Mon–Fri 9–5 EST · Nationwide
Subpoena Domestication in Wyoming | Non-UIDDA | Wyo. Stat. § 1-12-115 | Served 123 LLC

Wyoming Is a Non-UIDDA State — Commission Required Before Wyoming Subpoena Issues

Wyoming has not adopted the Uniform Interstate Depositions and Discovery Act. It is one of only a handful of U.S. jurisdictions that still requires the traditional commission-based process, alongside Massachusetts, New Hampshire, and Texas. Under Wyo. Stat. § 1-12-115 (Wyoming's enactment of the older 1920 Uniform Foreign Depositions Act), a deposition may be subpoenaed and compelled in Wyoming "upon issuance of a mandate, writ or commission from any foreign court, or with notice to or agreement of the parties to take the testimony of a witness in Wyoming" — "in the same manner as would be required for a case pending in state." In practice, this means the originating court must issue a commission, mandate, or writ before the Wyoming District Court will issue a Form 33 subpoena under W.R.C.P. 45. Out-of-state attorneys cannot simply file their foreign subpoena with a Wyoming clerk as they would in a UIDDA state.

🛡️ Wyoming Counsel Included on Every Order — Served 123 LLC's Competitive Moat

Wyoming's non-UIDDA commission-based process benefits substantially from local counsel for District Court interactions, motion practice, and contested matters. Served 123 LLC maintains a standing relationship with Wyoming-licensed counsel and includes Wyoming counsel on every Wyoming order at no additional client cost. No separate WY counsel retention, no separate engagement letter, no per-motion billing surprises. This is the core of our Wyoming service — and the reason out-of-state firms route their non-UIDDA work through us rather than cold-calling a local Cheyenne or Casper firm for a one-off subpoena engagement.

Wyoming Non-UIDDA Overview

Subpoena Domestication in Wyoming

Wyoming is one of the last remaining non-UIDDA states in the United States. Unlike the 40-plus jurisdictions that have adopted the Uniform Interstate Depositions and Discovery Act, Wyoming retains the traditional commission-based process for out-of-state discovery, codified at Wyo. Stat. § 1-12-115 — Wyoming's enactment of the older Uniform Foreign Depositions Act (UFDA), a 1920 uniform act that UIDDA was designed to supersede.

Under § 1-12-115, a deposition or document production may be compelled in Wyoming "upon issuance of a mandate, writ or commission from any foreign court" — or, as an alternative path, "with notice to or agreement of the parties to take the testimony of a witness in Wyoming." Once the commission (or notice/agreement) is in hand, the Wyoming District Court clerk may issue a subpoena per Wyo. R. Civ. P. 45, on Form 33 from the WRCP Appendix of Forms. W.R.C.P. 45 also permits a Wyoming-authorized attorney, as officer of the court, to issue and sign a subpoena.

Wyoming has 23 counties organized into 9 judicial districts, served by the Wyoming District Court (general-jurisdiction trial court). The state's low population (the lowest of any U.S. state) concentrates most discovery activity into a small set of hub counties: Cheyenne (state capital + F.E. Warren AFB), Casper (oil & gas), Laramie (University of Wyoming), Jackson (Teton County — high-net-worth), Rock Springs/Green River (Sweetwater — trona), Gillette (Campbell — Powder River Basin coal), and Sheridan. Despite its small footprint, Wyoming concentrates some of the most significant federal, energy, and high-wealth discovery in the United States.

🚨 Commission from Originating Court Is the Gating Step: The single most common cause of Wyoming domestication delay is the originating court's commission-issuance pace. Unlike UIDDA states where foreign subpoenas are reissued by a Wyoming clerk in days, Wyoming requires an upstream commission first. Plan for 2 to 4 weeks total turnaround. Served 123 LLC drafts the commission application template at intake and files it alongside the Wyoming subpoena package to compress total time.
Same-Day / Next-Day Rush in Seven Hub Counties (Post-Issuance): Once the Wyoming subpoena is issued, rush service is available in Laramie (Cheyenne), Natrona (Casper), Albany (Laramie), Teton (Jackson), Sweetwater (Rock Springs/Green River), Campbell (Gillette), and Sheridan. Rural counties (Niobrara, Hot Springs, Crook, Weston) require scheduled field runs across Wyoming's expansive geography.
⚠️ Federal Witness Exception — F.E. Warren AFB: Subpoenas to active-duty U.S. Air Force personnel at F.E. Warren AFB (90th Missile Wing — Air Force Global Strike Command) are subject to additional DoD Touhy regulations (32 C.F.R. pt. 516 series) and must be coordinated through the Staff Judge Advocate's office. The state-law process under § 1-12-115 and W.R.C.P. 45 remains the foundation, but federal approval pathways apply in parallel. We coordinate both tracks.
Wyoming Submission Packet
📄 Foreign Subpoena

