In anticipation of litigation, Counsel for Plaintiff employed investigators to locate and interview witnesses, to perform background checks, interview first responders, including state troopers and EMTs, as well as performing other investigative services regarding the crash.As a result of the crash, the Plaintiff was seriously injured and spent months in the hospital and rehabilitation facilities.This case arose out of a truck/automobile crash which occurred on January 8, 2020, in Baltimore County, Maryland.
Plaintiff John Doe, by and through his undersigned counsel, requests this Honorable Court quash the subpoena served on ABC Investigative Solutions, LLC (ABC). PLAINTIFF'S MEMORANDUM IN SUPPORT OF HIS MOTION TO QUASH DEFENDANT JANE SMITH’S SUBPOENA TO PRODUCE DOCUMENTS SERVED ON ABC INVESTIGATIVE SOLUTIONS, LLC The subpoena also seeks documents which are attorney work product, and there has been no showing of substantial need, undue hardship, and inability to obtain the information from another source.įor the reasons set forth herein and in Plaintiff's Memorandum in Support of his Motion to Quash attached hereto and incorporated herein by reference, Plaintiff respectfully requests this Honorable Court to quash the subpoena served on ABC Investigative Solutions, LLC.The subpoena is defective as it fails to identify the attorney issuing the subpoena.ABC, a non-party, is located more than 100 miles from the issuing Court. That makes this Court both the issuing court and compliance court. Defendant Smith issued the subpoena out of the United States District Court for the District of Maryland, where the action is pending and directed ABC to produce documents in Baltimore, Maryland. North Street, Baltimore, Maryland 21201 and Washington and Lincoln, 10 South Drive, Tampa, Florida 33610. The subpoena directs the Custodian of Records for ABC to produce the requested documents in two different locations: Washington and Lincoln, 2 N.Plaintiff John Doe, by and through his undersigned counsel, requests this Honorable Court quash the subpoena served on ABC Investigative Solutions, LLC (ABC) because: PLAINTIFF'S MOTION TO QUASH DEFENDANT JANE SMITH’S SUBPOENA TO PRODUCE DOCUMENTS SERVED ON ABC INVESTIGATIVE SOLUTIONS, LLC IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND Motion for protective order for medical records.But even in federal court, this practice of filing a motion and then the support for the motion is going out of style. We filed this way because it is federal court and this is how we have always done it. There is a short motion to quash and then a memorandum in support. In this case, the defendant seeks to subpoena our law firm's private investigator. Most motions to quash a subpoena involve timeliness, relevancy, improper court, undue burden, the time span covered, standing, and invasion of the attorney-client privilege or work product. Below are a sample motion and memorandum to quash a subpoena in federal court.
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