Q: Must a subpoena include "the annexed document" referred to in the subpoena? This is NY, the Supreme Court.
A:
A subpoena needs to describe the document or item requested with sufficient particularity as to enable the party served with the subpoena to produce the document or item. It does not need to include a copy of the document referenced in the subpoena itself.
https://codes.findlaw.com/ny/civil-practice-law-and-rules/cvp-sect-2301.html
Tim Akpinar agrees with this answer
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