Properly issued subpoena from originating state, signed by the issuing court

📜 Commission / Mandate / Writ

From originating court under § 1-12-115 — OR notice/agreement of parties as alternative path

📝 Form 33 WY Subpoena

WRCP Appendix Form 33 (Civil Case Subpoena) — substantial compliance with W.R.C.P. 45

🛡️ Wyoming Counsel Engagement

Standing WY-licensed counsel engaged on every order — included in pricing, ready for any motion practice

Wyoming's Seven Hub Counties
CHY
Laramie · State Capital & 90th Missile Wing
Laramie County · Cheyenne

Wyoming's state capital and largest city. F.E. Warren Air Force Base — headquarters of the 90th Missile Wing of Air Force Global Strike Command, operating Minuteman III intercontinental ballistic missile (ICBM) silos distributed across Wyoming, Nebraska, and Colorado. Oldest continuously active Air Force base. Cheyenne Regional Medical Center. Cheyenne VA Medical Center. Wyoming state government (Governor, Legislature, AG, Supreme Court). 1st Judicial District.

CAS
Natrona · Oil & Gas Extraction Hub
Natrona County · Casper

Wyoming's traditional oil & gas industry hub — "The Oil City." Casper is the center of Wyoming's upstream energy sector with numerous independent operators and service companies. Banner Wyoming Medical Center. Casper College. Natrona County International Airport. Salt Creek and Teapot Dome historic fields. 7th Judicial District.

LAR
Albany · University of Wyoming Flagship
Albany County · Laramie

University of Wyoming — Wyoming's only four-year public research university and the state flagship. UW College of Law (only law school in WY), UW College of Engineering & Applied Science, School of Energy Resources. UW Athletics (Mountain West Conference). Ivinson Memorial Hospital. 2nd Judicial District.

JAC
Teton · Highest Per-Capita Income County in the U.S.
Teton County · Jackson / Jackson Hole

Highest per-capita income county in the United States — a concentrated high-net-worth residential enclave driven in significant part by Wyoming's lack of state income tax. Gateway to Grand Teton National Park and Yellowstone National Park (southern entrance). St. John's Health. Jackson Hole Airport (only commercial airport inside a U.S. national park). Teton Village / Jackson Hole Mountain Resort. 9th Judicial District.

SWR
Sweetwater · World's Largest Trona Deposits
Sweetwater County · Rock Springs / Green River

Home to the world's largest known deposits of trona (the natural mineral form of soda ash — sodium carbonate), supplying a significant share of global soda-ash production. Operators include Tata Chemicals, Genesis Alkali, Sisecam Chemicals, and Solvay. Memorial Hospital of Sweetwater County. Interstate 80 freight corridor. Glass, detergent, and lithium-processing supply-chain discovery. 3rd Judicial District.

GIL
Campbell · Powder River Basin Coal
Campbell County · Gillette

Powder River Basin — the largest coalfield in the United States by production. Home to Peabody Energy's North Antelope Rochelle Mine and the Black Thunder mine (now Core Natural Resources, formerly Arch Resources). Massive coal rail logistics (BNSF, Union Pacific). Campbell County Health. Major oil, gas, coalbed methane, and uranium operations. "Energy Capital of the Nation." 6th Judicial District.

SHR
Sheridan · Historic Ranching & Coal
Sheridan County · Sheridan

Northern Wyoming's cultural and economic hub. Historic ranching corridor. Sheridan Memorial Hospital. Sheridan College. VA Medical Center Sheridan. Big Horn Mountains recreation. Continues Powder River Basin coal and oil/gas discovery activity. 4th Judicial District (also covers Johnson County).

