issuance or enforcement of a Rule 17(c) subpoena because such materials would only become relevant after a witness has testified. United States v. Slcelos, No. 15-CR-317 (KMW), 2018 WL 2254538, at *2 (S.D.N.Y. May 17, 2018), aff'd, 988 F.3d 645 (2d Cir. 2021) (collecting cases). The other theory of re