PDF《Exhibit C》

Exhibit C Case 1:11-cv-03718-LAK -JCF Document 264-3 Filed 08/31/11 Page

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14 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CHEVRON CORPORATION, Plaintiff, v.

MARIA AGUINDA SALAZAR, et al., Defendants, -and- STEVEN DONZIGER, et al., Intervenors. x : : : : : : : : : : : : : : x

11 Civ.

3718 (LAK) CHEVRON CORPORATION'

S APPENDIX TO ITS PRIVILEGE LOGS IN RESPONSE TO DEFENDANTS HUGO GERARDO CAMACHO NARANJO'

S AND JAVIER PIAGUAJE PAYAGUAJE'

S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS AND THINGS, FIRST SET OF INTERROGATORIES (AS REVISED), AND FIRST SET OF REQUESTS FOR ADMISSION Pursuant to Federal Rules of Civil Procedure 26, 33, 34,

37 and Local Rules 26.2 and 26.3 for the United States District Court for the Southern District of New York, as modified by this Court'

s July 26,

2011 Order [DI 143], Plaintiff Chevron Corporation ( Chevron ) hereby submits its Appendix to Chevron'

s Communications Privilege Log and Non-Communications Privilege Log ( Privilege Logs ), produced concurrently herewith in response to Defendants Hugo Gerardo Camacho Naranjo'

s and Javier Piaguaje Payaguaje'

s First Set of Requests for Production of Documents and Things, First Set of Interrogatories (as revised), and First Set of RequestS for Admission (collectively the Requests ). The Privilege Logs submitted concurrently and this Appendix, incorporated by reference therein, assert the attorney-client Case 1:11-cv-03718-LAK -JCF Document 264-3 Filed 08/31/11 Page

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14 2 privilege, the work product doctrine, the common interest doctrine, the State of California or any other state private financial information privilege, and any other applicable privilege or immunity for only such COMMUNICATIONS, DOCUMENTS, or other tangible things that are non-objectionable, relevant, and responsive to the Requests. Any COMMUNICATIONS, DOCUMENTS, or other tangible things withheld on the basis of the attorney client privilege, the work product doctrine, or any other protection from disclosure have been treated as confidential material. Certain categories and date ranges of COMMUNICATIONS, DOCUMENTS, or other tangible things may include some DOCUMENTS or other materials subject to objection by Chevron, or that are not necessarily relevant or otherwise responsive. By including certain categories or date ranges on the Privilege Logs, Chevron does not waive, and hereby expressly reserves, any applicable objections, including but not limited to relevance, responsiveness, burden, and scope.1 DEFINITIONS A. Authors and Recipients Chevron'

s Privilege Logs contain categories of authors and recipients that are described in greater detail in this Appendix. These lists may not be exhaustive;

they reflect Chevron'

s good faith effort following a reasonable search to identify appropriate authors and recipients of communications and other material as to which Chevron asserts privilege, work product, or other protection from disclosure.

1 Indeed, the Court substantially narrowed the scope of this litigation in an order released just this morning. See August 17,

2011 Memorandum Opinion, Chevron Corp. v. Salazar et al., 11-cv-3718 (LAK) (S.D.N.Y.) (Dkt. 229) (dismissing in part the LAPs'

twenty-eighth and thirty-first affirmative defenses). Chevron reserves the right to amend its privilege log as appropriate. Case 1:11-cv-03718-LAK -JCF Document 264-3 Filed 08/31/11 Page

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14 3 1. The term OUTSIDE COUNSEL means and refers to attorneys and staff working on behalf of attorneys, retained by CHEVRON, TEXACO, TEXPET, or any parent, subsidiary, or affiliated entity thereof, in connection with the LAGO AGRIO DISPUTES or related matters, including but not limited to the following law firms, attorneys, and staff, and any attorneys and staff working with them or at their direction in connection with the LAGO AGRIO DISPUTES or related matters: ? Adams, Hendon, Carson, Crow &