Posted on October 4, 2022 by Mark O'Donnell — 1 Comment

Jehovah’s Witnesses Post Mandatory Reporting Training Instructions, Existing Policies Unchanged

BREAKING NEWS:

October 4th, 2022

In an unexpected move, the Jehovah’s Witness Church, headquartered in New York State, has issued an Elders-only announcement in which Illinois ministers are prompted to take an online training course sponsored by the Department of Children and Family Services.

This announcement, directed only to Illinois-based Jehovah’s Witness elders, was officially released on October 4th, just six months after church elders Michael Penkava and Colin Scott were convicted in McHenry county for violating Illinois’ mandatory reporting laws. The two elders were sentenced to a year of probation, fines, and community service after they knowingly violated Illinois State law requiring ministers to report allegations of child abuse.

The two men argued that the Jehovah’s Witness Legal Department in New York advised them that they were under no obligation to report the sexual abuse of a 6-year-old girl in 2006. Twelve years later, the girl came forward to the Crystle Lake Illinois Police Department and reported that she had been raped and molested repeatedly by her own father, Arturo Hernandez-Pedraza throughout the 12-year period. Pedraza was arrested in 2019 and found guilty by a McHenry County jury on October 23rd, 2019. He was sentenced to a total of 50 years imprisonment.

One year later, prosecutors in McHenry county issued non-custodial arrest warrants for elders Michael Penkava and Colin Scott. The State charged the two men with criminal misdemeanor violations of the mandatory reporting act, a crime that carries a maximum penalty of a year in prison and up to a $2,500 fine. The elders waived their right to a jury trial and elected for a bench trial in the courtroom of Judge Mark Gerhardt. On March 18th, 2022, both defendants were found guilty. Judge Gerhardt sentenced them one week later. Neither defendant appealed the verdicts.

On October 3rd, an active Jehovah’s Witness elder came forward under the condition of anonymity to report that Jehovah’s Witnesses have issued a new directive recommending that Illinois elders take the online version of Mandatory Reporter Training “at their earliest convenience.”

October 4th 2022 Announcement for Illinois Jehovah's Witness Elders — October 4th, 2022 Announcement for Illinois Jehovah’s Witness Elders

The letter to Illinois elders was sent along with a second document titled “Questions and Answers.“

In the Announcement letter, elders are advised that “Illinois law requires ministers (elders) to attend state-provided training on reporting child abuse.” This Illinois law went into effect on January 1st, 2020, but there is no evidence to indicate that the Jehovah’s Witnesses complied with the legislation until after the criminal conviction of the two elders, Penkava and Scott.

Elders in Illinois are steered away from in-person training by directing them to the DCFS training website at https://mr.dcfstraining.org/.

After completing the online training modules, elders will receive a certificate of completion that is effective for three years. Additionally, prior to participation in the online training, elders in Illinois are told that they must review the “Questions and Answers” in advance. This is followed by the statement that “this training program does not change the direction outlined in the Shepherd book, chapter 14, paragraph 7. This direction still applies and should be followed.”

The Jehovah’s Witness elders employ the 274-page “Shepherd Book” as their confidential manual of instructions and guidance for handling congregation matters. Chapter 14 is exclusively devoted to the subject of child abuse. Paragraph 7 states, in part:

To ensure that elders comply with child-abuse reporting laws, two elders should immediately call the Legal Department for legal advice when the elders learn of an accusation of child abuse. A call should be made even when both persons involved are minors. The elders should not ask an alleged victim, the accused person, or anyone else to call the Legal Department on the elders’ behalf…

This directive does not appear to represent any change in the policies of Jehovah’s Witnesses with respect to the reporting of child abuse to secular authorities. Instead of permitting church elders to report allegations of abuse directly to the police, Jehovah’s Witness elders are required to contact their New York Legal Department, which documents in meticulous detail the nature and particulars of the abuse as part of their established intake process.

