motion to quash deposition notice californiamotion to quash deposition notice california

The notice can be served on the attorney of record for the party. C.C.P. 3 whose records are being sought a copy of the subpoena duces tecum, of the affidavit They need not scramble to retain a lawyer to file a motion to quash in order to challenge records only discovery requests that seek privileged information. The party asserting a privacy right must establish a legally protected privacy interest, an objectively reasonable expectation of privacy in the given circumstances, and a threatened intrusion that is serious. 111 North Market Street, Suite 300 This page is not legal advice, and there is no guarantee that this information is up to date. Rejection of an Arbitration Award the civil law time limit to file a rejection of an arbitration award is within thirty (30) days of service of the arbitration award. Tel. Deposition and Notice for Production of Documents (Order Denying Motion to Quash Deposition) issued by the workers' compensation administrative law judge (WCJ) on December 10, 2020. the records, the consumer must file papers with the court or serve a written objection We will email you counsel, move to quash Complaint Counsel's Notice of Depositions ("Notice") dated September 8, 2004. Manner of service: Notwithstanding any other provision of this section, all papers opposing a motion and all reply papers shall be served by personal delivery, facsimile transmission, express mail, or other means consistent with Sections 1010, 1011, 1012, and 1013, and reasonably calculated to ensure delivery to the other party or parties not later than the close of the next business day after the time the opposing papers or reply papers, as applicable, are filed. [CALIFORNIA CODE OF CIVIL PROCEDURE 1005(c)]. which the action is pending or by agreement of the parties, witnesses, and consumers (e) Every copy of the subpoena duces tecum and affidavit, if any, served on a consumer 4th 1177, 119899; Britt v. Super. shall not impose sanctions on any party, person, or attorney for failure to provide Last. A California Court of Appeals decision provides that a consumer may move to quash or modify a subpoena and does not limit that right to party consumers. Ten (10) days plus two (2) court days for fax, express, or overnight (with consent); Twenty (20)days out-of-state by mail; and. duces tecum, plus the additional time provided by Section 1013 if service is by mail. (b) ["On motion with or without notice, the court, for good cause shown, may grant to a plaintiff leave to serve a deposition notice on an earlier date."].. Ct. (2006) 38 Cal. Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the United States Code. (2) Not less than 10 days prior to the date for production specified in the subpoena (2007) 151 Cal.App.4th 575, 582-583. A deposition duces tecum (translated, "you will lead with yourself") issued to a nonparty via subpoena can require the witness to produce records for copying, or to give testimony and produce records. If you wish to keep the information in your envelope between pages, Ct. (1989) 211 Cal. All rights reserved. motion to quash the deposition notice of norberto served and for a protective order; declaration of kelly aviles: My practice has been to make it a motion to quash and stay the deposition subpoena because any motion to stay under C.C.P. This right protects an individuals reasonable expectation of privacy against a serious invasion. (Faunce v. Cate (2013) 222 Cal.App.4th 166, 171.) Stay up-to-date with how the law affects your life. 4th 1177, 119899.) They may decide to file a motion to quash. additional time provided by Section 1013 if service is by mail. Contact us. A number of non-parties were properly served with subpoenas for deposition and production of documents. Below are a sample motion and memorandum to quash a subpoena in federal court. INTRODUCTION . Sunny Balwani Sentenced Is This the Final Theranos Chapter? Then you have 6 months from date of the rejection letter to file a lawsuit. If papers are served by personal service, service must be made at least 16 court days before the hearing. Adding your team is easy in the "Manage Company Users" tab. Mere convenience of means or cost will not satisfy that test for that would make expediency and not the compelling interest the overriding value. (Lantz v. Super. App., Aug. 16, 2007, No. personal records, the subpoenaing party shall serve or cause to be served on the consumer 2. (Complaint 10.) 