I believe that the article is simply poorly worded. If, in the discovery process a subpoena is issued, then I would think that it has officially been issued by the Court and that for ease of processing the paper work a preformatted, preagreed to 'subpoena' may be filled out by the attorney's and sent.
Perhaps that is the case here, but I am certain that only the Court can officially issue subpoenas.
I really did not intend to make a big deal of this, as I fully knew what was meant, we all did. But when newspapers or other official informational sources become lazy in their reporting of facts and processes, it deepens the misunderstandings that abound regarding our system. There are many of examples of this:
"America is a democracy"
"Bill Clinton was never impeached"
These are two statements that are heard or read, quite often, most of us ignore them because we know what the intent was. But both statements are false.
As pertains to this article the correct wording, I think, should be:
"Fox requests subpoena for "U-Tube" or "Fox requests that U tube be subpoenaed"