24. The plaintiffs do not allege any wrongdoing against Chevron Canada.
The action is for collection of a judgment debt. The plaintiffs will
execute against Chevron Canada any legal, equitable or other right,
personal property, interest, whether direct or indirect, or equity
of redemption that Chevron, the judgment debtor, has in Chevron
25. The plaintiffs plead and rely on the Execution Act, R.S.O. 1990, c. E.24
and the Securities Transfer Act, 2006, S.O. 2006, c. 8.
26. The plaintiffs seek the appointment of an equitable Receiver to seize
the shares and assets of Chevron Canada, the entire beneficial ownership of which belongs to the Judgment-Debtor, Chevron.
Judicial history in Canada
 In 2013, Chevron and Chevron Canada challenged the
jurisdiction of the Ontario Superior Court of Justice to recognize and enforce the Ecuadorian judgment. The motion judge,
D.M. Brown J. (as he then was), dismissed their motion and
concluded that the Ontario court has jurisdiction to recognize
and enforce the judgment against these defendants.2 D.M.
Brown J. also concluded that this was an appropriate case
in which to exercise the court’s power to stay the proceedings
on its own initiative pursuant to s. 106 of the Courts of Justice
 The Court of Appeal for Ontario overruled his imposition
of a discretionary stay of the proceedings and upheld his decision on the jurisdictional issue. The court concluded that an
Ontario court has jurisdiction to determine whether the Ecuadorian judgment against Chevron may be recognized and
enforced in Ontario. The Court of Appeal also upheld D.M.
Brown J.’s jurisdictional decision with respect to Chevron
Canada concluding (as the Supreme Court of Canada observed)
that an Ontario court “has jurisdiction to adjudicate a recognition and enforcement action against Chevron that also names
Chevron Canada as a defendant”.4 The Supreme Court of
Canada upheld the Court of Appeal for Ontario’s decision
with respect to the Ontario court’s jurisdiction. The Supreme
Court made it clear, however, that its decision did not determine the issue of whether Chevron Canada has a separate
2 Yaiguaje v. Chevron Corp.,  O.J. No. 1955, 2013 ONSC 2527,
361 D.L.R. (4th) 489 (S.C.J.) (“Ont. S.C. decision”), affd in part (2013),
118 O.R. (3d) 1,  O.J. No. 5719, 2013 ONCA , affd in part 
3 S.C.R. 69,  S.C.J. No. 42, 2015 SCC 42 (“S.C.C. decision”).
3 Courts of Justice Act, R.S.O. 1990, c. C.43, s. 106.
4 S.C.C. decision, at para. 22.