We recently revamped our subpoena process here at the firm. The major revamp was a template Subpoena Duces Tecum that requests documents and information regarding just about anything we could need in a Utah divorce case.
Over the next few posts, I’ll provide our template requests one at a time.
Why Am I Doing This?
Why am I doing this when most attorneys guard their pleading language likes it’s the nuclear football?
Well, because subpoenas are difficult, and crafting good language that actually gets what you want without an objection takes a long time and a lot of work. If you don’t have an attorney helping you, it’s almost impossible to fashion effective subpoenas yourself. So, this is for all the do-it-yourself-divorcers out there. You need all the help you can get. ;-)
Psychological Therapy and Testing Records Request
The following is our subpoena request for psychological therapy and testing records:
“All records, documents, correspondences (including correspondences with third-parties regarding below-named person), call/communication logs, notes regarding communications, evaluations, doctors’ and nurses’ notes, raw test data, charts, test results, diagnostic studies, diagnostic films, bills, explanations of benefits, payment histories, psychological therapy or psychologists’ notes, pharmacy records, and all other records you may have in your possession regarding XXXX, born XXXX XX, XXXX.”
(Note: It really helps if this request is accompanied by a HIPAA-compliant release, but it works well without.)