Calcor Space Facility, Inc. v. Superior Court of Orange Cty.

We hold a subpoena under Code of Civil Procedure section 2020, subdivision (d) (all further statutory references are to the Code of Civil Procedure) must describe the documents to be produced with reasonable particularity. Generalized demands, insupportable by evidence showing at least the potential evidentiary value of the information sought, are not permitted. When responding to a motion for a protective order, the party seeking such discovery must supply evidence demonstrating a reasonable relationship between the materials sought to be produced and the issues involved in the case. We therefore issue a writ of mandate directing the trial court to vacate orders compelling a nonparty to produce materials in response to a subpoena describing generalized broad categories of materials rather than specific documents or, at least, categories of documents or materials which are reasonably particularized in relation to the manner in which the producing party maintains such records.

Facts

Delco Systems Operations contracted with Rockwell International to supply trainable gun mount systems (gun mounts). Delco, in turn, contracted with Thiem Industries, Inc., to produce some of…