“In light of the above, the Court agrees with Defendants that post-indictment, heath care administrative subpoenas that seek information that may be relevant to pending charges may not be directed towards a criminal defendant. As discussed above, Phibbs does not stand for the proposition that post-administrative subpoenas may be used for such a purpose, and the United States is unable to cite a single decision in which a post-indictment administrative subpoena has been enforced against a criminal defendant. Further, although not binding, the Court finds it noteworthy that the DOJ’s own guidance expressly counsel against the use of administrative subpoenas under the very circumstances presented herein.” United States v. Rakhit, 2020 U.S. Dist. LEXIS 168666 (N.D. Ohio Sept. 15, 2020).
Defendant’s guilty plea waived his Fourth Amendment claim. Waters v. State, 2020 Miss. App. LEXIS 530 (Sept. 15, 2020).