Case 1:16-cv-00455-RGA Document 108 Filed 04/26/17 Page 1 of 10 PageID #: 12527
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`Plaintiff,
`
`Defendants.
`
`
`
`
`
`C.A. No. 16-455 (RGA)
`
`ACCELERATION BAY LLC,
`
`
`
`
`
`TAKE-TWO INTERACTIVE SOFTWARE,
`INC., ROCKSTAR GAMES, INC. and
`2K SPORTS, INC.,
`
`
`
`
`
`
`
`
`
`
`
`
`v.
`
`
`
`NOTICE OF SUBPOENAS (V. BOURASSA AND L. MANGOTTI)
`
`
`
`PLEASE TAKE NOTICE THAT Defendants Take-Two Interactive Software, Inc.,
`
`Rockstar Games, Inc., and 2K Sports, Inc. will serve the subpoenas attached hereto on Mr. Virgil
`
`Bourassa (Ex. 1) and Ms. Linda Mangotti (Ex. 2).
`
`MORRIS, NICHOLS, ARSHT & TUNNELL LLP
`
`/s/ Stephen J. Kraftschik
`_____________________________________
`Jack B. Blumenfeld (#1014)
`Stephen J. Kraftschik (#5623)
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19899
`(302) 658-9200
`jblumenfeld@mnat.com
`skraftschik@mnat.com
`
`Attorneys for Defendants
`
`
`OF COUNSEL:
`
`David P. Enzminger
`Michael A. Tomasulo
`Gino Cheng
`David K. Lin
`WINSTON & STRAWN LLP
`333 South Grand Avenue, 38th Floor
`Los Angeles, CA 90071
`(213) 615-1700
`
`Daniel K. Webb
`Kathleen B. Barry
`WINSTON & STRAWN LLP
`35 West Wacker Drive
`Chicago, IL 60601
`(312) 558-5600
`
`Michael M. Murray
`WINSTON & STRAWN LLP
`200 Park Avenue
`New York, NY 10166
`(212) 294-3510
`
`April 26, 2017
`
`

`

`Case 1:16-cv-00455-RGA Document 108 Filed 04/26/17 Page 2 of 10 PageID #: 12528
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`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on April 26, 2017, I caused the foregoing to be
`
`
`
`electronically filed with the Clerk of the Court using CM/ECF, which will send notification of
`
`such filing to all registered participants.
`
`
`
`
`
`I further certify that I caused copies of the foregoing document to be served on
`
`April 26, 2017, upon the following in the manner indicated:
`
`Philip A. Rovner, Esquire
`Jonathan A. Choa, Esquire
`POTTER ANDERSON & CORROON LLP
`1313 North Market Street, 6th Floor
`Wilmington, DE 19801
`Attorneys for Plaintiff
`
`Paul J. Andre, Esquire
`Lisa Kobialka, Esquire
`James R. Hannah, Esquire
`Hannah Lee, Esquire
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Attorneys for Plaintiff
`
`Aaron M. Frankel, Esquire
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`1177 Avenue of the Americas
`New York, NY 10036
`Attorneys for Plaintiff
`
`
`VIA ELECTRONIC MAIL
`
`VIA ELECTRONIC MAIL
`
`VIA ELECTRONIC MAIL
`
`
`
`
`
`/s/ Stephen J. Kraftschik
`Stephen J. Kraftschik (#5623)
`
`
`
`
`
`

`

`Case 1:16-cv-00455-RGA Document 108 Filed 04/26/17 Page 3 of 10 PageID #: 12529
`Case 1:16-cv-00455-RGA Document 108 Filed 04/26/17 Page 3 of 10 PagelD #: 12529
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`
`
`
`
`
`
`
`
`EXHIBIT 1
`EXHIBIT1
`
`

