When a non-party has made an unaccepted offer for an asset whose value is in dispute, documents evidencing the non-party's degree of interest, interactions with relevant parties, and enquiries about the asset may be obtained by subpoena as apparently relevant to the integrity of the sale process. However, the non-party's internal calculations, modelling and valuations used to arrive at the offer price are not apparently relevant to the value of the asset and will not materially assist the issuing party's case — it is the fact of the offer and its terms that matter, not how the figure was derived. The test for setting aside a subpoena is apparent relevance, not admissibility.
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