Automated Summary
Key Facts
Plaintiff Mahammad Nawaz Raja claims identity theft regarding a Credit One Bank account opened in 2021 under the name 'Mohammad Raja' with address 42907 Park Brooke Court, Broadlands, VA. Defendants LVNV Funding LLC and others dispute this, alleging Raja opened the account and sometimes uses the name 'Mohammad.' The court denied motions to quash subpoenas to the DMV and Navy Federal but narrowed the Costco subpoena to require production only of records linked to specific identifiers (address, phone number, email, or SSN ending in 9586). The court canceled a scheduled hearing on March 13, 2026, finding oral argument unnecessary.
Issues
The court addressed whether LVNV's subpoenas to the DMV, Navy Federal, and Costco for personal information (address, SSN, email, etc.) were valid under Federal Rule of Civil Procedure 45(d) (undue burden) and Rule 26(b)(1) (relevance and proportionality). The court found the subpoenas relevant to LVNV's defense that Plaintiff opened the Credit One account and proportional to the case needs, except for the Costco subpoena, which was narrowed to avoid exposing unrelated third parties' data. The plaintiff's claim that the subpoenas sought sensitive information was rejected, as his lawsuit placed his identity at issue.
Holdings
- The court granted in part and denied in part the motion to quash the subpoena directed to Costco. The subpoena was narrowed to include only records associated with specific identifiers (address, phone number, email, SSN) to avoid capturing unrelated third parties' information, while still maintaining its evidentiary purpose of confirming the plaintiff's use of the Credit One card for a Costco membership.
- The court denied the motions to quash subpoenas directed to the DMV and Navy Federal, determining that the requested information is relevant and proportional to the case. The subpoenas are necessary to verify the plaintiff's identity and potential account usage, directly addressing the dispute over whether the plaintiff opened the Credit One account or was a victim of identity theft.
- The court canceled the scheduled hearing on the motions to quash, finding oral argument unnecessary under the applicable rules. This decision aligns with Federal Rule of Civil Procedure 78(b) and Local Rule 7(J) of the Eastern District of Virginia.
Remedies
- The Court cancels the hearing on the Motions to Quash Subpoenas scheduled for March 13, 2026, as it finds oral argument unnecessary under Federal Rule of Civil Procedure 78(b) and Local Rule 7(J).
- The Court grants in part and denies in part the Motion to Quash the subpoena directed to Costco. The subpoena is narrowed to require production only of records associated with at least one of the following identifiers: 42907 Park Brooke Court, Broadlands, Virginia, 20148-5304; (540) 687-0004; therajafamily@gmail.com; or SSN ending in 9586. This modification protects unrelated individuals while maintaining the subpoena's evidentiary purpose.
- The Court denies the Motions to Quash Subpoenas directed to the Virginia Department of Motor Vehicles (DMV) and Navy Federal Credit Union, allowing LVNV to enforce these subpoenas as issued. This decision is based on the relevance and proportionality of the requested information to LVNV's defense regarding the plaintiff's identity and account ownership.
Legal Principles
- The court applied Federal Rule of Civil Procedure 45(d), which requires a party issuing a subpoena to take reasonable steps to avoid imposing undue burden or expense, and mandates that courts quash or modify subpoenas that require disclosure of privileged material or subject a person to undue burden. The court also referenced Rule 45(d)(3)(A) and (B) in evaluating the subpoenas.
- The court considered Federal Rule of Civil Procedure 26(b)(1), which limits discovery to information relevant to a party's claim or defense and proportional to the case's needs. It emphasized that subpoenas targeting non-parties require a more demanding analysis to ensure good cause exists for their involvement.
Precedent Name
- Trans Union, LLC v. Scroggins
- Virginia Department of Correction v. Jordan
Cited Statute
Fair Debt Collection Practices Act
Judge Name
William B. Porter
Passage Text
- The Court has one narrow concern about the Costco subpoena. As written, it sweeps broadly enough to capture records of any individual named Mohammad or Muhammad Raja who holds a Costco membership in Virginia, potentially exposing unrelated third parties' personal information. The Court will narrow the Costco subpoena to require production only of records associated with at least one of the following known identifiers...
- The subpoenas are relevant to LVNV's defense and proportional to the needs of the case. Each seeks information probative of the central disputed question: whether Plaintiff opened the Credit One account himself or was, as he claims, a victim of identity theft.