However, the role and nature of the Witnesses’ Legal Department has become increasingly suspect in recent years. This has cast doubt upon the legality of advice administered by anonymous staffers at the Patterson New York legal offices. While investigating the Penkava and Scott criminal prosecutions, JWCA learned that the Illinois elders relied upon legal advice that was administered initially from a non-attorney, then later from a Jehovah’s Witness attorney named Greg Allen, who was not licensed to practice law in Illinois. In fact, there is no evidence suggesting that anyone in the Church’s Legal Department is authorized to practice law or give advice in Illinois.

Additionally, concerns have arisen in connection with civil child abuse cases that call into question whether Jehovah’s Witness elders are entitled to attorney-client privilege.

Attorney-client privilege suggests that the Legal Department at Jehovah’s Witness headquarters has entered into an attorney-client relationship with local Witness elders, but the newly-leaked documents indicate otherwise.

October 4th 2022 Questions and Answers for JW elders in Illinois

According to this document, “Since elders are volunteers of their local congregation and not employees of any corporation used by Jehovah’s Witnesses, please keep your own record and comply with retaking the course every three years.”

The prior paragraph poses a similar question:

QUESTION: The course prompts me to identify myself as an employee of a certain agency or organization. How should I respond to this without giving the wrong impression about being employed clergy of “Watchtower” or “Jehovah’s Witnesses?”

ANSWER: we reccomend that you identify yourself as a “religious volunteer” and reply “none” to the question about an employer.

The Jehovah’s Witnesses have maintained a long-standing practice of declaring that their members – including elders – are not agents of, or employed by the Church or any of its corporations. This policy is designed to protect the Church itself from liability, but leaves individual elders and members defenseless against criminal or civil complaints.

This stands in conflict with the fact that the actions of Witness elders are closely monitored and controlled, with no ability of an elder to act independently of the Church’s directions.

In the case of child abuse allegations, elders are required to communicate with and abide by the guidance they receive from their New York headquarters, including the Legal Department. Yet nowhere in any Jehovah’s Witness manuals or elder directives is there a statement that clarifies and identifies Witness elders as clients of the Church’s Legal Department.

As a general rule, the Jehovah’s Witness Legal Department is selective about any cases it takes on board, and only offers assistance when the Church identifies a challenge to its Constitutional rights.

According to the leaked letter to Elders, the Coordinator of Elders for each Illinois congregation of Jehovah’s Witnesses should ensure that all elders comply with the mandatory training requirement.

This does not mean that elders will comply with State reporting laws.

Documents:

October 4th, 2022 Announcement to Elders in Illinois

October 4th, 2022 Questions and Answers related to Announcement

Illinois Department of Children and Family Services website

Online Training for Mandated Reporters – website

Posted on August 15, 2022August 15, 2022 by Mark O'Donnell — Leave a comment

Pennsylvania Opens Grand Jury Criminal Investigation Into Jehovah’s Witnesses

Pennsylvania Grand Jury for Jehovah's Witnesses

Published February 8th, 2020

In 1884, the Watch Tower Bible and Tract Society was incorporated in the Court of Common Pleas in the Commonwealth of Pennsylvania. The movement of Charles Taze Russell became an established religious business, a tax-exempt corporation that would go on to control the lives of more than 8 million devoted followers,

One hundred years later and four hours southeast of Allegheny, I was baptized as one of Jehovah’s Witnesses in a tiled, heated baptismal pool in Crownsville Maryland. I was 16.

Thirty-five years after that, the Commonwealth of Pennsylvania served me with a subpoena to testify in a Grand Jury investigation into alleged criminal activity by the very same religious organization to which I devoted the formative and working years of my life. Let me explain why this happened.

I grew up in Baltimore, Maryland, the only child of devoted Jehovah’s Witness parents who had embraced the religion following the assassination of President John F. Kennedy, the Cuban Missile Crisis, and the escalation of the Vietnam war. Jehovah’s Witnesses pounded the pavements of Baltimore, preaching the imminence of Armageddon.

