of Rules 17(a) and (b)'s provisions of subpoenas to witnesses, which may issue without notice. See 2020 WL 6939677, at *8 (quoting United States v. Florack, 838 F. Supp. 77, 79 (W.D.N.Y. 1993)). However, Rule 17(c) subpoenas for records are quite unlike subpoenas for trial testimony: they can be made re