The case of the day is In re Gorsoan Ltd. (SDNY 2020). Gorsoan, a Cyprus company, and Gazprombank, the Russian bank, sued dozens of defendants, including Janna Bullock, in Cyprus, alleging a $25 million fraud. The Cyprus court issued a worldwide asset freeze injunction and requiring the defendants, including Bullock, to disclose their assets. Bullock did not comply with the order. So in 2013, Gorsoan obtained an order under § 1782 for issuance of a subpoena to Bullock. Although the court granted the application and the Second Circuit affirmed, “Bullock did not produce much, if any, discovery.” The judge, on Gorsoan’s motion, ordered a second deposition under judicial supervision, but at that deposition, Bullock invoked her right against self-incrimination and refused to testify.
In 2018, Gorsoan brought a second § 1782 application seeking leave to serve subpoenas on Zoe Bullock Remmel and Eugenia Bullock, Janna Bullock’s daughters, Zoya Kuznetsova, her mother, and Stuart Sundlun. The court granted the application, and Gorsoan moved to compel. Janna Bullock then moved to intervene, and after leave was granted, she moved to vacate order allowing the discovery and to quash the subpoenas. In January 2020, the court granted the motion to compel and denied the motion to vacate and to quash. 435 F. Supp. 3d 589.