Watchtower vice-president and oracle Frederick W. Franz famously came to Baltimore in 1966, delivering multiple conventions speeches, including the epic book release of Life Everlasting in Freedom of the Sons of God. This 400+ page publication unveiled a shocking timetable of world events, including the revelation that 1975 would mark the most significant modern date in history.

From that moment forward, everything changed. Urgency over the date 1975 drove Witnesses into a subtle frenzy, with Organization overseers using these new revelations as spiritual cattle prods, driving many to sell their homes and preach the news of the ends of the world.

When I was 8 years old, 1975 came and went, but new predictions emerged, and the old ones were revised. As a child, I could not accept that I was being lied to, so I trusted Jehovah’s Witnesses and their appointed elders.

Among the most trusted elders was a man named Charles Brineshults. Charlie, as he was known, was a long-time appointed elder, a widower, and held the distinction of being one of the elite few remaining “anointed” Jehovah’s Witnesses on Earth. He was also a serial pedophile, but I didn’t know that.

Even as a child my instincts told me something was not right. Brineshults shuffled from family to family, latching on to the generosity of anyone who would take him in. Of course, the homes he selected and the families he embraced all had children. Vulnerable children.

It was not until about 10 years ago during a group vacation that a close friend and longstanding elder heard the name Brineshults in conversation, and he piped in “Oh yeah, he diddled kids, you didn’t know?”

“What?” I exclaimed as I shot a piercing gaze across the South Carolina beach resort, expecting to hear this was some kind of joke. But it wasn’t. As it turns out, it was an open secret among dozens of families and nearly all of the elders in the congregation circuits I grew up in.

I was horrified. At that moment I could instantly recall sitting in the rear of a Kingdom Hall after a meeting, watching Charlie approach me with my father nearby. “Mark is so polite when he answers the phone, I am very impressed He speaks to clearly and with such maturity.”

I was barely 10 years old. Like so many others, I was unaware I was being groomed, and were it not for the screen of my extra-protective mother, I would most certainly have been one of his many victims.

And then there was Ongsingco.

Louis Ongsingco was a charismatic Watchtower-appointed pioneer minister and self-declared pied piper of the local Jehovah’s Witness children. He was engaging, well-traveled, and he liked girls. Young girls.

Louis was a jet-setting flight attendant who frequently returned from Paris or London with expensive chocolates and other gifts for the kids he liked the most. He was also a massage therapist.

He had a smooth-talking way of conversing with teen girls, advancing his hands further and further from their shoulders to their backs, then finally crossing the lines between friendly conduct and full-on sexual assault. I saw this myself.

I was barely a teenager when I approached local elder Robert “Bob” Manke about Ongsingco’s behavior with girls. Where else would I go? My parents couldn’t control Louis, and I didn’t know that this was a matter for the police. How could I? So I trusted that Manke and the other elders would handle the situation.

They didn’t. Instead, they told Ongsingco that I had outed him, which led to severe chastisement from Louis himself. It was frightening. Meanwhile, Louis kept up his behavior, and decades passed. After leaving the Witness religion in 2013, I wanted to see what happened to this man.

After a brief investigation, I discovered that Louis Ongsingco went on to sexually assault multiple women, both Jehovah’s Witnesses, and non-Witnesses. By 2001 at least seven different women filed two lawsuits against Ongsingco.

These lawsuits are independent of additional allegations against Ongsingco, including those of two women who claim that Ongsingco placed his hands down the front of their shirts when they were teenagers.

One of those women came forward to the Atlantic in 2019 and was interviewed by journalist Doug Quenqua, who investigated Jehovah’s Witnesses in his article The Secret Database of Child abuse.

