These sample objections to a Rule 45 subpoena in United States District Court are used by a party or nonparty to object to a Rule 45 subpoena that requests the production of documents. The sample objections on which this preview is based is 32 pages and include brief instructions, sample objections and a proof of service. The author is an entrepreneur and retired litigation paralegal that worked in California and Federal litigation from January 1995 through September 2017 and has created over 300 sample legal documents for sale. Note that the author is NOT an attorney and no guarantee or warranty is provided.

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Any Attorney or Party
Any Street
Any Town, CA 55555
714-555-5555
Any Attorney or Party
UNITED STATES DISTRICT COURT
________________ DISTRICT OF _________________
Any Plaintiff,
Plaintiff,
vs.
Any Defendant,
Defendant.
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Case No.
___________’s OBJECTIONS TO
______________’S RULE 45 SUBPOENA
DATE: TIME:
DEPT:
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_______________’S OBJECTIONS TO __________________’S RULE 45 SUBPOENA

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Be sure to remove this notice and all other notices before using
this document. 1
1TO: ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that _________________, a party/responding party in the above
styled and numbered cause of action, pursuant to Fed. R. Civ. P. 45(d)(2)(B), and without waiving
any further objection and/or assertions of privilege to any specific documents when or if such
documents are identified, hereby serves these written objections to _________’ subpoena to produce
documents.
Be sure to modify this to suit your individual situation. Do NOT
just use the wording here unless it definitely applies to your particular
situation. Add or delete any numbers above to suit your particular
situation. Serve the objections on the other party “before the earlier
of” the production date or 14 days after service of the subpoena. See
Fed. R. Civ. P. 45 (d)(2)(B).
GENERAL OBJECTIONS
1. ____________objects to the subpoena as it fails to allow a reasonable time to comply.
2. _______ objects to the subpoena as it subjects the responding party to undue burden.
The document request are unreasonably overbroad and in many respects the responding party can do
no more than guess as to the information which is being sought to be produced. Furthermore, the
records retention schedule for much of the requested material is five years. _______’ requests span a
__ 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

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for this material is extremely burdensome, time-consuming, labor intensive and expensive for the
responding party. Responding party further objects to the subpoena to the extent it requires the
responding party to conduct an extensive search of other party’s records, none of which are under the
control of the responding party. Assuming the responding party had the authority to conduct such
searches, which it does not, such an extensive search poses an undue burden in time, labor and
expense.
2. ____________ objects to the Document Requests as overly broad, unduly
burdensome, and not reasonably calculated to lead to the discovery of admissible evidence in
determining whether or not ________________________ .
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rule-45-subpoena-in-united-states-district-court
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_______________’S OBJECTIONS TO __________________’S RULE 45 SUBPOENA