A subpoena duces tecum is limited by the number of documents it may command,but not the type of documents.

Question

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A subpoena duces tecum is limited not only by the number of documents it may command but also by the type of documents it can request. The subpoena should specify the documents requested with sufficient particularity to avoid ambiguity or undue burden on the person or entity served with the subpoena.

A Subpoena Duces Tecum Is Limited by the Number of Documents