Our clients to subpoena duces tecum
ESI will not be produced until such time as requesting party agrees to bear the costs associated with its production. The warrant should be carefully reviewed to determine what is described and where the searchis to take place. The rule in equity that no man need discover matters tending to criminate himself, or to expose him to a penalty or forfeiture, is subject to an exception in respect to frauds and also where fiduciary relations exist. Fazio spent the first five years in practice representing manufacturers, insurance companies, hospitals, property owners, and state and municipal government entities as defendants in products liability, securities fraud, unfair business practice, and civil rights cases.