I am suing a city government, the individual city council members, that have "jurisdiction" over a particular class of recreational properties at issue, and city employees/officials that don't have "jurisdiction," but who were clearly authorized by the city council members to deal with these particular properties (e.g. the city's "Director" of these properties, the city's director of parks, etc.). This is a lot of people to ask questions. Any or all may or may not know the answers to the questions. With my limited number of interrogatories, how can I ask them all the questions I need answered? Direct the interrogatories to any that can answer? They do all have the same attorney, if that helps. Also, they were parties until dismissed. I'm challenging their dismissal by interlocutory appeal.
Sorry, you do not have the right to propound written discovery (such as interrogastories and request for admissions) on non-parties (or in your case, former parties) to the litigation. You do, however, have the right to subpoena these witnesses for deposition and to have them produce documents at deposition.
As Attorney Chen has indicated, you cannot send written discovery to non-parties. You can send a subpoena duces tecum (which is a latin term meaning a subpoena to produce documents only) and you can send a subpoena for a deposition. Your deposition subpoena can be a "person most knowledgeable" deposition listing categories on which you want the City to produce the people who are most knowledgeable and authorized to speak for the City.
If you have a lot of questions, a deposition is often the best way to get the answers. Be aware, however, if you go into a deposition without a lawyer, the city's lawyer will eat you alive if you do not know how to ask questions and respond to objections in the deposition. Be forewarned. You may need a lawyer to deal with this.
