Defendants have yet to meet their initial burden of articulating how Plaintiff Doe 2's employment file from her previous employer is relevant to any of Defendant SC's defenses. Furthermore, Rule 45(c)(3)(A) authorizes a court to quash or modify a subpoena if it requires disclosure of privileged or other protected matter, Fed. R. Civ. Pro. 45, if it risks “unfair prejudice to persons who are the subject of a subpoena's commands”[.]

Doe 2's PrimeCare employment records are relevant in this employment action. A summary of evidence in this case from witnesses including Doe 2 is that she resigned from her position with PrimeCare in lieu of termination on the basis that medication was missing and/or persons she supervised were involved in an issue with taking medications. Also, there has been testimony that Doe 2 was wrongfully accused of drug abuse, which she claims was not true, but is contradicted by other witnesses. In general, her credibility as a party is always at issue. Further, more recently, the psychological report provided of Dr. Dawn Sheehan of Doe 2 recounts her employment history as part of her assessment of Doe 2. That report includes specific references that Doe 2 reported that “[S]he worked as a nursing supervisor at Schuylkill County prison from 2006 until 2012, where she reportedly rectified deficiencies after a failed accreditation and was asked to assist at other facilities. She was highly regarded in this position but was unhappy with the perpetual on-call schedule and working with the inmate population. She reportedly left on good terms.” In addition, the report includes that the examiner felt Doe 2 “approached the evaluation in an open, honest, and genuine manner.” The employment records of Doe 2 are certainly relevant to findings made by this expert as they could contradict statements of Doe 2, not to mention bear on how she was perceived by the expert, which could impact those conclusions.

District courts provide magistrate judges with particularly broad discretion in resolving discovery disputes. See Farmers & Merchs. Nat'l Bank v. San Clemente Fin. Group Sec., Inc., 174 F.R.D. 572, 585 (D. N.J. 1997). When a magistrate judge's decision involves a discretionary [discovery] matter ..., “courts in this district have determined that the clearly erroneous standard implicitly becomes an abuse of discretion standard.” Saldi v. Paul Revere Life Ins. Co., 224 F.R.D. 169, 174 (E.D. Pa. 2004) (citing Scott Paper Co. v. United States, 943 F. Supp. 501, 502 (E.D. Pa. 1996)). Under that standard, a magistrate judge's discovery ruling “is entitled to great deference and is reversible only for abuse of discretion.” Kresefky v. Panasonic Commc'ns and Sys. Co., 169 F.R.D. 54, 64 (D.N.J. 1996); see also Hasbrouck v. BankAmerica Hous. Servs., 190 F.R.D. 42, 44-45 (N.D.N.Y. 1999) (holding that discovery rulings are reviewed under abuse of discretion standard rather than de novo standard); EEOC v. Mr. Gold, Inc., 223 F.R.D. 100, 102 (E.D.N.Y. 2004) (holding that a magistrate judge's resolution of discovery disputes deserves substantial deference and should be reversed only if there is an abuse of discretion).

Rule 45(c)(3)(A) of the Federal Rules of Civil Procedure authorizes a court to quash or modify a subpoena that subjects a person to undue burden. Fed. R. Civ. P. 45(c)(3)(A)(iv), ...; see Composition Roofers Union Local 30 Welfare Trust Fund v. Graveley Roofing Enter., 160 F.R.D. 70, 72 (E.D. Pa. 1995) (Joyner, J.) (stating same). Accordingly, a court may quash or modify a subpoena if it finds that the movant has met the heavy burden of establishing that compliance with the subpoena would be “unreasonable and oppressive.” Id. (citing Heat & Control, Inc. v. Hester Indus., 785 F.2d 1017, 1023 (Fed. Cir. 1986)). [However, when assessing a motion to quash we must also consider the fact that] Rule 26(b)(1) provides that discovery need not be confined to matters of admissible evidence but may encompass that which “appears reasonably calculated to lead to the discovery of admissible evidence.” Fed. R. Civ. P. 26(b)(1).

witness impeachment is a time-honored basis for discovery, as held long ago in Hickman v. Taylor, 329 U.S. 495, 511, 67 S.Ct. 385, 91 L.Ed. 451 (1947) (non-privileged information in attorney's files is discoverable because “[s]uch written statements and documents ... might be useful for purposes of impeachment or corroboration”); see also Wright, Miller, & Marcus, Federal Practice and Procedure, Civil 2d § 2015 (“Discovery is commonly allowed in which the discovering party seeks information with which to impeach witnesses for the opposition”).