`

`Case 1:16-cv-00455-RGA Document 108 Filed 04/26/17 Page 4 of 10 PageID #: 12530
`Case 1:16-cv-00455-RGA ‘Document 108 Filed 04/26/17 Page 4 of 10 PagelD #: 12530
`
`AO 88A (Rev. 12/13) Subpoenato Testify at a Deposition in a Civil Action
`
`UNITED STATES DISTRICT COURT
`for the
`
`District of Delaware
`
`ACCELERATION BAY LLC
`
`Plaintiff
`Vv.
`
`
`
` NeeNaarNepean”
`
`Civil Action No.
`
`16-455 (RGA)
`
`TAKE-TWO INTERACTIVE SOFTWARE, INC., -
`ROCKSTAR GAMES,
`INC., and 2K SPORTS,
`INC.
`Defendant
`
`SUBPOENATO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
`
`To:
`
`Virgil Bourassa, c/o. Kramer Levin Naftalis & Frankel LLP, 990 Marsh Road, Menlo Park, CA 94025
`(Name ofperson to whom this subpoenais directed)
`ATestimony: YOU ARE COMMANDEDto appearat the time, date, and place set forth below to testify at a
`deposition to be taken in this civil action. If you are an organization, you must designate one or moreofficers, directors,
`or managing agents, or designate other persons who consentto testify on your behalf about the following matters, or
`those set forth in an attachment:
`
`
`
`Place: Wilson Sonsini Goodrich & Rosati, 701 Fifth Avenue,
`Suite 5100, Seattle, Washington 98104-7036
`
`Date and Time:
`
`
`
`
`
`05/25/2017 9:00 am
`
`stenographer and videographer
`The deposition will be recorded by this method:
`
`
`O) Production: You, or your representatives, must also bring with youto the deposition the following documents,
`electronically stored information, or objects, and must permit inspection, copying,testing, or sampling ofthe
`material:
`
`
`
`The following provisions of Fed. R. Civ. P. 45 are attached — Rule 45(c), relating to the place of compliance;
`Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
`respondto this subpoena and the potential consequences of not doing so.
`
`Date:__04/25/2017
`CLERK OF COURT
`
`
`Signature ofClerk or Deputy Clerk
`Attorney’s signature
`
`The name, address, e-mail address, and telephone numberofthe attorney representing (name ofparty)
`Take-Two
`
`interactive Software, Inc., Rockstar Games,Inc. and 2k Sports,Inc. , who issues or requests this subpoena, are:
`Kathleen Barry, Winston & Strawn LLP, 35 W. Wacker Dr., Chicago, IL 60601 Tel: 312-558-8046, kbarry@winston.com
`
`
`OR
`
`
`
`Notice to the person whoissues or requests this subpoena
`If this subpoena commandsthe production of documents, electronically stored information, or tangible things, a notice
`and a copy of the subpoena mustbe served on each party in this case before it is served on the person to whomit is
`directed. Fed. R. Civ. P. 45(a)(4).
`
`
`
`

`

`Case 1:16-cv-00455-RGA Document 108 Filed 04/26/17 Page 5 of 10 PageID #: 12531
`
`AO 88A (Rev. 12/13) Subpoena to Testify at a Deposition in a Civil Action (Page 2)
`
`Civil Action No.
`
`16-455 (RGA)
`
`PROOF OF SERVICE
`(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)
`
`I received this subpoena for (name of individual and title, if any)
`.
`
`on (date)
`
`(cid:117) I served the subpoena by delivering a copy to the named individual as follows:
`
`(cid:117) I returned the subpoena unexecuted because:
`
`on (date)
`
`; or
`
`Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
`tendered to the witness the fees for one day’s attendance, and the mileage allowed by law, in the amount of
`$
`.
`
`My fees are $
`
`for travel and $
`
`for services, for a total of $
`
`0.00
`
`.
`
`.
`
`I declare under penalty of perjury that this information is true.
`
`Date:
`
`Additional information regarding attempted service, etc.:
`
`Server’s signature
`
`Printed name and title
`
`Server’s address
`
`

