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In re: Subpoenas Served on Bank of America, N.A., Barclays Bank PLC, Bank of New York Mellon, Citibank, N.A., Commerzbank AG, Deutsche Bank Trust Company Americas, HSBC Bank USA, N.A., JP Morgan Chase, N.A., PNC Bank, N.A., Standard Chartered PLC, UBS AG
1:25-mc-00158
S.D.N.Y.
Apr 30, 2025
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Background

  • Applicants moved to quash subpoenas issued to various banks as part of ongoing bankruptcy proceedings against BYJU’S Alpha, Inc. in Delaware Bankruptcy Court.
  • Respondent moved to transfer the motion to quash (“Quash Motion”) to the Delaware Bankruptcy Court, where the underlying bankruptcy case is pending.
  • The Delaware Bankruptcy Court has already handled significant portions of the case, including issuing a detailed opinion and holding parties in contempt over discovery disputes.
  • Applicants do not oppose transferring the Quash Motion provided there is a stay of the subpoenas but argue about ongoing compliance obligations.
  • The Southern District of New York considered whether the Quash Motion should be decided there or transferred for coordination with the underlying bankruptcy proceedings.
  • The court emphasized the efficient management of complex, contentious discovery by the court most familiar with the case’s background.

Issues

Issue Applicant's Argument Respondent's Argument Held
Whether to transfer the Quash Motion to Bankruptcy Court Not opposed if a stay is granted Bankruptcy Court best suited to resolve motion Transfer granted; Bankruptcy Court will decide
Which court is best positioned to rule on the subpoenas Local nonparties should not be burdened Delaware court familiar with issues and discovery Delaware Bankruptcy Court best suited
Impact of prior rulings in the issuing court Unspecified Bankruptcy Court has prior rulings and context Issuing court's familiarity supports transfer
Applicant's consent to transfer Consent conditioned on stay request No opposition noted No opposition, so transfer is appropriate

Key Cases Cited

  • None with official reporter citations were cited in the opinion.
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Case Details

Case Name: In re: Subpoenas Served on Bank of America, N.A., Barclays Bank PLC, Bank of New York Mellon, Citibank, N.A., Commerzbank AG, Deutsche Bank Trust Company Americas, HSBC Bank USA, N.A., JP Morgan Chase, N.A., PNC Bank, N.A., Standard Chartered PLC, UBS AG
Court Name: District Court, S.D. New York
Date Published: Apr 30, 2025
Docket Number: 1:25-mc-00158
Court Abbreviation: S.D.N.Y.