The following e-filed documents, listed by NYSCEF document number (Motion 004) 77, 78, 79, 80, 81, 82, 83, 84, 85, 86, 87, 88, 89, 90, 91, 92, 94, 95 were read on this motion to QUASH SUBPOENA. This discovery motion arises in an insurance-coverage action for a declaratory judgment. Nonparty Richard Caracciolo was injured on a construction site while employed by nonparty ThyssenKrupp North America, Inc.1 ThyssenKrupp was acting as a subcontractor to general contractor defendant Wilcox Development Corporation. Wilcox was in turn hired by the owner of the site, SHS Ralph LLC. SHS Ralph is the named insured on a policy issued by plaintiff Arch Specialty Insurance Company. ThyssenKrupp is the named insured on a policy issued by defendant HDI Gerling American Insurance Company; and Wilcox is the named insured on a policy issued by defendant. United Specialty Insurance Company. Arch has alleged that under the terms of the contracts between SHS Ralph and Wilcox, and SHS Ralph and ThyssenKrupp, SHS Ralph was required to be named as an additional insured on the HDI Gerling and United policies. Caracciolo brought a personal-injury action in Supreme Court, Queens County against SHS Ralph, which in turn impleaded ThyssenKrupp. (See Caracciolo v. SHS Ralph LLC, Index No. 512132/2016 [Sup Ct, Queens County] [the underlying action].) Arch has alleged in the current action that under the terms of the HDI Gerling and United policies, those insurers owe a defense and indemnity obligation to SHS Ralph (and thus to Arch as SHS Ralph’s subrogee). This motion relates to a nonparty subpoena served by Arch on ThyssenKrupp under CPLR 3101 (a) (4). The subpoena demands production of 28 different categories of documents — for the most part broadly construed to seek “all” or “any and all” documents in each category. ThyssenKrupp moves to quash the subpoena under CPLR 2304 and seeks a protective order under CPLR 3103. The motion is granted in its entirety. DISCUSSION Under CPLR 3103 (a), a court may — on the motion of a party or sua sponte — “issue a protective order precluding disclosure that is palpably improper in that it seeks irrelevant and/or confidential information, or is overly broad and burdensome.” (Arch Ins. Co. v. Delric Constr. Co., 174 AD3d 560, 561 [2d Dept 2019].) Here, Arch’s subpoena is improper on both counts.2 First, Arch’s subpoena, if enforced, would require extensive production of irrelevant information. For example, Arch seeks the underlying plaintiff’s employment records, accident history, and medical history. (See NYSCEF No. 85 at 12.) It demands ThyssenKrupp’s records relating to safety measures undertaken at the work site, responses to worker complaints at the site — including employees of other contractors — and documentation of any accidents that occurred at the site. (Id. at