`

`Case 1:16-cv-00455-RGA Document 108 Filed 04/26/17 Page 6 of 10 PageID #: 12532
`
`AO 88A (Rev. 12/13) Subpoena to Testify at a Deposition in a Civil Action (Page 3)
`Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13)
`(i) disclosing a trade secret or other confidential research, development,
`or commercial information; or
`(ii) disclosing an unretained expert’s opinion or information that does
`not describe specific occurrences in dispute and results from the expert’s
`study that was not requested by a party.
`(C) Specifying Conditions as an Alternative. In the circumstances
`described in Rule 45(d)(3)(B), the court may, instead of quashing or
`modifying a subpoena, order appearance or production under specified
`conditions if the serving party:
`(i) shows a substantial need for the testimony or material that cannot be
`otherwise met without undue hardship; and
`(ii) ensures that the subpoenaed person will be reasonably compensated.
`
`(c) Place of Compliance.
` (1) For a Trial, Hearing, or Deposition. A subpoena may command a
`person to attend a trial, hearing, or deposition only as follows:
` (A) within 100 miles of where the person resides, is employed, or
`regularly transacts business in person; or
` (B) within the state where the person resides, is employed, or regularly
`transacts business in person, if the person
` (i) is a party or a party’s officer; or
` (ii) is commanded to attend a trial and would not incur substantial
`expense.
` (2) For Other Discovery. A subpoena may command:
` (A) production of documents, electronically stored information, or
`tangible things at a place within 100 miles of where the person resides, is
`employed, or regularly transacts business in person; and
` (B) inspection of premises at the premises to be inspected.
`
`(d) Protecting a Person Subject to a Subpoena; Enforcement.
` (1) Avoiding Undue Burden or Expense; Sanctions. A party or attorney
`responsible for issuing and serving a subpoena must take reasonable steps
`to avoid imposing undue burden or expense on a person subject to the
`subpoena. The court for the district where compliance is required must
`enforce this duty and impose an appropriate sanction—which may include
`lost earnings and reasonable attorney’s fees—on a party or attorney who
`fails to comply.
` (2) Command to Produce Materials or Permit Inspection.
`(A) Appearance Not Required. A person commanded to produce
`documents, electronically stored information, or tangible things, or to
`permit the inspection of premises, need not appear in person at the place of
`production or inspection unless also commanded to appear for a deposition,
`hearing, or trial.
`(B) Objections. A person commanded to produce documents or tangible
`things or to permit inspection may serve on the party or attorney designated
`in the subpoena a written objection to inspecting, copying, testing, or
`sampling any or all of the materials or to inspecting the premises—or to
`producing electronically stored information in the form or forms requested.
`The objection must be served before the earlier of the time specified for
`compliance or 14 days after the subpoena is served. If an objection is made,
`the following rules apply:
`(i) At any time, on notice to the commanded person, the serving party
`may move the court for the district where compliance is required for an
`order compelling production or inspection.
` (ii) These acts may be required only as directed in the order, and the
`order must protect a person who is neither a party nor a party’s officer from
`significant expense resulting from compliance.
` (3) Quashing or Modifying a Subpoena.
`(A) When Required. On timely motion, the court for the district where
`compliance is required must quash or modify a subpoena that:
`
` (i) fails to allow a reasonable time to comply;
`(ii) requires a person to comply beyond the geographical limits
`specified in Rule 45(c);
`(iii) requires disclosure of privileged or other protected matter, if no
`exception or waiver applies; or
`(iv) subjects a person to undue burden.
`(B) When Permitted. To protect a person subject to or affected by a
`subpoena, the court for the district where compliance is required may, on
`motion, quash or modify the subpoena if it requires:
`
`(e) Duties in Responding to a Subpoena.
` (1) Producing Documents or Electronically Stored Information. These
`procedures apply to producing documents or electronically stored
`information:
`(A) Documents. A person responding to a subpoena to produce documents
`must produce them as they are kept in the ordinary course of business or
`must organize and label them to correspond to the categories in the demand.
`(B) Form for Producing Electronically Stored Information Not Specified.
`If a subpoena does not specify a form for producing electronically stored
`information, the person responding must produce it in a form or forms in
`which it is ordinarily maintained or in a reasonably usable form or forms.
`(C) Electronically Stored Information Produced in Only One Form. The
`person responding need not produce the same electronically stored
`information in more than one form.
`(D) Inaccessible Electronically Stored Information. The person
`responding need not provide discovery of electronically stored information
`from sources that the person identifies as not reasonably accessible because
`of undue burden or cost. On motion to compel discovery or for a protective
`order, the person responding must show that the information is not
`reasonably accessible because of undue burden or cost. If that showing is
`made, the court may nonetheless order discovery from such sources if the
`requesting party shows good cause, considering the limitations of Rule
`26(b)(2)(C). The court may specify conditions for the discovery.
`(2) Claiming Privilege or Protection.
`(A) Information Withheld. A person withholding subpoenaed information
`under a claim that it is privileged or subject to protection as trial-preparation
`material must:
`(i) expressly make the claim; and
`(ii) describe the nature of the withheld documents, communications, or
`tangible things in a manner that, without revealing information itself
`privileged or protected, will enable the parties to assess the claim.
`(B) Information Produced. If information produced in response to a
`subpoena is subject to a claim of privilege or of protection as
`trial-preparation material, the person making the claim may notify any party
`that received the information of the claim and the basis for it. After being
`notified, a party must promptly return, sequester, or destroy the specified
`information and any copies it has; must not use or disclose the information
`until the claim is resolved; must take reasonable steps to retrieve the
`information if the party disclosed it before being notified; and may promptly
`present the information under seal to the court for the district where
`compliance is required for a determination of the claim. The person who
`produced the information must preserve the information until the claim is
`resolved.
`
`(g) Contempt.
`The court for the district where compliance is required—and also, after a
`motion is transferred, the issuing court—may hold in contempt a person
`who, having been served, fails without adequate excuse to obey the
`subpoena or an order related to it.
`
`For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013).
`
`

