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28 [INSERT CAPTION AND STYLE OF CASE]
SUBPOENA DUCES TECUM [ACCOUNTANT-DIVORCE ACTION]
STATE OF: [insert jurisdiction]
COUNTY OF: [insert county or parish name]
WE COMMAND YOU TO SUMMON:
[insert name of accountant, address and name of person to be
served]
pursuant to [insert Rule, e.g., typically the rule is Rule 45] to produce
and permit inspection and copying of the books, documents, and other tangible things in your
possession, custody or control which are described below after ten (10) days from the date of
service hereof, but not later than twenty (20) days from the date of service hereof, at the office
of the attorney for the above-named [insert name of party on whose behalf the
subpoena deuces talcum is served] :
[insert name and address of attorney representing party
on whose behalf the subpoena duces tecum is served]
As used in the following separate requests, the term “documents and things” shall mean
to include, but not limited to, any and all letters, words, or numbers, or their equivalent set down
by handwriting, typewriting, printing, photo stating, photographing, magnetic impulse,
mechanical or electronic recording, or other form of data compilation.
1. All documents and things consisting of any tax returns, including corporate,
individual and joint-individual, prepared by you or your agents/employees, for
[insert name of account holder] for the years [insert date
desired] to the present.
2. All documents and things consisting of any financial statements, corporate and
individual and joint-individual, prepared by you or your agents/employees, for
[insert name of account holder] for the years [insert date
desired] to the present.
3. All documents and things consisting of any accountings, books, ledgers, records,
receipts and other tangible things relating to or referencing the financial
condition, including assets and liabilities, transfers of tangible and intangible
assets and/or property, of [insert name of account holder] for the
years [insert date desired] to the present.
4. All other documents and things consisting of notes, correspondence, memoranda
and other similar documents and tangible things prepared or created by you or
your agent/employees relating to or referencing [insert name of account
holder] for the years [insert date desired] to the present.
5. All documents and things consisting of certificates of deposits, funds, stocks,
bonds, debentures, negotiable instrument, trusts, securities or similar other things
for the use, benefit or other purposes of [insert name of account
holder] at any past or present time.
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28 6. All documents and things consisting of transfers of any kind or nature of any
tangible or intangible property, whether real or personal, which [insert name
of account holder] has or had any interest.
7. If you object to any disclosure stated or fairly inferred by the preceding numbered
requests upon any grounds of any privilege or legal doctrine, please provide a
brief description of each book, record, document, or other tangible or intangible
thing by item and category which you contend is privileged and/or is otherwise
subject to non-disclosure.
Issued under my hand and seal of said Court, this day of ,
____________________ , Clerk
[Insert county] , [insert state]
(Seal)
BY: D.C.