In re: Pilatus Bank PLC Pilatus Bank PLC v. Lawrence Connell

2021 DNH 079
CourtDistrict Court, D. New Hampshire
DecidedMay 11, 2021
Docket20-mc-94-JD
StatusPublished

This text of 2021 DNH 079 (In re: Pilatus Bank PLC Pilatus Bank PLC v. Lawrence Connell) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re: Pilatus Bank PLC Pilatus Bank PLC v. Lawrence Connell, 2021 DNH 079 (D.N.H. 2021).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

In re: Pilatus Bank PLC

Pilatus Bank PLC

v. Civil No. 20-mc-94-JD Opinion No. 2021 DNH 079 Lawrence Connell

O R D E R

Pilatus Bank PLC, which is located in Malta, brought an ex

parte petition pursuant to 28 U.S.C. § 1782, seeking judicial

assistance in obtaining discovery from Lawrence Connell for use

in a foreign tribunal. The court determined that Pilatus had

not satisfied the requirements of § 1782 and denied the petition

without prejudice to serving an amended petition on Connell.

Pilatus has served the amended petition, and Connell has filed

his response, objecting to the discovery that Pilatus seeks.

Standard of Review

Section 1782(a) provides as follows:

The district court of the district in which a person resides or is found may order him to give his testimony or statement or to produce a document or other thing for use in a proceeding in a foreign or international tribunal, including criminal investigations conducted before formal accusation. The order may be made pursuant to a letter rogatory issued, or request made, by a foreign or international tribunal or upon the application of any interested person and may direct that the testimony or statement be given, or the document or other thing be produced, before a person appointed by the court. By virtue of his appointment, the person appointed has power to administer any necessary oath and take the testimony or statement. The order may prescribe the practice and procedure, which may be in whole or part the practice and procedure of the foreign country or the international tribunal, for taking the testimony or statement or producing the document or other thing. To the extent that the order does not prescribe otherwise, the testimony or statement shall be taken, and the document or other thing produced, in accordance with the Federal Rules of Civil Procedure.

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.

In summary, section 1782(a) “authorizes district courts to order

persons residing in their district to participate in discovery

‘for use in a proceeding in a foreign or international tribunal’

when an application for such discovery is made by a foreign or

internal tribunal, or by ‘any interested person.’” In re

Porsche Automobil Holding SE, 985 F.3d 115, 120 (1st Cir. 2021)

(quoting § 1782(a)). Therefore, a court is authorized to

provide aid in discovery if:

1) the person from whom discovery is sought “resides or is found” in the district where the court sits; 2) the request seeks evidence (the “testimony or statement” of a person or the production of a “document or other thing”) “for use in a proceeding in a foreign or international tribunal”; 3) the request is made by a foreign or international tribunal or by “any interested person”; and 4) the material sought is not protected by “any legally applicable privilege.”

2 In re Schlich, 893 F.3d 40, 46 (1st Cir. 2018). The party

seeking discovery bears the burden of meeting the statutory

requirements. Id. at 49.

If those requirements are met, the court then has

discretion whether to grant the petition. Porsche, 985 F.3d at

120. Under the statute, the court must first determine whether

it is authorized to order the requested discovery and then, if

authorized, the court determines whether it should grant the

discovery request. Food Delivery Holding 12 S.A.R.L. v. DeWitty

& Assocs. CHTD, 2021 WL 860262, at *2 (D.D.C. Mar. 8, 2021).

In exercising discretion, courts consider four factors, the

first three of which pertain to aspects of the foreign

proceedings and the foreign tribunal, and the fourth of which

addresses the burden that would be imposed on the target of the

discovery. Intel Corp. v. Advanced Micro Devices, Inc., 542

U.S. 241, 264-65 (2002); Schlich, 893 F.3d at 47.

The first factor is whether the person from whom discovery

is sought is a party in the foreign proceeding. Id. at 47. If

so, there is less need for the evidence to be produced under

§ 1782 because the foreign tribunal can order discovery. Id.

The second factor considers the nature of the foreign tribunal

and the proceedings and whether the country and/or the tribunal

would be receptive to aid by a court in the United States. Id.

The third factor is whether the discovery request is an attempt

3 to avoid or circumvent discovery restrictions or policies in the

foreign country or in the United States. Id. The fourth factor

considers whether the discovery request is “unduly intrusive or

burdensome.” Id.

Background

Pilatus was a bank operating in Malta that was owned,

indirectly, by Ali Sadr Hashemi Nejad (“Sadr”). The New York

County District Attorney’s Office began an investigation of Sadr

in 2014, based on suspected involvement in activities that

included money laundering, offering a false instrument for

filing, and falsifying business records in a variety of business

ventures. United States v. Nejad, 436 F. Supp. 3d 707, 715

(S.D.N.Y. 2020). After a review of the data gathered through

search warrants, the District Attorney’s Office referred the

case to the United States Attorney’s Office for the Southern

District of New York for federal prosecution. Id. at 716. On

March 19, 2018, Sadr was indicted on six charges: conspiracy to

defraud the United States, conspiracy to violate the

International Emergency Economic Powers Act, bank fraud,

conspiracy to commit bank fraud, money laundering, and

conspiracy to commit money laundering.

On March 16, 2020, the jury found Sadr guilty on five of

the six charges, and his sentencing was scheduled for August 17,

4 2020. Sadr moved to vacate the guilty verdict and for a new

trial, and the government agreed, acknowledging the government’s

failures to disclose potentially exculpatory evidence. United

States v. Nejad, 487 F. Supp. 3d 206, 207 (S.D.N.Y. 2020). On

July 17, 2020, the guilty verdict was vacated, and the

indictment was dismissed with prejudice, which ended the

criminal proceeding against Sadr.1 United States v. Nejad, 18-

cr-224-AJN (S.D.N.Y. July 17, 2020); Nejad, 487 F. Supp. 3d at

207.

In the amended petition, Pilatus alleges that three days

after Sadr’s indictment, on March 21, 2018, the Maltese

Financial Services Authority (“MFSA”) took over Pilatus,

divested Sadr of his voting rights, stripped the directors of

authority, and halted business at the bank. The next day, the

In its amended petition, Pilatus represents that Sadr was 1

improperly indicted and was later “exonerated”. The cited decision in the Southern District of New York states that Sadr was found guilty, but the verdict later was vacated and the indictment dismissed because of prosecutorial misconduct due to withholding evidence. United States v. Nejad, 487 F. Supp. 3d 206, 207 (S.D.N.Y. 2020). The decision says nothing about an improper indictment or exoneration.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Intel Corp. v. Advanced Micro Devices, Inc.
542 U.S. 241 (Supreme Court, 2004)
Schlich v. Broad Inst., Inc. (In Re Schlich)
893 F.3d 40 (First Circuit, 2018)
XYZ Corp. v. United States
348 F.3d 16 (First Circuit, 2003)
Mees v. Buiter
793 F.3d 291 (Second Circuit, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
2021 DNH 079, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-pilatus-bank-plc-pilatus-bank-plc-v-lawrence-connell-nhd-2021.