[COURT NAME]
[COUNTY], [STATE]

[PLAINTIFF NAME], )
Plaintiff, ) Case No. [CASE NUMBER]
v. )
[DEFENDANT NAME], )
Defendant. )

MOTION TO QUASH SUBPOENA

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/NONPARTY] will and hereby does move the Court for an order quashing or modifying the subpoena served on [DATE] to [RECIPIENT].

MEMORANDUM OF POINTS AND AUTHORITIES

I. Introduction

The subpoena should be quashed or modified because it is overbroad, seeks privileged or confidential information, and imposes an undue burden.

II. Background

• Subpoena served: [DATE]
• Compliance date: [DATE]
• Documents or testimony sought: [SUMMARY]

III. Legal Standard

Courts may quash or modify subpoenas that require disclosure of privileged or protected matter, impose undue burden, or are irrelevant or disproportionate.

IV. Argument

A. The subpoena is overbroad and disproportionate.
[Explain scope and burden.]

B. The subpoena seeks privileged or confidential information.
[Identify privileges or privacy concerns and why protection is required.]

C. The subpoena fails to allow reasonable time for compliance or violates procedural requirements.
[Address timing, notice, or service defects.]

V. Requested Relief

[MOVING PARTY] respectfully requests that the Court:
1. Quash the subpoena in its entirety, or in the alternative, modify it as follows: [PROPOSED MODIFICATIONS].
2. Issue a protective order to safeguard confidential information.
3. Award costs or fees if permitted by law.

CONCLUSION

For the foregoing reasons, the Court should grant the motion to quash subpoena.

Respectfully submitted,

text
Dated: [DATE]

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

CERTIFICATE OF SERVICE

I certify that on [DATE], I served the foregoing Motion to Quash Subpoena on all counsel of record and subpoenaing parties via [METHOD OF SERVICE].

text
______________________________
[ATTORNEY NAME]

[PROPOSED] ORDER

The Court, having considered the Motion to Quash Subpoena, ORDERS as follows:
1. The subpoena served on [DATE] is [QUASHED/MODIFIED].
2. If modified, compliance is limited to: [LIMITATIONS].
3. Any confidential materials shall be subject to a protective order.

IT IS SO ORDERED.

Dated: [DATE]

__________________________________
[JUDGE NAME]
[STATE] Judge