Today’s column examines a U.S. District Court decision involving the protection afforded nonparties under the Federal Rules of Civil Procedure when subpoenaed for a deposition.The court observed that nonparties will be protected from undue burdens and that, in weighing requests to depose nonparties, courts will consider four factors: (1) the person’s nonparty status; (2) relevance of discovery sought; (3) need for discovery; and (4) breadth of the request.In Uppal v. Rosalind Franklin University of Medicine and …