In re: Subpoena of American Nurses Association

            2016 WL 1381352 (4th Cir., April 7, 2016)

            The United States Court of Appeals for the Fourth Circuit determined that a non-party’s attorney’s fees which are “necessary to a discovery proceeding under Rule 45 are expenses that may be shifted to the discovery-seeking party.” The Court also permitted the non-party’s e-discovery vendor fees to be shifted to the discovery-seeking party.