MEMORANDUM ORDER AND OPINION
TSOUCALAS, Judge:
Plaintiff moves for a waiver from enforcement of "the 100-mile rule" under Rule 45(e) of the Rules of the United States Court of International Trade (USCIT). Defendants oppose the motion.
Background
The facts surrounding this 19 U.S.C. § 1592 (1982) action are outlined in United States of America v. Daewoo Int'l (America) Corp. and Daewoo Corp., 12 CIT ___,
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