L. v. Uber Technologies
- Charles Breyer
- 3:24-cv-09217
- U.S. District Court · Northern District of California
- 2
In T.L. v. Uber Technologies, Judge Cisneros denied without prejudice T.L.’s motion to compel a Georgia provider’s subpoena compliance in Colorado.
T.L. and The Comfy Place, the nonparty mental-health-services provider whose records were sought.
What happened
In T.L. v. Uber Technologies, Inc., T.L. asked the court to require The Comfy Place, a Georgia mental-health-services provider, to produce T.L.’s treatment records under a subpoena. The subpoena required production at T.L.’s counsel’s office in Denver, Colorado.
The court had previously required T.L. and The Comfy Place to meet and confer and submit a joint letter if The Comfy Place opposed the motion. No joint letter was filed. But the court’s earlier order allowed it to enforce subpoenas requiring compliance in another district only if the nonparty consented, the Judicial Panel on Multidistrict Litigation transferred the motion, or the compliance district transferred it under the federal rules. The record did not show that any of those conditions applied.
The court denied T.L.’s motion without prejudice, allowing T.L. to file it in the District of Colorado or to refile it in this court after obtaining The Comfy Place’s consent. The court said it was not questioning the subpoena’s merits and that, on the current record, no reason was apparent why T.L. should not be able to access her own treatment records. Judge Cisneros signed the order.
The detailed version
- L. v. Uber Technologies · No. 3:24-cv-09217
- Charles Breyer
- Dec. 5, 2025
Background
T.L. moved under Rule 45 of the Federal Rules of Civil Procedure to compel The Comfy Place to comply with a subpoena seeking T.L.’s mental-health treatment records. The opinion describes The Comfy Place as a provider of mental-health services in Georgia. The subpoena required compliance at T.L.’s counsel’s office in Denver, Colorado.
The court had directed T.L. and The Comfy Place to meet and confer and file a joint letter by November 17, 2025, if The Comfy Place opposed the motion. No joint letter was filed. The court also noted that T.L. appeared to have served the motion only after the court requested proof of service, and stated that parties are expected to serve motions to compel on nonparties whose compliance is at issue.
Court’s Analysis
Rule 45 generally allows a party seeking document production to ask the court in the district where compliance is required to compel production. The court had previously ruled that, in this multidistrict litigation, it would hear motions to quash, modify, or enforce document-only subpoenas requiring compliance in another district only if one of three conditions was met: the responding nonparty consented to filing and adjudication in this court; the Judicial Panel on Multidistrict Litigation transferred the motion here; or the district where compliance was required transferred the motion under Rule 45(f).
The subpoena demanded compliance in Colorado, but the record did not indicate that any of those conditions was satisfied. The court also noted that it was unclear whether T.L. could properly require a Georgia entity to comply in Colorado, given Rule 45’s geographic limits. The court stated that even if the compliance location was improper, a motion to enforce or challenge the subpoena generally must be filed in the district where compliance is demanded.
Ruling
The court denied without prejudice T.L.’s motion to compel. It stated that T.L. could file a motion in the District of Colorado or refile in this court after obtaining The Comfy Place’s consent. The court expressly said that the procedural defects preventing relief did not reflect a decision on the subpoena’s merits. It stated that, based on the current record, no reason was apparent why T.L. should not be able to access T.L.’s own treatment records.
Judge A. J. Cisneros signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.