ORDER
G.R. SMITH, Magistrate Judge.
Claimant Pola Maritime, Ltd. ("Pola") has lodged a claim against respondents Agribusiness United Savannah Logistics, LLC ("Agribusiness Savannah"), and Agribusiness United DMCC (Dubai), LLC ("Agribusiness Dubai") before the London Maritime Arbitrators Association (LMAA). See doc. 1. Pola came to this Court seeking (and received) subpoenas to serve in this district, including Fed. R. Civ. P. 45(d)(3) subpoenas upon Agribusiness Dubai, Agribusiness United Multi Commodities, Inc. ("Agribusiness Commodities") and Agribusiness United North American Corporation ("Agribusiness North American"). See doc. 2. Objectors Agribusinesses Commodities and North American have moved to quash the subpoenas (docs. 10, 11 & 21)1 and Pola has cross-moved to compel them (doc. 18).
I. BACKGROUND2
Pola chartered the M/V N Schelde to transport agricultural cargo from Argentina to Atlantic Morocco, in a charter agreement with Agribusiness Savannah with a choice of law provision (English law) and choice of forum for any dispute (arbitration in accordance with the rules of the LMAA). A dispute arose, and Pola initiated arbitral proceedings against Agribusinesses Savannah and Dubai.
Pola contends that Agribusiness Dubai is actually the principal to the charter agreement — not Agribusiness Savannah, which signed as Dubai's agent.3 In the arbitral proceeding, Pola seeks: 1) indemnity from either or both Agribusinesses Savannah and Dubai for pending misdelivery/conversion claims, and 2) outstanding freight and demurrage (a charge for failure to load or discharge the ship within the time agreed) damages. The documents currently sought would allegedly illuminate the relationships among the various Agribusiness entities, for use in the proceeding before the LMAA.4
III. ANALYSIS
Objectors dispute that the subpoenas were properly issued pursuant to 28 U.S.C § 1782. Docs. 10 & 11; see also doc. 18, Exh. 1 (Agribusiness North America's objection and response to subpoena) & Exh. 2 (Agribusiness Commodities' objection and response to subpoena). Under § 1782(a), "[t]he district court in which a person resides or is found may order him to give his testimony or statement or to produce a document or other thing for use in a proceeding in a foreign or international tribunal . . . . The order may be made . . . upon the application of any interested person and may direct that the testimony or statement be given, or the document or other thing be produced before a person appointed by the court." A district court is authorized to grant an application if the following statutory requirements are met:
(1) the request must be made "by a foreign or international tribunal," or by "any interested person"; (2) the request must seek evidence, whether it be the "testimony or statement" of a person or the production of "a document or other thing"; (3) the evidence must be "for use in a proceeding in a foreign or international tribunal"; and (4) the person from whom discovery is sought must reside or be found in the district of the district court ruling on the application for assistance.
In re Clerici, 481 F.3d 1324, 1331-32 (11th Cir. 2007) (citing 28 U.S.C. § 1782(a)); see also In re Application of Microsoft Corp., 428 F.Supp.2d 188, 192 (S.D.N.Y. 2006). Here, as claimant in the arbitration, Pola is certainly an "interested person," seeking evidence found in this district, and that evidence sought is certainly within the meaning of § 1782. So, the question is whether the LMAA is a "foreign tribunal" for the purpose of § 1782.
A. Foreign Tribunals
As to what comprises a "foreign tribunal," the Supreme Court has noted that
when Congress established the Commission on International Rules of Judicial Procedure in 1958, it instructed the Rules Commission to recommend procedural revisions "for the rendering of assistance to foreign courts and quasi-judicial agencies." Section 1782 had previously referred to "any judicial proceeding." The Rules Commission's draft, which Congress adopted, replaced that term with "a proceeding in a foreign or international tribunal." Congress understood that change to "provid[e] the possibility of U.S. judicial assistance in connection with [administrative and quasi-judicial proceedings abroad]." S. Rep. No. 1580, at 7-8, U.S. Code Cong. & Admin. News 1964, pp. 3782, 3788; see Smit, International Litigation 1026-1027, and nn. 71, 73 ("[t]he term `tribunal' . . . includes investigating magistrates, administrative and arbitral tribunals, and quasi-judicial agencies, as well as conventional civil, commercial, criminal, and administrative courts"; in addition to affording assistance in cases before the European Court of Justice, § 1782, as revised in 1964, "permits the rendition of proper aid in proceedings before the [European] Commission in which the Commission exercises quasi-judicial powers").
