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proportionalityletters rogatoryrefund litigation
Perrigo v. United States
Perrigo Co. v. United States, 294 F. Supp. 3d 740 (W.D. Mich. 2018)
Key Principle
In a tax-refund suit, a court applying Rule 26(b) proportionality factors may deny the Government's request to issue letters rogatory/a Letter of Request to a foreign court where the added delay and cost outweigh the likely benefit of the foreign discovery sought.
Area of Law
General
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