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In Re: Bapa Holdings, Corp.

2025-11-24

Summary

Holding. NeWay Capital's motion to vacate the court's § 1782 discovery order and to quash the subpoena is denied.

BAPA Holdings sought discovery from NeWay Capital under 28 U.S.C. § 1782 for use in a foreign proceeding. The district court granted BAPA's application in May 2025, and NeWay subsequently moved to vacate that order and quash the subpoena. NeWay raised several challenges, including arguments that the court lacked personal jurisdiction, that BAPA failed to meet statutory and discretionary requirements, and that the ex parte application process violated due process. The court rejected each argument. Regarding jurisdiction, the court found NeWay "resides or is found" in the District of Columbia based on substantial evidence that the company holds itself out as D.C.-headquartered through its website, social media, annual reports, and SEC filings—sufficient to establish the "essentially at home" standard even though NeWay claimed to be a remote-work company. On the merits, the court concluded that BAPA adequately demonstrated the discovery was sought for use in a foreign proceeding through detailed descriptions and foreign counsel declarations, which courts routinely accept, and that NeWay failed to meaningfully challenge the court's earlier Intel factor analysis. The court also found no due process violation in the ex parte application process, noting that such applications are common in § 1782 cases and that NeWay received the opportunity to challenge validity through its motion to quash. The court noted that NeWay's subpoena-quashing arguments became moot after BAPA conceded improper service.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether the court had personal jurisdiction over NeWay under 28 U.S.C. § 1782
  • Whether BAPA satisfied statutory requirements and discretionary Intel factors for § 1782 discovery
  • Whether granting a § 1782 application ex parte without notice violates due process
  • Whether the subpoena was properly served and overbroad

Procedural posture

NeWay Capital moved to vacate the district court's May 2025 order granting BAPA Holdings' § 1782 application for discovery and to quash the subpoena issued pursuant to that order.

Authorities cited

Opinion

majority opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

IN RE APPLICATION OF BAPA

HOLDINGS, CORP., PURSUANT TO 28 Misc. Action No. 25-00026 (AHA)

U.S.C. § 1782 FOR JUDICIAL

ASSISTANCE IN OBTAINING EVIDENCE

FOR USE IN A FOREIGN PROCEEDING

Memorandum Opinion

On May 21, 2025, this court granted BAPA Holdings, Corp.’s application for discovery

from NeWay Capital LLC for use in a foreign proceeding under 28 U.S.C. § 1782. ECF No. 3.

NeWay now moves to vacate the court’s order and to quash the subpoena issued under the order.

The court denies NeWay’s motion.

I. Background

In February 2025, BAPA filed an ex parte application under 28 U.S.C. § 1782, to obtain

discovery from NeWay for use in a foreign proceeding. ECF No. 1. This court ordered BAPA to

show cause why the application should proceed ex parte. Minute Order (Apr. 2, 2025). The court

accepted BAPA’s showing, which included the expectation that any issues related to the subpoena

could be raised in a motion to quash, should NeWay choose to file one. See ECF No. 2 at 2. The

court granted BAPA’s application, concluding the discovery sought met the requirements of

§ 1782 and was appropriate under Intel Corp. v. Advanced Micro Devices, Inc., 542 U.S. 241

(2004). ECF No. 3. BAPA served a subpoena on NeWay, and NeWay now moves to vacate the

court’s order and quash the subpoena. ECF No. 5. 1

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NeWay’s pleadings do not comply with the formatting requirements in this court’s local rules. See Local Civ. R. 5.1(d). Failure to comply in the future may lead the court to strike the relevant pleading.