The Atlantic Article

In 2018 I was introduced to Douglas Quenqua, a respected writer whose work has appeared in the New York Times, CNBC, Buzzfeed, and other periodicals. Doug had learned that I had received hundreds of pages of child abuse case documents from several Jehovah’s Witness congregations, and he wanted to learn more.

Over the course of 2018, we spent a number of days discussing these documents, and why Jehovah’s Witnesses had not reported these cases to the police. The incidents were horrifying, and worse yet, they revealed that most of the perpetrators were still at large, and were in contact with children.

On March 22nd, 2019, the Atlantic released Doug’s article. 24 Hours later, two elders rang our doorbell before 10 AM. We did not answer. When we checked our security camera later, it was apparent who these men were. They were church elders from the Perry Hall Congregation of Jehovah’s Witnesses in Maryland.

One of the two elders is the father of a woman who was sexually assaulted by not one, but two Jehovah’s Witness men. The men were Brineshults and Ongsingco.

Two Church Elders at my door, seeking to disfellowship

I remember thinking how pathetic it was to be chased down by the very men who have been covering up child abuse for years, and whose children were among the victims.

On April 14th, 2019, Watchtower representative and local church elder Joel Raniolo mailed two certified letters to my home, demanding that we attend a judicial hearing at the Perry Hall church. When reached, Raniolo refused to divulge why he had sent the letters, and how he had obtained our personal information.

On May 14th, 2019, another Church elder announced to the Perry Hall congregation that Mark and Kimberly O’Donnell are no longer Jehovah’s Witnesses. It had been 35 years since my indoctrination and baptism back in February 1984.

The Pennsylvania Grand Jury

In the weeks following the release of the Atlantic article, national and global attention became focused on the Jehovah’s Witness religion. In particular, the Pennsylvania Office of the Attorney General took notice of the allegations of corruption within the Witness Organization.

The State of Pennsylvania is no stranger to the cover-up of abuse within religious organizations. In 2018, the Attorney General’s office released the results of a two-year investigation into the Catholic church, following multiple substantiated reports of child sexual abuse and corresponding cover-ups.

On July 2nd, 2019 I was interviewed in my home by the Deputy Assistant Attorney General of Pennsylvania, along with a Special Investigator for the State. For more than three hours I provided documentation and details concerning the policies and practices of Jehovah’s Witnesses, especially in connection with child abuse.

On July 29th a Special Investigator arrived at my Baltimore home and served a subpoena for me to appear before the 45th Investigative Grand Jury of the State of Pennsylvania.

Finally, on August 22nd, 2019, I arrived at the State Capitol before 7.30 AM and was sworn in by Judge J. Wesley Oler in his chambers. Moments later I entered the large Grand Jury room, where 23 grand jurors and approximately 12-15 alternates were stationed at their desks, positioned to take notes and record their questions on paper.

A Grand Jury is a special tool used by state and federal governments to investigate criminal allegations against persons or institutions. The powers of grand juries are wide-ranging and potent. They include the ability to subpoena and compel witnesses to testify, and those witnesses are encouraged to speak freely and without fear of reprisal.

Any form of retaliation is taken seriously by the office of the Attorney General and the presiding judge. Of course, Jehovah’s Witnesses had already executed retaliation on my wife and me in response to our efforts to shed light on the epidemic child abuse problem within the religion.

My testimony lasted more than two straight hours as I sat facing the Grand Jury and the Deputy Attorney General, together with several State Attorneys and Special Investigators.

Grand Juries can be cathartic experiences for cooperative witnesses who testify on the side of civil justice. That was my experience.

For the first half of my initial testimony, I recounted my personal history within the Jehovah’s Witness religion, beginning with my religiously isolated childhood. It was an opportunity to share my experiences with a large group of citizens who will ultimately make important decisions when they vote on the choices presented to them.

