hese documents from a third party instead of Plaintiff because it is an improper use of a third party subpoena. Zoological Soc. of Buffalo, Inc. v. Carvedrock, LLC, No. 10-CV-35A SR, 2013 WL 5652759, at •3 (W.D.N.Y. Oct. 15, 2013) (imposing sanctions under Rule 45 where party imposed an undue burden on a