Section 1782 of the United States Code (Assistance to foreign and international tribunals and to litigants before such tribunals) allows a foreign tribunal, litigant (or other interested person) to obtain evidence from persons found in the United States for use in a foreign proceeding. Used correctly, this can be a powerful and strategic tool.

Almost every aspect of the statute has been litigated. The key Supreme Court opinion on the interpretation of Section 1782 is Intel Corp. v. Advanced Micro Devices, Inc., 542 U.S. 241 (2004). The meaning of some provisions is well-settled, but others may be unclear or counterintuitive. An application has four mandatory statutory requirements and four discretionary elements. Courts "evaluate discovery requests under section 1782 in light of the statute's twin aims of providing efficient means of assistance to participants in international litigation in our federal courts and encouraging foreign countries by example to provide similar means of assistance to our courts." S.A. v. R. Inc., 51 F.3d 1095, 1097 (2d Cir. 1995).

Ex parte. In a departure from the normal adversary process, Applications are often filed and granted ex parte. Courts may require service of the Application upon the adversary party in the foreign proceeding in addition to the discovery target in the United States to allow them to oppose the Application. See, e.g., In re Eshelman, No. 5:23-MC-80015 (N.D. Cal. May 9, 2023) ("The target of the § 1782 Application, Google LLC, has filed a response in this matter, indicating that it does not oppose issuance of the subpoenas [but] requests that the Court include in its § 1782 order a requirement for Google to provide notice to the accountholder in question and to permit both Google and the accountholder 30 days after service to file a motion to quash or modify the subpoenas."). The duty of candor towards the court is heightened in ex parte proceedings. In re Application of Vestolit, No. MC 24-CV-01401 at *2 (D. Del. Jan. 14, 2025) the court temporarily denied an otherwise valid application because it did not sufficiently identify one of the subpoena targets and ordered "each of the seven lawyers whose name appears on the Application and on the memorandum filed in support of the Application" to show cause why that lawyer should not be deemed to have violated Model Rule 3.3(d).

The Court. The Application is filed in U.S. District Court. In districts where applications are common (S.D.N.Y.; S.D. Fla.; N.D. Cal.), the turnaround may be in days or weeks, and they are often granted when they are facially sufficient. The granting of an Application is vested in the court's discretion. Many courts will refer Applications to Magistrate Judges for a ruling. See In re Matter of the B&C Holding GmbH, Civil Action No. 23-365-JWD-EWD (M.D. La. Nov. 24, 2023) ("A § 1782 application is not among the pretrial matters specifically excluded from direct ruling by a magistrate judge under 28 U.S.C. § 636(b)(1)(A). Additionally, as a § 1782 application is a discovery tool, it does not appear to be a dispositive matter which would require a report and recommendation."). In other districts, a Magistrate Judge will issue a Report and Recommendation only. See In re Murchinson Ltd., No. 2:23-MC-00191, 2024 WL 5424926, at *1 (C.D. Cal. Jan. 25, 2024) (vacating order granting 1782 application and issuing report and recommendation instead). An order by the district court granting or denying an Application is immediately appealable, as long as the scope of discovery is conclusively determined from the record, In re Amgen Inc., No. 25-1407, --- F.4th ----, 2025 WL 1585165 (3d Cir. June 5, 2025) ("[t]he lack of a conclusive determination as to the scope of [a party's] discovery obligations renders any § 1782 order nonfinal and unappealable"), as can be orders for protective orders or to quash that would be considered interlocutory in other contexts.

The Statutory Factors

The Person. The person from whom discovery is sought may be an individual or an organization.

Is found. Courts have interpreted this requirement to mean the limits of personal jurisdiction consistent with due process. An organization is found where the business is incorporated, is headquartered, or where it has a principal place of business. An organization may be subject to general or specific jurisdiction. See In re del Valle Ruiz, 939 F.3d 520, 530 (2d Cir. 2019) ("Translated to account for a § 1782 respondent's nonparty status, we thus hold that, where the discovery material sought proximately resulted from the respondent's forum contacts, that would be sufficient to establish specific jurisdiction for ordering discovery. That is, the respondent's having purposefully availed itself of the forum must be the primary or proximate reason that the evidence sought is available at all."). If a person "is served with a subpoena while physically present in the district of the court that issued the discovery order, then for purposes of § 1782(a), he is 'found' in that district." In re Edelman, 295 F.3d 171, 180 (2d Cir. 2002). For a good discussion of the necessary showing for a foreigner who visits or stays in the United States to be "found" in the district see In re Application of William Laggner, Civil Action No. 23-mc-00074 (D. Colo. Jan. 11, 2024). If discovery is sought from persons found in multiple districts, correspondingly multiple applications are required. In some circumstances, the latter-filed actions may be stayed or dismissed if they are largely duplicative. See, e.g., In re Elliott Cap. Advisors, L.P., No. 4:16-MC-00030-SMR, 2016 WL 11974977 (S.D. Iowa Nov. 18, 2016) (collecting cases).