`

`Case 1:16-cv-00455-RGA Document 108 Filed 04/26/17 Page 7 of 10 PageID #: 12533
`Case 1:16-cv-00455-RGA Document 108 Filed 04/26/17 Page 7 of 10 PagelD #: 12533
`
`
`
`
`
`
`
`
`
`EXHIBIT 2
`EXHIBIT 2
`
`

`

`Case 1:16-cv-00455-RGA Document 108 Filed 04/26/17 Page 8 of 10 PageID #: 12534
`Case 1:16-cv-00455-RGA Document 108 Filed 04/26/17 Page 8 of 10 PagelD #: 12534
`
`AO 88A (Rev. 12/13) Subpoenato Testify at a Deposition in a Civil Action
`
`UNITED STATES DISTRICT COURT
`for the
`
`District of Delaware
`
`ACCELERATION BAY LLC
`Plaintiff
`Vv.
`TAKE-TWO INTERACTIVE SOFTWARE,INC.,
`
`ROCKSTAR GAMES, INC., and 2K SPORTS,
`INC.
`Defendant
`
`)
`)
`)
`)
`)
`)
`
`Civil Action No.
`
`16-455 (RGA)
`
`SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
`
`To:
`
`Linda Mangotti, c/o Kramer Levin Naftalis & Frankel LLP, 990 Marsh Road, Menlo Park, CA 94025
` (Nameofperson to whom this subpoenais directed)
`wT.estimony: YOU ARE COMMANDEDto appearat the time, date, and place set forth below totestify at a
`deposition to be taken in this civil action. If you are an organization, you must designate one or moreofficers, directors,
`or managing agents, or designate other persons who consentto testify on your behalf aboutthe following matters, or
`those set forth in an attachment:
`
`
`Place: Wilson Sonsini Goodrich & Rosati, 701 Fifth Avenue,
`05/23/2017 9:00 am
`Suite 5100, Seaitle, Washington 98104-7036
`
`The deposition will be recorded by this method:_stenographer and videographer
`
`
`Date and Time:
`
`C1 Production: You, or your representatives, must also bring with youto the deposition the following documents,
`electronically stored information, or objects, and must permit inspection, copying,testing, or sampling ofthe
`material:
`
`
`
`The following provisions of Fed. R. Civ. P. 45 are attached — Rule 45(c), relating to the place of compliance;
`Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and(g), relating to your duty to
`respondto this subpoena and the potential consequences of not doing so.
`
`Date:
`
`04/25/2017
`
`CLERK OF COURT
`
`OR ateto2Attorney's signature
`
`J
`
`Signature of Clerk or Deputy Clerk
`
`Take-Two
`The name, address, e-mail address, and telephone numberof the attorney representing (nameofparty)
`Interactive Software,Inc., Rockstar Games,Inc. and 2k Sports,Inc.
`, whoissues or requests this subpoena,are:
`Kathleen Barry, Winston & Strawn LLP, 35 W. WackerDr., Chicago, IL 60601 Tel: 312-558-8046, kbarry@winston.com
`
`
`Notice to the person whoissues or requests this subpoena
`If this subpoena commandsthe production of documents, electronically stored information,or tangible things, a notice
`and a.copy ofthe subpoena must be served on eachparty in this case beforeit is served on the person to whom itis
`directed. Fed. R. Civ. P. 45(a)(4).
`
`
`
`

