United States Fourth Circuit

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Chevron Corp. v. Page, 13-1382

In this consolidated appeal, petitioner Chevron seeks discovery of documents from respondent-attorneys in American courts to obtain evidence that a successful judgment against Chevron in Ecuador was fraudulently obtained. The district court's order requiring respondents to produce the requested documents is affirmed, where: 1) comity is a compelling reason to affirm the application of the Donzinger waiver of privilege in the Maryland proceeding to the documents in respondents' possession; 2) the crime-fraud exception to privilege applied because of respondents' involvement in obtaining the allegedly fraudulent judgment in Ecuador; and 3) various voluntary disclosures defeated the privileges asserted by effecting a subject-matter waiver.

Appellate Information

  • Decided 09/24/2014
  • Published 09/24/2014


  • Agee


  • United States Fourth Circuit


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