Crutcher v. Fidelity Nat’l Ins. Co., 2007 WL 430655 (E.D. La. Feb. 5, 2007)

Key Insight: Court declared subpoena invalid because requirements of Rule 26(d) apply to subpoenas issued to non-parties, and parties’ written correspondence did not satisfy the requirements of Rule 26(f) to meet, confer, and develop a discovery plan

Nature of Case: Insurance coverage

Electronic Data Involved: Hurricane damage evaluation materials prepared by third party