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Cogburn, Jr and US Magistrate Judge Susan C. Rodriguez. Motions referred to Susan C. Rodriguez: 1 Application Pursuant to 28 U.S.C. 1782 This is your only notice - you will not receive a separate document.(add)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/440416122/","id":440416122,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71591886/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/454971482/","id":454971482,"tags":[],"absolute_url":"/docket/71591886/1/united-states-v-wells-fargo-bank/","date_created":"2025-10-09T07:21:01.394633-07:00","date_modified":"2025-10-09T12:24:08.477545-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"1","attachment_number":null,"pacer_doc_id":"13505671478","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"MC-Application Pursuant to 28:1782","acms_document_guid":""}],"date_created":"2025-10-09T07:21:01.355324-07:00","date_modified":"2025-10-09T12:24:08.454010-07:00","date_filed":"2025-10-09","time_filed":"09:45:14","entry_number":1,"recap_sequence_number":"2025-10-09.001","pacer_sequence_number":3,"description":"Application Pursuant to 28 U.S.C. 1782, filed by United States. Responses due by 10/23/2025 (Powers, Janice) (Entered: 10/09/2025)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/440416118/","id":440416118,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71591886/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/454971479/","id":454971479,"tags":[],"absolute_url":"/docket/71591886/2/united-states-v-wells-fargo-bank/","date_created":"2025-10-09T07:21:00.978725-07:00","date_modified":"2025-10-11T04:49:17.847505-07:00","sha1":"676c2f2c951ebd3a6ae1063b3cd35d9baae7589b","page_count":10,"file_size":224930,"filepath_local":"recap/gov.uscourts.ncwd.121334/gov.uscourts.ncwd.121334.2.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.ncwd.121334/gov.uscourts.ncwd.121334.2.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"                        IN THE UNITED STATES DISTRICT COURT\n                   FOR THE WESTERN DISTRICT OF NORTH CAROLINA\n                                 CHARLOTTE DIVISION\n                                CASE NO. 3:25-MC-00130\n\nIN RE: REQUEST FOR JUDICIAL ASSISTANCE                                   )\nFROM THE NATIONAL CIVIL COURT OF FIRST                                   )\nINSTANCE, NO. 101 IN BUENOS AIRES,                                       )\nARGENTINA IN Matter of Martha Irene Cohan,                               )\nREF. NO. 1738/2024                                                       )\n\n                 MEMORANDUM OF LAW IN SUPPORT OF APPLICATION\n                     FOR ORDER PURSUANT TO 28 U.S.C. \u00a7 1782\n\n         Now comes the United States of America, by and through Assistant United States Attorney,\n\nJanice Powers, and hereby submits this Memorandum of Law in support of the Application for\n\nOrder,1 pursuant to 28 U.S.C. \u00a7 1782 and a Letter of Request from the National Civil Court of First\n\nInstance No. 101 in Buenos Aires, Argentina, in Matter of Martha Irene Cohan, Foreign Reference\n\nNo. 1738/2024 (as used herein and in papers filed herewith, the \u201cArgentine Court\u201d) for\n\ninternational judicial assistance to obtain certain bank account records from Wells Fargo Bank.\n\n                                               INTRODUCTION\n\n         The request for international judicial assistance comes from the National Civil Court of\n\nFirst Instance No. 101 in Buenos Aires, Argentina, which has issued a Letter of Request requesting\n\nevidence in the form of documentation from Wells Fargo Bank concerning joint or individual\n\n\n\n1\n  Gushlak v. Gushlak, 486 F. App\u2019x 215, 217 (2d Cir. 2012) (\u201cIt is neither uncommon nor improper for district courts\nto grant applications made pursuant to \u00a7 1782 ex parte. The respondent\u2019s due process rights are not violated because\nhe can later challenge any discovery request by moving to quash pursuant to Federal Rule of Civil Procedure\n45[(d)](3).\u201d). See also In re Letters Rogatory from Tokyo Dist., Tokyo, Japan, 539 F.2d 1216, 1219 (9th Cir. 1976)\n(\u201cLetters Rogatory are customarily received and appropriate action taken with respect thereto ex parte. The witnesses\ncan and have raised objections and exercised their due process rights by motions to quash the subpoenas.