Dear Sir, thank you very much for your detail answer. The subpoena is my respond to the witness (located outside the state @ North Carolina) declaration in lieu of testimony C.C.P 98. I try to read the rule and it said this must be personally served. My understand is the witness must be there to accept the subpoena, not the attorney who represents for her company. Is that correct? Also, the Notice to the Party to Produce Persons to Testify or Produce Documents at Trial you mentions above is for taking the deposition? I do not think I could use it since my trial only 15 days away.

Thank you and appreciate your answer.