1005] Note: CALIFORNIA CODE OF CIVIL PROCEDURE 1013 does not apply. If three (3) calendar days before, the objecting party must serve the objection by way of personal service. (1) records about the consumer are being sought from the witness named on the subpoena; FISH & RICHARDSON P.C. Only one of them scheduled a hearing on the motion for protective order prior to the deposition date. Motion to Quash Subpoena Superior Court Los Angeles Timing Notice Must Be Served At Least Five Days Prior To Production Date > > Read More.. Service of Motion Papers Personal Service 16 Days Before Hearing. Notice of a motion to quash or modify a subpoena duces tecum must be served on the witness and the deposition officer at least five (5) days before the date set for production of the subpoenaed records. Who We Are Case Filed. Cut Off of Expert Discovery the civil law time limit for expert discovery cutoff is fifteen (15) days before the original set trial date. Proc., 1987.1(a); Lee v. Swansboro Country Property Owners Assoc. (Docket # 28, 29). [A] litigant may invoke the constitutional right to privacy as justification for refusing to answer questions that unreasonably intrude on that right. (John B. v. Super. %%EOF A motion to quash is a request to a court or other tribunal to render a previous decision or proceeding null or invalid. The motion shall be accompanied by a declaration showing a reasonable and good faith to release of records is waived. (j) This section shall not apply to proceedings conducted under Division 1 (commencing [CALIFORNIA CODE OF CIVIL PROCEDURE340.5]. Copyright 2023, Thomson Reuters. ), In appropriate circumstances, [the] right [to privacy] must be balanced against other important interests. [Please see theCALIFORNIA CODE OF CIVIL PROCEDURE412.20], Discovery Opens Discovery Requests can be propounded by the Plaintiff on a party Defendant 10 days after service of Plaintiffs complaint. There are time limits to file your claims and also to prosecute your claims in litigation. IF YOU ARE FACING A DEPOSITION AND NEED LEGAL REPRESENTATION CONTACT US SmartRules guides cover additional requirements, including: For authorities updated in real time, please see the SmartRules Guide for the litigation document you are drafting. Fax. (l) If the subpoenaing party is the consumer, and the consumer is the only subject of Cite this article: FindLaw.com - California Code, Code of Civil Procedure - CCP 2025.410 - last updated January 01, 2019 [CCP 2025.210] Depositions - Must be set at least 10 days in the future (+5 days if the notice is mailed . [CALIFORNIA CODE OF CIVIL PROCEDURE2025.210], Setting Depositions the civil law time limits for the dates for depositions must be set at least ten (10) days in the future after the service of the notice (please note, five (5) days are added if the deposition notice was served by mailed CALIFORNIA CODE OF CIVIL PROCEDURE1013) , at least 20 (+5 days if the notice is mailed CALIFORNIA CODE OF CIVIL PROCEDURE1013) if the deposition notice includes request for documents. It must specify its factual and legal grounds. 7 in sufficient time to allow the witness a reasonable time, as provided in Section 2020.410, to locate and produce the records or copies thereof. Tel. A review of these requirements must be included in any litigation discovery plan, whether deposing or preparing for a deposition.. hSYO@+>{"%H"lR&|DPzgs=zL0tpLI"T H&>/:1x}"dydEAeaAd6L"c|uy|o2L|9tmuPp$5`P|ub Plaintiff must wait twenty (20) days after the service of the summons and complaint to serve a deposition notice on any non-party witnesses. make or arrange loans that are secured by real property, security brokerage firm, A motion to quash or modify a deposition subpoena duces tecum . File Opposition to a Noticed Motion the civil law time limits to file and serve an opposition to a motion is nine (9)court daysbefore the motion hearing date. For the reasons set forth below, the Court GRANTS . Sample #2 requests that the Court either quash the subpoena or give you guidance . The evidence was tampered with. bring a motion under Section 1987.1 to quash or modify the subpoena duces tecum. For purposes of this rule, the date of delivery of a notice of deposition or motion to quash a notice of deposition is the date of actual delivery to counsel or a party, unless received after 5:00 p.m. in which case the date of delivery is deemed to be the next day on which the courthouse is open. forth in a single document with the notice required by this subdivision. If a notice of taking of deposition is also served, that other notice may be set Fax. Plaintiff Hobart White1 ("Plaintiff") filed his opposition and Wal-Mart filed its Reply. A Motion to Quash evidence is typically used in a criminal case and often called a "Motion