MEMORANDUM OPINION

The plaintiff, the Commonwealth of the Northern Mariana Islands (“CNMI”), is a judgment creditor as to two tax judgments obtained against the two individual defendants, the Millards, nearly two decades ago. It here moves for a turnover order, pursuant to Rule 69 of the Federal Rules of Civil Procedure and N.Y. CPLR § 5225, as well as a preliminary injunction and additional discovery. CNMI alleges that the Millards have funds in accounts housed in Cayman Islands subsidiaries of garnishee Canadian Imperial Bank of Commerce (“CIBC”) and that CNMI is entitled under New York law to an order compelling CIBC to turn over the money.

This Court concludes that the text of the New York CPLR limits the ability of the Court to issue a turnover order to instances in which the entity to which the order is *206directed has “possession or custody” of property. As CIBC does not have “possession or custody” within the meaning of the statute, CNMI’s motion is denied. Nevertheless, there is significant merit to CNMI’s argument, which involves an unsettled question of state law. Absent interim relief, there would be a substantial risk that the funds in question would be dissipated during any appeal. Accordingly, the Court grants an injunction requiring maintenance of the status quo pending appeal. The Court also denies CNMI’s motion to compel discovery as moot.

Facts

Prior Proceedings

In 1994, CNMI obtained two separate judgments for unpaid taxes against the defendants, William Millard and Patricia Millard, in the respective amounts of $18,317,980.80 and $18,318,113.41. The amounts have grown, with interest, to more than $118 million.

The Millards resided in CNMI beginning in 1987, but relocated before CNMI obtained the judgments. In 2010, through various investigative means, CNMI learned that the Millards had renounced their U.S. citizenship and were residing in the Cayman Islands.

In March and April 2011, CNMI registered the judgments in this Court and the Southern District of Florida. It proceeded to file various turnover motions, pursuant to Federal Rule of Civil Procedure 69(a)(1) and N.Y. CPLR § 5225(b), naming as garnishees various financial institutions that hold, or allegedly hold, accounts belonging to the Mil-lards. To this point, eight different judges in this District — sitting in Part 1 — have presided over these related matters.1

On March 5, 2012, Judge Cote, sitting in Part 1, directed CIBC to show cause why it should not be (1) enjoined from permitting any transactions involving any property in which either or both of the Millards has an interest, and (2) ordered to turn over the funds, property, and other assets in which either or both of the Millards has an interest. The Court also temporarily restrained CIBC from certain activities related to accounts in which either or both of the Millards, or various corporate entities under their individual or collective ownership, holds an interest, and directed CIBC to preserve any documents pertaining to such accounts. The restraint remains in place. This Court heard argument on the motion on March 22, 2012.

The Evidence

CNMI alleges that the judgment debtors hold accounts at, or at subsidiaries of, CIBC FirstCaribbean International Bank (Cayman) (“CFIB”), a 92%-owned-and-controlled subsidiary of CIBC, both in their own names and in the names of various corporate entities under their individual or collective ownership. It further alleges that “since leaving CNMI, the Millards have employed sophisticated tactics in an effort to put their assets beyond the reach of CNMI and of the United States, including by the use of offshore tax havens and bank secrecy jurisdictions, by renouncing their United States citizenship[ ], and by creating a network of entities that purport to own or control the assets which the Millards in fact beneficially own or control.”2 After an apparently inadvertent disclosure of non-party subpoenas to members of the Millard family and the concomitant revelation that CNMI was undertaking post-judgment activities against the judgment debtors, “the Millards appear to have taken steps to further dissipate assets and conceal information.”3 As a result, the Court previously issued confidentiality orders and temporary restraining orders in these proceedings, and has permitted registration and discovery to be pursued under seal. This action also is proceeding under seal at this time.

Through non-party discovery, CNMI identified assets at CFIB in which it believes the judgment debtors hold interests, and it subsequently initiated this proceeding. CNMI alleges that the CFIB assets “are controlled personally by the Millards and appear to be *207used to hold personal assets and, in conjunction with several other entities and individuals, to otherwise obscure the Millards’ ownership of assets, to move money between the Millards and their family and friends, and between offshore and onshore accounts, and to pay personal expenses of the Millards and their family members.”4 CNMI asserts a right to possession of the assets to satisfy its judgments that is superior to the rights of the persons and entities in whose names the assets are held — which, if true, would subject the assets to recovery by CNMI.5