II. Discussion

NeWay argues, and BAPA does not dispute, that this court has authority to reconsider and

vacate its earlier order. See Pishevar v. Fusion GPS, No. 21-mc-105, 2025 WL 885115, at *8

(D.D.C. Mar. 21, 2025) (explaining that “courts should allow recipients of discovery authorized

under Section 1782 to challenge the initial order’s validity” (cleaned up) (quoting Banca Pueyo

SA v. Lone Star Fund IX (US), L.P., 55 F.4th 469, 471 (5th Cir. 2022)). NeWay argues the court

should do so here because (i) BAPA has not shown the court has personal jurisdiction over NeWay;

and (ii) BAPA has not shown the discovery sought satisfies § 1782 or the factors set forth in Intel,

542 U.S. 241. NeWay also argues the subpoena BAPA served should be quashed because of

improper service and overbreadth.

A. The Court Has Personal Jurisdiction Over NeWay

NeWay argues BAPA has not shown this court has personal jurisdiction over it, arguing

that it “has not designated Washington, D.C. for general jurisdiction purposes, nor is it registered

to do business in Washington, D.C.” ECF No. 5 at 2.

Section 1782 allows an action to be brought in “the district in which a person resides or is

found.” 28 U.S.C. § 1782(a). The parties agree this provision extends to the limits of due process.

ECF No. 5 at 4; ECF No. 7 at 8; see also In re del Valle Ruiz, 939 F.3d 520, 528 (2nd Cir. 2019)

(holding that “§ 1782’s ‘resides or is found’ language extends to the limits of personal jurisdiction

consistent with due process”). The Supreme Court has generally recognized two routes for

personal jurisdiction: general jurisdiction, where the defendant is “essentially at home” and the

court can hear “any and all claims” against them, and specific jurisdiction, which allows

jurisdiction over a party “less intimately connected with a State” if there is “an affiliation between

the forum and the underlying controversy.” Ford Motor Co. v. Mont. Eighth Jud. Dist. Ct., 592

U.S. 351, 358–59 (2021) (citations omitted). Consistent with these principles, courts generally

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agree that a business entity “is ‘found’ in a district where it is headquartered or incorporated.” In

re DiGiulian, No. 19-mc-132, 2020 WL 5253849, at *3 (D.D.C. Sept. 3, 2020) (quoting In re

Masters, 315 F. Supp. 3d 269, 274 (D.D.C. 2018)).

The court concludes that the record before it shows NeWay “resides or is found,” and is

fairly considered to be “at home,” in D.C. BAPA has introduced evidence that NeWay consistently

holds itself out as a business based in D.C. The company’s website lists only a D.C. address and

D.C. phone number. ECF No. 7-2 ¶ 4. And social media profiles for the company and its CEO and

chairman list D.C. as the company’s headquarters. ECF No. 7-2 ¶¶ 6–7. See Adler v. Loyd, 496

F.Supp.3d 269, 278 (D.D.C. 2020) (relying on office address provided on defendant’s website in

finding personal jurisdiction). So too do the company’s official reports and filings. NeWay’s

annual reports for the past eight years and SEC filings signed by NeWay officers identify a D.C.

address as its principal place of business. ECF No. 7-2 ¶¶ 14–21.

NeWay responds that it is a remote-work company and its physical address in D.C. is used

for mail forwarding. NeWay asks the court to find that it “resides or is found” in Mississippi, where

its chief of staff and one board member apparently live. ECF No. 5-1 ¶ 3. However, this fails to

overcome BAPA’s far more substantial showing that NeWay holds itself out as an organization

headquartered in D.C.

B. The Discovery Sought Satisfies § 1782 and Intel

NeWay also argues that the court should vacate its earlier opinion because BAPA has not

satisfied applicable legal standards for the discovery sought. ECF No. 5 at 3–4. The court does not

find its arguments persuasive.

