Cowley v. The Seattle Times
Plaintiff filed a claim for defamation in a Washington state court against defendant The Seattle Times Company (Seattle Times) based on what Cowley believed were false statements Seattle Times made in articles regarding his alleged criminal history in California and his alleged failure to disclose that history to the Tulalip tribes in Washington where he worked as a dentist. In response to the lawsuit, Seattle Times filed a petition in Sacramento County Superior Court for issuance of a subpoena duces tecum to Folsom State Prison, where Cowley had worked as a dentist, for all documents within its possession or under its control that related in any way to Cowley. Cowley filed a motion to quash the subpoena, arguing, among other things, the subpoena invaded his right to privacy. The trial court granted Cowleys motion to quash and awarded $6,300 in sanctions, finding the requirements of the subpoena oppressive.
Court hold the trial court did not abuse its discretion in granting Cowleys motion to quash the subpoena or in awarding sanctions, given the overbroad request for documents.
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