Civil or criminal. The proceeding may be civil, criminal, administrative, or quasi-judicial. Fonseca v. Blumenthal, 620 F.2d 322 (2d Cir. 1980). Examples of non-obvious "tribunals" include the Mexican Federal Commission for Protection Against Health Risks (Comisión Federal Para La Protección Contra Riesgos Sanitarios, "COFEPRIS"). El Poder del Consumidor v. The Coca-Cola Company, No. 1:24-CV-03665 (N.D. Ga. Oct. 30, 2024) ("COFEPRIS is an administrative agency with authority to investigate public-health complaints in the first instance, take and receive relevant evidence, and issue resolutions deciding all issues presented. Plus, its resolutions are subject to judicial appeal.").

A proceeding in a tribunal. In practice, this means not an arbitration, ZF Auto. US, Inc. v. Luxshare, Ltd., 596 U.S. 619, 633 (2022), and not an enforcement agency. The proceeding must be adjudicative in nature. See In re Banco BTG Pactual, No. 24 MISC. 304 (AT), 2025 WL 1079221, at *3 (S.D.N.Y. Apr. 9, 2025) (discussing challenge to application because foreign proceeding was essentially "enforcement proceedings related to debt [that] already exist[s]" and involve no "merit-based issue that remains to be decided."). Discovery can be used in an arbitration, however, if that use is secondary or ancillary to a primary acceptable use in the tribunal. Such a secondary use may be conditioned in some way. The proceeding may be existing or be "within reasonable contemplation." If the application indicates that the discovery it seeks is necessary to determine whether a claim in a foreign proceeding may be brought in the first place, it will likely be denied. In re Novalpina, No. 23 MISC. 25, 2025 WL 1160854, at *20 (S.D.N.Y. Apr. 21, 2025). Courts are divided as to whether a foreign proceeding is "within reasonable contemplation" where a petitioner represents that it will bring a foreign proceeding—and articulates legal theories on which it allegedly plans to rely—while simultaneously stating that the filing of the contemplated foreign claims is contingent on obtaining the Section 1782 discovery that is sought. In re Novalpina. A judicial proceeding to enforce a judgment, In re Clerici, 481 F.3d 1324 (11th Cir. 2007), or an arbitral award is a valid proceeding.

For use. Evidence is "for use" in a foreign proceeding if it can "be employed with some advantage or serve some use in [that] proceeding." Mees v. Buiter, 793 F.3d 291, 297 (2d Cir. 2015). Therefore, the applicant must demonstrate the "practical ability to inject the requested information into the foreign proceeding." An applicant may satisfy the statute's "for use" requirement even if the discovery sought is not necessary to succeed in the foreign proceeding. The discovery need not be sought for the purpose of commencing a foreign proceeding in order to be "for use" in that proceeding, so long as the proceeding is within "reasonable contemplation." A § 1782 applicant satisfies the statute's "for use" requirement by showing that the materials are to be used at some stage of a foreign proceeding. Mees v. Buiter, 793 F.3d 291, 299 (2d Cir. 2015). If the matter is criminal, discovery is available to a defendant or to a complainant who may trigger a criminal action. "The future proceedings must be more than speculative, however, and a 'district court must insist on reliable indications of the likelihood that proceedings will be instituted within a reasonable time.'" Application of Consorcio Ecuatoriano de Telecomunicaciones S.A. v. JAS Forwarding (USA), Inc., 747 F.3d 1262, 1270 (11th Cir. 2014). The term of art is "within reasonable contemplation." See In re Application of CETTEEN, No. 2:24-MC-00228, 2025 WL 1663707, at *3 (D. Utah Feb. 3, 2025) (denying application as "bare assertion that it is 'contemplating' misappropriation claims is insufficient."). Materials may be for use in a foreign proceeding as well as a domestic one. See In re Application of Philippe Martinez, No. 24-MC-00306 (RA)(SN), 2024 WL 5402058, at *5 (S.D.N.Y. Nov. 1, 2024) ("the law does not prohibit the Applicants from using evidence obtained in these proceedings in the Florida RICO Action, unless the Middle District of Florida orders otherwise."). They may be used in multiple proceedings. In re Application of Novo Nordisk, No. 7:25-MC-1-M-BM, 2025 WL 1448204 (E.D.N.C. May 20, 2025).

