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The proper form of response to this is a Motion to Quash. Here is the information on a Motion to Quash:
Motion to Quash or Modify Subpoena
On timely motion, the court by which a subpoena was issued (or in the case of a subpoena to a non-party, the court of the county where the non-party resides, is employed or transacts business) can quash, modify or place reasonable conditions on the subpoena if it:
Fails to allow reasonable time for compliance. SC RCP 45(c)(3)(A)(i).
Requires, in the case of a deposition or production prior to hearing or trial, a non party to travel more than fifty (50) miles from the county of residence or employment or where that person regularly transacts business in person.SC RCP 45(c)(3)(A)(ii).
Requires the disclosure of privileged or protected information and no waiver applies. SC RCP 45(c)(3)(A)(iii).
Subjects the subpoenaed person to an undue burden. SC RCP 45(c)(3)(A)(iv).
Requires disclosure of a trade secret or other confidential research, development or commercial information. SC RCP 45(c)(3)(B)(i).
Requires disclosure of an unretained expert's opinion or information not describing specific events or occurrences in dispute and resulting from the expert's study made not at the request of any party. SC RCP 45(c)(3)(B)(ii).
Requires a non-party to incur substantial travel expense. SC RCP 45(c)(3)(B)(iii).
In the case of motions to quash or modify brought under Section B of Rule 45(c)(3), the court may require the subpoenaing party to show a substantial need for the testimony or material that cannot be otherwise met without undue hardship and make assurances that the person to whom the subpoena is addressed will be reasonably compensated before the testimony can be taken. SC RCP 45(c)(3)(B)(iii).
In addition, since there seems to be a history you may also want to file a Motion for a Protective Order. A protective Order prevents the other party from using the legal process to harass you.
See this link for information on the Protective Order:
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