Monica S. Ramsey, et al. v. Independent Specialty Insurance Company, et al.

Summary

The United States District Court for the Eastern District of Louisiana grants non-parties Velocity Claims, LLC and Velocity Risk Underwriters, LLC’s motion to quash subpoenas duces tecum. The court finds that the subpoenas were improperly served, required production outside the geographic limits of Federal Rule of Civil Procedure 45, and allowed less than a reasonable time for compliance. The court notes additional concerns regarding cumulative, overbroad, confidential, and privileged discovery but does not resolve those issues.

Holdings

1. The motion to quash was timely because it was filed on the subpoenas’ compliance date and the record showed service and reissuance defects concerning the earlier subpoenas.
2. Service was defective because the subpoenas were not personally delivered to the non-parties’ agents for service of process.
3. The subpoenas were invalid because they required production beyond the geographic limit imposed by Rule 45(c)(2)(A).
4. The subpoenas were invalid because they required production less than fourteen days after service and therefore failed to allow a reasonable time to comply.

Questions Presented

1. Whether the motion to quash was untimely.
2. Whether service of the subpoenas on the non-parties’ Louisiana registered agent by Federal Express satisfied Federal Rule of Civil Procedure 45(b)(1).
3. Whether the subpoenas improperly required production outside the geographic limitations of Rule 45(c)(2)(A).
4. Whether the subpoenas allowed a reasonable time for compliance under Rule 45(d)(3)(A)(i).

Disposition

other