Relying on publicly available documents containing information regarding CIBC’s corporate organization, management, and consolidated financial statements, CNMI asserts that “CIBC has the control, power, authority and practical ability to order [CFIB] to turn over funds on deposit in the name of the Millards and entities controlled by the Millards pursuant to an order from this Court.”6 It notes that CIBC has imposed its “governance structure” on CFIB;7 that CIBC and CFIB have significant personnel overlaps, even at senior levels of management; 8 and that CIBC requires CFIB to comply with U.S. legal requirements such as Sarbanes-Oxley and the PATRIOT Act.9 In CFIB’s promotional materials, CFIB states that the CIBC governance structure “affords the parent company full oversight of the risk and control framework of all [of CFIB’s] operations.”10 Finally, CNMI points to a Federal Reserve document representing that, “[w]ith respect to access to information about [CIBC’s] operations, ... [CIBC] has committed to make available to the [Federal Reserve] Board such information on the operations of [CIBC] and any of its affiliates that the Board deems necessary to determine and enforce compliance with ... applicable federal law.”11

CIBC responds that CFIB is actually two “separate corporate entities, twice removed from CIBC.”12 It represents that while CFIB itself “does not offer deposit accounts in the Cayman Islands, ... two of its wholly-owned subsidiaries” do.13 Each, it states, is a “legally separate and independent en-tit[y].”14 It further states that CIBC and CFIB “do not have an information sharing agreement and that CIBC is unable to access accounts or account information held by [CFIB] or its subsidiaries.”15 Finally, CIBC represents that both CFIB subsidiaries in the Cayman Islands are subject to that country’s banking-secrecy laws.16

Discussion

Jurisdiction

In post-judgment proceedings that are “efforts] to collect ... federal court judgments], the courts have permitted judgment creditors to pursue, under the ancillary enforcement jurisdiction of the court, the assets of the judgment debtor even though the assets are found in the hands of a third party.” 17 The Court therefore has subject-matter jurisdiction over this action. In addition, the Court has personal jurisdiction over CIBC based on its many activities in and contacts with New York,18 a finding that is unopposed by CIBC.

Turnover Order

These proceedings are governed by Federal Rule of Civil Procedure 69, which states in *208relevant part that “[t]he procedure on execution and in proceedings supplementary to and in aid of judgment or execution must accord with the procedure of the state where the court is located but a federal statute governs to the extent it applies.”19 As operable through Rule 69,20 New York law authorizes a judgment creditor to initiate a special proceeding “against a person in possession or custody of money or other personal property in which the judgment debtor has an interest.”21 Where “the judgment debtor is entitled to the possession of such property” or “the judgment creditor’s rights to the property are superior to those of the transferee,” the court “shall” order the person “in possession or custody” to pay money in satisfaction of the underlying judgment.22 The task of the Court, then, is to determine whether CIBC has “possession or custody” of assets held in CFIB accounts located in the Cayman Islands.

“It is fundamental that a court, in interpreting a statute, should attempt to effectuate the intent of the Legislature.”23 Without guidance from either state or federal courts as to the specific question here, the Court is left with the text of Section 5225(b) in evaluating the ability of a court to order a bank to turn over funds located in accounts of its foreign subsidiaries.24 In attempting to predict what the New York courts would conclude here as to the meaning and import of “possession and custody,” the Court is reminded of the fact that “[t]he will of [a legislature] is ... subject to inevitable distortion by reason of the inadequate medium through which it must be communicated.”25 This case presents one such example.

As stated above, Section 5225(b) authorizes courts to order turnover of property that is in the “possession or custody” of the garnishee.26 The fundamental question before the Court, then, is: What does that phrase mean?

CNMI elects to color Section 5225(b)’s “possession or custody” requirement as a practical one that necessarily implicates the concept of “control.”27 It argues that “the judgment debtors own the assets that are held in a bank in the Cayman Islands and CIBC controls that bank and has the legal and practical ability to order that bank to turn over the judgment debtors’ assets to CNMI.”28

CNMI’s argument has substantial persuasive force. Both federal and New York rules *209of civil procedure contain various provisions using a phrase similar to that in issue here, and courts routinely have interpreted that phrase — “possession, custody, or control”29 —in practical terms along the lines urged by CNMI here.30 For example, the court in Tomlinson v. El Paso Corp.31 summarized the vast majority of federal cases as holding that Rule 34(a) of the Federal Rules of Civil Procedure, which allows document requests to be made as to “items in the responding party’s possession, custody, or control,”32 “enables a party seeking discovery to require production of documents beyond the actual possession of the opposing party if such party has retained any right or ability to influence the person in whose possession the documents lie.”33 Additionally, a court in this District held that documents are discoverable under Rule 34 “when that party has the right, authority, or practical ability to obtain the documents from a non-party to the action.” 34 And the Second Circuit, in discussing Rule 34(a), has stated that “a party is not obliged to produce, at the risk of sanctions, documents that it does not possess or cannot obtain.”35 The consensus meaning of the phrase “possession, custody, or control” is *210the same in the Rule 45 subpoena context.36

