Interrogatory or subpoena on a witness
On Law StackExchange a litigant in pro per outlined the following scenario. Unfortunately his post got censored there, that being the fate of many interesting, practical inquiries. "I have sued a California mobile-home park LLC for breach of contract and a couple of additional issues. The park manager's failure to properly and lawfully manage the park (which I told the real estate company that owns the park about) are the reason for the suit. She is mentioned as part of the problem, but she is not named as a defendant. Now I need to request discovery from her, but I'm not sure if she is a "party to the action" whom I should give an interrogatory--or a non-party witness whom I would subpoena information from. Is employee manager a party to the action?" Regarding your claim of breach of contract, the only entity to be named as defendant is the one with which you entered the contract. Your contract is with the company, whether it is the LLC or --if different-- ...