Appendix C — Model Third-Party Document Rider and Wave-One Schedule
Instrument status: proposed committee template; not issued, signed, or served. This appendix supplies substantive demand language for an authorized congressional committee to adapt and approve. A person or office without issuing authority cannot use it as compulsory process. No recipient is identified and no person is accused. The lawful issuer must attach this rider to its authentic subpoena form and complete the issuance record before service.
C.1. Issuance and scope record
The issuing committee shall maintain a signed record identifying: Congress and committee; adopted committee rules and delegated subpoena authority; authorization vote or authorized chair action and minority consultation; investigation and legislative-purpose memorandum identifier; legal name and service address of the actual custodian; exact accounts, legal entities, properties, contracts, wallet identifiers, or transactions within scope; starting and ending dates; production deadline and time zone; secure production destination; designated counsel contact; service method and proof; and all accommodations or narrowing agreements. The record is part of the authorization file and is not inferred from this template.
The scope record must identify a concrete legislative inquiry within the committee's jurisdiction, explain why each category materially assists it, evaluate less intrusive alternatives, and state a rational date range. A request concerning a President's personal records must receive the separation-of-powers analysis required by *Trump v. Mazars USA, LLP*, 591 U.S. 848 (2020), slip opinion at 18–20. The fact that an accountant or bank holds the records does not remove that analysis.
Do not serve until OGC or designated committee counsel certifies that organization, authority, jurisdiction, service, notice, accommodation, and litigation prerequisites are satisfied. The planned January 6, 2027 start is a readiness target, not a statutory right to bypass those prerequisites.
C.2. Common definitions
Covered Subject means only the legal persons, assets, account identifiers, and transactions enumerated in the authenticated issuance record. An affiliate is covered only if separately enumerated or if the demand expressly identifies the relationship and explains its relevance. Covered Period means the exact interval specified there, including a separately justified retention or opening-record interval. Document means recorded information within the recipient's possession, custody, or control, including native electronic files, attachments, structured databases, ledgers, messages, contracts, and ordinary-course metadata. Communication means an exchange of recorded information between identified participants. Identify means provide the name and stable identifier necessary to distinguish the relevant person, account, transaction, or record, subject to the minimization provisions below. These definitions do not create a duty to acquire documents beyond lawful control or to create a new substantive record.
C.3. Common production instructions
- Produce responsive, nonprivileged records within the Covered Period in the ordinary course or organized by request number, with a manifest explaining the organization. Preserve document-family relationships and identify the request categories addressed by each production segment. Do not remove unfavorable, duplicative-looking, amended, or reversed entries without documenting the treatment.
- Produce spreadsheets and structured ledgers in native format with formulas and data dictionaries where maintained. Produce email in a format preserving sender, recipients, sent time, attachments, and available message identifiers. Supply searchable text with scanned records where readily available. Do not convert a structured ledger to screenshots as the sole production. Agree technical formats with committee counsel when necessary to avoid disproportionate burden.
- Provide source-system time zone, currency conventions, field definitions, and relevant code tables. Identify whether a date is posting, value, execution, settlement, or record-creation date. Preserve raw precision. Do not convert currencies or aggregate entries without retaining the source values and explaining the calculation.
- Apply a stable production identifier to each document or native-file manifest entry. Supply SHA-256 hashes where practicable and explain packaging, encryption, and any export process that changes file bytes. Transmission credentials shall travel through a separate agreed channel. The public repository is not a production destination.
- Redact full personal account numbers, personal contact data, and unrelated customer information only under an agreement or governing legal requirement. Identify each redaction and its basis. Provide an unredacted restricted production when lawfully required and arranged. Do not redact responsive business content solely because it is embarrassing or commercially sensitive; request an appropriate confidentiality arrangement.
- If material is withheld as privileged or otherwise legally protected, produce the segregable nonprotected portion and a log sufficient for assessment without disclosing the protected substance. The log shall identify date, document type, author, recipients and capacities, general subject, protection asserted, and a concise basis. Where logging itself would violate law or reveal a SAR, notify designated committee counsel through the protected legal channel instead of disclosing it in an ordinary log.
