In New York, the same rules apply to both civil and criminal subpoenas. Section 610.40 of the New York Criminal Procedure Law (CPL) provides that, “[s]ervice must be made in the manner provided by the civil practice law and rules for the service of subpoenas in civil cases.” Under Section 2103 of the New York Civil Practice Law and Rules (CVP), service may be made by hand delivery, mailing, delivery to the witness’s or party’s residence, fax, overnight delivery service, or delivery to the witness’s or party’s attorney by various means.