Ott v. City of Milwaukee

Ct. of Appeals lacked jurisdiction to consider appeal of Dist. Ct.'s denial of two motions to quash subpoenas filed by two non-party state agencies. Ct. rejected agencies' contention that denials were reviewable under collateral-order doctrine and further found that agencies were required to generate contempt order prior to filing any appeal of said denials. Ct. alternatively rejected agencies' arguments that they were not subject to Dist. Ct.'s subpoena power because they were not "persons" under Rule 45, or that instant subpoenas could not be served on them via certified mail.