California Code of Civil Procedure states the following:
A notice of deposition must be served at least ten (10) days before the deposition unless the notice is served by mail in which case it must be served at least fifteen (15) days before the deposition. If production of consumer or employment records is being requested the notice must be served at least twenty (20) days before the deposition unless the notice is served by mail in which case it must be served at least twenty-five (25) days before the deposition.
Can you believe that a "litigation attorney" would attempt to take a deposition and fail to give the appropriate notice?