(November 18, 2015, 1:43 PM EST) -- PASADENA, Calif. — A union erred when it failed to file a subpoena duces tecum with a grocery chain’s counsel, but that defect was insufficient to excuse the market’s failure to file a petition to revoke the subpoena, the Ninth Circuit U.S. Court of Appeals ruled Nov. 13 (National Labor Relations Board, et al. v. Fresh and Easy Neighborhood Market, Inc., No. 12-55828, 9th Cir.; 2015 U.S. App. LEXIS 19763)....