NeWay first argues that BAPA has not shown it seeks the relevant discovery “for use in a

proceeding in a foreign or international tribunal.” 28 U.S.C. § 1782(a). According to NeWay, the

“best evidence” of this would have been a copy of the underlying complaint or other pleading that

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initiated the foreign action. ECF No. 5 at 3. But whether it used the best evidence or not, NeWay

supported its application with a detailed description, as well as a declaration by foreign counsel,

describing the foreign legal proceeding and relevance of the discovery to it. Courts routinely rely

on such declarations. See, e.g., In re Kuwait Ports Auth., No. 22-mc-00064, 2024 WL 4183210, at

*5–6 (D.D.C. Aug. 6, 2024), report and recommendation adopted, No. 22-mc-00064, 2025 WL

1529798 (D.D.C. May 29, 2025); In re Pishevar, No. 21-mc-105, 2023 WL 2072454, at *2–3

(D.D.C. Feb. 17, 2023). Indeed, as BAPA observes, § 1782 is not limited to pending judicial

proceedings, for which a complaint has been filed, but includes those “within reasonable

contemplation.” Intel, 542 U.S. at 259. NeWay does not respond to these arguments.

NeWay second argues that the court should decline BAPA’s request for discovery under

the Intel factors. In doing so, however, NeWay does not identify any error in the court’s earlier

analysis of those factors. See ECF No. 3 at 2. NeWay instead offers only conclusory assertions

that each factor favors it or that the factors cannot be assessed without a copy of the foreign

pleading, making no effort to analyze the factors or respond to BAPA’s arguments and declaration

addressing the factors. See ECF No. 5 at 6.

C. BAPA’s Ex Parte Application Did Not Violate Due Process

NeWay argues that BAPA violated its due process rights by filing an ex parte application

with this court, rather than providing it with notice. ECF No. 5 at 6; ECF No. 8 at 2. In support,

NeWay cites caselaw recognizing the importance of providing the target of a § 1782 discovery

order with the opportunity to challenge its validity. ECF No. 8 at 2 (quoting Banca Pueyo, 55 F.4th

at 471). NeWay’s argument is unsound. As courts have recognized, “it is neither uncommon nor

improper for district courts to grant applications made pursuant to § 1782 ex parte.” Gushlak v.

Gushlak, 486 Fed. App’x 215, 217 (2d Cir. 2012). And, “as a general matter, ex parte review is

justified by the fact that the parties from whom discovery is sought will be given adequate notice

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of any discovery taken pursuant to the request and will then have the opportunity to move to quash

the discovery or to participate in it.” In re Masters, 315 F. Supp. 3d at 272 (cleaned up). To be

sure, district courts often consider the propriety of resolving a § 1782 application ex parte,

followed by a possible motion to quash—as here—or requiring notice in the first instance. This

court required BAPA to show cause on that very question. Minute Order (Apr. 2, 2025); compare,

e.g., In re Masters, 315 F. Supp. 3d at 273 (finding “that ex parte review is nonetheless appropriate

because the Application does not appear to present complex issues that require the participation of

Bank of America or Citibank to resolve”), with Order at 2, In re Qatar Nat’l Bank, No. 24-mc00035 (D.D.C. Mar. 19, 2024), ECF No. 3 (recognizing that “[p]ermitting the party against whom

discovery is sought to weigh in before the court rules on the application both ‘streamlines the

proceedings by accelerating identification of grounds for objection’ and aids the court in assessing

Section 1782’s statutory and discretionary factors” (cleaned up)). But NeWay cites no authority

for the proposition that due process is violated when the target of a discovery order is given the

opportunity to challenge the order through a motion to quash, as it has done here.

D. NeWay’s Motion To Quash The Subpoena Is Moot

In addition to moving to vacate the court’s order, NeWay moved to quash the subpoena

BAPA served on it, arguing that the subpoena was improperly served and overbroad. ECF No. 5

at 4–5. BAPA has since conceded that its subpoena was improperly served and the parties agree

this renders moot NeWay’s challenges to the subpoena. ECF No. 7 at 17; ECF No. 8 at 2. 2

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As BAPA observes, NeWay’s motion to quash on the basis of overbreadth is “precisely” the type of objection “that parties are required to attempt to address through a conference between each other.” ECF No. 7 at 15. Upon service of a subpoena, the court expects the parties will engage in such efforts before bringing any issue about the scope of the subpoena before the court.

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III. Conclusion

For these reasons, NeWay’s motions to vacate and quash are denied.

AMIR H. ALI

United States District Judge

Date: November 24, 2025

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