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This is general information for practitioners, not legal advice, and the forms in it are examples only. Exchange procedures, registered agents and state discovery statutes change. Verify the current entity name and agent with the Secretary of State and the exchange's own legal page before serving anything, follow your jurisdiction's rules, and read and approve any form yourself before you use it. BlockScout, Inc. is not responsible for the accuracy or effectiveness of anything on this page.

What the Blockchain Shows, and What Only the Exchange Has

A BlockScout Law report maps an address's on-chain footprint from public blockchain records: the related addresses, the inflows and outflows, and the exchanges and services it interacted with. That is the part that is public. The part that is not public lives inside the exchange, and the only way to get it is from the exchange itself.

🪪

Who owns the account

Identity verification (KYC) records tie a blockchain address to a named person. The chain never does this on its own.

🏦

The fiat on- and off-ramps

Linked bank accounts and cards, with the dates and amounts of every dollar that went in or came out.

📈

Balances held at the exchange

Crypto that was bought and never withdrawn is invisible on-chain. The exchange's internal ledger is the only record.

🔁

Internal transfers

Transfers between two customers of the same exchange never touch the blockchain at all.

📅

Point-in-time statements

Account statements as of the dates a matter turns on: marriage, separation, filing, death.

🔗

The bridge between the two

The exchange's own list of deposit and withdrawal addresses, which reconciles the account to the on-chain footprint.

The two sources are complementary. The report tells you which exchange to ask and gives you the addresses and dates to ask about. The exchange records tell you who, how much, and where the money came from and went.

Have bank records but no address yet? Start there.
1 Look up each payee in the VASP Directory → 2 If it's a crypto service, you have your exchange → 3 Use this guide to get the addresses
Open the VASP Directory
A searchable directory of exchanges, brokers, payment apps and other virtual-asset service providers. A bank statement line that reads "CB PAYMENTS", "PAYWARD" or "BAM TRADING" is an exchange; the directory tells you which one and what it is called in a subpoena. Free account.

Step One: Name the Right Entity

Most requests that fail, fail here. "Coinbase" is a brand; the records are held by a specific legal entity, and the entity that serves US customers is usually not the one whose name is on the building. Serve the wrong one and the response is a letter explaining that they hold no responsive records.

  1. Start from the report's entity attribution. Each exchange touchpoint in a BlockScout Law report names the service and shows the deposit or withdrawal addresses and dates involved. That is your factual basis for the request and your date range.
  2. Find the US operating entity. Check the exchange's user agreement or privacy policy for the contracting entity named for US customers (for example "Coinbase, Inc.", "Payward Interactive, Inc. d/b/a Kraken", "Gemini Trust Company, LLC", "BAM Trading Services Inc. d/b/a Binance.US", "Robinhood Crypto, LLC", "Block, Inc." for Cash App).
  3. Pull the registered agent from the Secretary of State. Search the business-entity database in the state where you will serve. Exchanges almost universally require civil process to go to the registered agent, not to a support address, and several say so expressly in their terms.
  4. Note the home jurisdiction. Where the entity "regularly transacts business in person" decides where compliance can be compelled under Rule 45, and therefore where you will be litigating if they resist. Several large exchanges push that fight into the Northern District of California.

Separate entities, separate records

  • Binance.US is not Binance. BAM Trading Services (Binance.US) states it cannot respond to requests addressed to Binance, and vice versa.
  • Robinhood Crypto, LLC holds the crypto account; the brokerage is a different Robinhood entity.
  • Cash App bitcoin is Block, Inc.; a Square merchant account is a different relationship with the same parent.
  • Exchange trust companies (Gemini Trust Company, Paxos Trust Company, Coinbase Custody Trust Company) are chartered entities with their own records and, arguably, a different statutory posture.

Before You Subpoena: Ask the Party

In a divorce or estate matter the account holder is often a party, or the estate itself. A party request is faster, cheaper, and produces more than a subpoena, because every major exchange lets an account holder export their own complete history in minutes and the exchange will not narrow a customer's own download the way it narrows a third-party subpoena.

