In Arnett v. Dal Cielo (1996), the Medical Board of California had issued an administrative investigative subpoena to secure hospital peer review committee records but was thwarted by the claim of privilege under Evidence Code section 1157. The high court found the term "discovery" had a "specific legal meaning, to wit, the formal exchange of evidentiary information and materials between parties to a pending action." (Arnett v. Dal Cielo, supra, 14 Cal. 4th at pp. 20, 24.) The court also held that an administrative investigative subpoena that issued before the case was pending was not a discovery tool. (Id. at p. 24.) It thus essentially concluded the records sought via such subpoena were subject to disclosure at the investigative stage subject to formal discovery and the exercise of privileges after an action was initiated. A search warrant, like an administrative subpoena, is not a discovery tool as contemplated under the Evidence Code.