`

`Case 1:16-cv-00455-RGA Document 108 Filed 04/26/17 Page 9 of 10 PageID #: 12535
`
`AO 88A (Rev. 12/13) Subpoena to Testify at a Deposition in a Civil Action (Page 2)
`
`Civil Action No.
`
`16-455 (RGA)
`
`PROOF OF SERVICE
`(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)
`
`I received this subpoena for (name of individual and title, if any)
`.
`
`on (date)
`
`(cid:117) I served the subpoena by delivering a copy to the named individual as follows:
`
`(cid:117) I returned the subpoena unexecuted because:
`
`on (date)
`
`; or
`
`Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
`tendered to the witness the fees for one day’s attendance, and the mileage allowed by law, in the amount of
`$
`.
`
`My fees are $
`
`for travel and $
`
`for services, for a total of $
`
`0.00
`
`.
`
`.
`
`I declare under penalty of perjury that this information is true.
`
`Date:
`
`Additional information regarding attempted service, etc.:
`
`Server’s signature
`
`Printed name and title
`
`Server’s address
`
`

`

`Case 1:16-cv-00455-RGA Document 108 Filed 04/26/17 Page 10 of 10 PageID #: 12536
`
`AO 88A (Rev. 12/13) Subpoena to Testify at a Deposition in a Civil Action (Page 3)
`Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13)
`(i) disclosing a trade secret or other confidential research, development,
`or commercial information; or
`(ii) disclosing an unretained expert’s opinion or information that does
`not describe specific occurrences in dispute and results from the expert’s
`study that was not requested by a party.
`(C) Specifying Conditions as an Alternative. In the circumstances
`described in Rule 45(d)(3)(B), the court may, instead of quashing or
`modifying a subpoena, order appearance or production under specified
`conditions if the serving party:
`(i) shows a substantial need for the testimony or material that cannot be
`otherwise met without undue hardship; and
`(ii) ensures that the subpoenaed person will be reasonably compensated.
`
`(c) Place of Compliance.
` (1) For a Trial, Hearing, or Deposition. A subpoena may command a
`person to attend a trial, hearing, or deposition only as follows:
` (A) within 100 miles of where the person resides, is employed, or
`regularly transacts business in person; or
` (B) within the state where the person resides, is employed, or regularly
`transacts business in person, if the person
` (i) is a party or a party’s officer; or
` (ii) is commanded to attend a trial and would not incur substantial
`expense.
` (2) For Other Discovery. A subpoena may command:
` (A) production of documents, electronically stored information, or
`tangible things at a place within 100 miles of where the person resides, is
`employed, or regularly transacts business in person; and
` (B) inspection of premises at the premises to be inspected.
`
`(d) Protecting a Person Subject to a Subpoena; Enforcement.
` (1) Avoiding Undue Burden or Expense; Sanctions. A party or attorney
`responsible for issuing and serving a subpoena must take reasonable steps
`to avoid imposing undue burden or expense on a person subject to the
`subpoena. The court for the district where compliance is required must
`enforce this duty and impose an appropriate sanction—which may include
`lost earnings and reasonable attorney’s fees—on a party or attorney who
`fails to comply.
` (2) Command to Produce Materials or Permit Inspection.
`(A) Appearance Not Required. A person commanded to produce
`documents, electronically stored information, or tangible things, or to
`permit the inspection of premises, need not appear in person at the place of
`production or inspection unless also commanded to appear for a deposition,
`hearing, or trial.
`(B) Objections. A person commanded to produce documents or tangible
`things or to permit inspection may serve on the party or attorney designated
`in the subpoena a written objection to inspecting, copying, testing, or
`sampling any or all of the materials or to inspecting the premises—or to
`producing electronically stored information in the form or forms requested.
`The objection must be served before the earlier of the time specified for
`compliance or 14 days after the subpoena is served. If an objection is made,