  • Request for Production directed at the party for: the full transaction-history export (CSV) from each exchange account, every annual tax document the exchange issued (Form 1099-B, 1099-MISC, 1099-DA, gain/loss reports), all account statements, and the list of deposit and withdrawal addresses.
  • Interrogatories asking the party to identify every exchange, wallet, custodial account and self-custody device, with account identifiers and the date each was opened.
  • A signed authorization permitting the exchange to release records directly to you. Some exchanges honor these; all of them will at least accept it alongside a subpoena.
  • For estates, most exchanges have a deceased-customer process that releases records and assets to the personal representative on letters testamentary, a death certificate and identification. Use it before issuing process.

Then subpoena the exchange for the same records. The point of the subpoena is no longer discovery; it is verification. An export produced by a party is only as complete as the party chose to make it. The exchange's own production is the check.


Ask for the Addresses by Name

This is the part practitioners get wrong most often, and it is the reason a complete-looking production still leaves you unable to follow the money. A request for "all records" or "all account statements" of a crypto account does not get you the withdrawal destination addresses. It gets you what a bank statement would: dates, amounts, balances. An exchange statement for a withdrawal reads "Sent 0.5 BTC" and stops. It does not say where. The where is a 26- to 62-character blockchain address, and it lives in a different export, a different screen, or a confirmation email, depending on the exchange.

A statement tells you the money left. Only the destination address tells you where it went, and only the destination address lets you keep following it on-chain.

Opposing counsel is usually not withholding. They asked their client for "the Coinbase records," the client downloaded the statements, and nobody on that side knew there was anything else. So the request has to name the thing. Three rules:

  1. Name the data element, not the document. Ask for "the destination blockchain address and transaction hash of each withdrawal," not for "withdrawal records." A document request is satisfied by whatever document the responding party thinks fits. A data-element request is satisfied only by the data.
  2. Name where it lives. Each exchange keeps addresses somewhere specific: the withdrawal or "sent" history page (often a separate export from the transaction statement), the per-transaction detail view, the on-chain transaction hash, and the withdrawal confirmation email. Say so in the request, so "we produced the statements" is not a complete answer.
  3. Ask for both directions. Withdrawal destination addresses show where funds went. Deposit addresses assigned to the account show where funds came from and, matched against the report, prove the account is the one in the cluster.

The request language

Request for Production

For each withdrawal, transfer out, or "send" of any Digital Asset from any Exchange Account or Wallet during the Relevant Period: the date and time, asset, quantity, the destination blockchain address, and the blockchain transaction hash, as shown in the exchange's withdrawal or transfer history, the transaction detail record, and any withdrawal confirmation email, in native electronic form. This request is not satisfied by account statements or transaction summaries that omit the destination address.

Request for Production

Documents sufficient to identify every deposit or receiving blockchain address assigned to or generated by each Exchange Account and Wallet during the Relevant Period, with the asset and network for each.

Interrogatory

For each withdrawal or transfer of a Digital Asset from any Exchange Account or Wallet during the Relevant Period with a value exceeding $[threshold], state the date, asset, quantity, destination blockchain address, transaction hash, the identity of the person or entity that owns or controls the destination address, and the purpose of the transfer.

When the response is "we produced the statements"

Treat it as an incomplete response, not a refusal. The meet-and-confer letter should say, in substance: the statements produced do not include the destination address or transaction hash for withdrawals; those data elements exist in the exchange's withdrawal history export and transaction detail view and in the confirmation emails the exchange sent; please produce them by [date]. Attach a screenshot of the exchange's own withdrawal-history screen if you have one. Most productions follow within the week. If they do not, the motion to compel writes itself, because the request named the element and the response omitted it.