Courts focus on the practical aspect of “possession” and reject a narrow definition of the concept in other contexts as well. For example, drug-possession convictions regularly are sustained absent proof of actual, physical possession provided the government proves only that a person “knowingly ha[d] the power and the intention at a given time to exercise dominion and control over an object, either directly or through others.”37 The same generally is true of firearms statutes,38 and courts in the bankruptcy context are empowered to issue orders as to property within the court’s — or the parties’ — constructive possession.39

With all of that in mind, CNMI’s focus on the practical ability of a garnishee to effectuate a turnover of property of a debtor has a good deal of appeal. If CIBC as a practical matter can cause its subsidiaries to comply with a turnover order, it would seem incongruous to conclude that the Court is without the power to issue such an order in the first instance.

But the argument is not as compelling as first appears. Many courts, in construing practically the phrase “possession, custody, or control,” have focused specifically on the word “control”40 and distinguished it from mere “possession.”41 In United States v. *211Stein42 for example, this Court rejected a party’s attempt to “read the words ‘custody or control’ out of [Rule 16 of the Federal Rules of Criminal Procedure, which permits discovery of various materials within the government’s ‘possession, custody, or control,’] in flat contravention of the principle that all words in a statute, rule or contract are to be given meaning whenever possible.”43 The Court concluded that, where an earlier agreement, with limited exception, gave the government “the unqualified right to demand production by [a third party] of any documents it wishes for purposes of [the] case,” the government had “control” over documents even in the immediate possession of the party.44

The word “control” is entirely absent from Section 5225. The legislative omission of one word from statutory text, on its face, might not seem to be of enormous consequence. But, as so often is true, “the devil lurks precisely in such details.”45 Among the most fundamental canons of statutory interpretation is the rule that “[w]hen different terms are used in various parts of a statute or rule, it is reasonable to assume that a distinction between them is intended.”46 And that the differing language appears in multiple separate sections of the CPLR is of no moment to the application of that rule, as the additional canon of in pari materia requires that “statute or legislative act ... be construed as a whole, and all parts of an act are to be read and construed together to determine the legislative intent.”47

The Court is not convinced that it may properly treat the omission of the word “control” from Section 5225(b) as immaterial or inadvertent,48 particularly where the subject matter of both statutes — the reach of the court’s authority to order the turnover of property or documents — overlaps so fundamentally.49 Were the Court to read Section 5225(b) as CNMI contends it should, it effectively would amend the statute to include a meaning that is not within the actual text.50 As a result, the text does not support the argument CNMI asks it to bear here.

*212Logic supports this conclusion. It is more than reasonable to postulate that the Legislature intended to make the standard for asset turnover higher than that for the mere disclosure of information, given the varying degrees of possessory interests involved. Such speculation, however, is unnecessary. We need look only to the Legislature’s choices throughout the CPLR to verify that, indeed, such a scheme was its consistent choice. By this Court’s count, the Legislature employed the term “possession, custody, or control” in six different rules or sections of the CPLR.51 All but one of those six uses the phrase in the context of the potential disclosure of information — i.e., discovery.52 By contrast, the phrase “possession or custody” — without reference to “control” — appears in the CPLR eleven times.53 In each and every one, the rule or section governs or is related to the disposition of property.54 Clearly, then, the Legislature persistently chose to set a higher standard for instances where property is at issue than for disputes involving discovery. Faced with such a clear and consistent textual difference throughout the CPLR,55 coupled with an eminently reasonable and intuitive practical justification for it, the Court will not look the other way to avoid the conclusion that the omission of “control” in Section 5225 was deliberate and meaningful.

CNMI nevertheless attempts to blur the linguistic distinction between the two phrases, contending that both require practical tests and that the words “possession or custody” therefore inevitably encompass a meaning at least similar to “control.” It cites Koehler v. Bank of Bermuda Ltd.56 for the proposition that “a turnover order directed at an entity subject to jurisdiction in New York can reach assets located outside the [United States], where that entity has control over the assets in question.”57 CIBC, it argues, enjoys such “control” over CFIB through its stock ownership. CNMI further cites58 Gucci America, Inc. v. Curveal Fashion, 59 in replying to CIBC’s argument that CNMI could not cite a single case “that *213permits service on a New York branch of a bank that owns a different bank in order to restrain accounts at that separate and different bank.”60 It contends that the Gucci court ordered disclosure of documents held by the Malaysian subsidiary of a Singapore bank “on the grounds of control,” and that such a conclusion supports its entitlement to a turnover order here.61

Neither of CNMI’s cases is helpful to its argument. Gucci involved a different branch of one bank rather than a separately incorporated subsidiary — a distinction of enormous consequence here.62 Koehler is far more relevant, but likewise unavailing.