Intel Corp. v. Advanced Micro Devices, Inc., 542 U.S. 241, 247 (2004). Thus courts, as well as "quasi-judicial agencies" and "arbitral tribunals," comprise the types of bodies that § 1782 means to address. Pola contends that the LMAA is one such tribunal; Agribusinesses North American and Commodities disagree. Docs. 10 at 7 & 11 at 7 (arguing Pola is restricted to the discovery and disclosure procedures authorized by the LMAA and can't come fishing around the Southern District of Georgia with any federal subpoenas).
The Intel court, in setting forth a functional description of a "foreign tribunal" under § 1782, focused on the judicial reviewability of the decisions of the European Commission in determining that the body was a foreign or international tribunal under § 1782. 542 U.S. at 258 (the Commission's role "as a first-instance decisionmaker," subject to judicial review, did not "exclude" it "from § 1782(a)'s ambit"). And awards by the LMAA are reviewable by the English Courts pursuant to the English Arbitration Act of 1996.5 Hence, while the LMAA "is much like a purely private arbitration," its reviewability by a true judicial body brings it within the § 1782 definition of a "foreign tribunal." Ex rel Application of Winning (HK) Shipping Co. Ltd., 2010 A.M.C. 1761, 1773-74 (C.D. Cal. 2010); see also In re Ex Parte Application of Kleimar N.V., 220 F.Supp.3d 517 (S.D.N.Y. 2016) (the LMAA is a foreign tribunal within the meaning of § 1782); In re Owl Shipping, LLC, 2014 WL 53'2 at * 2 (D.N.J. Oct. 17, 2014) (same).
B. The Intel Factors
Even if the prima facie requirements are satisfied, the Intel court set forth additional, discretionary factors to be considered before authorizing discovery under § 1782:
(1) whether the person from whom discovery is sought is a participant in the foreign proceeding, because the need for § 1782(a) aid generally is not as apparent as it ordinarily is when evidence is sought from a nonparticipant; (2) the nature of the foreign tribunal, the character of the proceedings underway abroad, and the receptivity of the foreign government or the court or agency abroad to U.S. federal-court judicial assistance; (3) whether the § 1782(a) request conceals an attempt to circumvent foreign proof-gathering restriction or other policies of a foreign county or the United States; and (4) whether the request is otherwise unduly intrusive or burdensome.
Application of Consorcio Ecuatoriano de Telecomunicaciones S.A. v. JAS Forwarding (USA), Inc., 747 F.3d 1262, 1271-72 (11th Cir. 2014); see also In re: Clerici, 481 F.3d at 1331.
Here, as to the first factor, there is no dispute that neither Agribusinesses North America nor Commodities are participants in the LMAA proceeding. As to the second, however, "the tribunal at issue is a first-instance decision maker that renders decisions which are reviewable in an English court" and objectors have offered "no evidence or case law [ ] that indicates that the foreign government or court would be unreceptive to United States federal-court judicial assistance." Application of Winning (HK), 2010 A.M.C. at 1777; see docs. 10 at 10 & 11 at 10.
And neither objector has convincingly argued that Pola's subpoena requests "conceal an attempt to circumvent foreign proof-gathering restrictions or other policies of a foreign country or the United States." Application of Winning (HK), 2010 A.M.C. at 1777; see also Intel, 542 U.S. at 259-65. Indeed, they merely conclusorily contend that "this discovery . . . has been served in contravention of the terms of the arbitration," which has its own discovery and disclosure procedure. Doc. 10 at 10 & doc. 11 at 10. And the case law demonstrates that the English courts have explicitly sanctioned § 1782(a) as an appropriate vehicle for propounding discovery. See, e.g., South Carolina Ins. Co. v. Assurantie Maatschappij "De Zeven Provincient" NV, 1 App. Cas. 24 (1986), cited in Intel, 542 U.S. at 261-62 (noting the "House of Lords ruled that non-discoverability under English law did not stand in the way of a litigant in English proceedings seeking assistance in the United States under § 1782.").