`the following rules apply:
`(i) At any time, on notice to the commanded person, the serving party
`may move the court for the district where compliance is required for an
`order compelling production or inspection.
` (ii) These acts may be required only as directed in the order, and the
`order must protect a person who is neither a party nor a party’s officer from
`significant expense resulting from compliance.
` (3) Quashing or Modifying a Subpoena.
`(A) When Required. On timely motion, the court for the district where
`compliance is required must quash or modify a subpoena that:
`
` (i) fails to allow a reasonable time to comply;
`(ii) requires a person to comply beyond the geographical limits
`specified in Rule 45(c);
`(iii) requires disclosure of privileged or other protected matter, if no
`exception or waiver applies; or
`(iv) subjects a person to undue burden.
`(B) When Permitted. To protect a person subject to or affected by a
`subpoena, the court for the district where compliance is required may, on
`motion, quash or modify the subpoena if it requires:
`
`(e) Duties in Responding to a Subpoena.
` (1) Producing Documents or Electronically Stored Information. These
`procedures apply to producing documents or electronically stored
`information:
`(A) Documents. A person responding to a subpoena to produce documents
`must produce them as they are kept in the ordinary course of business or
`must organize and label them to correspond to the categories in the demand.
`(B) Form for Producing Electronically Stored Information Not Specified.
`If a subpoena does not specify a form for producing electronically stored
`information, the person responding must produce it in a form or forms in
`which it is ordinarily maintained or in a reasonably usable form or forms.
`(C) Electronically Stored Information Produced in Only One Form. The
`person responding need not produce the same electronically stored
`information in more than one form.
`(D) Inaccessible Electronically Stored Information. The person
`responding need not provide discovery of electronically stored information
`from sources that the person identifies as not reasonably accessible because
`of undue burden or cost. On motion to compel discovery or for a protective
`order, the person responding must show that the information is not
`reasonably accessible because of undue burden or cost. If that showing is
`made, the court may nonetheless order discovery from such sources if the
`requesting party shows good cause, considering the limitations of Rule
`26(b)(2)(C). The court may specify conditions for the discovery.
`(2) Claiming Privilege or Protection.
`(A) Information Withheld. A person withholding subpoenaed information
`under a claim that it is privileged or subject to protection as trial-preparation
`material must:
`(i) expressly make the claim; and
`(ii) describe the nature of the withheld documents, communications, or
`tangible things in a manner that, without revealing information itself
`privileged or protected, will enable the parties to assess the claim.
`(B) Information Produced. If information produced in response to a
`subpoena is subject to a claim of privilege or of protection as
`trial-preparation material, the person making the claim may notify any party
`that received the information of the claim and the basis for it. After being
`notified, a party must promptly return, sequester, or destroy the specified
`information and any copies it has; must not use or disclose the information
`until the claim is resolved; must take reasonable steps to retrieve the
`information if the party disclosed it before being notified; and may promptly
`present the information under seal to the court for the district where
`compliance is required for a determination of the claim. The person who
`produced the information must preserve the information until the claim is
`resolved.
`
`(g) Contempt.
`The court for the district where compliance is required—and also, after a
`motion is transferred, the issuing court—may hold in contempt a person
`who, having been served, fails without adequate excuse to obey the
`subpoena or an order related to it.
`
`For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013).
`
`