The following is the full text of the subpoena for documents which Tom DeLay’s legal team delivered to prosecutor Ronnie Earle. From the text, it seems clear that DeLay’s attorneys are interested in discovering details about Earle’s unusual polling of members of a just-disbanded grand jury immediately before going before another grand jury to seek an indictment of DeLay on money laundering charges. The defense is also interested in learning why Earle did not make public in a timely manner the fact that a grand jury had refused to indict DeLay:
You are commanded to produce and permit inspection and copying of the following documents and tangible things:
1. Any and all documents, emails, notes, telephone records, and telephone lists related to efforts made by you or any member of the Travis County District Attorney’s staff to contact former members of the 167th grand jury at any time between September 29, 2005 and October 3, 2005.
2. Any and all documents, emails, notes, photographs, recordings, transcriptions, or tangible things that you or any member of the Travis County District Attorney’s staff showed to, discussed with, or otherwise described or conveyed to any former member of the 167th grand jury at any time between September 29, 2005 and October 3, 2005.
3. Any and all documents, emails, notes, photographs, recordings, transcriptions, or tangible things obtained from any former member of the 167th grand jury at any time between September 29, 2005 and October 3, 2005.
4. Any and all documents, emails, notes, recordings, transcriptions, or tangible things related to efforts made by you or any member of the Travis County District Attorney’s staff to persuade the members of the 390th grand jury to change their decision or Pass on the matter after that grand jury voted to No Bill the allegations against Congressman Tom DeLay.
5. Any and all documents, emails, notes, recordings, transcriptions, or tangible things related to efforts made by you or any member of the Travis County District Attorney’s staff to delay the filing and the public disclosure of the No Bill vote from the 390th grand jury until Tuesday, October 4, 2005.
6. Any and all documents, emails, notes, recordings, transcriptions, or tangible things related to information obtained from any former member of the 167th grand jury at any time between September 29, 2005 and October 3, 2005 that you or any member of the Travis County District Attorney’s staff showed to, discussed with, or otherwise described or conveyed to any member of the 403rd grand jury.
7. Any and all documents, emails, notes, recordings, transcriptions, or tangible things related to the preparation and timing of the October 4, 2005 press release which purported to notify the public regarding the No Bill vote of the 390th grand jury.
8. Any and all documents, emails, notes, recordings, transcriptions, or tangible things that comprise the “additional information” referred to in the press release that was showed to, discussed with, or otherwise described or conveyed to any member of the 403rd grand jury.