Denial on the basis that the discovery is not "for use" examples: discovery requested to assist in trial preparation, see In re DNG, Case No. 23 Misc. 435 (S.D.N.Y. Jan. 11, 2024) ("DNG has repeatedly stated that its intended 'use' for the proposed U.S. deposition of Mulanaphy would be to assist in its trial preparation... DNG does not argue that the deposition itself would be admissible in the Singapore trial. Nor does it argue that the deposition would be taken in the service of pretrial procedures authorized by Singapore law."); if the foreign action has been dismissed during the pendency of the Application, HateAid gGmbH v. Twitter Int'l Unlimited Co., No. 23-MC-80235-HSG (N.D. Cal. Dec. 6, 2024).

By an interested person. A Section 1782 order may be granted only “upon the application of any interested person.” 28 U.S.C. 1782. The term “interested person” has been given “expansive definition.” see Certain Funds, Accts. &/or Inv. Vehicles v. KPMG, L.L.P., 798 F.3d 113, 119 (2d Cir. 2015). Still, it is not infinitely elastic. “[T]he ability simply to pass on information to parties in a proceeding, without more, cannot confer ‘interested person’ status any more than the ability of amicus counsel to pass along evidence and arguments to counsel representing one of the parties in litigation.” See In re Brookfield Infrastructure Partners L.P., No. 24-MC-533 (LJL), 2025 WL 2733450, at *3 (S.D.N.Y. Sept. 25, 2025).

Receptive. Absent specific directions to the contrary from a foreign forum, the statute's underlying policy should generally prompt district courts to provide some form of discovery assistance, and courts should deny discovery on the basis of a lack of receptiveness only where it is provided with "authoritative proof that the foreign tribunal would reject evidence" obtained with the aid of Section 1782. In re Atvos Agroindustrial Investimentos S.A., 481 F. Supp. 3d 166, 176-177 (S.D.N.Y. 2020). Countries found to be receptive include Argentina, Austria, Bahamas, Bermuda, Brazil, Canada, the Cayman Islands, Chile, Colombia, Curacao, Cyprus, Denmark, Ecuador, England, France, the General Court of the European Union, Germany, Ghana, Hong Kong, India, Italy, Japan, Luxembourg, Malta, the Marshall Islands, Mexico, Mongolia, Nigeria, Paraguay, Peru, Romania, Russia, Saint Kitts and Nevis, Singapore, Slovenia, South Korea, Spain, Venezuela, and Vietnam.

Scope of discovery. The general rule is that discovery under Section 1782 may be obtained under the rules and principles guiding discovery under the Federal Rules of Civil Procedure. See In re Tokyo Dist. Prosecutors Off., Tokyo, Japan, 16 F.3d 1016, 1020 (9th Cir. 1994). This may include the production of documents not physically present in the United States, as long as the person from whom discovery is sought has the necessary "possession, custody, or control" over them.

Privilege. A person may not be compelled to give his testimony or statement or to produce a document or other thing in violation of any "legally applicable privilege" under U.S. law, or the law of the jurisdiction in which the discovery is to be used. In some circuits, courts will require "authoritative proof" that the privilege would apply in the foreign tribunal. See In re Arida, LLC, No. 19-MC-522 (S.D.N.Y. June 2, 2021) (collecting cases); In re Banco Mercantil del Norte, S.A., No. 23-2200, --- F.4th ---, 2025 WL 259981, at *5 (4th Cir. Jan. 22, 2025) ("In line with the Second, Third, and Fifth Circuits, we agree that the party asserting a foreign privilege bears the burden of establishing that privilege... But we need not, for purposes of this case, adopt the Second and Fifth Circuit's 'authoritative proof' standard."). The "person" from whom discovery is sought may be an attorney or law firm and can be compelled to provide non-privileged records in their possession, custody, or control. See, e.g., In re Ex Parte Michelena, Case No. 1:21-mc-20289 (S.D. Fla. Jun. 14, 2021) ("Applicants assert that they are entitled to the information being sought as heirs to the Deceased, an assertion that Akerman fails to dispute in its Reply. In the Application, it is further explained that a majority of the documents and information being sought 'relates to ... account statements and other financial records that do not constitute attorney-client communications.' Akerman likewise fails to address or dispute this proffer."); In re SBK Art LLC, No. 24 MISC. 147, 2025 WL 1537474 (S.D.N.Y. May 30, 2025) (authorizing petitioner to obtain discovery from law firm, "but only within tightly defined parameters.").