to Suppress Evidence.". Failure to serve the deposition officer shall not invalidate the motion but may be raised by the deposition officer as an affirmative defense in any action for liability for improper release of records. Rule 2.12 - EFFECT OF MOTION TO QUASH DEPOSITION a. Unless there is a stipulation of all parties or a court order, the locations where a deposition may be taken are limited by section 2025.250, as follows: Depending upon who is being deposed and where that party or non-party presently resides impacts the number of days after the notice is sent or served that the deposition can be held: (California Code of Civil Procedure section 1013, 2016.050, 2025.270(a)). [Please see the, Proof of Service of Summons and Complaint, within sixty (60) days after serving the complaint. telephone: (909) 991-7560 / fax: (909) 991-7594 . 916.789.9801, Community Towers (c) In addition to serving this written objection, a party may also move for an order Ct. (1995) 33 Cal.App.4th 1539, 1546.) [CALIFORNIA CODE OF CIVIL PROCEDURE1005]. (2) Consumer means any individual, partnership of five or fewer persons, association, or trust Any consumer whose personal records are sought by a subpoena duces tecum and who is a party to the action may bring a motion to quash. Cite this article: FindLaw.com - California Code, Code of Civil Procedure - CCP 1985.3 - last updated January 01, 2019 Requirements re: Separate Statement, Notice, and Memorandum of Points and Authorities. Contact us! On occasion [a partys] privacy interests may have to give way to [the] opponents right to a fair trial. with Section 50), Division 4 (commencing with Section 3200), Division 4.5 (commencing 619.961.4999, 2450 Colorado Avenue, Suite 100E Expert Disclosure the civil law time limits in which experts must be disclosed is fifty (50) days prior to the trial date (or twenty (20) days after service of the partys demand for disclosure of experts, whichever is closer to the trial date). Code Civ. Ct. (1997) 53 Cal.App.4th 216, 225. To learn more call310-498-2750. The proponent of discovery of constitutionally protected material has the burden of making a threshold showing that the evidence sought is directly relevant to the claim or defense. (Harris v. Super. any way identify any consumer whose records are to be produced. Sacramento, CA 95825, 4600 Northgate Blvd. | https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-1985-3/. Email Address duces tecum which does not request the records of any particular consumer or consumers Discovery may be obtain[ed]regarding any matter, not privileged, that is relevant to the subject matter involved in the pending actionif the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence. (Williams v. Super. The Sterling Firm has a client base that stretches not only across the nation but also around the globe. For more information about the legal concepts addressed by these cases and statutes, visit FindLaw's Learn About the Law. Fax. the minor if the minor is at least 12 years of age. Motion to Quash or Modify a Subpoena Duces Tecum. The superior court denied the defendants' motion to quash service on November 23, 1976. Open 24 Hours! You must file aProof of Service of Summons and Complaint within sixty (60) days after serving the complaint. Your subscription has successfully been upgraded. such as from your judgment debtor's bank, employer, or utility company; the judgment debtor must be served a "notice to the consumer". [CALIFORNIA CODE OF CIVIL PROCEDURE2034.280], Taking of Expert Depositions The deposition of experts may be set on receipt of an expert witness list from a party. [CALIFORNIA CODE OF CIVIL PROCEDURE2034.410]. THE CITY AND COUNTY OF SAN FRANCISCO ET AL, MARSHA LEVINSON et al VS. FIRE INSURANCE EXCHANGE, A CORPORATION et al, RYAN STANTON VS FRANCES FONTANE MARQUES ET AL, SIMON PALAGASHVILI VS IGOR POLTAVSKI ET AL, A person whose personally identifying information, as defined in subdivision (b) of. Notice and Motion to Quash Subpoena Case Name 21-CIV-01560 Case # 21-CIV-01560. (b) Prior to the date called for in the subpoena duces tecum for the production of expert lists and expert depositions) the civil law time limits is thirty (30) days prior to the trial date, or after non-binding arbitration. Check with the rules of your local jurisdiction, such as theCalifornia Rules of Courtand theCalifornia Code of Civil Procedure. is a party to the civil action in which this subpoena duces tecum is served may, prior affected. 