In West Virginia, service of subpoenas in civil cases is governed by Rule 45 of the West Virginia Rules of Civil Procedure, and in criminal cases service of subpoenas is governed by Rule 17 of the Rules of Criminal Procedure. There are no special requirements that must be met to serve a subpoena on a member of the news media. Rule 45 states that a subpoena can be quashed or modified if it "fails to allow reasonable time for compliance[.]" Although the rules do not specify a number of days in advance of the appearance requested in the subpoena that the subpoena must be served, the amount of time is somewhat discretionary with the court. It should be noted that the West Virginia Supreme Court has quashed a subpoena served only four (4) days or so prior to trial on the basis that the service was not "diligent." Blankenship v. Mingo County Economic Opportunity Com'n, Inc., 187 W.Va. 157, 416 S.E.2d 471, 476 (1992). Rule 45 allows a party fourteen (14) days to object to a subpoena duces tecum, but allows less time to object if the subpoena specifies less time to respond.