Southridge Capital Mgmt., LLC v. Pitkin, 2008 WL 4150225 (Conn. Super. Ct. Aug. 18, 2008) (Unpublished)

Key Insight: Where Commissioner was legally authorized to conduct an investigation, subpoena sought documents and ESI that were reasonably relevant to investigation, and Commissioner had valid concerns regarding completeness of plaintiff?s prior productions, court found that investigative subpoena was issued for a proper purpose and denied plaintiff?s motion to quash; court further rejected plaintiff?s claim that subpoena was unduly burdensome, noting that plaintiff had failed to present any documentary evidence of its cost estimates and that plaintiff must bear production costs like any other cost of doing business

Nature of Case: Securities investigation conducted by Connecticut Commissioner of Banking

Electronic Data Involved: Email and other ESI