Narendra Lakhani v. Anil Patel

Syllabus

The issue presented, one of first impression, is whether a court-appointed Special Adjudicator's fees to resolve discovery disputes can be charged to an individual or entity who were not parties to the underlying litigation but petitioned the court to quash a subpoena. Because we conclude 4:41-2 limits the imposition of the Special Adjudicator's fees to the parties in the underlying litigation, we reverse the trial court's order imposing fees on the nonparty appellants, who moved to quash the subpoena, as they are nonparties to the underlying litigation.