Wyoming Legal Authority

  • Wyo. Stat. § 1-12-115: Uniform Foreign Depositions Act — mandate/writ/commission from foreign court OR notice/agreement of parties required; deposition then subpoenaed and compelled as in a WY case
  • Wyo. R. Civ. P. 45: Wyoming subpoena rule — form, issuance, service, witness fees, enforcement
  • W.R.C.P. 45(a)(3): Clerk of WY District Court issues subpoena signed-but-blank; OR WY-authorized attorney as officer of the court may issue and sign
  • W.R.C.P. 45(a)(1)(D): Every subpoena must substantially comply with Form 33 (Civil Case Subpoena)
  • W.R.C.P. 45(c)(3)(A): Motion to quash — subpoena that fails to allow reasonable time for compliance is subject to motion to quash
  • W.R.C.P. 45(d)(1): Document production — as kept in usual course OR organized/labeled by demand category
  • Form 33: WRCP Appendix of Forms — Civil Case Subpoena
  • 23 WY counties organized into 9 judicial districts — District Court is Wyoming's general-jurisdiction trial court
  • 32 C.F.R. pt. 516: DoD Touhy regulations apply in parallel for active-duty military witnesses at F.E. Warren AFB
  • UIDDA NOT adopted — Wyoming is non-UIDDA alongside MA, NH, TX
Step-by-Step

How It Works in Wyoming (Non-UIDDA)

From intake to affidavit — commission obtained from originating court, correct Wyoming District Court identified, Form 33 prepared, WY counsel engaged, District Court filing, witness fee tender, and service across all 23 Wyoming counties.

1

Submit Your Foreign Subpoena + Commission Status

Use the order form at the top of this page or email info@served123.com. Include the originating state, the Wyoming county where the recipient is located, your foreign subpoena PDF, and — critically — indicate whether your originating court has already issued a commission, mandate, or writ. If not, we'll draft the commission application template for you to file in the originating court.

🚨 Wyoming is non-UIDDA. A commission (or notice/agreement of parties) is required before the WY District Court will issue a subpoena under § 1-12-115.
2

Originating Court Commission Obtained

You (or we, through originating-state counsel) obtain the mandate, writ, or commission from the originating court authorizing discovery in Wyoming. The commission form varies by state — we maintain templates for the most common originating jurisdictions. Alternative path: if parties in the originating action agree to a notice-based Wyoming deposition, § 1-12-115 permits the deposition without a formal commission. We confirm the route at intake.

3

Wyoming Counsel Engaged (Included in Pricing)

Our standing Wyoming-licensed counsel is engaged on every non-UIDDA order at no additional client cost. WY counsel reviews the commission package, the foreign subpoena, and the proposed Form 33 for compliance with W.R.C.P. 45, and stands ready for any motion practice (quash, enforce, protective order) under W.R.C.P. 45(c).

4

Correct District Court + Form 33 Prepared

We confirm the correct WY District Court — 23 counties organized into 9 judicial districts. For depositions, the court for the district where the witness resides, is employed, or regularly transacts business; for production/inspection, where the records or premises are located per W.R.C.P. 45(a)(2). Form 33 (Civil Case Subpoena from WRCP Appendix) prepared to substantially comply with W.R.C.P. 45.

5

District Court Filing — Subpoena Issued

Commission + Form 33 + foreign subpoena filed with the Wyoming District Court clerk. Per W.R.C.P. 45(a)(3), the clerk issues a signed-but-blank subpoena OR a Wyoming-authorized attorney (our standing counsel) signs and issues as officer of the court. Typical WY District Court turnaround: 5 to 10 business days post-commission in hub counties; rural counties may take longer.

6

Witness Fee Tender + Service per W.R.C.P. 45

For attendance subpoenas, we prepare the Wyoming statutory witness fee and mileage tender required by W.R.C.P. 45 — tendered at the time of service. Service coordinated statewide: same-day / next-day rush in the seven hub counties; scheduled field runs in rural northern and western counties (Crook, Weston, Niobrara, Hot Springs, Sublette, Lincoln, Uinta). DoD Touhy coordination runs in parallel for F.E. Warren AFB witnesses.

7

Affidavit of Service Delivered

You receive a signed affidavit of service confirming full compliance with Wyoming's non-UIDDA framework (§ 1-12-115) and W.R.C.P. 45 — ready for immediate filing in your originating state court. Wyoming counsel remains on retainer through any post-service motion practice.

