Application of Hulley Enterprises Ltd., and Veteran Petroleum Ltd., for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery for Use in a Foreign Proceeding - District Court, E.D. Pennsylvania - 2-18-MC-00176 - 21 September 2018
Petitioners Hulley Enterprises Ltd., Yukos Universal Ltd., and Veteran Petroleum Ltd. (collectively "Petitioners") make this application pursuant to 28 U.S.C. § 1782 for leave to serve a document and deposition subpoenas on Alexandra Rutstein ("Ms. Rutstein"), a former attorney in the Moscow Office of White & Case LLP ("White & Case"), who now resides in this District.
Ex. A (Shepard Decl.), Exs. 2 & 3. Petitioners' subpoenas seek evidence for use in connection with Veteran Petroleum Limited, Yukos Universal Limited, Hulley Enterprises Limited v. The Russian Federation, Case No. 200.197.079/01, an ongoing litigation currently pending in the Court of Appeal of The Hague (the "Dutch Appellate Proceeding").
Although Section 1782 applications are routinely considered and granted ex parte, Petitioners here are giving notice to Respondent (Ms. Rutstein), and to counsel for the Russian Federation. Petitioners respectfully request the Court set the following briefing schedule: 21 days from date of service for any opposition brief, and 7 days for Petitioners' reply.