The following excerpt is from Eastman v. Allstate Ins. Co., Case No. 3:14-CV-00703-WQH-WVG (S.D. Cal. 2015):
10. Though issued pursuant to a federal rule, the subpoena at issue is no less authorised by law than any other order issued pursuant to a federal statutory command. See Chandler v. James, 180 F.3d 1254, 1266-67 (11th Cir. 1999) (noting that a refusal to comply with a subpoena duces tecum is violation of a court's judicial authority).
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