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What this buys you. Each destination address the other side produces is a new starting point. Run it. If it lands in the cluster the report already mapped, you have confirmed the account and the holdings. If it lands somewhere new, you have found another wallet, another exchange account, or another person, and the accounting is not finished yet.

Send a Preservation Letter First

Exchanges have retention schedules, accounts get closed, and an account holder who learns of a dispute may close theirs. A preservation letter costs nothing and takes an afternoon. Send it to the registered agent and, where the exchange publishes one, its legal-process contact, the day you identify the exchange.

What the letter should say

  • The matter, the court, and that litigation is pending or reasonably anticipated.
  • The account holder's full name, date of birth and known email addresses, and any account identifiers you have.
  • The specific blockchain addresses and transaction hashes from the report, with dates and amounts, as the basis for identifying the account.
  • The categories you will later subpoena (see below) and a request that they be preserved in native electronic form.
  • That a subpoena or court order will follow, and a contact for the exchange's counsel to reach you.

Subpoena Mechanics

Federal court: Rule 45

A federal subpoena may be served anywhere in the United States, but compliance can only be compelled within 100 miles of where the recipient resides, is employed, or regularly transacts business in person, and enforcement lies in the district where compliance is required. In practice that means a subpoena to a California-based exchange that is ignored or objected to gets litigated in California. Objections are due before the earlier of the compliance date or 14 days after service, so calendar that date when you serve.

State court: domesticate the subpoena

A subpoena issued by a state court has no force outside that state. To reach an exchange in another state you domesticate it under the Uniform Interstate Depositions and Discovery Act (UIDDA), which most states have adopted: you submit your home-state subpoena to the clerk in the county where the exchange's agent will be served, and the clerk issues a local subpoena on the same terms. California's version is the Interstate and International Depositions and Discovery Act (Cal. Code Civ. Proc. § 2029.300), which requires a Judicial Council application and a filing fee. A few states have not adopted the uniform act and use their own commission or letters-rogatory procedure; check the discovery state before you draft.

Notice to the account holder

Several states require advance notice to a consumer before their personal records are subpoenaed from a third party (California's CCP § 1985.3 is the best known), and a skipped notice is grounds for the exchange to refuse to produce. Whether a crypto exchange is a covered "witness" under these statutes is unsettled. The safe course is to give the notice regardless. In a family-law matter the account holder is usually the opposing party and the notice goes to counsel; in an estate matter, to the personal representative.

Who signs, who serves

Serve the registered agent, by the method your jurisdiction requires for a records subpoena, with the witness fee if one applies. Keep proof of service. Exchanges' legal departments receive volume and triage by whether the paper is facially valid; a subpoena with the wrong entity, no court caption, or an unsigned issuing attorney goes to the bottom of the pile.

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Expect the exchange to notify its customer. Several major exchanges say they notify the account holder of legal process as a matter of policy and allow a short window before responding, unless a court order forbids it. In a civil matter you will rarely obtain a non-disclosure order, so assume the account holder will know, and send your preservation letter before they do.

What to Request, and How to Word It

The clearest guidance on scope comes from the IRS's 2017 summons to Coinbase. Even after the IRS narrowed its request, the court struck three entire categories and pared two more, ordering production of identity and transaction records but refusing the know-your-customer due-diligence file, third-party access records, and customer correspondence. Narrow, particular, date-bounded requests get produced. Broad ones get fought, and the fight happens in the exchange's home court.

Categories that are routinely produced

  1. Account identification — account holder name, date of birth, address, email and phone on file, account number or identifier, and the date the account was opened and (if applicable) closed.
  2. Transaction-level history — every deposit, withdrawal, purchase, sale, conversion and transfer for the date range, with date and time (UTC), asset, quantity, USD value at the time, fees, post-transaction balance, and counterparty where recorded, in native electronic export format (CSV).
  3. Blockchain addresses — every deposit address assigned to the account and every external address the account withdrew to, with the transaction hash, date and amount for each. This is the record that reconciles the account to the on-chain footprint in your report.
  4. Linked payment methods — bank accounts (institution, last four digits), debit and credit cards, and payment-app links, with the dates each was added or removed, and the fiat transfers to and from each.
  5. Balances and statements — holdings by asset as of specified dates (give the dates: marriage, separation, filing, valuation, death), and all periodic statements for the range.
  6. Tax documents — any Form 1099 series or gain/loss report the exchange issued for the tax years in range.

