PATEL v. RABINOWITZ EX REL. LAKHANI

Record No. 0034-22-4.

879 S.E.2d 60 (2022)

75 Va. App. 663

Dakshay PATEL, Virginia Star, LLC, Sun Management Group, Inc., f/k/a Sandesara Management Group, Inc., American Enterprises, LLC d/b/a Sterling Gelatin, Inc., Saib, LLC, and Sterling Oil Resources LLC v. Receiver Jonathan I. RABINOWITZ EX REL. LAKHANI ASSOCIATES, LLC and Primis Bank, f/k/a Sonabank.

Court of Appeals of Virginia, Arlington.

November 1, 2022.


Attorney(s) appearing for the Case

Ryan J. Strasser ( Timothy L. McHugh ; Abbey M. Thornhill ; Troutman Pepper Hamilton Sanders LLP, on briefs), Richmond, for appellants.

Sara E. Kropf (Kropf Moseley PLLC, on brief), for appellee Receiver Jonathan I. Rabinowitz ex rel. Lakhani Associates, LLC.

No brief or argument for appellee Primis Bank, f/k/a Sonabank.

Present: Judges Huff, Raphael and Lorish


We consider here whether a judgment creditor may use the Uniform Interstate Depositions and Discovery Act (UIDDA), Code §§ 8.01-412.8 to 8.01-412.15, to serve an out-of-state document subpoena on third parties in Virginia when the judgment creditor only suspects that those third parties might hold property...

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