ADMINISTRATIVE SUBPOENA / CID RESPONSE GUIDE

1. INTAKE AND AUTHORITY

• Log receipt date/time; calendar return date.
• Identify issuing agency, statutory authority, and enforcement forum.
• Verify service compliance and jurisdiction over recipient.
• Confirm any Texas-specific CID/subpoena prerequisites and meet-and-confer requirements in agency regulations.

2. SCOPE REVIEW

• List requests; note date ranges, custodians, subject matter.
• Identify overbreadth, vagueness, burden, privilege, confidentiality, and trade secret issues.
• Map data sources: email, messaging, cloud storage, devices, paper files.

3. PRESERVATION AND HOLDS

• Issue legal hold to relevant custodians; suspend auto-deletion where needed.
• Preserve devices/accounts; coordinate with IT for snapshots/exports.

4. NEGOTIATION AND MEET-AND-CONFER

• Request extensions if needed; propose narrowed date ranges/custodians/search terms.
• Seek protective order or confidentiality assurances for sensitive data.
• Clarify production format (ESI specs), privilege clawback, and rolling productions.

5. COLLECTION AND REVIEW

• Collect from agreed sources; document chain of custody.
• Privilege review (A/C, work product); redact PII/PHI/trade secrets as appropriate.
• Create privilege log if required.

6. PRODUCTION

• Produce in agreed format; Bates-label; include cover letter identifying requests satisfied.
• Track what was withheld, redacted, or deferred.

7. WITNESS/APPEARANCE PREP (IF TESTIMONY REQUESTED)

• Determine designee (if 30(b)(6)-like); prepare outline, exhibits, and facts; rehearse; address confidentiality.
• Counsel attendance and objections per agency rules.

8. FOLLOW-UP

• Track deadlines for supplemental responses; monitor for additional requests.
• Maintain a record of all communications and productions.

9. CHALLENGE / MOTION TO QUASH (IF NEEDED)

• Grounds: lack of jurisdiction, overbreadth, undue burden, privilege, irrelevance.
• Consider filing with agency or enforcing court per statute.