In Re Argentina Application of Diego Glozman for Judicial Assistance Pursuant to o 28 U.S.C. § 1782

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 25-MC-24525-MOORE/Elfenbein
In re
DIEGO GLOZMAN,
Applicant,
Pursuant to 28 U.S.C. § 1782 for
Judicial Assistance in Obtaining
Evidence for Use in a Foreign Proceeding.
/
ORDER ON DIEGO GLOZMAN’S EX PARTE APPLICATION
FOR JUDICIAL ASSISTANCE PURSUANT TO 28 U.S.C. § 1782
THIS CAUSE is before the Court on Applicant Diego Glozman’s Ex Parte Application
for Judicial Assistance Pursuant to 28 U.S.C. § 1782 (the “Application”), ECF No. [1]. The
Honorable K. Michael Moore referred this matter to me “to take all necessary and proper action
as required by law with respect to the” Application. See ECF No. [3]. For the reasons explained
below, the Application, ECF No. [1], is GRANTED.
I. 	BACKGROUND
In the Application, Applicant asks the Court to grant him “leave to conduct discovery
pursuant to the Federal Rules of Civil Procedure,” including serving subpoenas on and taking the
depositions of JPMorgan Chase Bank, N.A.; Morgan Stanley Smith Barney LLC; and UBS
Financial Services Inc. (the “Discovery Targets”). See ECF No. [1] at 1, 12. Applicant notes that
he intends to use the discovery “in a marital property distribution proceeding” he filed in Argentina
against “his ex-wife Natalia Olga Meta” (the “Argentine Proceeding”). See ECF No. [1] at 1; ECF
No. [1-1] at 5. 	Specifically, Applicant seeks “information and documents” from “February 21,
2022 to the present,” including “account statements, wire transfer records, records reflecting the
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delivery 	of 	securities, 	account 	opening 	documents, 	signature 	cards, 	correspondence, 	and
documents evidencing beneficial ownership and asset transfers.”1 See ECF No. [1] at 3.
Applicant explains that “after some marital discord” but “before filing for divorce,” his ex-
wife “initiated a systematic scheme to conceal and divert marital property,” which involved
creating “offshore corporate structures and trusts in opaque jurisdictions” and transferring or
dissipating cash and other assets. See ECF No. [1] at 2. Because his ex-wife “refused to provide
accounting or documentation regarding the location, disposition, or management of the transferred
assets,” Applicant “initiated the Argentine Proceeding and sought provisional remedies in
Argentina to preserve marital assets.”2 See ECF No. [1] at 2. Applicant notes the “Argentine court
has already granted a number of” those provisional remedies and that the “discovery sought in this
Application is narrowly tailored to obtain records from U.S. financial institutions where accounts
directly or indirectly controlled by” his ex-wife “are located.” See ECF No. [1] at 3. He explains
the discovery will enable him “to fully trace and recover” any diverted “marital assets” so that the
Argentine court can enforce his “rights in the division of marital property.” See ECF No. [1] at 7–
8.
In the Application, Appellant argues that he meets all four statutory factors for relief under
§ 1782 because he “is a party in the Argentine Proceeding,” he “seeks documentary and testimonial
evidence from the Discovery Targets,” he intends to use the “documents and testimony from the
Discovery Targets to support the Argentine Proceeding,” and the Discovery Targets are “financial
institutions that conduct business and have offices in this District” (in particular, principal offices
1 Applicant notes he has tried to “limit the requests to significant dollar amounts above” $10,000 where
possible. See ECF No. [1] at 3; ECF No. [1-1] at 4.
2 The Argentine Proceeding is a “civil action filed in the National Civil Court No. 8, Buenos Aires,
Argentina, Case No. 54327/2025.” See ECF No. [1] at 2.
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in Miami). 	See ECF No. [1] at 5–9. 	Applicant also argues that the four discretionary factors
articulated by the Supreme Court in Intel Corp., v. Advanced Mico Devices, Inc., 542 U.S. 241
(2004), “weigh in favor of granting” the Application. See ECF No. [1] at 9–12. Specifically, he
argues that none of the Discovery Targets is or will be a party to the Argentine Proceeding, the
Argentine court both welcomes and is actively seeking the evidence he seeks through the
Application, the Application does not circumvent any Argentine restrictions against U.S. judicial
assistance because “there is no evidence of any Argentine law, rule, or legal basis that prohibits or
limits” the Application, and the discovery sought is not unduly burdensome or intrusive because
it is “the type of information” financial institutions like the Discovery Targets “regularly use and
maintain and should have readily available.” See ECF No. [1] at 9–12. He supports those
arguments with the declaration of his Argentine counsel, who avers that “Argentine procedural
laws accept the judicial assistance of foreign courts,” Argentine courts are “receptive to evidence
obtained abroad,” and Argentine courts do not have jurisdiction over the Discovery Targets to
order them to produce the requested evidence in the Argentine Proceeding. See ECF No. [1-1] at
