Paralegal Certification PrepLitigationHard

A paralegal is assisting an attorney with a complex business litigation case. The attorney needs to compel a non-party witness to appear for a deposition and bring specific financial records related to the case. What type of document should the paralegal prepare to ensure both the witness's presence and the production of the documents?

  1. ARequest for Production of Documents
  2. BInterrogatories
  3. CSubpoena Duces Tecum
  4. DSubpoena ad Testificandum
Show answer & explanation

Correct answer: C. Subpoena Duces Tecum

A Subpoena Duces Tecum is specifically designed to compel a witness to appear and to bring specified documents or tangible evidence with them. If only appearance were needed, it would be a Subpoena ad Testificandum.

Why the other options are wrong

  • A. A Request for Production of Documents is for parties to the lawsuit, not non-party witnesses.
  • B. Interrogatories are written questions for parties, not to compel non-party witnesses or document production.
  • D. A Subpoena ad Testificandum compels a witness's attendance to testify, but not the production of documents.

Subpoena Duces Tecum

A legal writ compelling a witness to appear in court or at a deposition and to bring with them specified documents, records, or other tangible evidence relevant to the proceedings.

  • Used to obtain both testimony and physical evidence.
  • Can be issued to both parties and non-parties.
  • Must specifically list the documents or items to be produced.

Memory trick: Compel attendance and documents for discovery.

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