These should be used very carefully. Non-party production is obtaining records from a person or entity that is not a party to the case, typically through a subpoena or a signed authorization. Financial institutions, employers, medical providers, schools, and government agencies are common non-party record sources.

Non-party subpoenas must comply with the applicable rules for service, notice, and the scope of what can be requested. The subpoenaed party has the right to object or seek protection from the court if the subpoena is overbroad.

Non-party production is particularly valuable in hidden asset cases. A subpoena to a bank for all accounts associated with a party's social security number can reveal accounts that were not disclosed.