ORDER DENYING MOTION TO QUASH AND FOR A PROTECTIVE ORDER AND GRANTING IN PART AND DENYING IN PART MOTION TO AUTHORIZE REGISTRATION OF JUDGMENT In 2015, following an arbitration proceeding in Ecuador, the Republic of Ecuador agreed to pay Respondent Occidental Exploration and Production Company (“OEPC”) and its parent Occidental Production Company (“OPC”) nearly $1 billion dollars to settle claims arising out of an oil exploration project in the Amazon. Thereafter, Petitioner Andes (“Andes”), pursuant to a contract with OEPC, claimed it was entitled to 40 percent of OEPC’s interest in the settlement amount. Andes prevailed on its claim in an arbitration proceeding in New York and received an award, which this Court confirmed by order dated December 2, 2021. The instant postjudgment discovery dispute arises out of Plaintiff Andes’s efforts to satisfy the $558 million judgment. It has been unable to do because the entire settlement amount was paid to and retained by OPC. On July 6, 2022, in response to a joint letter from the parties, I ordered OEPC to produce all “documents demanded by Andes” by July 20, 2022, and provided for Andes to “subpoena relevant current or prior officers and employees of OEPC, requiring their testimony as to the assets and financial condition of OEPC, and other relevant witnesses.” (ECF No. 50.) The Order further provided that “[t]he depositions [could] be taken remotely, on dates set by Andes, or as mutually agreed, or as ordered by the Court, and shall be completed by August 3, 2022.” (Id.) Thereafter, on July 11, 2022, moving pursuant to N.Y. C.P.L.R. §5223 and 5224(a)(1) and Fed. R. Civ. P. 69(a)(2), Andes identified and noticed depositions for nine individuals as well as a Rule 30(b)(6) corporate representative for non-party OPC. Six of the proposed deponents — Stephen Chazen, Marcia Backus, Rick Callahan, Karen Lippe, Altaf Presla, and Megan Wetterauer — are officers of OPC. A seventh — Jennifer Kirk — is a former OPC and OPEC officer. The parties met and conferred on July 14, 2022. At the conference, OPC’s counsel offered to produce an unidentified 30(b)(6) witness and demanded that Andes agree to suspend compliance with the remaining subpoenas. Andes did not object to deposing the corporate witness first but declined to agree to hold the other subpoenas in abeyance. On July 19, 2022, OPC filed a motion, pursuant to CPLR 2304 and FRCP 54(d)(3), to quash the subpoenas for deposition testimony as to six of the individual OPC officers (Chazen, Backus, Callahan, Lippe, Prasla, and Wetterauer) and filed a supplemental motion to quash as to Kirk; OPC also moved for a protective order pursuant to CPLR 3103. (ECF Nos. 51, 54.) On July 26, 2022, Andes opposed the motions and additionally moved for authorization to register its judgment in other states (California, Texas, and Minnesota) in the hopes of identifying assets there and, if need be, to enforce its deposition subpoenas. (ECF No. 60.) This Order addresses all open motions. For reasons provided below, the motions to quash and for a protective order are denied, and the motion to authorize the registration of the judgment is granted in part and denied in part. DISCUSSION I. Motions to Quash and for a Protective Order “[B]road post-judgment discovery in aid of execution is the norm in federal and New York state courts.” Aurelius Capital Master, Ltd. v. Republic of Argentina, 589 Fed. Appx. 16, 17 (2d Cir. 2014) (quoting EM Ltd. v. Republic of Argentina, 695 F.3d 201, 207 (2d Cir. 2012)). Federal Rule of Civil Procedure 69(a)(2) allows judgment creditors to “obtain discovery from any person — including the judgment debtor — as provided in these rules or by the procedure of the state where the court is located.” Fed. R. Civ. P. 69(a)(2). Both the federal and the New York state rules allow liberal post-judgment discovery, See Fed. R. Civ. P. 26(b)(1) (permitting discovery “regarding any nonprivileged matter that is relevant to any party’s claim or defense”); N.Y. C.P.L.R. §5223 (permitting discovery of “all matter relevant to the satisfaction of the judgment”). Although Rule 69(a)(2) allows a party to move pursuant to federal or state rules, N.Y. C.P.L.R. 5224(a)(1) provides for service of depositions only on witnesses within New York State. In contrast, Fed. R. Civ. P. 45(c) allows for nationwide service of process but provides that a subpoena may command a person to attend a deposition only “within 100 miles of where the person resides, is employed, or regularly transacts business in person.” Fed. R. Civ. P. 45(c)(1)(A). A party may move to quash the subpoena for falling outside of the 100-mile geographical range but must do so in the district court for the place where compliance would be required. Fed. R. Civ. P. 45(d)(3). Andes identified the seven individual officers or employees and their relevant knowledge or experience as follows. Stephen Chazen signed the January 7, 2016 Settlement Agreement on behalf of both OEPC and OPC. (Settlement Agreement at 35.) Just one day earlier, the directors of OEPC (including Kirk and Clark) had granted Chazen a General Power of Attorney to act on OEPC’s behalf, including “the authority to do and perform any and all acts in the name and on behalf of [OEPC]….” (Jacobs Decl. Ex. 7.) The Settlement Agreement, executed by Chazen — who was then the CEO of OPC — caused OEPC’s entire interest in the $1 billion Settlement Amount to be transferred to OPC. Moreover, OEPC itself identified Chazen as one of only four people “involved with” OEPC’s “decision to withhold…the Settlement Amount from Andes….” (ECF No. 49-11 at 12-13.) Rick Callahan and Jennifer Kirk are officers or directors of OEPC (or were as recently as October 2021). (See Jacobs Decl. Ex. 2 (Statement of Information filed by OEPC in October 2021).) Callahan is the CEO of OEPC (or was as of October 2021), and the only publicly identified CEO in OEPC’s mandatory California public filings. Kirk is identified in the same filings as a director of OEPC and is heavily involved in OEPC’s corporate affairs and was included on an email chain dated August 2, 2016 involving OEPC and OPC’s accounting for the Ecuadorian Settlement Amount. Marcia E. Backus was identified by OEPC as one of only three people “involved with the negotiation of the Settlement Agreement on behalf of OEPC,” and one of only four people “involved with” OEPC’s “decision to withhold…the Settlement Amount from Andes….” (Id.) She also directed the payment of OEPC’s legal bills by OPC. (ECF No. 49-11 at 14.) Altaf Prasla, Karen Lippe, and Megan Wetterauer have been identified by Andes in its review of OEPC’s document productions as individuals with significant knowledge regarding OEPC’s accounting practices, including accounting for the disposition of OEPC’s interest in the Settlement Amount. (Jacobs Decl.