\u201d); In re\nLetter of Request from Supreme Ct. of Hong Kong, 138 F.R.D. 27, 32 n.6 (S.D.N.Y. 1991); In re Application of\nMasters for an Order Pursuant to 28 U.S.C. \u00a7 1782 to Conduct Discovery for Use in a Foreign Proceeding, 315 F.\nSupp. 3d 269, 272 (D.D.C. 2018); But see In re Anglin, No. 7:09cv5011, 2009 WL 4739481, at *1-2 (D. Neb. Dec. 4,\n2009). Note, even though these applications are generally filed ex parte, they do not need to be filed under seal. See,\ne.g. Order denying Motion to Seal U.S.\u2019s Application for Ex Parte Order Appointing Commissioner Pursuant to 28\nU.S.C. \u00a7 1782, In re Mutual Assistance of Local Court of Wetzlar, Germany, 1:17-mc-00078-SKO, 2018 WL 306678,\nat *3 (E.D. Cal. Jan. 5, 2018).\n\n\n\n    Case 3:25-mc-00130-MOC-SCR                      Document 2           Filed 10/09/25          Page 1 of 10\n\fbanking accounts, financial assets, deposits, credits, shares, securities, bonds or other assets of any\n\nkind at the time of her passing on November 29, 2018 and the current location of any such assets\n\nbefore or after her passing belonging to Martha Irene Cohan for use in a Civil Probate Matter of\n\nMartha Irene Cohan, Foreign Reference Number 1738/2024, DOJ Reference Number: 189-44-25-\n\n108. See Exhibits 1 and 2 to Powers Declaration.\n\n       The facts of this case, as stated in the Letter of Request, indicate that this is a civil\n\nproceeding in Probate in the Argentine Court and requests that Wells Fargo provide information\n\npertaining to banking, financial, and related accounts, to specifically include:\n\n       1.      Wells Fargo\u2019s confirmation of the banking, investment, or other financial\n               accounts or assets in the name of:\n\n               a.      Martha Irene Cohan also known as:\n\n                      i.       Martha Cohen\n                     ii.       Martha de Alianak\n                    iii.       Marta Iren Cohan de Alianak\n                    iv.        Marta I.C. de Alianak\n                     v.        Martha I.C. de Alianak\n\n               b.      Date of Birth:\n\n               c.      Residence: Buenos Aires, Argentina\n\n               d.      Nationality: Argentinian\n\n               e.      National Identity Document No.:\n\n               f.      Wells Fargo Account Number:                    , originally a Wachovia\n                       Bank account with account number. Also Account Number:\n                         , originally Wachovia Securities; and Prudential Financial account\n                       number                . These accounts are all now accounts with Wells\n                       Fargo Bank. Attached are prior statements and check pertaining to these\n                       accounts.\n\n       2.      A detailed description of the composition of investments, financial assets, and\n               accounts held by Mrs. Cohan, together with their updated values.\n\n       3.      The current status and location of the accounts.\n\n\n\n                                                2\n   Case 3:25-mc-00130-MOC-SCR                Document 2        Filed 10/09/25       Page 2 of 10\n\fThe Argentine Court\u2019s request was transmitted to the U.S. Department of Justice, Civil Division,\n\nOffice of Foreign Litigation, Office of International Judicial Assistance, Washington, D.C.\n\npursuant to the Hague Convention on the Taking of Evidence Abroad in Civil or Commercial\n\nMatters, Mar. 18, 1970, 23 U.S.T. 2555, 847 U.N.T.S. 12140 [hereinafter HCCH 1970 Evidence\n\nConvention].\n\n         The request was then transmitted to the U.S. Attorney\u2019s Office for the Western District of\n\nNorth Carolina for execution in accordance with 28 C.F.R. \u00a7 0.49(c). In order to execute these\n\nrequests for international judicial assistance, authority must be obtained from this Court. 28 U.S.C.\n\n\u00a7 1782.\n\n                                          ARGUMENT\n\nI.       THE HCCH 1970 EVIDENCE CONVENTION\n\n         The HCCH 1970 Evidence Convention affords each signatory nation the use of the judicial\n\nprocess of other signatory nations, where such assistance is needed in civil or commercial matters,\n\n\u201cto facilitate the transmission and execution of Letters of Request and to further the\n\naccommodation of the different methods which they use for this purpose.\u201d HCCH 1970 Evidence\n\nConvention pmbl. The HCCH 1970 Evidence Convention \u201cprescribes certain procedures by which\n\na judicial authority in one contracting state may request evidence located in another contracting\n\nstate.