Question juridique clé
Whether the appellant had standing to challenge the partial closing order in mutual legal assistance proceedings.
Solution extraite
He lacked the personal and direct effect required by Art. 80h lit. b IRSG and Art. 21(3) IRSG, so he could not appeal.
Motifs extraits
The seized documents came from premises rented by his separated wife, not from premises owned or rented by him. Mere mention in the documents, family ties, alleged business involvement, or asserted access to the premises did not establish the specific proximity required by federal law.