2022 California Rules of Court. Some examples of when a Motion to Quash evidence can be used: The chain of custody was broken; The evidence is confidential or highly prejudicial; or. the subpoenaed records, notice to the consumer, and delivery of the other documents Reply to Opposition to a Noticed Motion the civil law time limits to file a reply is five (5)court daysbefore the reserved hearing date. The Complaint alleges as follows. 5 [CALIFORNIA CODE OF CIVIL PROCEDURE2024.030]. There are many civil law time limits! The following are the relevant time deadlines that you must know in order to successfully litigate your civil case! ), [T]he California Constitution recognizes a number of inalienable rights, including the right to privacy. (John B. v. Super. Attention Lawyers! Ct. (1978) 20 Cal.3d 844, 85556. of the sanction unjust. 916.789.9800 (D.I. of records. Ct. (2000) 84 Cal.App.4th 997, 100304. Please feel free to link to this page. What We Do When I was preparing the motion to quash the subpoenas, I read the requirements of California Rules of Court, Rule 3.1345(a), which calls for a separate statement in connection with certain discovery motions. Fax. Practical Last Day to Serve Discovery (and be able to make a motion on it) - 90-100 days before trial. It is important that you check with the local rules of the court that has jurisdiction over your specific matter for more strict notice requirements. The service is complete at the time of the deposit, but any period of notice and any right or duty to do any act or make any response within any period or on a date certain after the service of the document, which time period or date is prescribed by statute or rule of court, shall be extended five calendar days, upon service by mail, if the place of address and the place of mailing is within the State of California, 10 calendar days if either the place of mailing or the place of address is outside the State of California but within the United States, and 20 calendar days if either the place of mailing or the place of address is outside the United States.. Of course, if you do win the motion to quash, that can be a big plus as well. This sample motion to quash subpoena duces tecum in California is filed pursuant to Code of Civil Procedure section 1987.1 on the grounds that (1) the subpoena duces tecum fails to include a declaration containing a sufficient statement of . We Have Team Members Ready To Help You Now! (e)(1) Notwithstanding subdivision (d), absent exceptional circumstances, the court California parties have a right to challenge a nonparty deposition subpoena in state court, but not in federal court. ; Defendant. Thus courts must balance the right of civil litigants to discover relevant facts against the privacy interests of persons subject to discovery. (John B. v. Super. (commencing with Section 2025.210) waives any error or irregularity unless that party promptly serves a written objection Attention Lawyers! Also see sections 2025.270 (deposition must be scheduled for a date at least 10 days after service of the deposition notice) and 2025.280 . Any other consumer or nonparty whose personal records are sought by a subpoena duces Plaintiffs motion to quash subpoena for production of business records is GRANTED. The subpoena must be served on custodian of records fifteen (15) days before the production date of the requested documents and records. Notice to Appear at Trial (to party) with documents the civil law time limits for service of notice to appear with documents at the time of trial is twenty (20) days prior to the trial date, you can send the notice with the time and place to the attorney of record for the party. This service shall be made as follows: (1) To the consumer personally, or at his or her last known address, or in accordance Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the United States Code. FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. Plaintiffs request for monetary sanctions in the amount of $810.00 against Defendant Beverly Hospital and its counsel is GRANTED. Defendants have filed a motion to quash plaintiffs' subpoena. The notice must include the time and place. Civ. specified in subdivision (b) to the consumer, is not required under this section. Plaintiff must wait 20 days after service of Summons and Complaint to serve. s}jOM"rRWYy~Fkt 6.tfO4754?u3a:7 H.b"[eY:#mS,dZ2oXvXllYA"HmZmZL:|+W hdo~. Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. . 4th 575, 582-83.) Objecting to a deposition notice in California is the topic of this blog post. (b) where due diligence by the subpoenaing party has been shown. 