United States v. Exposito, 4:23-cr-00063

Mark Exposito was indicted on charges of conspiracy and multiple counts of wire fraud involving Bradley Fenton, Fenton Motor Group, and its subsidiaries.
Exposito subpoenaed documents from Lane Gorman Trubitt, LLC (LGT), an accounting firm that prepared tax returns for the alleged victims, seeking records relevant to his defense.
LGT moved to quash the subpoena, citing concerns over legal penalties for releasing confidential client information without court authorization.
Federal Rule of Criminal Procedure 17(c) requires advance notice to victims before compelling third-party document production.
Only Bradley Fenton, among the named victims and entities, was shown to have been properly notified per court and rule requirements.

Issue	Exposito's Argument	LGT's Argument	Held
Whether subpoena notice to all victims was proper	Serving Fenton suffices, given entity dissolution and his role	Notice not sufficient; proper notice to each victim required	Partial notice insufficient; only Fenton adequately notified
Whether LGT can lawfully produce documents	Court order protects LGT from penalties; documents are needed	Needs court order to avoid liability for disclosing client info	Court order granted for Fenton-related documents only
Scope of permissible document production	Seeks broad production covering victims and subsidiaries	Argues improper scope without full notice to all entities	Only production as to Fenton, per notice and rule
Access and handling of produced materials	Defense team access needed for preparation	Standard restrictions to control confidential material	Strict protective order and destruction after proceedings

No key cases with official reporter citations were cited in the opinion.