In this case before the U.S. District Court for the Northern District of Illinois, the Federal Rules of Civil Procedure were examined closely with respect to a subpoenaed nonparty deposition. The court stated that nonparties will be protected by undue burden and that, in weighing requests to depose nonparties, courts will consider four factors:
- The person’s nonparty status;
- Relevance of discovery sought;
- Need for discovery; and
- Breadths of the request.
In this case, the plaintiff Prabhjot Uppal graduated as a physician from Rosalind Franklin University of Medicine and Science in 2005. He obtained a residency at Lutheran General Hospital in Park Ridge, Ill.