TEEC Angel Management, LLC, et al. v. Tsingyuan Ventures LLC, et al.

Summary

The court resolves a discovery dispute concerning identical document subpoenas served by plaintiffs on at least 39 limited partners of defendants’ investment fund. It quashes the subpoenas as to requests for documents available from defendants, but defers responses to two requests seeking non-parties’ analyses and decisions to invest until resolution of a pending motion for partial summary judgment. The court declines to quash the subpoenas on the basis of alleged harassment or embarrassment.

Holdings

1. The subpoenas were quashed to the extent they sought documents responsive to RFPs 3 through 7 because those documents should be available from defendants in the first instance.
2. The court did not quash the subpoenas as to RFPs 1 and 2, but nonparties were not required to respond to those requests until the presiding judge decided the pending motion for partial summary judgment.
3. The court declined to quash the subpoenas on the ground that plaintiffs served them to harass or embarrass defendants or nonparties.

Questions Presented

1. Whether the subpoenas should be quashed or modified because requests for documents available from defendants impose an undue burden on nonparties.
2. Whether requests for nonparties' analyses of and decisions to invest in defendants' fund were relevant and proportional to the needs of the case.
3. Whether the subpoenas were served for an improper purpose, including harassment or embarrassment.

Disposition

other