Servotronics, Inc. v. Rolls-Royce PLC

Dist. Ct. did not err in ultimately denying request under 28 USC section 1782(a) by party in foreign private arbitration proceeding for Dist. Ct. to issue subpoena to compel U.S. entity to produce documents for use in London, England arbitration. Ct. of Appeals agreed with Dist. Ct. that section 1782(a) does not permit Dist. Ct. to order discovery for use in private foreign commercial arbitrations, where Ct. of Appeals found that term “tribunal” in section 1782(a) applied only to state-sponsored foreign and international tribunals.