How Rule 45 Update May Change Remote Trial Subpoenas

By Timothy Cook and Gillian Farrell ( October 20, 2026, 5:22 PM EDT) -- The U.S. Bankruptcy Court for the Central District of California issued subpoenas to two witnesses to testify at trial by video. The witnesses lived in the U.S. Virgin Islands, and they moved to quash, arguing that they were beyond the California court's subpoena power. They prevailed.[1]...

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