There were moments of levity amidst the proceedings, including a curious exchange in which I discussed the history of the Witnesses’ custom Bible, the New World Translation. I explained how the translation was largely the brainchild of Frederick W. Franz, whose linguistic education was limited to a maximum of two years study of Greek, and no training in Hebrew.

The irony of this information was not lost upon the investigating members of the Grand Jury.

The Grand Jury and the JW Organization

As the morning progressed, my testimony turned to the driving force behind the reason these people were assembled in this room- to comprehend whether the religious hierarchy which drives this religion is responsible for the failure to report the crime of child abuse.

A large whiteboard was placed to my left, facing the grand jurors. At the very top, the letters “GB” were written in large letters, then circled. It was clear that the Deputy Attorney General of Pennsylvania understood that the decisions and power of this religion lay at the top of a complicated network of corporations, congregations, Circuit Overseers, and churchgoers.

I spent some time attempting to explain the spider web of mechanisms used by Jehovah’s Witnesses, describing the difference between their view of the spiritual and the legal.

Branch Committees, Corporations, Circuit Overseers, Congregations, Elders, Ministerial Servants, Pioneers, Publishers- all of these found their way to the diagram of the Witness organization. Lines were drawn connecting all of the organizational machinery which comprises the Jehovah’s Witness religion. In the end, all roads terminated at the Governing Body.

After testifying for more than two hours, I was excused and held in a waiting area while the Grand Jurors scribbled their questions on paper and handed them to the Deputy Assistant Attorney General, after which I was brought back into the room, and given the opportunity to respond to the questions.

The process was dignified, and thorough, but clearly an incremental process. Four months later, I found myself escorted once again into the halls of Pennsylvania justice, this time in a brand new government complex even more secure than the prior Strawberry Square location.

Grand juries are most often 18 months in length, with citizen jurors obliged to comply with the civic duty once per month for several days at a stretch. In some cases, grand juries are extended another 6 months. So it was no surprise that I returned 4 months after my initial testimony, this time to discuss documents.

Documents

The smoking gun of certain crimes lies in the creation of a paper trail of evidence that substantiates repetitive negligent or criminal behavior. If there’s one thing the Jehovah’s Witnesses are not lacking, it’s documents.

From the inception of Watch Tower Pennsylvania in 1884, Jehovah’s Witnesses have been in the document business. As the religion branched from printing Bibles and books to buying and selling real estate, the global corporations expanded, and so did the need to maintain centralized control over a growing member base.

By the 1970s, the Witnesses had tightened controls over congregation elders, formed Governing Body Committees, and published letters to all Elders on various corporation letterheads. They even began publishing a secret elder’s manual with strict instructions that it be concealed from anyone not an elder.

The expansion of congregation elder bodies meant that members trusted local elders to handle certain matters which would otherwise be best handled by law enforcement. Elder bodies became the police department for Jehovah’s Witnesses.

As the organization became further centralized, policy letters became the norm. While many documents dealt with routine activities for the church, other letters started to emerge which seemed to border on matters best left for law enforcement.

On July 1st, 1989, Watchtower New York issued a now-famous six-page letter to all congregation elders, labeled “confidential.” This letter warned elders not to divulge confidential information to “unauthorized” persons, including the police.

It was clear that the rising number of child abuse cases in the Organization needed to be addressed, but Watchtower insisted that their New York Legal department act as first point of contact for any elders who learn of abuse.

This letter served as the opening salvo in a policy of obstruction of justice for victims of child abuse and the law enforcement agents who could have helped them.

On December 18th, 2019, I sat before the Pennsylvania Grand Jury, listening to the reading of the entire six-page letter from 1989.

It began to hit me how serious these letters were, and how vital they are to the investigation into Jehovah’s Witnesses. Every line, every paragraph was dissected and scrutinized. And then more letters were introduced.

On March 14, 1997, Watchtower released yet another directive to elders, and this time they asked for documentation of known child abusers serving in any congregation. It was, in effect, an official announcement of a secret database of child abusers.