As to the fourth factor, objectors' contention that the subpoenas are unduly burdensome and intrusive on their face because they "seek documents unrelated to any pending claim or defense" and "outside the scope of permissible discovery" (docs. 10 at 10-11 & 11 at 10-11; see also doc. 18, Exhs. 1 ¶ 2) is not convincing in the face of the evidence already in hand. Pola has shown that the Agribusiness entities often behave interchangeably, transferring funds among themselves and referring internally to one another — both formally and informally, and inconsistently — as "Agribusiness United," such that it can be difficult to tell which entity is operating at any given time. Doc. 13-1 (Declaration of Thomas Tisdale) at ¶¶ 7-17; see also supra fn. 3. The discovery sought is clearly targeted to fleshing those relationships out, see supra fn. 4, and is keyed to Pola's contention that Agribusiness Dubai is the principal to their charter agreement, with Agribusiness Savannah merely its agent. The type of materials sought is relevant (largely limited to sussing out the corporate structure and interplay of the various Agribusinesses) and is limited to a relevant time frame (the past three years). The § 1782(a) discretionary factors militate toward permitting discovery.
Once the § 1782 factors are met, it is "the federal discovery rules, Fed. R. Civ. P. 26-36," which "contain the relevant practices and procedures for the taking of testimony and the production of documents." Weber v. Finker, 554 F.3d 1379, 1384-85 (11th Cir. 2009), quoted in Application of Consorcio Ecuatoriano, 747 F.3d at 1272. Objectors' conclusory contention that the subpoenas are "grossly overbroad" and thus must be quashed is simply not enough for this Court to determine the problem with production. See docs. 10 at 10 & 11 at 10. Indeed, they rest their entire objection on a single sentence describing the "problem" they have as being the "sheer size and vagueness of the requests." See docs. 10 at 12 & 11 at 12. But they offer no meaningful objections to the number, time period, or scope of documents to be produced and testimony sought. See id. They further contend that answering the subpoenas will require them to "disclose confidential pricing information," but offer no clue as to what privileged materials might be disclosed or why a protective order couldn't be drafted to keep those materials confidential. See docs. 10 at 12-13 & 11 at 12-13. And that is just not enough. See, e.g., Conway v. H&R Block Eastern Enterp., Inc., 2017 WL 2120074 at *1 & 3 (S.D. Ga. May 15, 2017).
Though the Court recognizes that requests for "any and all" documents are clearly overbroad, see, e.g., Fed. R. Civ. P. 34(b)(1)(A) (requiring "reasonable particularity" in requests), objectors have offered no argument as to how the subpoenas are unanswerable — the scope of each request can be narrowed through a meaningful conference between counsel and any fears that confidential commercial information could be released to the public allayed by a well written protective order.
That said, it is clear from their papers that the parties have not met and conferred — much less meaningfully so — to narrow the scope of their dispute before seeking court intervention.6 They must do so, and return to this Court only with narrowed, specific, and supported objections to claimant's subpoenas. C.f. S.D. Ga. Loc. R. 26.5(c); Scruggs v. Int'l Paper Co., 2012 WL 1899405 at *2 (S.D. Ga. May 24, 2012) ("the lawyers here are professionals" and thus capable of fulfilling their duty to fully meet and confer before seeking the Court's intercession). Put another way, they shall in good faith (at least by phone if not in person) attempt to resolve movant's objections without further Court involvement. Fees may be assessed for any bad faith shown.7
III. CONCLUSION
In sum, objectors Agribusinesses North America and Commodities' motions to quash the subpoenas (docs. 10 & 11) are DENIED without prejudice, Agribusiness Dubai's motion to quash the subpoena (doc. 9) is DENIED as moot, claimant Pola's motion to compel compliance with the subpoena (doc. 18) is DEFERRED in abeyance of the parties' successful meet and confer discussions and compromises, and the parties are ORDERED within 30 days of service of this Order to update the Court as to whether a resolution has been reached and claimant's motion is withdrawn.
SO ORDERED.
