Nicholas v. Windham Int’l, Inc., 373 F.3d 537 (4th Cir. 2004)

Key Insight: No abuse of discretion to deny enforcement of subpoena directed to plaintiffs’ nonparty company where defendants had already deposed plaintiffs and conceded that the company would have no additional information, plaintiffs would be designated Rule 30(b)(6) witnesses if discovery were allowed, and plaintiffs had already produced email from their business accounts and remained under a continuing obligation to supplement their earlier productions

Nature of Case: Ancillary proceeding to enforce subpoena

Electronic Data Involved: Email