In the Matter of the Application of The Municipality of Mariana & Others for an Order Under 28 U.S.C. § 1782 To Take Discovery from Margaret Beck

CourtDistrict Court, D. Arizona
DecidedMay 7, 2024
Docket2:24-cv-01046
StatusUnknown

This text of In the Matter of the Application of The Municipality of Mariana & Others for an Order Under 28 U.S.C. § 1782 To Take Discovery from Margaret Beck (In the Matter of the Application of The Municipality of Mariana & Others for an Order Under 28 U.S.C. § 1782 To Take Discovery from Margaret Beck) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Matter of the Application of The Municipality of Mariana & Others for an Order Under 28 U.S.C. § 1782 To Take Discovery from Margaret Beck, (D. Ariz. 2024).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 In The Matter Of The Application Of The No. MC-23-00036-PHX-DJH Municipality Of Mariana & Others For An 10 Order Under 28 U.S.C. § 1782 To Take ORDER Discovery From Margaret Beck 11

12 13 14 In August 2023, Applicants filed an ex parte application under 28 U.S.C. § 1782 to 15 take certain discovery from Respondent Margaret Beck (“Ms. Beck”) (Doc. 1) 16 (the “Application”).1 Applicants intend to use this discovery in Município de Mariana and 17 Others v. BHP Group (UK) Ltd and BHP Group Limited [2019] EWHC (TCC) HT-2022- 18 000304 (Gr. Brit.) (the “English Litigation”), which is a lawsuit that Applicants filed in the 19 High Court of Justice in London against non-parties BHP Group (UK) and BHP Group 20 Limited (collectively “BHP”) (Doc. 1-2 at 1–2) regarding the collapse of the Fundão Dam 21 in Brazil. The Court granted the Application, finding that the threshold statutory 22 requirements and discretionary factors under Section 17822 supported foreign discovery 23 from Ms. Beck through her capacity as a former BHP executive (Doc. 3) 24 (the “September 2023 Order”). Ms. Beck has since filed a Motion to Quash Subpoenas 25 (Doc. 10).3 Also pending before the Court is a “Motion for Leave to Intervene and to

26 1 Ms. Beck is a resident of Tempe, Arizona.

27 2 Unless where otherwise noted, all Section references are to Title 28 of the United States Code. 28 3 The matter is fully briefed. Applicants filed a Response (Doc. 13) and Ms. Beck filed a 1 Confirm Participation in the Discovery Sought” (Doc. 16) (“Motion to Intervene”) filed by 2 BHP.4 3 The Court held a Telephonic Case Management Conference on the matters in 4 April 2024 and (1) ordered Applicants and Ms. Beck to meet and confer on the scope of 5 discovery sought by Applicants and file a joint notice summarizing their discussions; 6 (2) took Ms. Beck’s Motion to Quash under advisement; and (3) ordered Applicants and 7 BHP to meet and confer on the parameters of BHP’s limited intervention and file a joint 8 notice formalizing their agreement. (Doc. 26) (the “Telephonic Conference). Upon review 9 of the parties’ briefing and joint notices (Docs. 28; 29; 30), the Court now issues its ruling 10 on the pending motions. 11 I. Ms. Beck’s Motion to Quash Subpoenas (Doc. 10) 12 The September 2023 Order permitted Applicants to subpoena Ms. Beck under 13 Section 1782 to testify by deposition and produce certain documents for use in the English 14 Litigation. For the following reasons, the Court will deny Ms. Beck’s Motion to Quash. 15 A. Background: the English Litigation 16 The English Litigation arises out of the November 5, 2015, collapse of the 17 Fundão Dam, which is a dam near Belo Horizonte, Brazil, used to store iron ore tailings, a 18 toxic waste product of mining operations carried out by Samarco Mineração SA 19 (“Samarco”). (Doc. 1-2 at 2). The collapse “release[ed] approximately 50 million cubic 20 meters of iron ore wastewater generated by Samarco’s mining operations[,]” “destroyed 21 nearby villages, killed 19 people, and caused destruction along the entire length of the Rio 22 Doce basin.” (Id.) The BHP owns a fifty (50) percent interest in the joint venture that 23 operates Samaraco. (Id. at 4). 24 Applicants filed an “Amended Master Particulars of Claim” against BHP in the

