Case 1:20-mc-00036-JEB-DAR Document 8 Filed 08/04/20 Page 16 of 18 The application’s request for a Rule 30(b)(6) deposition is particularly problematic and overbroad. The proposed topics have no meaningful limitation and include all “the subjectmatters described [in the document requests].” Appl. at 17. Nor does the application attempt to explain how such a deposition would be meaningfully additive or relevant beyond the topics and information covered by the document requests themselves, or the information already available to the ICJ. Bayer AG v. Betachem, Inc., 173 F.3d 188, 191–92 (3d Cir. 1999) (affirming district court’s denial of Section 1782 petition where additional redacted information sought from documents would be “cumulative”). The plain overbreadth of the applicant’s requests makes it appropriate to deny the application outright. Nokia, 2013 WL 6073457, at *3 (“Because [the applicant’s] subpoena application is not narrowly tailored, and appears highly intrusive as well as unduly burdensome, this factor weighs strongly against” granting the application); see Cathode Ray Tube, 2013 WL 183944, at *4 (there is no need to “trim” overbroad requests; they “may be rejected” (quoting Intel Corp., 542 U.S. at 265)). Finally, the application raises serious foreign policy and international comity concerns. Cathode Ray Tube, 2013 WL 183944, at *3 (“[F]actors like comity among nations and parity among parties can be touchstones in this analysis.”). The applicant’s requests seek access to the personal communications of senior Myanmar officials and their connections with various other individuals, entities, or groups, without following established policies for a foreign government to seek such information from entities like Facebook. See 18 U.S.C. § 2702(b)(9); 18 U.S.C. § 3512; see also In re Letters Rogatory from the Tokyo Dist. Prosecutor’s Office, 16 F.3d 1016, 1021 (9th Cir. 1994); Cathode Ray Tube, 2013 WL 183944, at *3 (quashing Section 1782 12