UNZIPPED APPAREL, LLC v. Bader

Opinion

MALLANO, Acting P. J.

In civil litigation, discovery may be obtained from a nonparty only through a “deposition subpoena.” (Code Civ. Proc., § 2020.010, subd. (b); section references are to the Code of Civil Procedure unless otherwise indicated.) The Civil Discovery Act (Act) (§ 2016.010 et seq.) authorizes a nonparty’s “oral deposition,” “written deposition,” and “deposition for [the] production of business records” (§ 2020.010, subd. (a)(l)-(3)).

A deposition subpoena for business records directs a nonparty’s “custodian of records” to deliver a copy of the requested documents to a…