Categories to request sparingly, or not at all

  • Login and IP records — useful to show who was operating the account and from where, but privacy objections are strongest here. Request a narrow date range and state why it matters.
  • Correspondence with the exchange — the contents of communications are protected under the Stored Communications Act, and this category was refused in the Coinbase order. Get it from the party instead.
  • KYC due-diligence files, risk scores, internal notes — refused in the Coinbase order and almost never produced to a civil litigant.
Particularize by account holder, date range, asset and category. Ask for native format. Attach the report's address list and transaction hashes as the identifying basis.

Sample definition and request language

Definition. "Account" means any account at [Entity] held in the name of, controlled by, or associated with [Name], DOB [date], email [addresses], including any account to which the following blockchain addresses were assigned or from which withdrawals were made to the following addresses: [address list from report].

Request. For the period [date] through [date], all records of transactions in the Account, including for each transaction the date and time, type, asset, quantity, U.S. dollar value at the time of the transaction, fees, resulting balance, and the counterparty and blockchain address and transaction hash where applicable, produced in native electronic format as exported from [Entity]'s systems.

Request. Records sufficient to show the balance of each asset held in the Account as of [date 1], [date 2] and [date 3].


Exchange by Exchange

What follows is what each exchange publishes about legal process as of October 2026, with the gaps marked. Registered agents are deliberately not listed here because they change; pull the current one from the Secretary of State in the state where you serve.

ExchangeUS entityCivil processNotes
Coinbase Coinbase, Inc. (Delaware) User agreement requires civil subpoenas, complaints and small-claims papers to be served on the registered agent for service of process, by state. Law-enforcement requests go through a separate portal and are not the civil path. Notifies customers of legal process as policy unless a court order prohibits it. The 2017 IRS summons order is the best public guide to what Coinbase will and will not produce.
Kraken Payward Interactive, Inc. d/b/a Kraken (Payward, Inc. parent) Privacy notice confirms disclosure "in response to court orders, subpoenas, and other legal process." No published civil-process page; serve the registered agent. Has litigated subpoena compliance in N.D. Cal. (In re Subpoena to Payward, Inc., No. 4:23-mc-80248). Expect motion practice to land there.
Gemini Gemini Trust Company, LLC (New York trust company), 600 Third Avenue, New York Privacy policy expressly contemplates sharing with "civil litigants, law enforcement and other issuers of legal requests." Publishes law-enforcement guidelines; no separate civil page found. Trust-company charter: a New York entity, so a New York subpoena may not need domestication.
Binance.US BAM Trading Services Inc. d/b/a Binance.US, Miami, FL Published guide addresses law enforcement only (LERT@binance.us; accepts only requests from government domains). Civil process: serve the registered agent. States it does not notify users of government requests and cannot respond to requests addressed to Binance (the non-US exchange).
Crypto.com Confirm the current US contracting entity in the user agreement before serving No published legal-process page found. Serve the registered agent of the US entity named in the user agreement. Confirm the entity carefully; the group uses several "Foris" entities.
Cash App (bitcoin) Block, Inc. (formerly Square, Inc.), Oakland, CA Privacy notice confirms production in response to "legal process." No published civil page found; serve the registered agent. Records include government ID, linked bank and card numbers, and transaction details including transacting parties.
Robinhood Crypto Robinhood Crypto, LLC, Menlo Park, CA Publishes a law-enforcement request guide; civil process goes to the registered agent. The crypto account and the brokerage account are different entities with different records.
PayPal / Venmo (crypto) PayPal, Inc. Publishes a legal-process page in its Legal Hub; civil subpoenas to the registered agent. Crypto bought in PayPal or Venmo could not be withdrawn on-chain until 2022, so older activity is internal-only and never appears in an on-chain report.
River, Strike, Swan and other bitcoin-only platforms River Financial Inc. (Delaware); Zap Solutions, Inc. (Strike); Swan Bitcoin Privacy policies confirm compliance with subpoenas; River states it will notify customers of government requests where permitted. Serve the registered agent. Smaller legal teams; a clear, narrow request with the report attached tends to move faster than at the large exchanges.

