Court Enforces TCPA Subpoenas Against Nonparties Who Evaded Personal Service

Short summary

A Puerto Rico federal court enforced TCPA subpoenas against nonparties who evaded personal service, holding that motions to enforce are governed by Rule 5 (not Rule 4) and that jurisdiction over nonparties comes from subpoena service under Rule 45. The court found that alternative service was proper because respondents clearly received and responded to the subpoenas. The ruling provides a clear roadmap for litigators chasing discovery from unresponsive vendors or lead generators.

• •Court held motion to enforce subpoena is served under Rule 5, not Rule 4, so mailing sufficed
• •Jurisdiction over nonparties comes from Rule 45 subpoena service, not from the enforcement motion
• •Respondents' partial response to subpoenas undermined their claim they never received notice

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