6. The Motion is ripe for review.
II. 	LEGAL STANDARD
“Section 1782 is the product of congressional efforts, over the span of nearly 150 years, to
provide federal-court assistance in gathering evidence for use in foreign tribunals.” Intel Corp.,
542 U.S. at 247. The “history of Section 1782 reveals Congress’ wish to strengthen the power of
district courts to respond to requests for international assistance.” Application of Consorcio
Ecuatoriano de Telecomunicaciones S.A. v. JAS Forwarding (USA), Inc., 747 F.3d 1262, 1269
(11th Cir. 2014) (emphasis and quotation marks omitted).
“A district court has the authority to grant an application for judicial assistance if the
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following statutory requirements in § 1782(a) are met: (1) the request must be made ‘by a foreign
or international tribunal,’ or by ‘any interested person’; (2) the request must seek evidence, whether
it be the ‘testimony or statement’ of a person or the production of ‘a document or other thing’; (3)
the evidence must be ‘for use in a proceeding in a foreign or international tribunal’; and (4) the
person from whom discovery is sought must reside or be found in the district of the district court
ruling on the application for assistance.” In re Clerici, 481 F.3d 1324, 1331–32 (11th Cir. 2007)
(footnote omitted) (quoting § 1782(a)). Evidence is for use in a foreign proceeding if an applicant
“has the practical ability to inject” it into the proceeding and it can “be employed with some
advantage or serve some use in the proceeding.” 	See In re Application of Salem, No. 23-CV-
23186, 2024 WL 4464288, at *10 (S.D. Fla. Aug. 28, 2024) (quotation marks omitted), R.&R.
adopted sub nom. In re Salem, No. 23-CV-23186-KMM, 2024 WL 4314771 (S.D. Fla. Sept. 27,
2024); In re Pons, 614 F. Supp. 3d 1134, 1144 (S.D. Fla.), aff’d sub nom. Pons v. AMKE Registered
Agents, LLC, 835 F. App’x 465 (11th Cir. 2020). “If these requirements are met, then § 1782
‘authorizes, but does not require, a federal district court to provide assistance.’” In re Clerici, 481
F.3d at 1332 (quoting Intel, 542 U.S. at 255); see also United Kingdom v. United States, 238 F.3d
1312, 1319 (11th Cir. 2001) (“[A] district court’s compliance with a § 1782 request is not
mandatory.”).
“Once the prima facie [statutory] requirements are satisfied, the Supreme Court in Intel
noted these factors to be considered in exercising the discretion granted under § 1782(a): (1)
whether ‘the person from whom discovery is sought is a participant in the foreign proceeding,’
because ‘the need for § 1782(a) aid generally is not as apparent as it ordinarily is when evidence
is sought from a nonparticipant’; (2) ‘the nature of the foreign tribunal, the character of the
proceedings underway abroad, and the receptivity of the foreign government or the court or agency
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abroad to U.S. federal-court judicial assistance’; (3) ‘whether the § 1782(a) request conceals an
attempt to circumvent foreign proof-gathering restrictions or other policies of a foreign country or
the United States’; and (4) whether the request is otherwise ‘unduly intrusive or burdensome.’” In
re Clerici, 481 F.3d at 1334 (quoting Intel, 542 U.S. at 264–65). None of these factors is required
or automatically dispositive — they simply “bear consideration in ruling on a § 1782(a) request.”
See Intel, 542 U.S. at 264. 	In fact, even if a court concludes an application contains “unduly
intrusive or burdensome requests,” it may still exercise its discretion to grant the application
because those specific requests “may be rejected or trimmed.” Id. at 265.
Finally, though the Supreme Court has not specifically listed it as a factor in the analysis,
sometimes courts look at how granting or denying a § 1782 application would impact international
comity concerns. That’s because “the animating purpose of § 1782 is comity: Permitting federal
courts to assist foreign and international governmental bodies promotes respect for foreign
governments and encourages reciprocal assistance.” ZF Auto. US, Inc. v. Luxshare, Ltd., 596 U.S.
619, 632 (2022); see also In re Pimenta, 942 F. Supp. 2d 1282, 1289 (S.D. Fla. 2013) (noting “the
twin aims of the statute: providing an efficient means of assistance to participants in international
litigation and encouraging foreign countries to provide reciprocal assistance to our courts”).
