In United States v. Ail, a court in this District applied the lessons of Armstrong to deny a motion to compel discovery concerning an outrageous government conduct claim. No. CR 05-325-RE, 2007 WL 1229415, at *3-4 (D. Or. Apr. 24, 2007). There, United States District Judge Redden, after recounting Armstrong's reasoning, explained that an "outrageous governmental misconduct claim is at least roughly analogous to the selective prosecution claim brought in Armstrong."

(noting disapprovingly that “many [of defendant's] requests are duplicative” and that requiring a party to reproduce material is burdensome); United States v. Ail, No. CR 05-325-RE, 2007 WL 1229415, at *6 (D. Or. Apr. 24, 2007) (“Further disclosure related to the informants' alleged profits would be cumulative, and defendants cannot use Rule 17(c) as a discovery tool, or a means to conduct a ‘fishing expedition.'”); United States v. Mason, No. CR 05-324-RE, 2008 WL 1909115,

United States v. Segal, 276 F.Supp.2d 896, 899 (N.D. Ill. 2003) (citing United States v. Raineri, 670 F.2d 702, 712 (7th Cir. 1982) (holding that the United States possessed a legitimate interest in quashing a defense subpoena issued to government witnesses because "preventing undue lengthening of the trial, undue harassment of its witnesses, and prejudicial over-emphasis on [the witness's] credibility")). The Court finds that the United States has standing because the subpoena issued to López may result in "harassment of potential witnesses, as well as undue lengthening of the trial and discovery process" with evidence that may neither be relevant nor admissible. United States v. Ail, No. 05-325, 2007 WL 1229415, 2007 U.S. Dist. LEXIS 30786 (D. Or. Apr. 24, 2007) (holding that the United States had standing in moving to quash defendant's subpoena issued to potential witnesses); United States v. Giampa, No. 92–437, 1992 WL 296440, 1992 U.S. Dist. LEXIS 15214 (S.D.N.Y Oct. 7, 1992) (holding government had standing to move to quash Rule 17(c) subpoenas to non-party witness based on the government's "interest in preventing any undue lengthening of the trial, any undue harassment of [the witness] and his family, and any prejudicial over-emphasis on [the witness's] credibility").Indeed, quashing a subpoena issued to a third-party on the United States' motion pursuant to Rule 17 is not unprecedented.

(Docket no. 146 at n. 5). This Court will therefore address the Motion to Quash on its merits. See United States v. Ail, 2007 WL 1229415 at *5 (D. Or. Apr. 24, 2007) (noting that whether or not government has standing to move to quash Rule 17 subpoena to third parties, third parties have standing). Defendant Fieger is an attorney.