\u201d Soci\u00e9t\u00e9 Nationale Industrielle A\u00e9rospatiale v. U.S. Dist. Court for the S. Dist. of Iowa, 482\n\nU.S. 522, 524 (1987). The HCCH 1970 Evidence Convention is in force in both the United States\n\nand Argentina. Hague Conference on Private International Law, Status Table for the Convention\n\nof 18 March 1970 on the Taking of Evidence Abroad in Civil or Commercial Matters, available at\n\nhttps://www.hcch.net/en/instruments/conventions/status-table/?cid=82 (last visited September 26,\n\n2025).\n\n\n\n                                               3\n     Case 3:25-mc-00130-MOC-SCR             Document 2        Filed 10/09/25      Page 3 of 10\n\f        Article 10 of the HCCH 1970 Evidence Convention provides that:\n\n        In executing a Letter of Request the requested authority shall apply the appropriate\n        measures of compulsion in the instances and to the same extent as are provided by\n        its internal law for the execution of orders issued by the authorities of its own\n        country or of requests made by parties in internal proceedings.\n\n        HCCH 1970 Evidence Convention, art. 10. Furthermore, Article 9 of the HCCH 1970\n\nEvidence Convention provides, in pertinent part, that: \u201cthe judicial authority which executes a\n\nLetter of Request shall apply its own law as to the methods and procedures to be followed, and\n\nthat a \u2018Letter of Request shall be executed expeditiously.\u2019\u201d Id. at art. 9.\n\n        Under Article VI of the United States Constitution, treaties, such as the HCCH 1970\n\nEvidence Convention, are the law of the land, on an equal footing with acts of Congress, and are\n\nbinding on the courts. See Bell v. Clark, 437 F.2d 200, 203 (4th Cir. 1971). See also Gandara v.\n\nBennett, 528 F.3d 823, 830 (11th Cir. 2008) (stating that self-executing treaties are \u201cimmediately\n\nand directly binding on state and federal courts pursuant to the Supremacy Clause\u201d) (Rodgers, J.,\n\nconcurring) (quoting Medellin v. Texas, 552 U.S. 491, 510 (2008)); Bishop v. Reno, 210 F.3d 1295,\n\n1299 (11th Cir. 2000) (concluding that \u201can Act of Congress\u201d is on \u201cfull parity with a treaty\u201d)\n\n(quoting Reid v. Covert, 354 U.S. 1, 18 (2000)).\n\nII.     STATUTORY CONSIDERATIONS WEIGH IN FAVOR OF GRANTING THE\n        UNITED STATES\u2019 APPLICATION\n\n        The authority for this Court to assist foreign tribunals in obtaining documents is contained\n\nin 28 U.S.C. \u00a7 1782. This section states:\n\n               Assistance to foreign and international tribunals and to litigants\n               before such tribunals\n\n               (a)     The district court of the district in which a person resides or\n                       is found may order him to give his testimony or statement or\n                       to produce a document or other thing for use in a proceeding\n                       in a foreign or international tribunal, including criminal\n                       investigations conducted before formal accusation. The\n\n\n\n                                                4\n      Case 3:25-mc-00130-MOC-SCR             Document 2        Filed 10/09/25     Page 4 of 10\n\f                       order may be made pursuant to a letter rogatory issued, or\n                       request made, by a foreign or international tribunal or upon\n                       the application of any interested person and may direct that\n                       the testimony or statement be given, or the document or\n                       other thing be produced, before a person appointed by the\n                       court. By virtue of his appointment, the person appointed\n                       has power to administer any necessary oath and take the\n                       testimony or statement. The order may prescribe the practice\n                       and procedure, which may be in whole or part the practice\n                       and procedure of the foreign country or the international\n                       tribunal, for taking the testimony or statement or producing\n                       the document or other thing. To the extent that the order\n                       does not prescribe otherwise, the testimony or statement\n                       shall be taken, and the document or other thing produced, in\n                       accordance with the Federal Rules of Civil Procedure.\n\n28 U.S.C. \u00a7 1782(a). See also Societe Nationale Industrielle Aerospatiale v. U.S. Dist. Ct. for S.