MIIA's emergency motion to quash its subpoena, June 12, 2015

U.S. District Court, District of Massachusetts · from GovInfo · 2 pages · 121 KB
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UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 
JAMES ROSENCRANZ, ) 
Plaintiff, ) 
) 
v. ) 1:14-cv-13050-JGD 
) 
JAMES A. FREEMAN, ) 
Defendant. ) 
EMERGENCY MOTION OF NON-PARTY, MIIA PROPERTY AND CASUALTY
GROUP, INC., TO QUASH SUBPOENA AND FOR A PROTECTIVE ORDER 
Pursuant to Rules 26 and 45 of the Federal Rules of Civil Procedure, MIIA Property and
Casualty Group, Inc. (“MIIA”) hereby moves this honorable court for an order to quash the
subpoena served upon it by the Plaintiff, James Rosencranz (“Plaintiff”), and for a protective
order. 
As explained more fully in the accompanying memorandum of law, the subpoena issued
to MIIA should be quashed because it (1) seeks documents that are neither admissible nor
reasonably calculated to lead to the discovery of admissible evidence, (2) seeks documents
available either from the defendant or from public sources, and (3) subjects MIIA, a non-party, to
undue and unnecessary burden. In addition, a protective order should issue barring any further
discovery regarding the claims and training information sought by the Plaintiff in the subject
subpoena, including any testimony regarding said claims and training information. 
Accordingly, MIIA respectfully requests that the Court GRANT this motion to quash the
subpoena issued to it by the Plaintiff, and issue the requested protective order. MIIA further
requests that it be awarded its costs in opposing the Plaintiff’s subpoena. 
Case 1:14-cv-13050-JGD Document 30 Filed 06/12/15 Page 1 of 2

REQUEST FOR ORAL ARGUMENT 
MIIA hereby requests a hearing on this Motion to Quash and for a Protective Order. 
Date: June 12, 2015 Respectfully submitted, 
MIIA Property and Casualty Group, Inc., 
A non-party, 
By its attorneys, 
/s/ Deawn C. Takahashi 
Arthur E. Maravelis (BBO#564673) 
Deawn C. Takahashi (BBO#657282) 
TANG & MARAVELIS, P.C. 
50 Mall Road, Suite 111 
Burlington, MA 01803 
(781) 221-1400 
Certificate of Service 
I hereby certify that a true copy of the above document was served upon Plaintiff by
forwarding same via ECF on June 12, 2015. 
/s/ Deawn C. Takahashi 
______________________________ 
Deawn C. Takahashi 
Case 1:14-cv-13050-JGD Document 30 Filed 06/12/15 Page 2 of 2