Summary
This United States District Court order denies the defendants' motion to quash a subpoena duces tecum directed at a non-party vehicle leasing company. The court grounds its decision on the defendants' failure to comply with local rules requiring a pre-filing good-faith conference, their untimely filing after the subpoena's compliance deadline, and their lack of standing to challenge the request. The court subsequently orders the non-party to produce the responsive documents by January 29, 2025.
Topics
Practice areas
Questions Presented
- Whether the motion to quash the subpoena was timely under Fed. R. Civ. P. 45(d)(3)(A).
- Whether Defendants have standing to challenge the subpoena duces tecum served on a non‑party.
Holdings
- The motion was untimely because it was filed after the subpoena compliance deadline and therefore is denied.
- Defendants lack standing to challenge the subpoena, and the motion is denied.
Key quotations
“First, “[m]otions regarding subpoenas are considered discovery motions and are governed by the procedural requirements that govern discovery motions.” L.U. Civ. R. 45(e).”
Factual background
Plaintiffs served River City Capital Leasing, LLC with a subpoena on December 13, 2024 requesting documents identifying vehicles leased to Intermodal Cartage Co., LLC between June 1, 2022 and December 22, 2022. Defendants filed a motion to quash the subpoena on January 6, 2025, ten days after the compliance deadline, asserting lack of standing and failure to follow good‑faith conference requirements.
Procedural history
Plaintiffs served a subpoena duces tecum on non‑party River City Capital Leasing, LLC. Defendants filed a motion to quash the subpoena on January 6, 2025, alleging lack of standing and untimeliness. The court denied the motion.