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_______________’S OBJECTIONS TO __________________’S RULE 45 SUBPOENA
1 Be sure to remove this notice and all other notices before using
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this document.
4 TO: ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
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PLEASE TAKE NOTICE that _________________, a party/responding party in the above
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styled and numbered cause of action, pursuant to Fed. R. Civ. P. 45(d)(2)(B), and without waiving
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any further objection and/or assertions of privilege to any specific documents when or if such
9 documents are identified, hereby serves these written objections to _________’ subpoena to produce
10 documents.
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Be sure to modify this to suit your individual situation. Do NOT
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13 just use the wording here unless it definitely applies to your particular
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situation. Add or delete any numbers above to suit your particular
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situation. Serve the objections on the other party “before the earlier
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18 of” the production date or 14 days after service of the subpoena. See
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Fed. R. Civ. P. 45 (d)(2)(B).
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21 GENERAL OBJECTIONS
27 records retention schedule for much of the requested material is five years. _______’ requests span a
28 __ year time period from the present to ____. Trying to search, locate and reconstruct backup drives
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_______________’S OBJECTIONS TO __________________’S RULE 45 SUBPOENA
1 for this material is extremely burdensome, time-consuming, labor intensive and expensive for the
2 responding party. Responding party further objects to the subpoena to the extent it requires the
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responding party to conduct an extensive search of other party’s records, none of which are under the
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control of the responding party. Assuming the responding party had the authority to conduct such
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searches, which it does not, such an extensive search poses an undue burden in time, labor and
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15 rule-45-subpoena-in-united-states-district-court
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_______________’S OBJECTIONS TO __________________’S RULE 45 SUBPOENA