His company would have to appear, sure. But not him. And by "appear" I mean, hire a lawyer and designate a 30(b)(6) witness. I'd definitely subpoena him. But i

His company would have to appear, sure. But not him. And by "appear" I mean, hire a lawyer and designate a 30(b)(6) witness. I'd definitely subpoena him. But it can take a lot of money to get to that point...