California, United States of America
The following excerpt is from Chen v. Regents of Univ. of Cal., B290999 (Cal. App. 2020):
issued to a medical provider other than Delshadi suggests the possibility that the production of the report by the subpoenaed party might not be properly authenticated. (See Cooley v. Superior Court (2006) 140 Cal.App.4th 1039, 1045 [subpoenaed party cannot supply section 1561 declaration for documents it did not prepare or generate].)
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