It never rains but it pours. The case of the day is In re Naranjo (4th Cir. 2014). The case was an appeal by the Lago Agrio plaintiffs and one of their lawyers, Letters Blogatory contributor Aaron Marr Page, from discovery orders in separate proceedings brought by Chevron under Section 1782 and under FRCP 45. The Section 1782 proceedings were in aid of the BIT arbitration between Chevron and Ecuador and in aid of the appellate proceedings in Ecuador. The FRCP 45 proceedings arose out of subpoenas Chevron issued in the RICO case in the Southern District of New York. In both cases, the issue was whether Page could assert an attorney-client privilege.