A party procuring a subpoena for production must be prepared to identify expressly and precisely the legitimate forensic purpose for each paragraph or group of paragraphs of the subpoena, not merely in terms of utmost generality. A subpoena requiring production of 'all' originals and copies of documents held by numerous persons and offices, without justification for the breadth, is oppressive and liable to be set aside. The recipient of a subpoena may move to set it aside without first producing the documents to the court.
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