Fill and Sign the Motion Quash Subpoena Form

IN THE ______________ COURT OF ______________ COUNTY STATE OF ________________       ) )       ) Petitioner/Plaintiff, ) ) ) NO.       Vs. ) )       ) Respondent/Defendant ) ) MOTION TO QUASH DEPOSITION SUBPOENA DUCES TECUM COMES NOW _______________________, by and through its attorney and moves the Court to Quash Deposition Subpoena Duces Tecum served upon it on the ____ day of _____________, 20___. In the alternative, Movant prays that the Defendants be required to submit written questions under Rule ____, ____________ Rules of Civil Procedure as to the information contained in Request numbers 1, 2 and 3b under the "knowledge" portion of the Subpoena Duces Tecum and number 2 under the "records” portion of the Subpoena Duces Tecum. As grounds therefore, Movant would respectfully show to the Court the following, to wit: 1. _________________________ was sold to the present owner on the ____ day of _____________, 20___ 2. Movant has no knowledge and/or records pertaining to the information requested in Numbers 3a, 3c, and 3e of the first section of the Subpoena Duces Tecum and Numbers 1 and 3 of the second section of the Subpoena Duces Tecum. Movant states that the information requested in number 3d in the first section and in number 4 in the second section are overly - 1 - broad and burdensome, and would, have very little relevance to the income of ___________________. No sales associate was an employee and therefore there are no payroll records as to sales associates. 3. Movant has the knowledge and/or records to generate answers to written questions submitted under Rule ____, ______________ Rules of Civil Procedure as to the name, address, telephone number and date of affiliation of all sales agents for the company in 20____ and 20____, along with the commissions earned by __________________ in 20____ and 20____. The estimated time to secure this information is four hours and can be produced in response to __RCP Rule ___ questions. 4. WHEREFORE, PREMISES CONSIDERED, Movant prays that upon hearing of this matter, that this Court will issue an order Quashing the Deposition Subpoena Duces Tecum and release Movant from responsibility to appear at said deposition; and further ordering the reimbursement of salary of a person to research the answers to the questions submitted under ___RCP Rule____, and reimbursement of attorney’s fees in connection with the preparation and attendance at the hearing on this Motion. Respectfully submitted, Dated: Name:       Title:       Address:       Address:       City, State, Zip:       Phone:       Fax:       E-Mail:       Attorney No.:       CERTIFICATE OF SERVICE - 2 - I, ______________________________, do hereby certify that I have this day mailed, U.S. Mail, postage prepaid, a true and correct copy of the above and foregoing to __________________________________, at the following address; ___________________________________________________________________ THIS the ____ day of _____________, 20____. ______________________________ - 3 -