Legal Authority

Wyoming Non-UIDDA Statutory Reference

Wyo. Stat. § 1-12-115 (Uniform Foreign Depositions Act) + W.R.C.P. 45 + Form 33 — Wyoming's traditional non-UIDDA commission-based framework governing every Wyoming subpoena domestication.

AuthoritySubjectKey Provision
Wyo. Stat. § 1-12-115Foreign DepositionsWyoming Uniform Foreign Depositions Act — mandate, writ, or commission from foreign court OR notice/agreement of parties; deposition then subpoenaed and compelled as in a WY case
UIDDA StatusNOT AdoptedWyoming is one of only 4–6 non-UIDDA states (alongside MA, NH, TX, and some lists CT) — requires commission-based process
W.R.C.P. 45WY Subpoena RuleForm, issuance, service, witness fees, motion to quash, enforcement
W.R.C.P. 45(a)(3)IssuanceClerk issues signed-but-blank subpoena OR WY-authorized attorney issues and signs as officer of the court
W.R.C.P. 45(a)(1)(D)Form ComplianceEvery subpoena must substantially comply with Form 33 (Civil Case Subpoena) from WRCP Appendix
W.R.C.P. 45(c)(3)(A)Motion to QuashSubpoena that fails to allow reasonable time for compliance subject to motion to quash; WY counsel handles
W.R.C.P. 45(d)(1)ProductionDocuments produced as kept in usual course of business OR organized/labeled by demand category
Form 33Mandatory FormCivil Case Subpoena from WRCP Appendix of Forms — required WY format
WY Court Structure23 / 923 counties organized into 9 judicial districts; District Court = WY general-jurisdiction trial court
32 C.F.R. pt. 516DoD TouhyFederal Touhy regulations run in parallel for F.E. Warren AFB active-duty military witnesses

*Wyoming is a non-UIDDA state. Commission from originating court is the gating requirement per § 1-12-115 (alternative: notice/agreement of parties). District Court filing fees vary by district. 23 counties organized into 9 judicial districts. Same-day / next-day rush service available post-issuance in Laramie (Cheyenne), Natrona (Casper), Albany (Laramie), Teton (Jackson), Sweetwater (Rock Springs/Green River), Campbell (Gillette), and Sheridan — the seven Wyoming hub counties. Wyoming counsel is included on every order at no additional client cost.

Service Package

What's Included With Every Wyoming Order

End-to-end Wyoming non-UIDDA handling across all 23 counties — commission package, Wyoming counsel included, Form 33 preparation, W.R.C.P. 45 compliance, District Court filing, witness fee tender, statewide service, and signed affidavit.

Commission Package

Commission/mandate/writ template prepared for originating court — or notice/agreement path coordinated per § 1-12-115.

🛡️ Wyoming Counsel Included

Standing WY-licensed counsel engaged on every order at no additional client cost — ready for motion practice under W.R.C.P. 45(c).

Correct District Court

23 counties covered across 9 judicial districts. Urban hubs vs. rural counties confirmed at intake.

Form 33 per W.R.C.P. 45

Civil Case Subpoena from WRCP Appendix prepared for clerk issuance or WY attorney issuance as officer of court.

Witness Fee Tender

WY statutory witness fee and mileage per W.R.C.P. 45 — tendered at service for attendance subpoenas. DoD Touhy for F.E. Warren.

Affidavit of Service

Signed affidavit confirming full non-UIDDA compliance — § 1-12-115 + W.R.C.P. 45 + Form 33 (PDF delivered).

Subpoena Types

Types We Domesticate in Wyoming

All major subpoena types under Wyoming's non-UIDDA commission-based framework — with Form 33 preparation, Wyoming counsel engagement, and statewide service across all 23 counties.

👤

Deposition Subpoena (Attendance)

Commands personal testimony at deposition after originating court commission. Issued on Form 33 per W.R.C.P. 45 by WY District Court clerk or WY attorney. WY statutory witness fee and mileage tender.

🛡️

F.E. Warren AFB / 90th Missile Wing Discovery

Subpoenas to active-duty Air Force personnel at F.E. Warren Air Force Base (90th Missile Wing — Minuteman III ICBM operations under Air Force Global Strike Command). DoD Touhy regulations apply in parallel — we coordinate the SJA office alongside the state-law process.