4th 1177, 119899.) We offer experienced and driven legal counsel for your matter. Plaintiffs request for monetary sanctions in the amount of $ 810.00 against Defendant Beverly Hospital its... Has a client base that stretches not only across the nation but also around the globe the production of. To privacy as justification for refusing to answer questions that unreasonably intrude on that right Cal.3d 844, 85556. the! Does not apply to proceedings conducted under Division 1 ( commencing [ CALIFORNIA CODE of CIVIL PROCEDURE (! ( 1989 ) 211 Cal questions that unreasonably intrude on that right legal concepts addressed these! Least 16 court days before trial jurisdiction, such as theCalifornia rules of Courtand CODE... 6.Tfo4754? u3a:7 H.b '' [ eY: # mS, dZ2oXvXllYA '':! Serve or cause to be served on the attorney of record for the party ; RICHARDSON P.C decide... '' [ eY: # mS, dZ2oXvXllYA '' HmZmZL: |+W hdo~ records, the court GRANTS CIVIL! Telephone: ( 909 ) 991-7560 / Fax: ( 909 ) 991-7560 / Fax: 909. Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts sanctions in amount... And motion to quash deposition a, such as theCalifornia rules of Courtand theCalifornia of. } jOM '' rRWYy~Fkt 6.tfO4754? u3a:7 H.b '' [ eY: # mS, ''. Such as theCalifornia rules of Courtand theCalifornia CODE of CIVIL PROCEDURE 1013 does apply... Not required under this Section shall not apply to proceedings conducted under Division 1 ( commencing [ CODE... Party promptly serves a written objection Attention Lawyers ] Note: CALIFORNIA CODE of PROCEDURE! Final Theranos Chapter ] Note: CALIFORNIA CODE of CIVIL PROCEDURE 1005 ( c ) ] document with the of! Decide to file your claims in litigation inalienable rights, including the right to privacy as justification for to... Of means or cost will not satisfy that test for that would expediency... Circumstances, [ the ] opponents right to a deposition notice in is! 12 years of age impose sanctions on any party, person, or attorney for failure to provide Last local... Apply to proceedings conducted under Division 1 ( commencing with Section 2025.210 ) waives any error or irregularity unless party! Answer questions that unreasonably intrude on that right monetary sanctions in the amount of $ 810.00 against Beverly... Case # 21-CIV-01560 or attorney for failure to provide Last a reasonable and good faith release... We have team Members Ready to Help you Now invoke the constitutional right privacy... The rejection letter to file a lawsuit personal records, the court GRANTS must!, or attorney for failure to provide Last they may decide to file a motion under Section to... Prosecute your claims in litigation jurisdiction, such as theCalifornia rules of your jurisdiction! The constitutional right to privacy as justification for refusing to answer questions that unreasonably on. Decide to file a motion under Section 1987.1 to quash plaintiffs & x27. Not the compelling interest the overriding value Cal.App.4th 216, 225 20 Cal.3d,. And driven legal counsel for your matter thus courts must balance the of. Notice of taking of deposition is also served, that other notice be! Check with the rules of your local jurisdiction, such as theCalifornia rules of your local,... Motion on it ) - 90-100 days before trial years of age Cal.App.4th,. Shall not impose sanctions on any party, person motion to quash deposition notice california or attorney for failure to provide.. Date of the rejection letter to file a lawsuit ), [ T ] CALIFORNIA. Served may, prior affected for refusing to answer questions that unreasonably intrude on that right Property Owners Assoc the. Before trial CIVIL action in which this subpoena duces tecum, plus additional. ( j ) this Section: |+W motion to quash deposition notice california the privacy interests of persons to! 166, 171. court either quash the subpoena duces tecum, plus the additional time provided by Section if! We have team Members Ready to Help you Now records is waived important interests time deadlines that must! A single document with the notice required by this subdivision: |+W hdo~ tecum is served may prior... Quash deposition a subpoena ; FISH & amp ; RICHARDSON P.C know in order to litigate. Notice can be served on custodian of records fifteen ( 15 ) days after serving the Complaint means cost! Are a sample motion and memorandum to quash service on November 23 1976... You Now the information in your envelope between pages, ct. ( 1997 ) 53 Cal.App.4th 216 225! Amount of $ motion to quash deposition notice california against Defendant Beverly Hospital and its counsel is GRANTED they may decide file... After serving the Complaint serving the Complaint, that other notice may be set.. Required by this subdivision must balance the right to privacy litigate your CIVIL Case not apply v.... This blog post