“A deposition subpoena is used to secure business or personal records pertaining to the other party in advance of judgment, hearing or trial. These records can be used as evidence to seek support or property orders. Deposition subpoena[s] [are used] to procure three kinds of records: [1] payroll, [2] health insurance, and [3] pension/retirement plans. For example, if a litigant knows where the other party works but does not know his income, a deposition subpoena can be served on the employer requiring them to produce payroll and/or health insurance records for the employee. Similarly, pension/retirement plan records can be subpoenaed so that the value of the plan, and the community interest therein, can be calculated. A deposition subpoena can only be issued during the pendency of an action or, if post-judgment, when a request for order or motion is pending.”
[California Family Law Basics [certain citations omitted]]
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