Entity names and policies are drawn from each company's published user agreement, privacy notice or law-enforcement page as of October 2026. Where a cell says "no published page found," none was located on the company's public legal pages at that time; it does not mean the company will not respond.


Offshore Exchanges: A Reality Check

Binance (non-US), OKX, Bybit, KuCoin, MEXC and similar exchanges are organized outside the United States and have no registered agent to serve. A US subpoena has no force against them. Your options, in descending order of practicality:

  1. Get it from the party. Every one of these platforms lets the account holder export their history. A Request for Production, an order compelling it, and an adverse-inference instruction if it is not produced will get you further than any process directed at the exchange.
  2. Follow the money to a US on-ramp. Funds that reached an offshore exchange usually arrived from, or left to, a US exchange or bank first. The on-chain report shows the path; subpoena the US end of it.
  3. A letter of request under the Hague Evidence Convention through the courts of the exchange's home jurisdiction. Slow (months to a year), expensive, and dependent on that country's willingness to compel its companies. Rarely worth it in a family or estate matter.
  4. Voluntary cooperation. Some offshore exchanges will respond to a court order accompanied by the account holder's consent. Worth one letter.

Templates: The Paper Itself

Five documents cover nearly every matter. Each is written generically; conform the caption, signature block and numbering to your court's rules and local form. Bracketed text is yours to fill. Where a template refers to "the Report," attach the BlockScout Law report, or at minimum its address list and transaction hashes, as the exhibit it names.

These are example forms, not legal advice

The templates below are illustrative examples only. They are not legal advice, do not create an attorney-client relationship, and have not been reviewed for any particular court, jurisdiction or matter. Before using any of them, you must read, revise and approve the document yourself, conform it to the applicable rules of civil procedure, local rules and the exchange's current requirements, and take responsibility for it as your own work product.

BlockScout, Inc. makes no representation that these forms are accurate, complete, current or effective, and accepts no responsibility for their accuracy, their sufficiency, or any outcome of their use. Discovery statutes, exchange entities and legal-process policies change without notice; verify everything against current sources before serving anything.

1. Preservation letter to the exchange

Example only · Letter · send the day the exchange is identified
[Date]

VIA [overnight courier / certified mail] AND EMAIL
[Entity legal name]
c/o [Registered agent name]
[Agent street address]
[City, State ZIP]

Re:   Request to Preserve Records
      [Case caption], Case No. [number], [Court]
      Account holder: [Full name], DOB [date], email(s) [addresses]

Dear Legal Department:

This firm represents [Party] in the above-captioned [divorce / probate / civil] matter, which is pending in [Court]. We write to request that [Entity] preserve all records relating to any account held in the name of, controlled by, or associated with [Full name] (the "Account Holder"), including any account to which the blockchain addresses listed in Exhibit A were assigned, or from which withdrawals were made to those addresses.

Please preserve, in native electronic form, for the period [start date] to the present:

  1. Account identification and verification records, including the account holder's name, date of birth, address, email addresses and telephone numbers on file, account identifiers, and the dates the account was opened and closed;
  2. Complete transaction records, including deposits, withdrawals, purchases, sales, conversions and transfers, with date and time, asset, quantity, U.S. dollar value, fees and resulting balance;
  3. All blockchain deposit addresses assigned to the account and all external addresses to which withdrawals were sent, with the transaction hash, date and amount of each;
  4. Linked bank accounts, cards and payment methods, and all fiat transfers to and from them;
  5. Periodic account statements and balance records; and
  6. Tax documents issued to the account holder.