At oral argument, CNMI contended that Koehler “fills the missing gap despite the different language in the CPLR” because, it argued, the Koehler court, in analyzing Section 5225, did so “in terms of control as opposed to actual possession.”63 But any language in Koehler to that effect was unnecessary to the decision.64 The New York Court of Appeals there answered a question certified to it by the Court of Appeals for the Second Circuit, viz. “whether a court sitting in New York may order a bank over which it has personal jurisdiction to deliver stock certificates owned by a judgment debtor (or cash equal to their value) to a judgment creditor, pursuant to CPLR article 52, when those stock certificates are located outside New York.”65 It answered that question in the affirmative.66 However, the Court of Appeals did not go — indeed, could not have gone — farther than that question and the facts before it. Neither the Court of Appeals, nor the Second Circuit after the certified question was answered,67 ever addressed the consequence of the fact that the garnishee bank in Koehler had transferred the stock certificates at issue to another company during the litigation — that the assets in issue were in the actual possession of a separate, affiliated entity. Yet the question left open by the courts in Koehler is precisely what is at issue before this Court in this case.

The Court is not satisfied that CNMI has satisfied its burden under Section 5225(b)68 to show that CIBC is in “possession or custody” of the Millards’ CFIB Cayman Islands accounts.69 Given the Court’s *214legal conclusion as to the import of the omission in Section 5225 of the word “control,” that the targeted accounts are housed entirely at CFIB' — -an entity which, however closely linked to CNMI, has not even been served in this action — effectively ends the inquiry.

That said, the Court is mindful that the issue it has decided is an unsettled question of New York law on which it is unlikely to have the last word. Moreover, although the Court need not decided the point in the present context, it notes that CNMI has made a substantial showing that under the more relaxed, “practical” standard advocated by CNMI, CNMI’s evidence might be sufficient to warrant a turnover order. As discussed above, by its own public statements, CIBC enjoys “full oversight of the risk and control framework of all [of CFIB’s] operations.” 70 It touts also its “committment] to make available to the [Federal Reserve] Board ... information on the operations of [CIBC] and any of its affiliates” to comply with federal law.71 It requires CFIB to comply with U.S. legal requirements such as Sarbanes-Oxley and the PATRIOT Act.72 And CIBC and CFIB have significant personnel overlaps, even at senior levels of management 73 — though, to be sure, the extent of those overlaps is disputed by CIBC.74 While the import of all of those evidentiary matters are in dispute, the Court considers that they, at the very least, suggest that it is within CIBC’s practical power to, somehow, access and turn over the account funds in question here.75

*215It follows, then, that if a finding that “CIBC has the control, power, authority and practical ability to order [CFIB] to turn over funds on deposit in the name of the Millards and entities controlled by the Millards pursuant to an order from this Court”76 were sufficient as a matter of law under Section 5225, an evidentiary hearing delving further into the merits of these and additional bits of evidence could be appropriate.

Injunction Pending Appeal

This Court previously issued a restraining order as to CIBC and the Millard accounts at issue. Because of the paucity of state-law decisions interpreting the precise meaning of “possession or custody” under Section 5225(b), compounded with the risk that the Millards’ knowledge of these turnover actions might already be jeopardizing CNMI’s ability to secure funds in satisfaction of its tax judgments, the Court finds it appropriate to leave that restraint in place, under Federal Rule of Appellate Procedure 8, pending CNMI’s appeal to the Second Circuit77 and, if that Court were to deem it appropriate, certification of this interesting question to the New York Court of Appeals for an authoritative determination of state law.78 Despite its denial of CNMI’s motion, the Court considers CNMI’s argument to have sufficient force amidst admittedly murky concepts to eventually have a fair chance of success on the merits. It further finds that CNMI’s interests face irreparable injury should the restraint dissolve, that continuing the restraint will not harm the interests of the CBIC in any way, and that the public interest lies in preventing the further dissolution or movement of assets in avoid-anee of a registered tax judgment.79 Accordingly, an appropriate injunction pending appeal will issue.

Discovery

Finally, the Court notes that CNMI has moved for an order compelling additional discovery regarding the Millards’ associated accounts in the CBIC subsidiary banks.80 As the Court has denied the motion for a turnover order, these and any other discovery issues pending between CNMI and CIBC are now moot.

Conclusion

For the foregoing reasons, the plaintiffs motion for a turnover order and preliminary injunction against the defendant [Sealed DI] is denied, as is the plaintifPs motion to compel disclosure [DI 76], the latter on the ground of mootness and without prejudice to renewal should circumstances warrant. The restraining order previously entered is continued in force pending the filing and disposition of any appeal from this order.

SO ORDERED.