An Administrative Subpoena Duces Tecum May Issue By The California Corporations Commissioner To Subpoena Witnesses In Order To Investigate Violations Of The Corporate Securities Law.

Believing that a corporation might be engaged in violations of the Corporate Securities Law of 1968 [CSL; Corporations Code section 25000], the California Corporations Commissioner issued a subpoena duces tecum requiring the production of certain documents. When all of the documents were not forthcoming, the Commissioner subpoenaed the custodian of records, and the corporation refused to comply. The trial court ordered compliance, and the corporate defendant appealed.  The appellate court affirmed, holding the California Corporations Commissioner properly exercised its statutory authority to issue an administrative subpoena duces tecum and subpoena witnesses for the purpose of investigating possible violations of the CSL.  The People ex rel. Jan Lynn Owen, as Corporations Commissioner v. Media One Direct, LLC  (Cal. App. Fourth Dist., Div. 1; February 27, 2013) 213 Cal.App.4th 1480.