The U.S. District Court for the District of Nevada quashed a third party subpoena on a bank because the subpoena was overbroad.

Plaintiffs sued a series of individuals and corporate entities for construction defects, fraud and conspiracy. Plaintiffs alleged that the defendants “converted property and misled them through incomplete repairs, non-disclosures, misinformation, inaccurate reserves and an inadequate budget, into purchasing” the subject properties. Plaintiffs later amended their complaint to add allegations that the various defendants were alter egos of each other, and issued a third party subpoena to a bank requesting “any and all banking records” concerning the defendants, including “but not limited to, any and all e-mails, correspondence, etc.”