Unzipped Apparel, LLC v. Bader

In Unzipped Apparel, LLC v. Bader (2007) 156 Cal.App.4th 123, the court specifically noted that for a business record subpoena, the 60-day period during which a motion to compel must be filed, begins to run when the deponent serves objections on the party. At the time the objections are served, the record of deposition is complete. (Unzipped, supra, 156 Cal.App.4th at p. 136.) In reference to the 60-day period, the Unzipped court noted that "the deadline was mandatory." (Ibid.)