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1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

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8 UNITED STATES DISTRICT COURT

9 ________________ DISTRICT OF _________________

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11 Any Plaintiff, ) Case No.
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12 Plaintiff, ) ___________’s OBJECTIONS TO
) ______________’S RULE 45 SUBPOENA
13 vs. )
)
14 DATE: TIME:
Any Defendant, )
DEPT:
)
15 Defendant. )
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)
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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

22 1. ____________objects to the subpoena as it fails to allow a reasonable time to comply.
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2. _______ objects to the subpoena as it subjects the responding party to undue burden.
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The document request are unreasonably overbroad and in many respects the responding party can do
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no more than guess as to the information which is being sought to be produced. Furthermore, the
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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

7 expense.

8 2. ____________ objects to the Document Requests as overly broad, unduly
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burdensome, and not reasonably calculated to lead to the discovery of admissible evidence in
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determining whether or not ________________________ .
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12 To purchase the entire 32 page document visit:
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15 rule-45-subpoena-in-united-states-district-court
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_______________’S OBJECTIONS TO __________________’S RULE 45 SUBPOENA