Misc. The court may allow a deposition to be conducted under the rules of the tribunal where the discovery is to be used instead of the default Federal Rules of Civil Procedure. Discovery may be conditioned upon the indemnification by the party seeking discovery of the person from whom discovery is sought if the disclosure would lead the person to incur a fine. A recalcitrant discovery target is subject to civil contempt and fines for noncompliance. For example, see In re Application of LM Property Development, No. 22-CV-62185 (S.D. Fla. Oct. 1, 2024) ("More specifically, the undersigned recommends that: (i) Respondent continue to be held in civil contempt; (ii) Respondent's daily fine for noncompliance be increased; and (iii) Petitioners be awarded reasonable attorneys' fees and costs incurred in connection with the Motion").

The discretionary (Intel) factors.

Even if all statutory factors are met, a district court may deny an application based on its evaluation of the discretionary factors. See, e.g., In re Application of Quadre, No. 24-MC-1341-MMP, 2025 WL 502054, at *9 (S.D. Cal. Feb. 14, 2025) ("[E]ven where an applicant satisfies § 1782's statutory prerequisites, the district court still retains substantial discretion to permit or deny the requested discovery.").

First discretionary factor: whether the respondent is a participant in the foreign proceeding. This factor is important because § 1782 assistance is more likely to be justified when the discovery target is a nonparticipant and thus more likely to be outside the foreign tribunal's reach. In other words, the availability of evidence—not the target's participation per se—is the key. See, e.g., In re Macquarie Bank Ltd., No. 2:14-cv-00797, 2015 WL 3439103, at *6 (D. Nev. May 28, 2015) ("Although the case law at times refers to whether the 'person' is within the foreign tribunal's jurisdictional reach, the key issue is whether the material is obtainable through the foreign proceeding.").

Second discretionary factor: the nature of the foreign tribunal and its receptivity to § 1782 assistance. The idea is to provide help where reasonably appropriate, without imposing or creating profitless work. An Applicant who seeks to inject evidence at an appellate stage must explain how such evidence could be received in the judicial process. In re Green Dev. Corp. S.A. de C.V., No. WDQ-15-2985 (D. Md. Oct. 1, 2015), for example, the court recommended denial of a petition in part because there was "no evidence that Petitioner has indicated to the Honduran court its purported need for the information sought. Nor is there any reason to believe that the Honduran court would be receptive to the introduction of new information during its appellate review of Petitioner's case pending before it."

Third discretionary factor: Circumvention of Foreign Proof-Gathering Restrictions or Other Policies. The evaluation of this factor may be quite detail- and fact-intensive. For example: "There is no suggestion that Petitioner is looking to bypass Mexican evidentiary restrictions. At the same time, however, there are some procedural red flags that give the undersigned pause. First, Petitioner is seeking information and testimony regarding Coca-Cola's Mexican subsidiaries, but Petitioner has failed—conspicuously, in the undersigned's view—to include these entities in its administrative complaint. Second, Petitioner filed its § 1782 application in this Court just twelve days after filing the administrative complaint. Third, Petitioner concedes that COFEPRIS has authority to request evidence directly from Coca-Cola's Mexican subsidiaries and, what's more, that it even has its own right to ask COFEPRIS to make such evidentiary requests. Yet rather than allowing COFEPRIS to take the lead, or nudging it to do so, Petitioner instead decided to quickly file the instant application seeking this Court's assistance. Meanwhile, there is no sign that COFEPRIS itself has requested any of the proposed discovery. To be sure, as Petitioner points out, there is no exhaustion requirement under § 1782. In other words, Petitioner was not required to first seek discovery through COFEPRIS before coming to this Court. At the same time, however, the omission of Coca-Cola's Mexican subsidiaries from the administrative complaint, the speed with which Petitioner arrived in this Court, the fact that Petitioner hasn't asked COFEPRIS to obtain any of the proposed discovery, and finally, the lack of action by COFEPRIS collectively suggest that Petitioner may be trying to circumvent the agency's investigative autonomy." El Poder del Consumidor v. The Coca-Cola Company, No. 1:24-CV-03665 (N.D. Ga. Oct. 30, 2024). Differently stated, "a perception that an applicant has side-stepped less-than-favorable discovery rules by resorting immediately to § 1782 can be a factor in a court's analysis."

