Mattson Chapter 7 Bankruptcy Order Denying Motion to Quash Subpoenas
Summary
The United States Bankruptcy Court for the District of Maine denied debtor Kevin J. Mattson's consolidated motion to quash subpoenas issued by Montresor, LLC to three financial institutions—Gardiner Federal Credit Union, Kennebec Savings, and Winthrop Federal Credit Union. The court held that Mr. Mattson lacked standing under Fed. R. Civ. P. 45(d)(3)(A)(iv) because non-recipients of subpoenas cannot challenge them on grounds of undue burden. The motion was denied on April 16, 2026.
“As Mr. Mattson is not the recipient of the subpoenas, he has no standing to move for quashal and, therefore, the motions is DENIED.”
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What changed
The court denied the debtor's motion to quash subpoenas issued by Montresor, LLC to three credit unions and a savings bank, citing a long-standing rule that non-recipients lack standing under Fed. R. Civ. P. 45(d)(3)(A)(iv) to challenge subpoenas on undue burden grounds. The ruling follows established precedent from multiple district courts. Affected parties in bankruptcy contested matters should be aware that only subpoena recipients themselves may move to quash on grounds of undue burden or relevance—not third parties such as debtors or targets of the underlying litigation.
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Apr 24, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
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April 16, 2026 Get Citation Alerts Download PDF Add Note
In re: Kevin J. Mattson
United States Bankruptcy Court, D. Maine
- Citations: None known
- Docket Number: 24-20188
Precedential Status: Unknown Status
Trial Court Document
UNITED STATES BANKRUPTCY COURT
DISTRICT OF MAINE
In re:
Chapter 7
KEVIN J. MATTSON, Case No. 24-20188
Debtor.
ORDER DENYING DEBTOR’S CONSOLIDATED
MOTION TO QUASH SUBPOENAS
Kevin J. Mattson, the debtor in the above-captioned case, seeks an order quashing, or in
the alternative, modifying subpoenas Montresor, LLC issued to Gardiner Federal Credit Union,
Kennebec Savings, and Winthrop Federal Credit Union on or about April 2, 2026 in connection
with a pending contested matter. Mr. Mattson contends that the requests for information
contained in the subpoenas are unduly burdensome because they are duplicative of requests
Montresor, LLC made in connection with an earlier proceeding. Though Mr. Mattson does not
reference the rule, the Court presumes he is moving under Fed. R. Civ. P. 45(d)(3)(A)(iv), as
made applicable to this proceeding by Fed. R. Bankr. P. 7045.
Courts have long held that non-recipients lack standing under Fed. R. Civ. P. 45(d)(3) to
challenge a subpoena on the basis of undue burden. See, Silverstone Holding Grp., LLC v.
Zhongtie Dacheng (Zhuhai) Inv. Mgmt. Co., Ltd., 605 F.Supp.3d 199, 202-03 (S.D.N.Y. 2023)
(“[b]ecause Silverstone is not the recipient of the subpoena, it does not have standing to
challenge the subpoena on the independent grounds of undue burden or relevance.”). See also,
Renaissance Custom Homes, LLC v. Elite Homes, LLC, 2024 WL 6078711, at *1 (D. Ore. Oct.
9, 2024); (Wyatt B. v. Kotek, 2024 WL 1905563, at *2 (D. Ore. May 1, 2024); Torres v. Equifax
Info. Services, 2023 WL 12073732, at *1 (M.D. Pa. Aug. 29, 2023); Gabriel v. Albany Coll. of
Pharmacy and Health Sciences – Vermont Campus, 2014 WL 3378629, at *3 (D.Vt. July 10,
2014).
As Mr. Mattson is not the recipient of the subpoenas, he has no standing to move for
quashal and, therefore, the motions is DENIED.
Dated: April 16, 2026 /s/ Peter G. Cary
Judge Peter G. Cary
United States Bankruptcy Court
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