A subpoena or court order for these records will follow. This letter is not itself a demand for production. Please direct any questions to the undersigned at [phone] or [email].

Sincerely,

[Attorney name]
[Bar number]
[Firm]
[Address]

Exhibit A — Blockchain addresses and transaction hashes identified in the Report dated [date]:
[address] — [first/last seen dates] — [role: deposit to / withdrawal from Entity]
[address] — ...

2. Subpoena duces tecum to the exchange: Schedule A

The subpoena form itself is your court's form. This is the attachment that does the work.

Example only · Schedule A · attach to the court's subpoena form
SCHEDULE A TO SUBPOENA DUCES TECUM
Directed to: [Entity legal name], c/o [Registered agent]

                                 DEFINITIONS

1. "You" and "Entity" mean [Entity legal name], its parents, subsidiaries, affiliates and any entity that holds records on its behalf.
2. "Account Holder" means [Full name], date of birth [date], and includes any email address listed in Definition 4.
3. "Account" means any account, wallet or sub-account at Entity held in the name of, controlled by, or associated with the Account Holder, including any account (a) opened using an email address or telephone number in Definition 4, or (b) to which any blockchain address in Exhibit A was assigned, or (c) from which any withdrawal was made to a blockchain address in Exhibit A.
4. "Identifiers" means the following: email addresses [list]; telephone numbers [list]; and the blockchain addresses and transaction hashes set out in Exhibit A.
5. "Relevant Period" means [start date] through [end date / the date of production].
6. "Document" has the broadest meaning permitted by [Rule 34 / state equivalent] and includes electronically stored information in the form in which it is ordinarily maintained.

                                INSTRUCTIONS

A. Produce transaction records in native electronic format (CSV or the export format ordinarily available to the Account Holder), together with any data dictionary or field description necessary to read them.
B. Produce identification documents and statements as PDF.
C. If no responsive Account exists, so state in writing, identifying each Identifier searched.
D. If you withhold any Document on a claim of privilege or privacy, identify it by category and state the basis.
E. Production may be made by secure electronic delivery to [email / portal] in lieu of appearance.

                            DOCUMENTS REQUESTED

REQUEST 1. Documents sufficient to identify each Account, including the account holder's name, date of birth, residential address, email addresses and telephone numbers on file, account number or identifier, and the dates each Account was opened and, if applicable, closed or restricted.

REQUEST 2. For each Account, all records of transactions during the Relevant Period, including for each transaction the date and time (UTC), transaction type, asset, quantity, U.S. dollar value at the time of the transaction, fees, and resulting balance, and, where applicable, the counterparty, blockchain address and transaction hash.

REQUEST 3. For each Account, every blockchain deposit address assigned to the Account, and every external blockchain address to which a withdrawal was made during the Relevant Period, with the transaction hash, date, asset and amount of each deposit and withdrawal.

REQUEST 4. For each Account, Documents sufficient to identify every bank account, debit or credit card, and payment method linked to the Account during the Relevant Period (institution name and last four digits), the dates each was added or removed, and all fiat currency transfers to and from each.

REQUEST 5. For each Account, Documents sufficient to show the balance of each asset held as of [date 1], [date 2] and [date 3].

REQUEST 6. All periodic account statements for each Account for the Relevant Period.

REQUEST 7. All Forms 1099 or other tax reporting documents issued to the Account Holder for tax years [years].

[OPTIONAL, NARROW — REQUEST 8. For the period [narrow range], records of logins to each Account showing date, time and IP address.]

