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· In the instance of an invalid subpoena duces tecum, the health information manager should first refer the issue to the health-care provider's legal counsel for assistance. The counsel has several choices, including (1) responding by letter to the requesting attorney informing him or her of the health-care provider's refusal to release the requested information; (2) filing with the court a motion to quash; or (3) where appropriate, advising the health information manager to release the requested information in whole or in part.

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