The issuing court's familiarity with the case and the risk of inconsistent rulings provided reason enough to transfer the motion.
The federal district court in Minneapolis, Minnesota transferred a non-party debt collector's motion to quash a subpoena to the Eastern District of California, where the underlying antitrust class action is pending. The court concluded that Experian Information Solutions, Inc. had shown exceptional circumstances under Federal Rule of Civil Procedure 45(f) for the transfer. The court found that the issuing court is best positioned to rule, that similar subpoena disputes are already before that court, and that the non-party would face no undue burden from the transfer (Adams v. Experian Information Solutions, Inc., No. 0:26-mc-00065-SGE (D. Minn. Oct. 26, 2026)).
Background. The underlying case is a putative class action where the plaintiffs allege that the defendant credit reporting agencies, including Experian, violated the Sherman Act and its California counterpart in connection with the reporting of medical debt. They also assert claims for tortious interference with contracts under California and New Jersey law, alleging that the defendants conspired to restrain trade and drive health care providers out of certain markets with how it handles medical debt. Experian previously won dismissal of the antitrust claims, but still faces tortious-interference claims.
On July 15, 2026, Experian served a document subpoena on IC System, Inc., a Minnesota debt collection agency and non-party to the litigation, for use at the class certification stage. IC System moved to quash the subpoena in the District of Minnesota, the court where compliance is required. Experian opposed the motion and asked the court to transfer it to the Eastern District of California under Rule 45(f).
Rule 45. The court began with the rule's structure. Although a Rule 45 subpoena is issued by the court where the action is pending, authority to resolve disputes over it rests with the court where compliance is required; in this case, Minnesota. Rule 45(f) permits the compliance court to transfer a motion to the issuing court if the subpoenaed person consents or if the court finds exceptional circumstances. IC System did not consent, so Experian bore the burden of showing exceptional circumstances.
Applying the framework used in this district, the court weighed three considerations: whether the underlying litigation will be disrupted absent transfer, whether the non-party will suffer undue burden or cost if the dispute is transferred, and whether the issuing court is in the best position to rule. It found that the factors largely favored transfer.
On the third consideration, which the court addressed first, it concluded that the California court is unquestionably in the best position to decide the motion. The case has been pending there for three years, and that court has adopted a detailed discovery plan and is far more familiar with the complexities of the matter. The court relied on a decision from this district observing that where the issuing court has defined the scope of and need for preliminary class-related discovery, it makes little sense for the compliance court to decide whether a subpoena's requests fall within that scope. The California court has also set timelines for the initial phase of class certification discovery.
The court added that two other motions concerning very similar subpoenas are already pending before the California court after being transferred from the Southern District of New York and the District of Columbia. Transferring this motion, the court reasoned, will conserve judicial and litigant resources, and it cited a prior decision of this district that transferred a motion to compel where a similar motion had already been sent to the issuing court. The court acknowledged that in the other two matters the parties had agreed to transfer, but held that this distinction did not require a different result given the near-identical issues. Keeping the motion in Minnesota would also risk inconsistent rulings, whereas transfer would avoid "piecemeal rulings by different judges, reaching different conclusions, in resolving identical disputes."
On the burden consideration, the court was unpersuaded that IC System would suffer undue burden or cost by litigating in California. It was apparently undisputed that IC System's counsel could appear remotely before the California court, as both parties had planned to do in Minnesota, and the presiding judge's case management procedures permit remote appearances in discovery matters. The court also noted that IC System appears to have California counsel engaged in the matter. Finally, the court found that hearing the motion in California rather than Minnesota would not increase IC System's burden of complying with the subpoena if ordered to do so.
The court also was not convinced that keeping the motion in Minnesota would disrupt the California schedule, since class certification discovery will continue for several more months. It concluded, however, that this consideration did not outweigh the others, and that exceptional circumstances warranted transfer.
The court granted Experian's motion to transfer, and directed that the pending motion to quash be transferred to the Eastern District of California. Because it ordered transfer, the court did not address the merits of the underlying claims or the arguments on the motion to quash.
The Case is No. 0:26-mc-00065-SGE.