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​Updates on the recent Russian-related § 1782 applications – U.S. courts weigh discovery requests tied to sanctions, shareholder disputes, and asset battles.

by | Sep 11, 2025 | 1782 Blog | 0 comments

Section 1782 of Title 28 of the U.S. Code allows parties to seek discovery in U.S. courts for use in foreign proceedings. In recent years, Russian individuals and entities—often subject to sanctions or engaged in high-stakes disputes abroad—have increasingly turned to § 1782 as a tool to obtain evidence from U.S. banks, funders, and counterparties. Follow the recent Russian-related § 1782 applications:

1. In re: Yulia Guryeva‑Motlokhov (S.D.N.Y., Case No. 1:25‑mc‑00098)

Yulia Guryeva-Motlokhov, daughter of sanctioned Russian billionaire Andrey, seeks discovery under § 1782 for the “Alfa Nero” yacht litigation, targeting U.S. financial institutions for wire transfer records related to Antiguan officials. The court quashed her subpoenas on June 4, 2025 finding the materials were not demonstrably “for use” in the foreign proceeding as required under § 1782. Notice of Appeal was filed on July 1, 2025.

2. In Re Andrey Grigoryevich Guriev (FL 1:25‑mc‑20896)

Andrey Guriev, the sanctioned Russian billionaire and former CEO of PhosAgro, filed a § 1782 application in the Southern District of Florida (Case No. 1:25‑mc‑20896)

Guriev aims to uncover the structure, communications, funding sources, and motivations behind litigation funding provided to Alexander Gorbachev (a former associate and challenger to Guriev’s stake at PhosAgro), whose claim was dismissed in the UK. He seeks depositions and documentary evidence from third-party funders to counter prior wrongful claims and support enforcement of his rights.
On July 11, 2025 the court granted the Application for Judicial Assistance Pursuant to 28 U.S.C. § 1782. with a Status Report due by 10/10/2025.

Related UK Trial: Gorbachev v. Guriev
Claimant: Alexander Gorbachev alleged ownership rights to roughly 24.75% of PhosAgro, worth billions.
Outcome: After a six-week trial in April–May 2024, the claim was dismissed. The English High Court judge ruled Gorbachev’s pleadings were inconsistent and unreliable.
Costs Awarded: Gorbachev was ordered to pay at least £12 million (~$15.2 million) in UK court costs, which he reportedly cannot satisfy.