Lopez v. Watchtower Bible & Tract Society of New York, Inc.

A non-party witness must be subpoenaed for a deposition unless, among other things, the witness can be expected to comply with a party’s directive to appear for the deposition.  Ordinarily, a party may take a deposition of a non-party only by serving the non-party with a subpoena.  (CCP 2025.280(b).)  However, a subpoena is not required…