III. 	DISCUSSION
A. Applicant Has Met the Four Requirements of § 1782
As noted above, the four factors set out in the statute govern the first step in the § 1782
analysis. See In re Clerici, 481 F.3d at 1331–32. Here, Applicant has met each of them.
First, an “interested person” is making Applicant’s request. See § 1782(a); In re Clerici,
481 F.3d at 1331. Applicant is a litigant in the Argentine proceeding, which he initiated. See ECF
No. [1] at 2, 6. 	That makes Applicant a party to the relevant foreign proceeding, and as the
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Supreme Court has noted, “litigants are included among, and may be the most common example
of, the ‘interested persons’ who may invoke § 1782.” See Intel, 542 U.S. at 256 (alteration
adopted).
Second, Applicant’s request “seek[s] evidence,” including the “‘testimony or statement’ of
a person” and the production of “‘a document or other thing.’” See In re Clerici, 481 F.3d at 1331–
32 (quoting § 1782(a)). Indeed, Applicant’s request “seeks documentary and testimonial evidence
from the Discovery Targets by serving a subpoena upon each entity in substantially similar form
as the subpoenas attached” to the Application. See ECF No. [1] at 6.
Third, the evidence Applicant seeks is “for use in a proceeding in a foreign or international
tribunal.” See § 1782(a); In re Clerici, 481 F.3d at 1332. 	As explained in the Application, the
discovery sought is for use in the Argentine Proceeding. See ECF No. [1] at 7. The Argentine
Proceeding, which “is pending before a conventional civil court,” ECF No. [1] at 7, is certainly a
proceeding in a foreign tribunal, see Intel, 542 U.S. at 249 (explaining that Congress’ use of
“tribunal” is expansive and “not confined to proceedings before conventional courts, but extends
also to administrative and quasi-judicial proceedings.”). And the discovery requested is for use in
the Argentine Proceeding because Applicant has the practical ability under Argentine law to inject
any discovered information related to marital assets into that proceeding to protect those assets by
identifying what marital property was diverted, see ECF No. [1] at 7, so the information will give
Applicant some advantage or serve some use in the proceeding, see In re Application of Salem,
2024 WL 4464288, at *10; In re Pons, 614 F. Supp. 3d at 1144.
Finally, the entities from which Applicant seeks the evidence reside or are found in this
District. See § 1782(a); In re Clerici, 481 F.3d at 1332. As the Application notes, the Discovery
Targets “conduct business and have offices in this District,” specifically principal offices in Miami.
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See ECF No. [1] at 9. 	And when a company “has an office and does business in Miami,” it is
found in the Southern District of Florida for purposes of § 1782. See Consorcio Ecuatoriano, 747
F.3d at 1269.
For those reasons, the Court finds that Applicant has satisfied the four statutory factors
under § 1782.
B. The Intel Factors Weigh in Favor of Granting the Application
Once the statutory requirements are satisfied, the discretionary factors the Supreme Court
set out in Intel govern the second step in the § 1782 analysis. See 542 U.S. at 264–65; In re Clerici,
481 F.3d at 1334. Here, each of the four Intel factors weighs in favor of granting the Application.
First, the entities from which Applicant seeks the discovery are not participants in the
foreign proceeding. As the Supreme Court has explained, “when the person from whom discovery
is sought is a participant in the foreign proceeding,” the “need for § 1782(a) aid generally is not as
apparent as it ordinarily is when evidence is sought from a nonparticipant in the matter arising
abroad” because a “foreign tribunal has jurisdiction over those appearing before it, and can itself
order them to produce evidence.” 	Intel, 542 U.S. at 264. 	“In contrast, nonparticipants in the
foreign proceeding may be outside the foreign tribunal’s jurisdictional reach; hence, their
evidence, available in the United States, may be unobtainable absent § 1782(a) aid.” 	Id. 	The
Argentine Proceeding involves Applicant and his ex-wife’s “divorce and division of marital
property,” see ECF No. [1] at 10, which is a personal matter unlikely to involve financial
institutions as parties. For that reason, and because the Argentine court cannot order the Discovery
Targets to produce the requested evidence, see ECF No. [1] at 10, the first Intel factor weighs in
favor of granting Applicant § 1782(a) aid.
