When counsel subpoenas records from a provider, employer or other third party, the responses arrive over weeks or months: some complete, some partial, some with a certificate and some without. The work is in tracking and organizing them as they come in.
Track what was requested
Keep a list of every subpoena: recipient, date served, what was requested and the date range. Each response is checked against that list when it arrives.
Intake each response the same way
- Save the original exactly as received, with the date and how it came in.
- Note whether a certificate or declaration of the custodian was included.
- Compare the contents to what was requested, and list anything missing.
- Number and index the pages so every page can be cited.
Flag gaps early
A missing date range or record type is much easier to chase right away than months later. Give counsel a short note of what came in and what is still outstanding.
Keep a single index
One index across all responses, by source and date, lets anyone on the case find a record in seconds and see at a glance what has not arrived.
Our records request log and Bates number generator help with tracking and numbering.
Litigation support is performed at the direction of a licensed attorney. Issuing and enforcing subpoenas are matters for counsel.
This article is general information, not legal, tax or regulatory advice. Rules change; confirm current requirements with the responsible agency or a licensed professional.
