Attorney General Investigations
Attorney General Investigations & Civil Investigative Demands
A Civil Investigative Demand from the Texas Attorney General is one of the most serious documents a business can receive. How you respond in the first days matters.
Bill Cobb served as Deputy Attorney General for Civil Litigation at the Texas Attorney General's Office, responsible for initiating, approving, negotiating, and settling investigations for violations of Texas Antitrust, Consumer Protection, and civil Medicaid fraud laws. That experience from the inside is a unique asset for businesses facing AG scrutiny today.
- CID response strategy & management
- Document production & privilege protection
- Consumer protection investigation defense
- Texas Antitrust investigation defense
- Civil Medicaid fraud investigation defense
- Trade secret & confidentiality protection
- Parallel proceeding coordination
- Pre-enforcement compliance review
- AG enforcement litigation defense
"We know what the Attorney General's Office is looking for — because we've looked for it. Contact us the day you receive a CID."
Frequently Asked Questions
How do I respond to a Texas Attorney General civil investigative demand (CID)?
Treat a CID as a serious exercise of government power, not an accusation or lawsuit, and act fast — responses are generally due in under 30 days. Immediately preserve all potentially responsive documents (disable any automatic deletion) and retain counsel experienced with the Texas AG, who can seek an extension of the return date, confirm the CID meets the statute's requirements, and engage the AG to narrow the request. Going straight to court to shut down the investigation is rarely the right move; early, cooperative engagement paired with concrete, well-grounded objections is more effective, because courts hear targeted discovery objections but not broad challenges to the investigation itself.
Can I push back on the scope of a CID or agency demand?
Yes. CIDs can be negotiated — counsel may work with the AG to narrow the classes of documents requested or shorten the time period covered, and can raise objections or file a petition to modify or set the CID aside (generally before the return date or within 20 days of service). The scope of an antitrust CID is limited to material that would be discoverable under the Texas Rules of Civil Procedure, giving a basis to resist overbroad requests. Push-back must take the form of concrete, well-grounded objections rather than a blanket refusal, since courts hear targeted objections but reject broad challenges to the investigation itself.
What happens if I ignore a Texas Attorney General CID or Request to Examine?
Noncompliance carries stiff penalties. Beyond a motion to compel, ignoring an AG demand can bring misdemeanor charges, and failing to comply with a Request to Examine your books and records can even mean forfeiture of your right to do business in Texas. If the demand is overbroad, the answer is not silence — it's a timely petition to modify or set aside the demand, or negotiated narrowing through counsel, before the return date. Cooperation paired with well-grounded objections almost always beats stonewalling, because the AG's office remembers which is which when deciding how hard to press.
These answers are general information about Texas law, not legal advice, and they may not reflect the most current legal developments. Reading them does not create an attorney-client relationship with Cobb & Gervasi PLLC — we are not your attorneys unless and until we agree in writing to represent you. Every situation is different; consult a lawyer about your specific circumstances before acting.
Insights on Attorney General Investigations
28 articles · View all on the blog →
When the Attorney General Comes Knocking: How to Respond to a Civil Investigative Demand in Texas
A Civil Investigative Demand is not a lawsuit, but it is a serious exercise of government power.
Texas AG Ken Paxton v. Big Tech
Texas Attorney General Ken Paxton has pursued major antitrust and consumer-protection actions against leading technology companies.
Small business exception in Texas Antitrust Act should be expanded to prevent AG overreach
Why Texas’s small-business exception to attorney-general antitrust CIDs should cover more business forms.
The attorney general’s statute of limitations – and damage limitations - in consumer protection claims
The Texas Attorney General has major timing advantages over private DTPA litigants, including no ordinary limitations deadline for DTPA enforcement claims.
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Pandemic litigation challenged the scope of the Governor’s disaster powers, with most early cases failing procedurally but some mask-mandate cases gaining traction.
Texas Legislature endorses Governor’s unilateral and unchecked use of emergency powers
The Legislature considered but largely failed to enact reforms limiting the Governor’s emergency powers under the Texas Disaster Act.
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