- This rider does not demand a SAR, confirmation of its filing, information revealing its existence, grand-jury material protected by a controlling secrecy rule, or records whose production is prohibited by a binding statute or court order. Identify a legal obstacle to designated counsel to the extent lawful. Ordinary underlying bank records remain responsive when independently producible; do not label them as SAR-related. See 31 C.F.R. § 1020.320(e).
- Notify committee counsel promptly of a claimed burden, ambiguity, foreign-law restriction, or technical impediment. State the affected category, estimated volume and burden, and a proposed narrower or staged alternative. Good-faith consultation does not itself extend the deadline; only an authorized written accommodation does. Preserve disputed material while the issue is resolved.
- If no responsive record is located, identify the systems and custodians searched and the search limitations. If responsive records were deleted, lost, transferred, or destroyed, describe the known circumstances, relevant retention policy, approximate date, and available recovery sources. Do not speculate about facts outside the custodian's knowledge.
- Submit rolling productions where agreed. Accompany each installment with its search and production status, outstanding categories, and anticipated completion date. A final completion statement must distinguish completed searches, inaccessible sources, withheld material, and unresolved questions.
C.4. Substantive request modules
An issuer selects only modules supported by its purpose memorandum and scope record. The presence of a module here does not authorize a universal demand.
Module 1: Banks, clearing institutions, and payment processors
Produce account-opening documents, beneficial-customer and authorized-user records, account-control changes, and ordinary-course due-diligence records for enumerated accounts and subjects; periodic statements and transaction-level ledgers; wire/payment messages and associated references identifying originator, beneficiary, intermediary institutions, date, amount, currency, and purpose; deposit and disbursement instruments for enumerated transactions; credit agreements, collateral instruments, guarantees, amendments, and payoff records; and ordinary communications concerning the identified transactions or their commercial purpose. Limit person-level data to the covered account relationships. A clearing record can identify a payment route without establishing a state's territorial jurisdiction or the customer's criminal intent.
Module 2: Accountants and valuation firms
Produce executed engagement letters, scope descriptions, invoices, financial statements and schedules, final and material draft valuations, source records supplied for the enumerated valuation or financial statement, and nonprivileged communications concerning identified discrepancies or valuation assumptions. Specify the relevant engagement and period. Tax-return information obtained through statutory congressional tax channels retains its own restrictions; a document in an accountant's custody does not automatically share the legal treatment of every IRS-held record. Review attorney-client, work-product, and any asserted tax-practitioner protection by document and applicable law rather than assuming either universal privilege or universal waiver.
Module 3: Registered agents, formation services, and corporate custodians
Produce formation and amendment instructions, organizers and instructing customers, service agreements, payment records, manager/member information actually maintained, communications establishing authority to act, and records of transfers or changes in control concerning enumerated entities. State what ownership information was and was not collected in the ordinary course. Do not demand that a registered agent certify ultimate beneficial ownership it does not know. Formation in Delaware, Wyoming, or Nevada alone establishes neither wrongdoing nor an agency's power to dissolve an entity.
Module 4: Hospitality, leases, licensing, and investment counterparties
Produce contracts and amendments, booking and event agreements, invoices, payments and refunds, corporate-customer identifiers, payer/beneficiary information actually maintained, rate approvals, commissions, distributions, licensing or management-fee calculations, and communications about enumerated transactions. For government-linked customers, identify the documented customer and payer without requiring a speculative sovereign attribution. Narrow guest-level information to what is necessary; aggregate unrelated hospitality records first. For funds and investments, produce subscription/allocation agreements, investor rights, fees, side letters, distributions, and documented source-of-funds information for the covered interest.
