In a criminal bribery prosecution, the appellant international financial organization challenged a third party production order and subpoenas issued in support of a Garofoli wiretap challenge.
The Court held that archival and personnel immunities under the Bretton Woods and Related Agreements Act applied to records and investigators of the organization’s integrity unit, and no waiver was established.
The Court further held that, in the Garofoli context, third party production requires a reasonable likelihood of probative value to the affiant-knowledge issues, not broad relevance to trial truth.
Because that threshold was not met, the production order was set aside.
