Christopher Steel Deposition
Christopher Steel Deposition
Christopher Steel Deposition
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ALEKSEJ GUBAREV, XBT HOLDINGS )
S.A., and WEBZILLA, INC. )
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Plaintiffs, ) Case No.
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v. ) 0:17-cv-60426-UU
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BUZZFEED, INC. and BEN SMITH, )
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Defendants. )
through his undersigned counsel of record, and, pursuant to Fed. R. Civ. P. 24, moves the Court to
allow his intervention in this action for the sole purpose of objecting to the Courts entry of the
Request for International Judicial Assistance through The Hague Convention of 18 March 1970
on the Taking of Evidence Abroad in Civil or Commercial Matters (Rec. Doc. No. 54, Aug. 10,
2017) (Hague Request). The Court entered the Hague Request the day following the filing of
Plaintiffs Motion for Court to Issue Request for International Judicial Assistance on August 9,
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As Plaintiffs admitted, Mr. Steele is a British citizen . . . [and] is beyond the jurisdiction of this or any American
Court. Plaintiffs Motion for Court to Issue Request for International Judicial Assistance on August 9, 2017 (Rec.
Doc. No. 52, Aug. 9, 2017) (Plaintiffs Motion). Mr. Steeles special appearance for the limited purpose of
objecting to Plaintiffs third party discovery attempt does not create general jurisdiction nor waive his personal
jurisdiction defenses under Fed. R. Civ. Pro. 12.
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Case 0:17-cv-60426-UU Document 55 Entered on FLSD Docket 08/10/2017 Page 2 of 3
This Court has discretion to refuse the Plaintiffs request seeking to compel discovery from
a foreign nonparty. See Yellow Pages Photos, Inc. v. Ziplocal, LP, 795 F.3d 1255, 1273 (11th Cir.
2015) (The decision whether to issue letters rogatory lies within the discretion of the district
court.). The deposition sought is impermissible and unlawful on multiple grounds, not the least
of which is that the self-same Plaintiffs have a direct defamation action pending against Mr. Steele
in the United Kingdom in which the requested deposition is strictly prohibited. Plaintiffs thus are
seeking to employ this Court in an end-run around their limitations in their parallel U.K. action.
To more fully itemize and support his objections to the Hague Request, Mr. Steele
respectfully requests the Court to allow him to file a motion to quash the Hague Request or before
OF COUNSEL:
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Case 0:17-cv-60426-UU Document 55 Entered on FLSD Docket 08/10/2017 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that I have this day filed the foregoing MOTION TO INTERVENE OF
CHRISTOPHER STEELE with the Courts CM/ECF Service, which will provide electronic