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Summary On December 19, 2022, the SDNY further restricted the use of Section 1782 discovery by ruling that an ICSID tribunal constituted under the Italy-Panama BIT does not qualify as a “foreign or international tribunal” within the meaning of Section 1782. Background 28 U.S.C. § 1782 (“Section 1782”) provides that a U.S. district court may order the production of “testimony or statement or . . .
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