Module 5: Crypto exchanges, stablecoin issuers, and custodial intermediaries
Produce customer-to-account and customer-to-wallet mappings for enumerated identifiers, KYC records actually maintained, authorized-user changes, deposit and withdrawal ledgers with transaction hashes and chain identifiers, internal transfer references needed to avoid double-counting, issuance/redemption requests and settlement records, relevant custody agreements, and communications concerning covered transactions. Produce token quantities with contract address and decimals. Do not supply passwords, private keys, seed phrases, authentication secrets, or operational access. If an address is shared or omnibus, explain the internal allocation records and their limitations. Identify the actual custodian and lawful control before directing a demand to a decentralized protocol.
Module 6: Campaign and nonprofit vendors
Produce executed service agreements, invoices, purchase orders, payment and refund records, subcontractor statements for covered work, allocation methodologies, and communications about specified services or payer identities. Narrow donor, member, and associational information to demonstrated relevance, with First Amendment review and appropriate protections. A committee shall not demand all political contacts or memberships simply because a vendor served more than one client.
C.5. Preservation notice
Upon valid service, preserve potentially responsive records within the defined scope, including ordinary-course metadata, relevant mobile and messaging exports, account ledgers, contractual records, and materials held by identified custodians. Suspend routine deletion only to the extent necessary for those records. Preserve originals and document collection steps. Do not alter a live financial or blockchain system to manufacture evidence. Identify ephemeral sources and discuss a proportionate preservation plan promptly. A separate voluntary preservation letter must accurately identify itself as voluntary and shall not claim subpoena authority that has not been exercised. The committee shall issue written release or modification of preservation obligations when appropriate.
C.6. Custodian statement
The custodian's signed statement shall identify the declarant, role, basis of personal knowledge, records systems, covered searches, production identifiers, extraction method, and known limitations. The statement shall declare that the production consists of records maintained or obtained in the described ordinary-course systems; explain when and by whom entries were ordinarily made, to the declarant's knowledge; identify any export or transformation; and distinguish business records from specially prepared analytical exhibits. It shall state whether the production is complete as to the agreed searches and list exceptions. Where a declaration under 28 U.S.C. § 1746 is appropriate, counsel shall attach the legally applicable executed declaration with signature, date, and place as required. This model does not itself establish authentication or satisfy every jurisdiction's business-record requirements; receiving prosecutors obtain the certification and testimony their rules require.
C.7. Phased wave-one execution schedule
| Phase | Trigger and custodian | Initial scope | Review gate and next action |
|---|---|---|---|
| Readiness | Before committee organization; public sources only | Registry, SEC, FEC, property, public contract, public chain records | Source verification and legislative-purpose design; no service |
| Preservation | Lawful authority and identified evidence-loss risk | Targeted records and custodians; technically feasible hold | Counsel approves authority, scope, notice and burden |
| Wave 1A | Authorized banks/processors and entity custodians | Enumerated account/contract identity, transaction indexes, opening/control records | Resolve identity and date range; assess challenges before expansion |
| Wave 1B | Identified accountants, hospitality, licensing, investment counterparties | Specific statements, agreements, invoices, distributions, valuations | Compare commercial baseline and eliminate unrelated records |
| Wave 1C | Verified custodial crypto/issuer intermediaries | Specific hashes, addresses, account mappings, issuance/redemption settlement | Require chain/off-chain reconciliation and attribution review |
| Wave 1D | Campaign/nonprofit vendors with documented relevance | Defined service/payment transactions and subcontract allocation | First Amendment and privacy review; avoid donor fishing |
| Wave 2 | Identified gaps from productions | Narrow supplementary records and custodian testimony | Written necessity, legal basis, proportionality, and enforcement decision |
The committee's actual return dates follow valid organization, service, reasonable response time, preservation needs, and accommodations. An artificial Day-One deadline must not substitute for that assessment. Civil enforcement, contempt referrals, asset restraint, state CID issuance, and prosecutorial charging each require their own authority and decision-maker. This schedule neither freezes property nor directs a prosecutor's use of evidence.