This document is page 2 of a legal filing (Document 195) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 5, 2021. The text presents legal arguments regarding the limitations of Rule 17 subpoenas in criminal cases, arguing they cannot be used for broad discovery or to find leads, unlike in civil procedure. The text heavily cites legal precedents including *Bowman Dairy Co. v. United States*, *United States v. Purin*, and *United States v. Tagliaferro* to establish the standard for requiring document production.
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