\n\nDist. of Iowa, 482 U.S. 522, 529 (1987) (providing a brief history of the HCCH 1970 Evidence\n\nConvention). Section 1782 \u201cis the product of congressional efforts, over the span of nearly 150\n\nyears, to provide federal-court assistance in gathering evidence for use in foreign tribunals.\u201d Intel\n\nCorp. v. Advanced Micro Devices, Inc., 542 U.S. 241, 247 (2004). By this law, Congress intended\n\nthat the United States set an example to other nations by making judicial assistance generously\n\navailable. See, e.g., In re Request for Assistance from Ministry of Legal Affairs of Trin. & Tobago,\n\n848 F.2d 1151, 1153-54 (11th Cir. 1988) (discussing several historical instances in which Congress\n\nhas broadened \u00a7 1782, each time increasing the statute\u2019s ability to provide international judicial\n\nassistance), abrogated on other grounds by Intel Corp., 542 U.S. 241.\n\n       District courts have repeatedly appointed Department of Justice Attorneys to act as\n\ncommissioners pursuant to this provision for the purpose of rendering judicial assistance to foreign\n\ncourts. See, e.g., In re Clerici, 481 F.3d 1324, 1327 (11th Cir. 2007) (affirming a district court\u2019s\n\nappointment of an Assistant United States Attorney to obtain sworn answers to questions posed in\n\nletters rogatory). See also In re Request for Judicial Assistance From the Nat'l Court of Original\n\n\n\n\n                                               5\n   Case 3:25-mc-00130-MOC-SCR               Document 2        Filed 10/09/25      Page 5 of 10\n\fJurisdiction No. 68 in Buenos Aires, Argentina, No. 3:19-MC-31-J-39MCR, 2019 WL 5528394\n\n(M.D. Fla. Oct. 25, 2019) (appointing Department of Justice Attorney commissioner to obtain\n\nevidence from Merrill Lynch).\n\n         This Court is authorized to provide assistance to the Argentine Court if the three\n\nrequirements set forth in \u00a7 1782 are met. Those requirements are: (1) the person or document for\n\nwhich discovery is sought resides or is found in the district; (2) the discovery is for use in a\n\nproceeding before a foreign or international tribunal; and (3) the application is made \u201cby a foreign\n\nor international tribunal\u201d or \u201cany interested person.\u201d In re Application Pursuant to 28 U.S.C. \u00a7\n\n1782 for an Order Permitting Bayer AG to Take Discovery, 146 F.3d 188, 193 (3d Cir. 1988);\n\nSchmitz v. Bernstein Liebhard & Lifshitz, LLP, 376 F.3d 79, 83 (2d Cir. 2004). See also S. Rep.\n\nNo. 88-1580 at 2 (1964), reprinted in 1964 U.S.C.C.A.N. 3782, 3783 (providing Congress\u2019s\n\ngeneral statement regarding purpose behind the statute); Intel, 542 U.S. at 248-49 (providing brief\n\nhistory of Section 1782 and federal court aid to foreign tribunals).\n\n         Here, each of these threshold statutory requirements is easily met. First, Wells Fargo\n\n\u201cresides or is found in\u201d the Western District of North Carolina because the company\u2019s subpoena\n\nprocessing center is located in Charlotte, North Carolina.2 Second, the Letter of Request explains\n\nthat the request is for evidence in the matter pending before the National Civil Court of First\n\nInstance No. 101 in Buenos Aires, Argentina, in Matter of Martha Irene Cohan, Foreign Reference\n\nNo. 1738/2024. See Exhibit 2 to Powers Declaration at 1-16. Third, the Letter of Request itself\n\nalso reflects that it \u201cis made by a foreign or international tribunal,\u201d the National Civil Court of\n\nFirst Instance No. 101 in Buenos Aires, Argentina. Id.\n\n\n\n2\n  When executing requests for financial records, the Office of International Judicial Assistance\u2019s policies and\nprocedures require that the request be executed in the district where the subpoena processing center is located for the\nparticular financial institution.\n\n\n                                                       6\n    Case 3:25-mc-00130-MOC-SCR                      Document 2           Filed 10/09/25          Page 6 of 10\n\fIII.     DISCRETIONARY CONSIDERATIONS WEIGH IN FAVOR OF GRANTING\n         THE UNITED STATES\u2019 APPLICATION\n\n         \u201c[A] district court is not required to grant a \u00a7 1782(a) discovery application simply because\n\nit has the authority to do so.\u201d See Intel, 542 U.S. at 264. Indeed, \u00a7 1782 \u201caffords the district courts\n\n\u2018wide discretion\u2019 in responding to requests for assistance in proceedings before foreign tribunals.