Defendants Aren’t Subjects of Cause of Action Not Mentioning Them by Name—C.A.

The Court of Appeal for this district has held that in an action alleging that a process server tortiously posted unlawful detainer notices at the gated residence of a lessor of commercial property, rather than on the leased premises as authorized by a judge, three named defendants were not the targets of a cause of action for trespass because they were not specifically identified as persons who “directed” the conduct.