Exhibit A — Identifiers (blockchain addresses and transaction hashes from the Report dated [date]) [attach]

3. Requests for Production to the opposing party

Example only · RFP set · crypto-specific requests to add to your standard set
REQUESTS FOR PRODUCTION — DIGITAL ASSETS

Definitions: "Digital Asset" means any cryptocurrency, token, stablecoin or other blockchain-based asset. "Exchange Account" means any account at a cryptocurrency exchange, broker, custodian, or payment application offering Digital Assets (including Coinbase, Kraken, Gemini, Binance.US, Crypto.com, Cash App, Robinhood, PayPal and Venmo). "Wallet" means any software, hardware or paper wallet, seed phrase or private key by which Digital Assets are held or controlled. "Relevant Period" means [start date] to the present.

REQUEST 1. For each Exchange Account you held, controlled or had signature authority over during the Relevant Period, the complete transaction-history export (in the exchange's native CSV or equivalent format) for the Relevant Period.

REQUEST 2. All periodic statements for each Exchange Account for the Relevant Period.

REQUEST 3. All tax documents issued by any Exchange Account or Digital Asset platform for tax years [years], including Forms 1099-B, 1099-MISC, 1099-DA and any gain/loss report.

REQUEST 4. For each withdrawal, transfer out, or "send" of any Digital Asset from any Exchange Account or Wallet during the Relevant Period: the date and time, asset, quantity, the destination blockchain address, and the blockchain transaction hash, as shown in the exchange's withdrawal or transfer history, the transaction detail record, and any withdrawal confirmation email, in native electronic form. This request is not satisfied by account statements or transaction summaries that omit the destination address.

REQUEST 4A. Documents sufficient to identify every deposit or receiving blockchain address assigned to or generated by each Exchange Account and Wallet during the Relevant Period, with the asset and network for each.

REQUEST 5. For each Wallet, Documents sufficient to show every receiving address used during the Relevant Period and the balance of each Digital Asset as of [date 1], [date 2] and [date 3].

REQUEST 6. All records of transfers of fiat currency to or from any Exchange Account, including the bank or card statements reflecting them.

REQUEST 7. All Documents reflecting the purchase, sale, transfer, gift, loan, staking, lending or pledge of any Digital Asset during the Relevant Period, including confirmations and receipts.

REQUEST 8. All communications with any Exchange Account provider concerning account opening, verification, restriction or closure during the Relevant Period.

REQUEST 9. A signed Authorization for Release of Records, in the form attached as Exhibit B, for each Exchange Account identified in response to Interrogatory [no.].

4. Interrogatories to the opposing party

Example only · Interrogatory set · identify every account and wallet
INTERROGATORIES — DIGITAL ASSETS

INTERROGATORY 1. Identify every Exchange Account you have held, controlled, or had access to at any time during the Relevant Period, stating for each the provider, the account identifier, the email address and telephone number used to open it, the date opened, the date closed (if applicable), and whether it remains open.

INTERROGATORY 2. Identify every Wallet in which you have held or controlled Digital Assets during the Relevant Period, stating for each the type (software, hardware, paper, multisignature or custodial), the device or application, every blockchain address associated with it, and its current location or custodian.

INTERROGATORY 3. For each Exchange Account and Wallet identified above, state the quantity and U.S. dollar value of each Digital Asset held as of [date of marriage / date of separation / date of filing / date of death / today].

INTERROGATORY 4. For each withdrawal or transfer of a Digital Asset from any Exchange Account or Wallet during the Relevant Period with a value exceeding $[threshold], state the date, asset, quantity, destination blockchain address, transaction hash, the identity of the person or entity that owns or controls the destination address, and the purpose of the transfer.

INTERROGATORY 5. Identify every person other than you who has, or during the Relevant Period had, access to any Exchange Account, Wallet, seed phrase or private key identified above.

INTERROGATORY 6. State whether any Digital Asset identified above has been lost, stolen, or rendered inaccessible, and for each, describe the circumstances, the date, and any report made to an exchange, law enforcement or insurer.