25 Reply (Doc. 14). The parties requested oral argument on the Motion to Quash Subpoenas. The Court finds that the issues have been fully briefed and oral argument will not aid the 26 Court’s decision. Therefore, the Court will deny the requests for oral argument. See Fed. R. Civ. P. 78(b) (court may decide motions without oral hearings); LRCiv 7.2(f) (same). 27 4 The matter is fully briefed. Applicants filed a Response (Doc. 21) and BHP filed a Reply 28 (Doc. 27). The parties requested oral argument on the Motion to Intervene, but have since stipulated that the Motion should be granted. See infra Section III. 1 High Court of Justice in London (Doc. 1-4).5 Among other things, Applicants alleged that 2 BHP “continued to increase capacity of the Fundão Dam to keep up with increases in iron 3 ore production while ignoring physical cracks and repeated warnings that increasing the 4 tailings capacity posed risks to safety and created the possibility of collapse.” (Doc. 1-2 5 at 5–6). Applicants brought three causes of action under Brazilian civil law: 6 (1) “Applicants seek to hold [BHP] strictly liable as indirect polluters within the meaning 7 of Article 3 (IV) of the Brazilian Environmental Law”; (2) “Applicants claim fault-based 8 liability under Article 186 of the Brazilian Civil Code”; and (3) “Applicants seek to hold 9 [BHP] liable as ‘controlling shareholders’ as defined in Article 116 of the Brazilian 10 Corporate Law.” (Id. at 2). 11 Applicants represent that Ms. Beck served as the Vice President of Finance for the 12 BHP’s iron ore business from September 2013 to March 2016. (Id. at 5). Applicants further 13 state that from July 2014 to April 2016, Ms. Beck “was a member of the Samarco Board 14 [of Directors], acting as alternate director,” and “attended at least four Samarco Board 15 meetings that took place in advance of the collapse.” (Id.) Applicants intend to depose 16 Ms. Beck on the following topics: 17 1. Deponent’s understanding and knowledge of Samarco’s corporate 18 structure and governance; 19 2. Deponent’s understanding and knowledge of Samarco’s business relationship with BHP, including information on Samarco’s 20 interactions with BHP related to the Fundão Dam; 21 3. Information related to BHP’s and Samarco’s understanding or 22 awareness of the risks relating to the Fundão Dam, including 23 structural changes made to the Dam between the years September 2013-March 2016; 24 4. The decisions authorized or recommended by the Samarco Board in 25 relation to the Fundão Dam, including BHP’s oversight and 26 involvement over the same; 5. BHP’s policies, decisions, and internal discussions regarding its supervision, management, funding, control 27 28 5 BHP filed an “Amended Defence” (Doc. 1-5). 1 of, and profits generated from, Samarco; and 2 6. Deponent’s preparation for this deposition 3 (Doc. 1-6 at 5). Additionally, Applicants served on Ms. Beck the following requests for 4 productions (“RFPs”): 5 6 1. All Documents in Your possession concerning pay slips, W-2s, W-9s, 1099s, and other forms of compensation between and among Ms. 7 Beck and Samarco. 8 2. All Documents concerning employment contracts or agreements 9 between You and Samarco. 10 3. All Communications between or among You and any Samarco 11 employee, executive, Samarco Board member, or agent of Samarco concerning BHP’s relationship with Samarco, including but not 12 limited to, BHP’s supervision, management, and control over 13 Samarco. 14 4. All Communications between or among You and any Samarco employee, executive, Samarco Board member, or agent of Samarco 15 concerning Samarco’s operations involving the Fundão Dam. 16 5. All Communications between or among You and any Samarco 17 employee, executive, Samarco Board member, or agent of Samarco 18 concerning Your role and responsibilities in Samarco management, operations, or daily affairs. 19 20 (Id. at 12). 21 B. Legal Standard: the Intel Factors 22 Ms. Beck argues this Court should exercise its discretion to quash the subpoenas.6 23 (See generally Doc. 10). When considering an application for foreign discovery under 24 Section 1782, a court should weigh the following discretionary factors, commonly referred 25 6 Ms.

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In the Matter of the Application of The Municipality of Mariana & Others for an Order Under 28 U.S.C. § 1782 To Take Discovery from Margaret Beck, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-matter-of-the-application-of-the-municipality-of-mariana-others-azd-2024.