This is the second in a series of posts regarding Utah divorce subpoenas.

In each post, I’ll provide one subpoena request that has been proven effective in getting information in our divorce cases.

We use subpoenas constantly as part of our 28-step divorce system. They are a great way to gather accurate information.

This is because you never fully realize how much people lie until you get subpoenaed documents.

For example, I’ve had someone tell me on the stand he/she stopped taking a certain cocktail of drugs that caused very serious and dangerous psychological problems in the past. After that testimony, we subpoenaed prescription records and found that person had filled prescriptions for that exact cocktail of drugs both before and after testifying.

Stuff like that is a goldmine in divorce and child custody cases; and, often, you can only discover gold when you subpoena documents from outside sources.

So, without further ado, here’s the request.

Medical Provider Records Request

The following is our subpoena request for medical records directly from a medical provider (I’ll post a request for medical insurance records another time):

“All records, documents, correspondences (including correspondences with third-parties regarding below-named person), call/communication logs, notes regarding communications, evaluations, doctors’ and nurses’ notes, physical therapy notes and records, raw test data, charts, test results, diagnostic studies, diagnostic films, bills, explanations of benefits, payment histories, psychological therapy or psychologists’ notes, psychiatrists’ notes, pharmacy records, and all other records you may have in your possession regarding XXXX, born XXXX XX, XXXX, Social Security Number XXXX.”

(Note: It really helps if this request is accompanied by a HIPAA-compliant release, but it works well without.)

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