ianal but if I were drafting simula's motion to quash, I would mention that the categories of information fb wants are confidential or trade secrets under most

ianal but if I were drafting simula's motion to quash, I would mention that the categories of information fb wants are confidential or trade secrets under most employment agreements, including probably fb's and that rule 45 requires the court to quash if the subpoena is for 'privileged or other protected matter' and if you can prove undue burden you can sanction their firm (in theory at least) (could also just refresh the northern district's efile until big G responds, then steal theirs)