Can I file one complaint for "Unlawful Towing" and list multiple co-defendants on the one (1) complaint? (versus one complaint per defendant)
A: You can, and in fact you must sue each defendant in the same lawsuit -- or you lose your right to sue those who you do not join in the action. To join multiple defendants, each one must be "fairly traceable" to the transactions and/or occurrences which caused your injury.
Also, until one party produces the lease in court, I won't know if a real estate agent is involved but at that point, isn't it too late to do anything about it? My understanding is that day in court is my final opportunity to address this matter.
A: If another person appears to be a defendant, then you ask the court to postpone the hearing and permit you to join another defendant, because you were unaware until the time that the lease was produced that another defendant existed.
In a regular civil action, you would initiate discovery before trial and then once you had the lease, you would amend your complaint to join the other defendant(s). But in a small claims (or any action where there is limited discovery and only one hearing), you would have to request a continuance, so that you could join/amend and then issue a summons to the new defendant.
In order to "subpoena the security records" do I name say, the security guard who was on duty the night they towed my car, and HE would then produce those records in court?
A: You name the "custodian of records" for the security company, and specify the records that you seek. This is called a "subpoena duces cecum" (subpoena for personal appearance and production of evidence).
Can a subpoena be served to a legal resident of an address without naming them specifically?
A: Only a "custodian of records" can be named by reference. Anyone else must be specifically named.
What I'm after is the lease to be produced in court - not whether it's Mom or Dad Tenant who delivers the document. Correct?
A: If you are not suing the tenant(s), then you're making a mistake. You don't know who put #399 into the lease, and since you don't, then you must assume that it could be anyone through whose hands the lease has passed (tenant, landlord, property management, security company, property owner, etc.).