Discovery and Testimony. In order to comply with timelines for hearings, the UFT and DOE agree that hearings must be held in as efficient a manner as possible. Disputes relating to document production, witness lists and other procedural issues often consume hearing time and should be dealt with to the maximum extent possible in the pre-hearing conference. To that end, the UFT and DOE have already agreed in the June 27, 2008 letter from the Chancellor to President of the UFT to certain discovery procedures. The hearing process itself can be conducted in a more efficient manner that allows for issues to be fully and fairly litigated. To accomplish this, the parties to the hearings shall adhere to the following guidelines:
Discovery and Testimony. Each of the Stratus Parties agree to cooperate fully in responding to Chevron’s requests for discovery or information in the RICO Action, the arbitration currently pending in the Permanent Court of Arbitration, the Hague, Netherlands, under the U.S.-Ecuador Bilateral Investment Treaty, PCA Case No. 2009-23 (the “BIT Arbitration”), and any action pursuant to 28 U.S.C. § 1782 seeking discovery relating to the Lago Agrio Litigation or the BIT Arbitration or any action relating to the Lago Agrio Litigation or the Lago Agrio Judgment or against a “Non-Party Co-Conspirator,” identified in Paragraph 18 and its subparts in the First Amended Complaint of the RICO Action, whether previously filed or to be filed in the future, in any jurisdiction (the “Related Actions”), whether in a court of law or an arbitration. Such agreement to cooperate shall include but not be limited to (1) responding to any outstanding or future Chevron discovery request in the RICO Action; (2) making Xxx Xxxxx and Xxxxxxx Xxxxxxx, and other Stratus employees as necessary, available to testify in person, by deposition or by written statement, under oath, in any stage of the RICO Action, the BIT Arbitration, or the Related Actions, at the request of Chevron upon reasonable notice; and (3) taking steps to obtain and produce to Chevron the complete, unredacted Stratus materials currently possessed by Xxxxxxx’s counsel at Silver & DeBosky. Beltman and Xxxxx each further specifically agrees to testify in person, by deposition or by written statement, under oath, in any stage of the BIT Arbitration, the RICO Action, or Related Actions, including hearing testimony, at the request of Chevron upon reasonable notice. The Stratus Parties each understand that they are obligated to tell the truth, as required by oath, affirmation, legal obligation, or declaration made under penalty of perjury, when providing written or oral testimony in any judicial, arbitral, or other forum, or giving written or oral statements in any investigation.
Discovery and Testimony. The Xxxxxxx Parties, including, without limitation, their corporate representatives, including Xxxxxxxxxxx Xxxxxx, agree to cooperate fully in responding to Chevron's requests for discovery or information in the RICO Action, the arbitration currently pending in the Permanent Court of Arbitration, the Hague, Netherlands, under the U.S.- Ecuador Bilateral Investment Treaty, PCA Case No. 2009-23 (the "BIT Arbitration"), and any action pursuant to 28 U.S.C. § 1782 seeking discovery relating to the Lago Agrio Litigation or the BIT Arbitration or any action relating to the Lago Agrio Litigation or the Lago Agrio Judgment, whether previously filed or to be filed in the future, in any jurisdiction (the "Related Actions"), whether in a court of law or an arbitration. Such agreement to cooperate shall include, but not be limited to, (1) responding to the RICO Subpoenas and any future Chevron discovery request in the RICO Action; and