\u201d\n\nAl Fayed v. United States, 210 F.3d 421, 424 (4th Cir. 2000) (quoting In re Esses, 101 F.3d 873,\n\n876 (2d. Cir. 1996)). The Supreme Court set forth certain discretionary factors for a district court\n\nto consider before granting a request for judicial assistance:\n\n         (1) whether the person from whom discovery is sought is a participant in the foreign\n         proceeding; (2) the nature of the foreign tribunal, the character of the foreign\n         proceedings, and the receptivity of the foreign entity to judicial assistance; (3)\n         whether the request conceals an attempt to circumvent foreign proof-gathering\n         restrictions or other policies of a foreign country or the United States; and (4)\n         whether the requested information is unduly intrusive or burdensome.\n\nIntel, 542 U.S. at 264-65. \u201cIn exercising its discretion under \u00a7 1782, the district court should be\n\nguided by the statute\u2019s \u2018twin aims of providing efficient means of assistance to participants in\n\ninternational litigation in our federal courts and encouraging foreign countries by example to\n\nprovide similar means of assistance to our courts.\u2019\u201d Al Fayed, 210 F.3d at 424 (quoting In re\n\nMalev Hungarian Airlines, 964 F.2d 97, 100 (2d Cir. 1992)). See also United States v. Morris (In\n\nre Letter of Request from Amtsgericht Ingolstadt, Fed. Republic of Ger.), 82 F.3d 590, 592 (4th\n\nCir. 1996) (\u201cPlainly, the . . . statute envision[s] considerable cooperation with foreign courts\u2019\n\nrequests for assistance and a general practice of reciprocity.\u201d).        Here again, each of these\n\ndiscretionary factors weigh in favor of assisting the Argentine Court.\n\n         With respect to the first factor, \u201calthough this factor was originally expressed as a\n\n\u2018participant\u2019 versus \u2018nonparticipant\u2019 analysis under the facts presented in Intel, the true question\n\nat hand is whether the requested discovery is available to the foreign tribunal without the assistance\n\n\n\n                                                 7\n       Case 3:25-mc-00130-MOC-SCR             Document 2         Filed 10/09/25     Page 7 of 10\n\fof this Court.\u201d In re Request for Judicial Assistance from the Dist. Court in Svitavy, Czech, 748\n\nF. Supp. 2d 522, 526 (E.D. Va. 2010) [hereinafter In re Svitavy]. See also Intel, 542 U.S. at 264\n\n(\u201c[N]onparticipants in the foreign proceeding may be outside the foreign tribunal\u2019s jurisdictional\n\nreach; hence, their evidence, available in the United States, may be unobtainable absent \u00a7 1782(a)\n\naid.\u201d). Wells Fargo is not a party to the proceedings and is not subject to the Argentine Court\u2019s\n\njurisdiction because it is located in Charlotte, North Carolina; thus, the first factor weighs in favor\n\nof granting the motion.\n\n       Second, there is nothing in the Letter of Request to suggest that this Court should decline\n\nto grant the Application based on the nature of the Argentine Court or the character of the\n\nproceedings. Additionally, this request was initiated by the National Civil Court of First Instance\n\nNo. 101 in Buenos Aires, Argentina and not by an independent party; therefore, the Argentine\n\nCourt is clearly receptive to the assistance of this Court and the second factor weighs in favor of\n\ngranting the motion. See In re Svitavy, 748 F. Supp. 2d at 527 (discussing a specific application\n\nof the second Intel factor).\n\n       With respect to the third factor, because the requester is the National Civil Court of First\n\nInstance No. 101 in Buenos Aires, Argentina, there is sufficient assurance that the request for\n\njudicial assistance is not an attempt to circumvent Argentine\u2019s discovery rules or to thwart policies\n\nof either the United States or Argentina. See id. at 529 (\u201c[T]he fact that the request was initiated\n\nby the Svitavy Court itself, rather than a private litigant, provides sufficient assurance that the\n\nrequest does not attempt to circumvent Czech discovery rules or Czech policy.\u201d). While the\n\nrecords and information sought by the Argentine Court are held by a United States financial\n\ninstitution, the Right to Financial Privacy Act (\u201cRFPA\u201d), 12 U.S.C. \u00a7 3401 et seq., does not apply\n\nto this request under \u00a7 1782. See Young v. U.S. Dept. of Justice, 882 F.2d 633, 638-39 (2d Cir.