We all saw the subpoena the Feds served to Dean and others for records. Since according to the bible (aka Wikipedia) "A subpoena is a writ by a government agency, most often a court, that has authority to compel testimony by a witness or production of evidence under a penalty for failure," I don't think Jeff could have subpoenaed Dean. He might sue Dean on behalf of the Company to turn over all books and records. Either way this is a necessary legal measure to limit Dean's ability to "find" at a later point in time "new documents".