The dismissal sanction set forth in OCGA § 9-11-37 (b) (2) (C) refers to the "disobedient party" and it is axiomatic that it applies only to the parties to the lawsuit. See NRD Partners, II, L.P. v. Quadre Investments, 364 Ga. App. 739, 742-743 (2) (a), 875 S.E.2d 895 (2022) (holding that OCGA § 9-11-37 (b) (2) does not expressly authorize attorney fees award against non-parties as a contempt sanction).Appellants do not enumerate as error the trial court’s imposition of attorney fees against Hermes.

To the extent that OCGA § 9-15-14 provides an incomplete remedy to a party who is faced with a non-party who files numerous vexatious motions, "it is for our legislature, rather than this court, to fashion a more complete remedy." NRD Partners II v. Quadre Investments , 364 Ga. App. 739, 743 (2) (a), 875 S.E.2d 895 (2022).

OCGA § 9-11-37 (b) (2) authorizes a trial court to impose sanctions when "a party fails to obey an order to provide or permit discovery." See also NRD Partners II, L.P. v. Quadre Investments, LP , 364 Ga. App. 739, 741–42 (2), 875 S.E.2d 895 (2022). (f) Attorney-Client Privilege.

See, e.g., Hartloff v. Hartloff, 745 N.Y.S.2d 363 (N.Y.App.Div. 4th Dept. 2002) (holding that the trial court did not have jurisdiction to assess counsel fees, costs, and sanctions against nonparties, where the nonparties had not been named as defendants in the action, had not been served with process notifying them of any claim for money damages, and had not been afforded the opportunity to defend such claim). See also NRD Partners II, L.P. v. Quadre Investments, LP, 875 S.E.2d 895, 899 (Ga.Ct.App. 2022) (holding that the trial court could not award attorney fees against a nonparty in a contempt sanction). Even if Code § 8.01-9 did permit the GAL's appointment, the GAL in this matter failed to meet the statutory burden of rendering "substantial service" in representing her client's interests in order to receive compensation.