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Responding to a Rule 45 Subpoena - Who Pays the Costs and Fees? - LaszloLaw
https://www.laszlolaw.com/responding-to-a-rule-45-subpoena-who-pays-the-costs-and-fees/
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responding to subpoena
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In Federal litigation, the general rule is that the party responding to the Rule 45 subpoena pays the costs and fees associated with responding. Essentially, federal courts see it as a cost of doing business.
