408-4 Exhibit D

June 6th, 2024

Brief/Memorandum in Support re [407] MOTION for Reconsideration re [238] Order on Motion to Amend/Correct, filed by Tracy Caekaert, Camillia Mapley.

Note: This exhibit includes a summary of the Jehovah’s Witness Legal Department History.

Attachments:

# (1) Exhibit A PLs’ 2nd Set of J.D. to WTNY, Thomas Jefferson Jr.
# (2) Exhibit B PLs’ 2nd J.D. to Watch Tower PA, Philip Brumley
# (3) Exhibit C Documents Obtained Timeline
# (4) Exhibit D 2022-12-02 WTNY’s Resp to PLs’ 4th Disco (CV-20-52)
# (5) Exhibit E CONFIDENTIAL Excerpts from 2024-03-07 Depo. Transcript WTPA 30(b)(6) – Mario Moreno
# (6) Exhibit F 2024-01-08 Benjamin F. Yonce Expert Report
# (7) Exhibit G Excerpts from 2023-08-11 Depo. Transcript B. Lovett
# (8) Exhibit H Excerpts from 2024-01-10 Depo. Transcript Hardin 30(b)(6)
# (9) Exhibit I Excerpts from 2023-07-12 Depo. Transcript Delbert Hiebert
# (10) Exhibit J Excerpts from 2023-07-11 Depo. Transcript Thomas Meyers
# (11) Exhibit K CONFIDENTIAL Excerpts from 2024-03-07 Depo. Transcript WTPA 30(b)(6) – Devine
# (12) Exhibit L 30(b)(6) Deposition Notices