United States v. Janbakhsh
3:22-cr-00340
M.D. Tenn.Jul 3, 2025Background
- Defendant Mahan Janbakhsh issued broad Rule 17(c) subpoenas seeking various documents and communications from multiple non-party and former co-defendants ahead of his criminal trial.
- The subpoenaed parties and individuals (Ron Janbakhsh, David Raybin, Michael Abelow, Christian Quiroz, Paul Bruno, Steven Piper, Diego Cifuentes, Steve Winchester, among others) filed motions to quash or failed to comply.
- Janbakhsh also filed motions to compel compliance from Cifuentes and Winchester, claiming necessary preparation for his defense.
- The Court reviewed the challenged subpoenas, emphasizing the requirements under Rule 17(c) and the standards established by United States v. Nixon.
- The trial is set for July 2025; the parties’ arguments were fully briefed, and factual background was not reiterated in this order.
- The ruling largely focuses on the overbreadth, lack of specificity, and improper use of subpoenas for discovery or impeachment rather than obtaining specific, admissible evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rule 17(c) subpoenas were overly broad and unspecific | Subpoenas fail Nixon specificity; are improper discovery tools | Sought broad document categories, arguing necessity for defense | Subpoenas were overbroad, failed Nixon; quashed |
| Whether subpoenas sought materials available via other means | Documents obtainable by Rule 16 or are Jencks Act material | Claimed additional material not otherwise producible | Requests duplicative of discovery; quashed |
| Whether subpoenas could seek impeachment material | Rule 17(c) forbids use for pure impeachment evidence | Sought records for witness impeachment and bias challenge | Use for impeachment is improper; quashed |
| Whether motions to compel compliance should be granted | Subpoena requests similarly flawed as quashed subpoenas | Claimed non-response impedes defense preparation | Motions to compel denied; requests failed Nixon |
Key Cases Cited
- United States v. Nixon, 418 U.S. 683 (1974) (establishes the standard for issuing a Rule 17(c) subpoena: relevance, admissibility, specificity)
- Bowman Dairy Co. v. United States, 341 U.S. 214 (1951) (interpreting Rule 17(c) as not creating a broad criminal discovery right)
- United States v. Hughes, 895 F.2d 1135 (6th Cir. 1990) (Rule 17(c) cannot be used solely to obtain impeachment material)
- United States v. Llanez-Garcia, 735 F.3d 484 (6th Cir. 2013) (Rule 17(c) is not an additional discovery device)