⛏️

Energy & Mining Discovery

Powder River Basin coal (Peabody, Core Natural Resources/Arch — Gillette), Sweetwater trona/soda ash (Tata, Genesis Alkali, Sisecam, Solvay — Rock Springs/Green River), Casper oil & gas, Converse County wind and petroleum development. Royalty, environmental, product liability, and commercial energy discovery.

💎

Jackson Hole High-Net-Worth Discovery

Teton County is the highest per-capita income county in the U.S. — a concentrated high-net-worth residential enclave. Trust, estate, tax, divorce, and commercial litigation discovery involving hedge fund principals, tech executives, and ultra-high-net-worth families who reside or domicile in Jackson Hole route through the 9th Judicial District.

Who We Serve

Who Uses Our Wyoming Service?

From Cheyenne and Casper to Laramie, Jackson, Rock Springs, Gillette, and Sheridan — Served 123 LLC handles non-UIDDA subpoena domestication across all 23 Wyoming counties with Wyoming counsel included on every order.

⚖️

Law Firms

Out-of-state attorneys who need discovery from WY witnesses but can't justify retaining one-off WY counsel for a single subpoena. We handle the commission, WY counsel, Form 33, District Court filing, and service end-to-end.

🛡️

Federal & Defense

Counsel targeting F.E. Warren AFB (90th Missile Wing — Minuteman III ICBM operations), Air Force Global Strike Command. We coordinate DoD Touhy alongside the state-law commission process.

⛏️

Energy & Mining Counsel

Counsel targeting Powder River Basin coal operators (Peabody Energy, Core Natural Resources/Arch), Sweetwater trona operators (Tata Chemicals, Genesis Alkali, Sisecam), Casper oil & gas, and Converse County wind/petroleum. Royalty, environmental, product liability.

💎

Trust, Estate & High-Net-Worth Counsel

Counsel targeting Teton County / Jackson Hole residents — highest per-capita income county in the U.S. Trust, estate, divorce, tax, and commercial discovery involving WY-domiciled high-net-worth individuals and family offices (driven by WY's lack of state income tax).

🎓

Academic & Healthcare

Counsel needing records from the University of Wyoming (Laramie — only 4-year public university), Cheyenne Regional Medical Center, Banner Wyoming Medical Center (Casper), St. John's Health (Jackson), Ivinson Memorial (Laramie), and Campbell County Health (Gillette).

🔍

Litigation Support

Legal support firms outsourcing WY non-UIDDA work — we handle commission drafting, WY counsel engagement, 23-county District Court routing, Form 33 preparation, and statewide service including DoD Touhy coordination.

Common Questions

Wyoming Subpoena Domestication FAQ

The most common questions about domesticating subpoenas in Wyoming — including Wyoming's non-UIDDA status, the § 1-12-115 commission requirement, W.R.C.P. 45, included Wyoming counsel, and the F.E. Warren AFB / energy / high-wealth discovery landscape.

