[COURT NAME]
[DIVISION] DIVISION

[PLAINTIFF NAME(S)], §
§
Plaintiff[s], §
§ CIVIL ACTION NO. [CASE NO.]
v. §
§
[DEFENDANT NAME(S)], §
§
Defendant[s]. §
________________________________________________§______________________________________________

[MOVING PARTY] MOTION TO QUASH SUBPOENA
________________________________________________________________________________________________

[// GUIDANCE: Insert any required local-rule header language here.]

NOTICE OF MOTION AND MOTION

PLEASE TAKE NOTICE that on [HEARING DATE] at [TIME], or as soon thereafter as counsel may be heard, [MOVING PARTY] will and hereby does move the Court under Fed. R. Civ. P. 45(d) to quash or modify the subpoena issued to [RECIPIENT] on [DATE].

This Motion is based on the accompanying memorandum, declarations, exhibits, the pleadings on file, and such other argument or evidence as may be presented.

MEMORANDUM OF POINTS AND AUTHORITIES

I. Introduction

The subpoena at issue is improper and should be quashed or modified because it [IMPOSES UNDUE BURDEN/SEEKING PRIVILEGED OR IRRELEVANT INFORMATION/FAILS TO ALLOW REASONABLE TIME].

II. Background

• Subpoena issued by: [PARTY] on [DATE].
• Recipient: [PERSON/ENTITY] located in [CITY/STATE].
• Compliance date and location: [DATE / PLACE].
• Materials sought: [SUMMARY].

III. Meet-and-Confer Efforts

• Meet-and-confer letter sent: [DATE].
• Conference(s) held: [DATE/TIME], by [phone/video/in person].
• Issues narrowed to: [LIST].

IV. Legal Standard

The Court must quash or modify a subpoena that fails to allow a reasonable time to comply, requires disclosure of privileged or protected matter, or subjects a person to undue burden. Fed. R. Civ. P. 45(d)(3).

V. Argument

A. The subpoena imposes an undue burden.
[Explain burden, cost, scope, and lack of proportionality.]

B. The subpoena seeks privileged or protected information.
[Explain privilege or privacy issues and propose protective measures.]

C. The subpoena seeks irrelevant or overly broad materials.
[Explain overbreadth and lack of relevance.]

D. The subpoena should be modified if not quashed.
[Offer narrowed scope, date ranges, custodians, or confidentiality terms.]

VI. Requested Relief

[MOVING PARTY] respectfully requests that the Court:
1. Quash the subpoena in whole or in part.
2. Alternatively, modify the subpoena as follows: [LIMITATIONS].
3. Award costs or expenses as permitted under Rule 45(d)(1).

CONCLUSION

For the foregoing reasons, the Court should grant the Motion to Quash.

Respectfully submitted,

text
Dated: [DATE]

______________________________
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
Attorney for [MOVING PARTY]

CERTIFICATE OF SERVICE

I certify that on [DATE], I served the foregoing Motion to Quash Subpoena on all counsel of record via [METHOD OF SERVICE] in compliance with Fed. R. Civ. P. 5.

text
______________________________
[ATTORNEY NAME]

[PROPOSED] ORDER

The Court, having considered [MOVING PARTY]'s Motion to Quash Subpoena and any opposition, ORDERS as follows:
1. The Motion is GRANTED and the subpoena is QUASHED in whole.
2. Alternatively, the subpoena is MODIFIED as follows: [LIMITATIONS].

IT IS SO ORDERED.

Dated: [DATE]

______________________________________
[JUDGE NAME]
United States District Judge