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VIII.G | DISCOVERY FROM NON-PARTIES
Rule 45 does not require a party issuing a subpoena for ESI to a non-party to confer with the non-party in advance. Nevertheless, in most cases, the party issuing the subpoena and the non-party responding to the subpoena should discuss, in advance, the same issues a party would discuss with an opposing party before commencing discovery of ESI.
Discovery Practice | Middle District of Florida — rev. 6/5/15
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