Summary

MEMORANDUM OF LAW IN SUPPORT OF PAO TATNEFT'S MOTION TO COMPEL COMPLIANCE WITH POST-JUDGMENT SUBPOENA

Petitioner PAO Tatneft ("Tatneft") respectfully submits this memorandum of law, together with the declaration of Channing Turner, Esq., dated February 18, 2026, with exhibits, in support of its motion under Federal Rules of Civil Procedure 45(d)(2)(B)(i) and 69(a)(2) for an order compelling Quinn Emanuel Urquhart & Sullivan, LLP ("Quinn Emanuel") to comply with a post-judgment subpoena duces tecum, dated August 28, 2025 (the "Subpoena").

PRELIMINARY STATEMENT

Tatneft seeks to enforce a post-judgment subpoena to judgment-debtor Ukraine's counsel, Quinn Emanuel, which may have information relevant to identifying property of Ukraine potentially subject to execution. The firm has previously represented Ukraine in litigation and currently represents Ukraine's 100% state-owned bank, the Joint Stock Company State Savings Bank of Ukraine ("Oschadbank") as the plaintiff in an action pending in the United States District Court for the District of Columbia. The Subpoena avoids privileged information and targets only information that could reveal the location of the judgment debtor's assets. None of the objections advanced by Quinn Emanuel justifies or excuses the firm's non-compliance.

The Court should therefore direct Quinn Emanuel to produce all responsive documents.

The Subpoena seeks information that lies within the heartland of judgment enforcement discovery, material that is not subject to different rules for a sovereign judgment debtor. It contains just eight requests. Request Nos. 1 through 5 seek information concerning Oschadbank, which as a 100% state-owned bank likely handles Ukrainian assets and/or accounts. Request Nos. 6 through 8 request information concerning any accounts from which Ukraine has paid Quinn Emanuel and any property Quinn Emanuel may hold on Ukraine's behalf--information that judgment creditors like Tatneft are unequivocally entitled to receive.

Rule 69(a)(2) allows a judgment creditor to obtain discovery in aid of execution from "any person," including the debtor's law firm, and authorizes "broad inquiry to discover hidden or concealed assets." See Parts I.A. and I.D, infra. To the extent a debtor's current or prior counsel has information concerning the debtor's assets, the case law correctly rejects the notion that a debtor may shelter non-privileged information concerning its assets in possession of its lawyer.

To date, Quinn Emanuel has refused to comply with the Subpoena in any way, primarily because Quinn Emanuel asserts that other proceedings in this District concerning separate subpoenas excuse its compliance and should be resolved to Quinn Emanuel's unilateral satisfaction first. In particular, Quinn Emanuel incorrectly asserts that a "moratorium on discovery" is in place while ignoring Magistrate Judge Netburn's order dated May 2, 2025, that lifted the then-stay of post-judgment discovery--before Tatneft issued the Subpoena to Quinn Emanuel.

Quinn Emanuel's position has no merit for several reasons. First, Quinn Emanuel has cited no authority that excuses compliance with the Subpoena simply because the firm believes other proceedings should be resolved first. Tatneft's January 2021 judgment against Ukraine has remained unpaid for more than five years, and Ukraine has transparently adopted a strategy of obstruction-by-litigation. Quinn Emanuel may not add to the obstruction with unjustified objections to basic asset discovery.

Second, the information Tatneft seeks from Quinn Emanuel--such as the name of correspondent banks used by Oschadbank and identification of financial accounts and assets of Ukraine--is materially different from the information that Tatneft seeks in the bank subpoena cases in which Ukraine's motion to quash is pending. In the bank cases, Tatneft seeks, among other things, information concerning transactions occurring within Ukraine's accounts, which Ukraine has claimed, based on vague generalities, may implicate its national security if such information is produced to Tatneft. But concerns over transaction-level information are not present here. The Subpoena to Quinn Emanuel requests only "documents sufficient to identify"

sources of payment and accounts. National security arguments provide no basis for withholding mere account numbers, and Tatneft has already offered to enter into a reasonable confidentiality agreement. As shown below, Quinn Emanuel's other objections also fail to justify its noncompliance.

Accordingly, Tatneft respectfully asks this Court to compel Quinn Emanuel to fully comply to the Subpoena within 20 days of entry of the Court's order.

FACTUAL AND PROCEDURAL BACKGROUND

A. The Arbitration Award, $172.9 Million Judgment Against Ukraine, And Affirmance Of The Judgment On Appeal

Tatneft commenced arbitration against Ukraine on December 11, 2007, under the United Nations Commission on International Trade Law Arbitration Rules, seeking relief for breaches by Ukraine of an international, bilateral investment treaty...

Footnotes omitted