43 CFR § 2.283
If I serve a subpoena <em>duces tecum,</em> must I also submit a <em>Touhy</em> request?
August 12, 2025
§ 2.283 If I serve a subpoena duces tecum, must I also submit a Touhy request?
Yes. If you serve a subpoena for employee testimony, you also must submit a request under United States ex rel. Touhy v. Regan, 340 U.S. 462 (1951)? If you serve a subpoena duces tecum for records in the possession of the Department, you also must submit a Touhy Request.
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