The fourth factor: Discovery Burden. This factor is in practical terms coextensive with the standard undue burden analysis that is evaluated in Federal discovery under Rule 26(b)(1).

Uses. Section 1782 applications have commonly been used to discover the identity of anonymous or pseudonymous posters; in probate and divorce cases; for business disputes, fraud, embezzlement; in aid of bankruptcy and receiverships; for patent infringement; to help enforce arbitral and judicial awards.

Notable cases and examples of common patterns:

Business disputes

In re Application of Luis Aron, Case No. 3:23-mc-00841-AN (D. Or. Jan. 3, 2024). Petitioner states that he is involved in multiple legal proceedings in the Republic of Paraguay related to a dispute between himself and the "Gomez Family" regarding the ownership and finances of Doral, a corporation that is "the exclusive licensee for Adidas in Paraguay." In November 2019, petitioner filed a lawsuit against the Gomez Family in Paraguay, and he is now attempting to enforce a resultant court order granting him access to Doral's books and records. In August 2020, the Gomez Family "knowingly and intentionally filed false criminal charges" against petitioner, and as a result, a Paraguayan court issued an "international capture order" against him. Petitioner "recently" commenced a criminal action against the Gomez Family, and in August 2023, a Paraguayan court ordered a raid of Doral's offices in connection with the criminal investigation. Petitioner seeks information from the Adidas Entities that he believes will assist him in the Paraguayan legal proceedings, specifically in determining the period and extent of the Gomez Family's control of Doral, whether the Gomez Family has sought kickbacks, and any representations that the Gomez Family made about petitioner's role in Doral's business affairs. Note: this is an example of a pattern of entanglements fairly common in matters arising from Latin America.

In re Frasers Grp. PLC, Civil Action No. 23-2279 (D.N.J. Jan. 12, 2024). Frasers filed a civil claim in the High Court of Justice, Business and Property Courts of England and Wales, Commercial Court, alleging among other things that a London Morgan Stanley subsidiary's decision to impose a margin call of more than $900 million on Saxo Bank relating to Hugo Boss call option was arbitrary and capricious, and asserting claims under English law for the torts of inducing breach of contract and causing loss by unlawful means.

In re Mizuho Financial Group, Inc., No. 2:23-MC-00025 (C.D. Cal. Aug. 28, 2023). Mizuho sought discovery to support filing an action in Japan to enforce its registered trademarks by asserting claims against parties who have been operating infringing sites.

In re Ex Parte Application of Sumitomo Pharma UK Holdings, Ltd., No. 24-MC-290 (S.D.N.Y. Jan. 2, 2025). A minority investor who filed an appraisal proceeding sought discovery for use in Bermuda.

In re Ex Parte Application of Nokia, No. 23-01395 (D. Del. Apr. 18, 2024) and In re Ex Parte Amazon, No. 24-493 (D. Del. Jan. 16, 2025). Amazon and Nokia engaged in an unusual tit-for-tat arising from patent infringement litigation in Europe. Both applications were decided by the same court and both were denied, albeit on different grounds. Nokia's application was denied on Intel discretionary factors after observing that part of it was likely a "fishing expedition" to determine whether an action it expected to file would be viable. Amazon's application was denied based on the weighing of the Intel factors, particularly the possibility that the requested discovery could be ordered by German courts.

In re Man Group, No. 24-MC-559 (JHR) (OTW), 2025 WL 846134, at *2 (S.D.N.Y. Mar. 13, 2025). Seeking to identify individuals believed to have been involved in a billion-dollar bribery scheme.

Tracing assets

In re Application of Golden Meditech Holdings Ltd., No. 24 MISC. 24 (S.D.N.Y. Dec. 30, 2024). Applicant sought discovery from fourteen banks to trace allegedly misappropriated funds.