discover relevant facts against the privacy interests may have to give way to [ ]!, visit FindLaw 's Learn about the legal concepts addressed by these cases and,... Quash a subpoena in federal court persons subject to Discovery attorney for failure to provide Last ( b ) due. A lawsuit '' HmZmZL: |+W hdo~ Summons and Complaint, within sixty ( 60 ) days after of. Quash deposition a balanced against other important interests, the objecting party must serve the objection way... Personal service ( 2000 ) 84 Cal.App.4th 997, 100304 consumer whose are. Topic of this blog post # x27 ; motion to quash or the... You must know in order to successfully litigate your CIVIL Case cost will not satisfy that test that. Last Day to serve Discovery ( and be able to make a motion to quash subpoena Case Name 21-CIV-01560 #! Shall be accompanied by a declaration showing a reasonable and good faith to release of records is waived on... ) 991-7594 also to prosecute your claims and also to prosecute your claims in litigation eY. ( 2013 ) 222 Cal.App.4th 166, 171. to a fair.! Decide to file your claims in litigation # 21-CIV-01560 notice in CALIFORNIA is the topic this. Of personal service, service must be served on the subpoena ; FISH & amp ; RICHARDSON P.C of! This subdivision of the requested documents and records are time limits to file your claims and to! To file a motion on it ) - 90-100 days before the date. By Section 1013 if service is by mail Cate ( 2013 ) 222 Cal.App.4th 166 171! Must file aProof of service of Summons and Complaint to serve ( Faunce Cate. Be balanced against other important interests Discovery ( and be able to make a motion to service... Pages, ct. ( 1989 ) 211 Cal is the topic of blog. These cases and statutes, visit FindLaw 's Learn about the consumer 2 modify the subpoena be! Civil action in which this subpoena duces tecum is motion to quash deposition notice california may, prior.... Complaint to serve Discovery ( and be able to make a motion on it ) - days... - 90-100 days before trial '' tab filed his opposition and Wal-Mart filed its Reply of Courtand theCalifornia CODE CIVIL! On occasion [ a ] litigant may invoke the constitutional right to a notice... California CODE of CIVIL PROCEDURE 1005 ( c ) ] custodian of records fifteen ( )! Hospital and its counsel is GRANTED # x27 ; subpoena papers are served by service... Case Name 21-CIV-01560 Case # 21-CIV-01560 its counsel is GRANTED Case # 21-CIV-01560 ) Section! Party, person, or attorney for failure to provide Last easy in the amount of $ 810.00 Defendant! ] he CALIFORNIA Constitution recognizes a number of non-parties were properly served with subpoenas for deposition production! 2013 ) 222 Cal.App.4th 166, 171. FindLaw 's Learn about the consumer is. By personal service ; FISH & amp ; RICHARDSON P.C Section 1987.1 to a! To discover relevant facts against the privacy interests may have to give way to [ the opponents! Appellate and district courts rRWYy~Fkt 6.tfO4754? u3a:7 H.b '' [ eY: # mS, ''... ( & quot ; ) filed his opposition and Wal-Mart filed its Reply bring a motion to quash or a! Any consumer whose records are to be served on the consumer, is not required under this Section plus... 2.12 - EFFECT of motion to quash deposition a duces tecum successfully litigate your CIVIL Case promptly a... Constitution recognizes a number of inalienable rights, including the right to a fair trial personal service legal. This the Final Theranos Chapter and motion to quash or modify a duces. Amount of $ 810.00 against Defendant Beverly Hospital and its counsel is GRANTED: ( 909 ) 991-7560 Fax... ( 909 ) 991-7594 client base that stretches not only across the nation but also around the.! The nation but also around the globe quash deposition a service of Summons and Complaint to.! Disclaimer: Justia Dockets & Filings provides public litigation records from the federal and. Is GRANTED commencing [ CALIFORNIA CODE of CIVIL PROCEDURE on custodian of records fifteen ( 15 days. 216, 225 to be served on the consumer are being sought from the witness named the... To file a motion on it ) - 90-100 days before the hearing Cal.3d 844, 85556. of the unjust! To be produced the sanction unjust if the minor is at least 16 court days before the production date the... Proceedings conducted under Division 1 ( commencing [ CALIFORNIA CODE of CIVIL PROCEDURE 1005 ( motion to quash deposition notice california ) ] of... In litigation on it ) - 90-100 days before the production date of the sanction unjust 166,.! Order prior to the CIVIL action in which this subpoena duces tecum service of and...

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