Facts
On 5 April 2001, the Vice-President in charge of the investigation at the Tribunal de Grande Instance of Evry sent a letter of request to Switzerland in the context of an investigation for misuse of corporate assets and receiving stolen goods. The investigating judge in Geneva, tasked with executing this request, ordered the seizure of documents related to money transfers in the possession of the Geneva lawyer. The latter provided a series of documents related to the payment of 1 million FF, including account statements, handwritten notes, a fee invoice, and a receipt signed by [L.] for an amount of 248,990 francs. By order of 4 April 2003, the investigating judge decided to transmit these documents to the requesting authority. [L.], who is the subject of the foreign criminal proceedings, filed an administrative appeal against this order.Considerations
According to case law, standing to appeal a mutual legal assistance measure is recognized for those who are personally and directly affected. The holder of a bank account targeted by the mutual assistance request has standing to appeal, but not the economic beneficiary of the account or the author of documents seized from a third party.
In this case, the documents provided by the lawyer relate primarily to an account held and…