California Shellfish, Inc. v. United Shellfish Co. (1997) 56 Cal.App.4th 16, involved the application of the 20-day "deposition hold," which precludes a plaintiff from serving a "deposition notice" until "20 days after the service of the summons on, or appearance by, any defendant." ( 2025.210, subd. (b).) The plaintiff in Shellfish served subpoenas for business records on a nonparty before any defendant was served with process or had appeared. The nonparty moved to quash the subpoenas for violation of the 20-day hold. The plaintiff argued that the hold applied only to oral depositions of a party, not a business records subpoena served on a nonparty. The trial court rejected that argument. So did the Court of Appeal, explaining: "The statutory inclusion, under the heading 'Oral deposition,' ... of several specific provisions relating to deposition subpoenas which seek only business records demonstrates that the Legislature included a business records subpoena within the general category of 'oral depositions,' and intended the provisions of section 2025.210, including the 20-day hold in subdivision (b) to apply. ... "Every section of the Discovery Act pertaining to any method of discovery enumerated in section 2019.010 requires that at least one defendant has been served with the summons and complaint, and is subject to a holding period after service on a defendant, or requires that the party to whom the discovery is propounded has been served with the summons and complaint. ... If, as plaintiff contends, the deposition hold does not apply when a deposition subpoena seeks only business records, this would be the only exception to application of a hold. There is no rationale for such an exception." (Shellfish, supra, 56 Cal.App.4th at p. 22.) In California Shellfish, Inc. v. United Shellfish Co. (1997) the court applied the 20-day "deposition hold" in Code of Civil Procedure section 2025, subdivision (b)(2) to all discovery by deposition, including "records only" deposition subpoenas against nonparties. The proponent in California Shellfish argued that Code of Civil Procedure section 2025 only applied to oral depositions which require the presence and testimony of the deponent, not to section 2020's independent method for document discovery from nonparties . The court disagreed, finding "the inclusion, under the heading 'Oral deposition,' in section 2025, of several specific provisions relating to deposition subpoenas which seek only business records demonstrates that the Legislature included a section 2020, subdivision (d) subpoena within the general category of 'oral depositions,' and intended the provisions of section 2025, including the hold in subdivision (b)(2) to apply." (56 Cal. App. 4th at p. 21.) California Shellfish extended "deposition holds" to nonparties even though the code section never so stated expressly. That is because "sections 2025 and 2028 . . . are the general sections governing the procedures for oral and written depositions, and are applicable to depositions of party deponents and nonparty witnesses alike." ( Id. at p. 23.) The California Shellfish, supra, court saw no reason to create a harsher rule for nonparties than for parties. The court was concerned about the potential for abuse "by a calculating litigant who might conclude that it could benefit from the opportunity to access information it might not otherwise have . . . ." (56 Cal. App. 4th at p. 24.)