How have courts quashed defense subpoenas to obtain internal documents from insurance companies?

California, United States of America

The following excerpt is from People v. Pierce, 251 Cal.Rptr.3d 140, 38 Cal.App.5th 321 (Cal. App. 2019):

As such, in quashing the defense subpoenas, the trial court reasonably concluded that the defense requests for such internal documents was of minimal relevance and value for the defense, and overburdensome on the insurance carriers. (Cf. People v. Kaurish (1990) 52 Cal.3d 648, 687, 276 Cal.Rptr. 788, 802 P.2d 278 [concluding that trial court did not abuse its discretion in granting prosecution's motion to quash a defense subpoena to discover certain police reports, because defendant's request "was broad and somewhat burdensome" and defendant "failed to provide greater specificity or a greater showing of relevance in his broad discovery request"].)

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