INTERROGATORY 7. State whether the blockchain addresses listed in Exhibit A are, or were during the Relevant Period, owned or controlled by you, and if not, identify the person who owns or controls each.

5. Authorization for release of records

Example only · Authorization · have the party sign; send with the subpoena
AUTHORIZATION FOR RELEASE OF ACCOUNT RECORDS

To: [Entity legal name]

I, [Full name], date of birth [date], residing at [address], am the holder of the account(s) at [Entity] associated with the email address(es) [addresses] and telephone number(s) [numbers].

I authorize [Entity] to release to [Attorney name], [Firm], [address], [email], and to any person designated by that firm, all records relating to my account(s) for the period [start date] through [end date], including identification and verification records, transaction history, blockchain deposit and withdrawal addresses, linked payment methods, account statements and tax documents.

This authorization is given in connection with [Case caption], Case No. [number], pending in [Court]. It remains in effect until [date / the conclusion of that matter] unless revoked in writing. A copy of this authorization is as valid as the original.

Signed: ______________________________    Date: ______________
Printed name: [Full name]

[Notary block if required by the exchange or your jurisdiction]
!
Domesticating in another state. Under the UIDDA you do not redraft Schedule A; you present your home-state subpoena, with Schedule A attached, to the clerk in the county of service together with that state's application form (in California, the Judicial Council form under CCP § 2029.300) and fee, and the clerk issues the local subpoena incorporating your terms. Serve the local subpoena on the registered agent.

When the Records Arrive

The exchange's deposit and withdrawal address list is the key that joins the two halves of the picture. Each withdrawal address the exchange produces should appear in the report's related-address cluster; each deposit address should show inbound transactions from addresses in the cluster. Where they match, you have an identified, documented chain from a named account to an on-chain balance. Where they do not, you have found either another account or another person, and a new address to run.

Have the exchange's address list? Run the addresses.
1 Paste each withdrawal address → 2 Compare the clusters → 3 Attach both to the matter
Start your first case free
A first pass from public blockchain records, in about five minutes. Not a forensic investigation; it scopes the matter and gives an expert a head start.

Frequently Asked Questions

Can a civil litigant subpoena Coinbase at all?
Yes. Coinbase's user agreement sets out how: civil subpoenas are served on its registered agent for service of process in the relevant state. The federal Right to Financial Privacy Act restricts only government access and does not cover exchanges in any event, and the Stored Communications Act permits a provider to disclose non-content records to anyone other than a government entity. What a court will actually compel is a question of scope, which is why the request must be particular.
Do I need a wallet address before I subpoena an exchange?
No, but it helps a great deal. A subpoena can identify the account by the holder's name, date of birth and email. Adding the blockchain addresses and transaction hashes from the report gives the exchange an exact match and removes the most common ground for a "no responsive records" response.
How long does an exchange take to respond?
None of the major exchanges publishes a civil turnaround, and Binance.US states expressly that it cannot guarantee one. Practitioners commonly report four to eight weeks for a clean, narrow request to a US exchange, longer where the exchange objects or notifies the customer and waits out a response window. Build that into your scheduling order.
Will the exchange tell the account holder?
Usually. Coinbase and several other major exchanges notify customers of legal process as a matter of policy unless a court order prohibits it, and consumer-notice statutes in some states require you to notify them yourself. Assume the account holder will know, and send the preservation letter first.
What if the exchange produces records that do not match the on-chain report?
That is a finding, not a failure. Addresses in the report's cluster that the exchange does not recognize belong to a different account or a different custodian; addresses the exchange produces that are not in the cluster are new starting points. Run them. The combination of the two sources is what makes the accounting complete.
Is a BlockScout Law report enough on its own?
No. It is a fast first pass built from public blockchain records: the related addresses, the entities interacted with, and the inflows and outflows. It is not a forensic investigation and not a substitute for a forensic accountant or expert witness. It tells you which exchanges to ask and what to ask them for, and gives an expert a head start when one is needed.