Subpoenas and subpoenas duces tecum shall be issued in accordance with the rules of criminal procedure and these rules and shall be served at least forty-eight hours before any appearance is required before the grand jury, unless waived by the witness. The court, for good cause, may shorten the time limit imposed by this rule.
Colo. R. Crim. P. 6.1
Annotation Grand jury dependent on courts for subpoenas. One significant limitation upon the grand jury is that it must rely upon the courts to compel the production of documents or the attendance of witnesses, and, on motion of the witness subpoenaed, the court is given discretion to quash, modify, or order compliance with the subpoena. Losavio v. Robb, 195 Colo. 533, 579 P.2d 1152 (1978). For in camera examination of subpoenaed bank records, see Pignatiello v. District Court, 659 P.2d 683 (Colo. 1983). Applied in People ex rel. Gallagher v. District Court, 198 Colo. 468, 601 P.2d 1380 (1979).