On Page two, the letter stated:

“However, the body of elders should discuss this matter and give the Society a report on anyone who is currently serving or who formerly served in a Society-appointed position in your congregation who is known to have been guilty of child molestation in the past.”

This single sentence has formed the basis for a series of civil lawsuits in California in which attorney Irwin Zalkin and his team have worked many years to expose, knowing that Watchtower is harboring the names of thousands of child abusers in its database. Many of the abusers are still at large and serving in positions of authority among Jehovah’s Witnesses.

These were just a few of the many letters I reviewed and certified as authentic for the Pennsylvania Grand Jury.

What Effect Will the Grand Jury Have?

I cannot speculate on the full nature of this investigation, as these proceedings are sealed off from the public and the press. The Office of the Attorney General cannot confirm or deny that there is an investigation. They cannot confirm or deny that they will seek to investigate and subpoena specific individuals, such as victims, attorneys, experts, active elders, or members of the organization who serve at the highest level.

Subpoena for Mark ODonnell-jwca2 — Subpoena for the 45th Investigative Grand Jury

Only those who testify, and who have not been placed under a gag order from the presiding judge may discuss their testimony, if they choose to do so. Otherwise, until their investigation is complete, they will not comment.

There are a number of possible consequences of this Grand Jury investigation, and it may take some time before we see the results. One outcome is a presentment- a recommendation that charges be filed against a person or organization. Another outcome is a formal report, like the Catholic Church report released in 2018.

Whatever the case, the Office of the Attorney General has the power to issue search warrants and subpoenas, to compel testimony, and may even cross state lines to accomplish their work.

After a lifetime in the Jehovah’s Witness organization, having seen the damaging effects of child abuse and the cover-up of these crimes, I am thankful that the Commonwealth of Pennsylvania has finally turned its attention to the organization which silenced the voices of survivors and those who champion their rights.

This article was originally published on February 8th, 2020. The USA Today followed this article by publishing their report on the same day.

USA Today Article: https://www.usatoday.com/story/news/investigations/2020/02/08/jehovahs-witnesses-under-investigation-pennsylvania-attorney-generals-office/2425260001/

The Philadelphia Inquirer published their article later the same day.

Philadelphia Inquirer Article: https://www.inquirer.com/news/pennsylvania-grand-jury-investigating-jehovah-witnesses-sex-abuse-cover-up-20200209.html

On Monday, February 10th, 2020, Reveal News and the Center for Investigative Journalists published a report by journalist Trey Bundy.

Reveal News Article: https://revealnews.org/article/pennsylvania-opens-grand-jury-investigation-into-jehovahs-witnesses-cover-up-of-child-sex-abuse/

The Philadelphia Inquirer journalist David Gambacorta followed his original article with a follow-up on February 14th, 2020.

Philadelphia Inquirer Report #2: https://www.inquirer.com/news/jehovahs-witnesses-sex-abuse-cover-up-pennsylvania-grand-jury-investigation-20200214.html

Additional article references to the investigation:

From the Soloff and Zervanos Law Firm: https://www.soloffandzervanos.com/blog/2020/02/pennsylvania-open-grand-jury-investigation-into-jehovahs-witness-child-sex-abuse-cover-up.shtml

Posted on August 1, 2022August 1, 2022 by Mark O'Donnell — Leave a comment

2019: Governing Body of Jehovah’s Witnesses Named as Defendants in Child Abuse Lawsuits

Published August 21st, 2019

“We need to focus on the institution, not the individual priests. Practice and policy. Show me the church manipulated the system so that these guys wouldn’t have to face charges. Show me they put those same priests back into parishes time and time again. Show me this was systemic, that it came from the top down…

…We’re going after the system.”

– From the 2015 film Spotlight

On August 14th, 2019, multiple civil lawsuits were filed in the State of New York, naming the Governing Body of Jehovah’s Witnesses as co-defendants.

