3. File a motion to quash

The motion to quash is the only certain means of seeking protection against a subpoena. See Idaho Rule of Civil Procedure 45(d); Idaho Criminal Rule 17(b). Some parties will wait until the time of the compelled appearance, whether it be in a deposition or in a court appearance, and assert the privilege in response to questions posed at that time. Doing so, however, at least in Idaho state court, runs the risk (but not necessarily the certainty) of having the court rule that the privilege has been waived.