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Possible responses are numerous, including a request for additional time and asserting privilege on behalf of the client. The response must be in writing, and must be sent to all parties in the case, as well as the Court. The response must be received by the requestor on or before the date indicated on the subpoena.
Slightly different from a standard subpoena, the Duces Tecum subpoena doesnt require any oral testimony or deposition at trial. Instead, it requires the named party to produce the necessary evidence or documents to an attorney or the courthouse before proceedings begin.
There are basically six types of discovery in family court: 1) interrogatories; 2) requests for production of documents and inspection 3) requests for admissions; 4) depositions; 5) subpoenas duces tecum; 6) physical and mental examinations.
Generally, therapists should respond to the subpoena, in writing, by the due date on the subpoena even if it is to assert privilege or to inform the Court that the therapist is unable to comply with the subpoena.
A Subpoena Duces Tecum (meaning subpoena for production of evidence) is a court order requiring the person subpoenaed to produce books, documents or other records under his or her control at a specified time/place in a court hearing or a deposition.

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A subpoena ad testificandum is a court summons to appear and give oral testimony for use at a hearing or trial. The use of a writ for purposes of compelling testimony originated in the ecclesiastical courts of Church during the High Middle Ages, especially in England.
Discovery may be carried out by directly asking a person questions (oral depositions), by sending a person written questions (interrogatories and depositions on written questions), and by requesting that the person provide documents (motions for production, subpoenas duces tecum).
Once the subpoena has been received, the recipient should identify and calendar when it must respond to the subpoena (commonly referred to as the return date. If necessary, the recipients lawyer may need to quickly contact the issuing party to negotiate an extension. Any extensions should be in writing.
Subpoena is a command in the form of written process requiring a witness to come to court to testify. Subpoena ad Testificandum: A summons to appear somewhere and give testimony. Subpoena Duces Tecum: A summons to appear somewhere and to bring something (take something) with you and to possibly give testimony too.
A subpoena duces tecum or a subpoena for documents is a court order that requires a third party to produce documents. It is different from a subpoena for testimony, or subpoena ad testificandum, because it does not require the party to give testimony.

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