The all-male eight-member ruling authority faces accusations of negligence by controlling an institution that carelessly abused its power, resulting in the sexual abuse of a large number of minor children.

Attorney Irwin Zalkin is going after the system.

New York and San-Diego-based Zalkin identified the core reasons for naming the self-appointed Governing Body as defendants in the latest round of lawsuits.

“They are now going to be named defendants in a lawsuit. They are headquartered in the State of New York. They direct all of the activities of the Jehovah’s Witness Organization from the State of New York. They are very hands-on. The Governing Body is very hands-on in making policy and practice for the organization in issuing directives to elders including directives related to their sexual abuse policy. “

Among the directives approved by the Governing Body of Jehovah’s Witnesses is the 274-page secret elder’s manual known as Shepherd the Flock of God. An entire chapter has been devoted to managing child abuse, with the very first subheading titled “Legal Considerations.”

While Jehovah’s Witness elders claim that they endeavor to cooperate with law enforcement, they are neither permitted nor encouraged to immediately phone the police when they become aware of child molestation allegations.

Instead, they are under strict instructions to promptly phone Watchtower’s legal department in Patterson New York, where anonymous men type detailed allegations into their child abuse database. Before handing the call off to the religious Service Department, legal advisors decide whether mandatory reporting laws apply to clergymen in the state where the crimes occurred.

csa-intake 2018 — 2018 JW Legal Department Intake Form- Top

Despite clergy-mandated reporting in nearly every State, Watchtower’s legal department relies heavily upon a broad interpretation of clergy-penitent privilege, a loophole which Watchtower leaders exploit in virtually every child abuse case.

The quandary is, courtrooms across the United States disagree with the liberal interpretation of clergy privilege. Watchtower claims that all conversations between elders and victims, perpetrators, Circuit Overseers, Appeals Committees, and New York Service Department elders are covered by this privilege.

However, clergy privilege was intended to protect the confession of a perpetrator to his priest or elder, It was never intended to protect an internal investigation initiated by a body of elders within a congregation. Attorneys for Jehovah’s Witnesses believe they are being unfairly held to the Catholic Church model, where privilege only applies to a confession made between the penitent and his priest.

JW Child Abuse Elders Manual Chapter 14 — JW Elders Manual

Multiple Lawsuits Filed

In the wake of the newly-enacted Child Victims Act legislation, dozens of lawsuits were filed on behalf of victims seeking justice. While a significant number of cases target Catholic New York Dioceses, Jehovah’s Witness abuse survivors are also lining up seeking justice, compensation, and validation.

The New York law sets aside Statute of Limitations restrictions for a period of one year, opening the door for victims previously barred from suing organizations that covered up abuse.

Because Jehovah’s Witnesses are an insular religious community, very few cases were ever brought before criminal or civil courts. Witnesses are encouraged never to bring reproach upon the “name of Jehovah” by straying outside of the organization to resolve matters involving church members. Such matters include allegations of child abuse.

While parents are sometimes advised by elders that they are free to report abuse allegations to the authorities, under no circumstances are they implicitly directed to do so.

Survivors Michael Ewing and Heather Steele know all too well what it’s like to have their lives destroyed by appointed members of the Jehovah’s Witness religion. Both have sought the aid of the Zalkin Law Firm after decades of suffering the after-effects of their abuse and the corresponding cover-up.

Court documents describe evidence that church leadership intentionally tried to circumvent law enforcement in an effort to reduce notoriety.

The abusers in both cases were appointees of the Governing Body, including an elder and a ministerial servant. Both are considered agents of the church.

Attorney Zalkin outlines a long history of non-compliance and non-cooperation with law enforcement, citing numerous secret church mandates sent only to congregation elders.