No. Wyoming is a non-UIDDA state — one of only a few U.S. jurisdictions that has not adopted the Uniform Interstate Depositions and Discovery Act, alongside Massachusetts, New Hampshire, and Texas. Wyoming instead follows the older Uniform Foreign Depositions Act (UFDA), codified at Wyo. Stat. § 1-12-115. Under § 1-12-115, upon issuance of a mandate, writ, or commission from any foreign court — or with notice to or agreement of the parties — a deposition may be subpoenaed and compelled in Wyoming in the same manner as would be required for a case pending in state. The Wyoming District Court then issues the subpoena per Wyo. R. Civ. P. 45 on Form 33 from the WRCP Appendix.
The Wyoming process is traditional and commission-based. Step 1: counsel in the originating state obtains a mandate, writ, or commission from the originating court authorizing discovery in Wyoming (as an alternative, § 1-12-115 also permits the deposition upon notice to or agreement of the parties, bypassing the commission). Step 2: the commission and a proposed Wyoming subpoena on Form 33 are submitted to the clerk of the Wyoming District Court in the county where the witness resides, is employed, or transacts business. Step 3: the Wyoming District Court clerk — or a Wyoming-authorized attorney acting as officer of the court — issues the Wyoming subpoena per Wyo. R. Civ. P. 45. Step 4: service is performed per W.R.C.P. 45 service rules. Served 123 LLC handles every step and includes standing Wyoming counsel on every non-UIDDA order.
The Wyoming District Court in the county where the witness is located. The District Court is Wyoming's general-jurisdiction trial court. Wyoming has 23 counties organized into 9 judicial districts. For depositions, the proper District Court is the county where the witness resides, is employed, or transacts business. For production/inspection, it is the county where the documents or premises are located. Under Wyo. R. Civ. P. 45, a subpoena for trial attendance issues from the court for the circuit in which the trial is held, a deposition subpoena issues from the court for the circuit designated in the notice of deposition, and a separate production/inspection subpoena issues from the court for the circuit where production or inspection is to occur.
Wyoming has simply not enacted the UIDDA. As a low-population state with a traditionally cautious approach to out-of-state judicial reach, Wyoming has retained the older Uniform Foreign Depositions Act at Wyo. Stat. § 1-12-115. The statute reflects the pre-2007 commission-based practice that once governed all interstate discovery. Because the UIDDA has not been adopted, out-of-state attorneys cannot simply file their foreign subpoena with a Wyoming clerk and receive an immediately issued Wyoming subpoena — some form of authority from the originating court (mandate, writ, or commission) must accompany the request, or the parties must be in notice/agreement under § 1-12-115's alternative path.
In practice, Wyoming counsel is strongly advisable for non-UIDDA domestication and is often required by local District Court practice, particularly for contested matters or motions to quash, enforce, or modify. Unlike UIDDA states where out-of-state attorneys can domesticate subpoenas without local counsel, Wyoming's commission-based process benefits substantially from a Wyoming-licensed attorney presenting the matter to the District Court. Served 123 LLC maintains a standing relationship with Wyoming-licensed counsel and includes Wyoming counsel on every non-UIDDA order at no additional client cost — this is the core of our Wyoming service and a distinction from UIDDA-state work.
Wyoming concentrates several nationally significant discovery categories despite its small population. Laramie County (Cheyenne) is the state capital and home to F.E. Warren Air Force Base — headquarters of the 90th Missile Wing of Air Force Global Strike Command, which operates Minuteman III intercontinental ballistic missile silos across Wyoming, Nebraska, and Colorado. Sweetwater County (Rock Springs and Green River) sits atop the world's largest known trona deposits, supplying a significant share of global soda ash production (Tata Chemicals, Genesis Alkali, Sisecam). Campbell County (Gillette) is the heart of the Powder River Basin — the largest coalfield in the United States by production, home to the Peabody Energy North Antelope Rochelle mine, Arch Resources (now Core Natural Resources) Black Thunder mine, and related operations. Natrona County (Casper) is the state's traditional oil and gas extraction hub. Albany County hosts the University of Wyoming — Wyoming's only four-year public university. Teton County (Jackson) is the highest per-capita income county in the United States — a gateway to Grand Teton and Yellowstone National Parks and a concentrated high-net-worth residential enclave driven in part by Wyoming's lack of state income tax.
Wyoming's non-UIDDA process takes longer than UIDDA-state domestication because it requires obtaining a commission from the originating court before the Wyoming District Court will act. Typical end-to-end timing is 2 to 4 weeks, depending on (1) how quickly the originating court issues the commission, (2) the specific Wyoming District Court's processing queue, and (3) service logistics across Wyoming's expansive rural geography. Urban District Courts (Cheyenne, Casper, Laramie, Jackson, Rock Springs, Gillette, Sheridan) typically process within 5 to 10 business days of commission receipt; rural counties may take longer. Served 123 LLC manages the originating-court commission request alongside the Wyoming filing to compress total turnaround.
Wyoming uses Form 33 — Civil Case Subpoena — from the Appendix of Forms to the Wyoming Rules of Civil Procedure. Wyo. R. Civ. P. 45 requires every Wyoming subpoena to substantially comply with Form 33, to run in the name of the State of Wyoming, to identify the issuing court, the title of the action, and the civil action number, and to set forth the text of W.R.C.P. 45 subdivisions (c), (d), and (e). A blank signed subpoena form is available from the District Court clerk, to be completed by the requesting party before service. An attorney as officer of the court may also issue and sign a Wyoming subpoena. Served 123 LLC prepares Form 33 on every Wyoming order.
View all subpoena domestication FAQs →