Probate and family law

In re De Holguin, 20-23410-MC (S.D. Fla. Dec. 2, 2020). The application sought the production of documents and depositions from law firm Shutts & Bowen LLC and attorney Maria Del Pilar Rubio. According to the application, Ms. Rubio had a romantic relationship with the Decedent and exercised undue influence over him in the procurement of a will executed in Florida. Applicant, Mary Ann James de Holguin, had been married to the decedent for at least twenty years before his death, sought to invalidate that Florida will in a Colombian proceeding.

In re Application of Atiku Abubakar, 1:23-cv-05099 (N.D. Ill. Sep. 19, 2023) was an unusual Application to uncover educational records from a university to challenge the eligibility of a presidential candidate in Nigeria.

Revealing the identity of anonymous and pseudonymous internet personas

In re Ex Parte Application of Seyon In, Case No. 5:24-mc-80285 (N.D. Cal. Dec. 19, 2024). Applicant "is an influencer and streamer who uses the nickname 'Juice Seyeon' on YouTube, Instagram, and Afreeca TV." She seeks identity of anonymous defamer. Note: this is the most common use of Section 1782 Applications filed from East Asia.

Dannacher v. Cloudflare, Inc., No. 24-MC-80066 (N.D. Cal. July 10, 2024). The court granted an application to support a criminal complaint in Dubai. Applicant is a Swiss citizen residing in Dubai, UAE, who received a series of emails from an unknown source demanding payment to deactivate a website accusing him of money laundering. Applicant's business associate received an email threatening to post a similar website targeting him unless Applicant paid. Applicant's wife also received an email threatening to expose her as a "criminal husband wife."

Liapis v. Meta Platforms, Inc., No. 24-MC-80267-PHK, 2025 WL 1294651 (N.D. Cal. May 5, 2025). The court granted an application seeking user identification to support a criminal defendant's challenge to his prosecution in Australia.

In re Gliner, No. 24-4624, 2025 WL 968393, at *4 (9th Cir. Apr. 1, 2025). The Ninth Circuit reversed the district court's denial of a "§ 1782 application due to its assumed impacts on the [publisher's] First Amendment right of anonymity. But the First Amendment may not protect [them] at all. '[F]oreign citizens outside U.S. territory do not possess rights under the U.S. Constitution,' including those under the First Amendment."

Abuse of the Section 1782 process

In re Ex Parte Application of Dr. Fredric Eshelman, Case No. 5:23-mc-80015 (N.D. Cal. May 9, 2023) is noteworthy as an example of an Application that was granted initially as facially sufficient but later voluntarily dismissed when it was opposed by Google and the John Doe represented by the ACLU. The Application, by an American citizen, sought to uncover the identity of an anonymous American defamer by relying on actions that the applicant intended to bring in Germany and India. In my opinion, this was a clear abuse of the Section 1782 process to circumvent otherwise applicable U.S. law that would protect the defamer's identity and his exercise of First Amendment rights. See Highfields Capital Mgmt., L.P. v. Doe, 385 F. Supp. 2d 969, 975–76 (N.D. Cal. 2005).

Misc.

In re Ex Parte Application of National Bank Trust, Case No. 3:20-mc-85 (D. Conn. Mar. 7, 2023), involved the interplay of Section 1782 and OFAC sanctions against Russia, given that the petitioner's majority owner was a sanctioned entity. The court found that the sanctions regime did not prohibit discovery in aid of execution of a judgment entered in the United Kingdom.

United States v. Zubaydah, 595 U.S. 195 (2022), involved Abu Zubaydah, a detainee in the Guantanamo Bay Naval Base, who sought to subpoena two former Central Intelligence Agency contractors to obtain information (for use in Polish litigation) about his treatment in 2002 and 2003 at a CIA detention site, which Zubaydah claimed was located in Poland. The Supreme Court held that the state secrets doctrine applies to Section 1782 discovery.

In re Application of the Republic of Türkiye, Case No. 24 Misc. 557, 2025 WL 2200159 (S.D.N.Y. Aug. 1, 2025), a previously granted Application was vacated and subpoenas quashed when the movant persuaded the court that "Türkiye's application does not represent a bona fide attempt to seek evidence relevant to the criminal matters involving him, but is instead part of a years-long campaign of harassment and retaliation against the Turkish government's political enemies and the Gülen movement in particular."