To correct the subpoena the information requested should be narrowed by stipulating that the documents must be dated on or before a specified period of time during which the fraud is suspected to have occured. In addition, if possible, the specific parties believed to have been involved in the fraud should be named as the parties' whose correspondence, letters, memorandums, etc. are requested.
For example, if the fraud is supposed to have taken place between Jan.-April 2005, then you would say:
"all original documents and copies of any understandings, contracts, correspondence, letters, memoranda, accounting reports, and business reports written, drafted, created, responded to, recieved, forwarded, read, or otherwise circulated or used by the End Run Corporation, its subsidiaries and affiliates, and any individuals, companies, or entities outside the ownership of End Run Corporation between Jan. 1, 2005 and April 30, 2005, inclusive.
amongst since the organization of the End Run Corporation.
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