Second, the “nature of the foreign tribunal, the character of the proceedings underway
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abroad, and the receptivity of the foreign government or the court or agency abroad to U.S. federal-
court judicial assistance” all suggest that the Application should be granted. See Intel, 542 U.S. at
264; In re Clerici, 481 F.3d at 1334. The Argentine Proceeding is a civil matter pending before a
conventional court, and Argentine procedural laws are receptive to evidence obtained abroad. See
ECF No. [1] at 10. In fact, the court presiding over the Argentine Proceeding “is actively seeking”
evidence like what the Application requests, including by issuing an August 2025 order “for letters
rogatory” requiring the production of other similar information from other financial institutions.
See ECF No. [1] at 10; ECF No. [1-1] at 20–23, 30. 	Because the Argentine court would be
receptive to this Court’s assistance, the second Intel factor weighs in favor of granting the
Application.
Third, the Application does not “conceal[] an attempt to circumvent foreign proof-
gathering restrictions or other policies of a foreign country or the United States.” See Intel, 542
U.S. at 265; In re Clerici, 481 F.3d at 1334. As noted above, there is no evidence of any Argentine
law or rule prohibiting or limiting Applicant’s ability to obtain information through a § 1782
application. See ECF No. [1] at 10. 	Indeed, Applicant’s Argentine counsel explained that
Argentine procedural laws accept the judicial assistance of foreign courts and Argentine courts are
receptive to evidence obtained abroad. See ECF No. [1-1] at 6. Finally, Applicant cannot procure
evidence from the Discovery Targets using Argentine laws or court procedures because the
Argentine court does not have jurisdiction over them. 	See ECF No. [1-1] at 6. 	Because any
evidence gathered through a § 1782(a) proceeding will not violate Argentine law or proof-
gathering restrictions, the third Intel factor weighs in favor of granting the Application.
Finally, Applicant’s request is not unduly intrusive or burdensome. See Intel, 542 U.S. at
265; In re Clerici, 481 F.3d at 1334. 	The Application seeks information from specifically
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identified accounts at three financial institutions during a limited timeframe (February 2022 to the
present). 	See ECF No. [1] at 3, 12. 	Those accounts are connected to Applicant’s ex-wife,
“companies and trusts associated with her, and the marital property at issue in the Argentine
Proceeding.” See ECF No. [1] at 11. The evidence sought — including account statements, wire
transfer records, and beneficial ownership documents — is the type of information that these
financial institutions regularly maintain in the ordinary course of business. See ECF No. [1] at 11.
And Applicant has limited the requests to significant dollar amounts above $10,000 wherever
possible. See ECF No. [1] at 3; ECF No. [1-1] at 4. As a result, the Court finds that the § 1782(a)
requests are not unduly intrusive or burdensome, so the fourth Intel factor weighs in favor of
granting the Application.
For those reasons, the Court finds that all four Intel factors weigh in favor of granting the
Application for § 1782 aid.
C. Granting the Application Would Further the Policy Underlying § 1782
As a final consideration, the Court evaluates whether granting the application would further
the policy underlying § 1782, which is to encourage international comity. See ZF Auto., 596 U.S.
at 632; In re Pimenta, 942 F. Supp. 2d at 1289. Allowing Applicant to marshal the power of our
courts to assist him in gathering evidence to use in the Argentine Proceeding aligns with
“Congress’ wish to strengthen the power of district courts to respond to requests for international
assistance.” 	See Consorcio Ecuatoriano, 747 F.3d at 1269 (emphasis and quotation marks
omitted). And it would certainly “encourag[e] foreign countries to provide reciprocal assistance
to our courts.” 	See In re Pimenta, 942 F. Supp. 2d at 1289. 	As a result, the Court finds that
granting the Application would further the international comity concerns that underlie § 1782.
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IV. 	CONCLUSION
Because Applicant has satisfied the four statutory factors under § 1782, all four Intel factors
weigh in favor of granting the Application, and granting the application would further the
international comity policy underlying § 1782, it is ORDERED and ADJUDGED as follows:
1. 	The Application, ECF No. [1], is GRANTED;
2. 	Applicant is authorized to issue subpoenas for documents and testimony in the form of the
subpoenas attached to the Application as Exhibit C, see ECF No. [1-3];
3. 	Discovery shall be conducted in accordance with the Federal Rules of Civil Procedure;
4. 	The Court reserves jurisdiction to enter further orders that are necessary and proper to
enforce this Order; and
5. 	Applicant shall file a status report on or before May 3, 2026, indicating the status of the
discovery identified in the Application and whether this matter may be closed.
DONE AND ORDERED in Chambers in Miami, Florida on February 3, 2026.
______________________________________
MARTY FULGUEIRA ELFENBEIN
UNITED STATES MAGISTRATE JUDGE
cc: All counsel of record
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