We've got a similar situation. Driver was indicted for accident, then fled to another country. Now a civil firm has filed a subpoena for documents and a Notice of deposition on Written Questions for our file in the accodent case.

I'd sure appreciate a motion to quash from anyone who's got one handy.

Thanks.

Thanks so much, Todd Sellars, for all the materials I could possibly use.

I forgot about my baseballs at a home run derby analogy. A bunch of lawyers must have attended a personal injury trial seminar where an idiot was speaking.

It is really important for you to attend the hearing until it is over.

What?

It's spammers trying to pad their number of posts.

Our office received a Notice for Request for Production on a civil case (decedent's family suing criminal defendant)and the criminal case is still pending. Has anyone responded to a similar request for production asserting work product and law enforcement privileges (rather than filing a motion to quash and for protective order) and if so, would you mind sharing? In reading TRCP 192.6 and 193.3 it seems that responding to the production request and asserting privileges is preferred as opposed to a motion to quash and for protective order.