\n\n\n\n\n                                                8\n   Case 3:25-mc-00130-MOC-SCR                Document 2        Filed 10/09/25       Page 8 of 10\n\f1989) (finding RFPA did not apply to DOJ attorney who was acting in capacity as a commissioner\n\nunder \u00a7 1782); In re Letter of Request for Judicial Assistance from Tribunal Civil de Port-Au-\n\nPrince, 669 F. Supp. 403, 407 (S.D. Fla. 1987) (finding RFPA inapplicable to request pursuant to\n\n28 U.S.C. \u00a7 1782). Therefore, the third Intel factor weighs in favor of granting the Argentine\n\nCourt\u2019s request for judicial assistance.\n\n       And with respect to the fourth factor, the request seeks account information necessary to\n\nadjudicate a proceeding in the nature of division of marital property and other related issues and\n\nwould not be unduly intrusive or burdensome. See, e.g., In re Svitavy, 748 F. Supp. 2d at 529\n\n(holding that providing DNA by buccal swab is not unduly burdensome). See also In re Clerici,\n\n481 F.3d at 1335 (holding that it was witness\u2019s burden to move to limit discovery, absent which\n\nthe Court was not going to address scope of request). For this reason, the fourth factor also weighs\n\nin favor of granting the request.\n\n       In summary, consideration of the four discretionary factors set forth by the Supreme Court\n\nin Intel favors authorizing judicial assistance to the National Civil Court of First Instance No. 101\n\nin Buenos Aires, Argentina.\n\n                                           CONCLUSION\n\n       Attached to the Declaration of Assistant United States Attorney Janice Powers is the\n\nproposed subpoena that this office intends to serve (in substantially similar format) on Wells Fargo\n\nshould the Court grant the Application pursuant to 28 U.S.C. \u00a7 1782. Upon receipt, the records\n\nwill be sent to the Department of Justice, Civil Division, Office of International Judicial Assistance\n\nfor transmission to the National Civil Court of First Instance No. 101 in Buenos Aires, Argentina.\n\n       WHEREFORE, the United States respectfully requests that the Court issue an Order, in the\n\nform attached to the Application, appointing Assistant United States Attorney Janice Powers\n\n\n\n\n                                                9\n   Case 3:25-mc-00130-MOC-SCR                Document 2        Filed 10/09/25      Page 9 of 10\n\fCommissioner for the purpose of issuing a subpoena to execute the request for international\n\njudicial assistance.\n\n        Respectfully submitted this 9th day of October, 2025.\n\n                                             RUSS FERGUSON\n                                             UNITED STATES ATTORNEY\n\n                                             s/Janice Powers\n                                             JANICE POWERS\n                                             Assistant United States Attorney\n                                             North Carolina Bar No. 60504\n                                             227 West Trade Street, Suite 1650\n                                             Charlotte, North Carolina 28202\n                                             Telephone No. (704) 344-6222\n                                             Janice.Powers@usdoj.gov\n\n\n\n\n                                             10\n   Case 3:25-mc-00130-MOC-SCR             Document 2       Filed 10/09/25    Page 10 of 10\n\f","ocr_status":1,"date_upload":"2025-10-09T10:17:50.287615-07:00","document_number":"2","attachment_number":null,"pacer_doc_id":"13505671481","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Memorandum in Support of Motion","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/455006222/","id":455006222,"tags":[],"absolute_url":"/docket/71591886/2/1/united-states-v-wells-fargo-bank/","date_created":"2025-10-09T10:17:41.527064-07:00","date_modified":"2025-10-09T10:17:41.527087-07:00","sha1":"","page_count":34,"file_size":5903013,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"2","attachment_number":1,"pacer_doc_id":"13505671482","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit Powers Declaration","acms_document_guid":""}],"date_created":"2025-10-09T07:21:00.950846-07:00","date_modified":"2025-10-09T12:24:08.322444-07:00","date_filed":"2025-10-09","time_filed":"09:46:20","entry_number":2,"recap_sequence_number":"2025-10-09.001","pacer_sequence_number":6,"description":"MEMORANDUM in Support re 1 Application Pursuant to 28 U.S.C. 1782 by United States. 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