art. 1442, CITGO “designate one or more

officers, directors, managing agents, or other persons who consent to testify and/or

are competent to testify on its behalf, regarding the [twenty-five areas of

examination], as well as to such other relevant information as the witness may

possess” and to produce any and all documents relating to these twenty-five areas.

CITGO responded to the notice by producing its environmental manager,

David Hollis, as its Article 1442 designee. On April 25, 2007, the plaintiffs deposed

Mr. Hollis. In that deposition Mr. Hollis testified concerning ten of the twenty-five

areas of examination listed in the original notice. However, he could provide no

information concerning the remaining fifteen areas.

The day after taking Mr. Hollis’ deposition, the plaintiffs filed a second notice

of deposition seeking discovery of information regarding the fifteen items not

addressed the day before. In their notice, the plaintiffs again requested that, pursuant

to La.Code Civ.P. art. 1442, CITGO “designate one or more officers, directors,

managing agents, or other persons” to be deposed on these remaining areas, and to

produce all documents related to these areas.

CITGO responded to this filing on August 17, 2007, by filing a motion seeking

to limit the scope of discovery and to quash the Article 1442 deposition. In its

motion, CITGO asserted that it was facing hundreds of legal actions involving

thousands of plaintiffs in both state and federal forums, and that the United States

Department of Justice had begun an investigation to determine if federal laws were

violated in the incident. Asserting that because its employees had become the subject

of the federal investigation, and because these employees might require separate

2 criminal counsel and might find it necessary to invoke the self-incrimination

provisions of U.S. Const. amend. V during any deposition testimony, CITGO sought

a stay order from the trial court prohibiting the plaintiffs from taking the testimony

of any person under criminal investigation. However, CITGO did not identify these

persons or explain how an individual employee’s testimony could be subject to

criminal inquiry.

At a September 24, 2007 hearing on its motion, CITGO presented no evidence

in support of the assertions in its August 17 motion despite the fact that the trial court

gave the litigants specific evidentiary matters it would consider in determining

whether a protective order should be issued.1 Instead, CITGO’s counsel asserted that

the corporation would be hamstrung in responding to the litigation or in addressing

settlement issues because of the federal criminal consequences of anything it might

do in civil litigation. However, when questioned by the trial court, counsel for

CITGO acknowledged that he had no information that anyone with CITGO had

received a target letter from the federal prosecutors.

During the proceedings, counsel for CITGO deferred to a number of criminal

defense attorneys who were present in the court room during the hearing.2 Although

their status in the litigation lends little to the resolution of the issue now before us,

one of the defense attorneys, Mr. Kevin Stockstill, acknowledged that his twenty-five

clients were specific persons notified by CITGO that they were its Article 1442

1 The trial court suggested that it would consider a protective order after considering three basic areas: (1) exactly how the criminal investigation related to the pending civil proceedings; (2) whether those who may be deposed are targets of the criminal investigation; and (3) whether the subject matter of the suit suggested a violation of state or federal criminal law. 2 The record does not establish how many spectator attorneys were present at the hearing. It does make clear, however, that none of the attorneys who addressed the trial court were counsel of record for any party then before the court, that none would identify his client, and that none were under oath when presenting information to the trial court. Furthermore, neither counsel for CITGO nor any of the criminal defense lawyers who addressed the court suggested that any of those under criminal investigation would not consent to testify on behalf of CITGO.

3 designees, although counsel for CITGO never made such an assertion.3

In denying CITGO’s request for a protective order, the trial court stated:

Normally, when I usually get these situations where the law enforcement agency is asking that we hold off because they’re conducting an investigation is normally what happens. And it’s not happening in this case. The defendants are asking for this. Have you found that case? Where’s it at? Give it to me. I know it’s not important what the facts are, but a lot of times - - it’s not a real big case. Okay, in this case, this Thibodeaux vs. Thibodeaux this 538 So.2d 683, and it’s a Third Circuit Court of Appeal Louisiana Case. In this case, there was apparently a questioning of a witness. And that witness took the fifth and the Court of Appeals granted the writs and held that the District Court was to review each question to which the defendant exercised his privilege against self-incrimination in order to determine if privy was properly invoked. The trial court acted improperly in ordering defendant to answer all questions propounded at oral deposition and written interrogatory, insofar as, questions could have resulted in defendant incriminating himself in criminal activity. So, it seems like it comes to the trial judge’s responsibility to determine whether, or not, at some point, whether, or not, the question that they he took the fifth on could have involved some criminal conduct. That’s what it seems to say. Which I don’t have a problem with that. I thought that was the law anyway. Now, it was the good ol’ Third Circuit. They’re pretty compelling over Carter what the Third Circuit says. But anyway, this is what I’m going to rule. Number one, protective order is denied.

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