Dellwood Foods, Inc. v. Abrams
Dellwood Foods, Inc., indicted for antitrust violations under the General Business Law, moved to quash post-indictment subpoenas issued by the Attorney-General to its sales personnel. Dellwood contended these subpoenas constituted an abuse of process, arguing their sole purpose was to gather evidence for the pending trial. The court, presided over by Judge Lawrence J. Tonetti, affirmed Dellwood's standing to challenge the subpoenas. While acknowledging the Attorney-General's investigatory powers do not abate post-indictment, the court applied a 'dominant purpose' test, requiring subpoenas to further legitimate investigations rather than merely prepare for trial. Following an *in camera* review, the court determined the subpoenas were for a valid ongoing investigation, not solely for trial preparation. Consequently, Dellwood's motion to quash the subpoenas was denied.