In both complaints, Zalkin states:

“Notwithstanding the reports received in response to the March 1997 and July 1998 letters which continue to be sent to this day, defendants WATCHTOWER and GOVERNING BODY left intact a longstanding Jehovah’s Witness policy dating to a July 1989 policy letter that required elders to frustrate law enforcement efforts to investigate child molestation, and to contact defendant WATCHTOWER’S Legal Department about child abuse allegations instead of cooperating with law enforcement or reporting child molestation allegations to the police. Similarly, victims were still to be discouraged from seeking any form of therapy where Jehovah’s Witness molestations may be disclosed to non-members. Despite being staffed with ministers, defendant WATCHTOWER’S Service Department has never made a mandated child abuse report to law enforcement.”

Attorney Zalkin seeks to hold the top officials for Watchtower responsible, specifically the eight members of the Governing Body. In 2014, Zalkin filed a motion to compel the deposition of the longest-standing member of the Governing Body, Gerrit Losch.

In defiance of this motion, Losch used two law firms outside of Watchtower to quash the motion to compel, with Losch claiming that he did not answer to Watchtower or create any of their corporate policies. Watchtower’s attorneys compared Losch to the Dalai Lama.

Zalkin intends to prove that Losch’s professed detachment from Watchtower’s corporate structure is an attempt to evade accountability for the creation of dangerous and influential policies which affect over 8 million Witnesses worldwide.

While the Governing Body removed itself from the legal corporations owned by the religious empire in 2000, the new lawsuits indicate that this was merely a legal formality and that there are no policies which do not fall under the jurisdiction of the ruling body.

The Governing Body and their corporations are in fact, alter egos of each other.

Meanwhile, in New Jersey, two more abuse victims have come forward as a result of the abuse of Heather Steele and her sister.

Plaintiffs Lynn Hagan and Tarah Bird have filed a 30-page civil lawsuit in which they allege that their own biological father, Donald Nicholson, sexually abused them for twenty years. Nicholson was the same prominent church elder who molested Heather Steele.

Complaint Filed by Hagan and Bird

Nicholson had been arrested and found guilty of molesting the two daughters of Jehovah’s Witness elder Lee Steele, who was a New York State Trooper at the time. Nicholson pled guilty in 1982 and spent 3 1/2 years in prison.

Nicholson Re-Offends While Incarcerated

Approaching the end of his prison sentence, Nicholson was transferred to the Wallkill Correctional Facility in New York, which had just initiated a family visitation program for qualifying prisoners. During recurring overnight visits, four-year-old plaintiff Tarah Bird was regularly forced to endure sexual assaults while her mother, Gail Nicholson, watched.

Gail Nicholson died on October 3, 2018.

According to court documents filed on behalf of Nicholson’s daughters, the Governing Body of Jehovah’s Witnesses harbored a known child molester from 1974 to 2010. Attorneys for Hagan and Bird state:

“Additionally, upon information and belief, a known child molester was appointed to the Governing Body in 1974, and he controlled Watchtower Defendants’ database of molesters, policies toward their judicial cases, and non-reporting to authorities until his death in 2010”

The Governing Body member referred to is Theodore “Ted” Jaracz. It is unclear whether the law firm of Bochetto and Lentz will present physical documentation to substantiate the allegations against Jaracz.

Additional Lawsuit Filed Against Governing Body and Watchtower

On August 15th, 2019, attorney Irwin Zalkin filed yet another civil lawsuit against the Governing Body of Jehovah’s Witnesses, this time in the Superior Court of California, Los Angeles County.

The new case alleges that Kevin Ramirez was molested by Humberto Ramirez (not his father) between 1999 and 2001 when Kevin was between six and eight years of age. The documents state:

“Humberto molested Plaintiff on numerous occasions, including during and after Church events such as field service, bible study, and during a Jehovah’s Witness Assembly.”

Complaint filed by Kevin Ramirez

Humberto Ramirez was a congregation elder, appointed at through the oversight of the Governing Body of Jehovah’s Witnesses. According to the complaint, in 2001 Kevin finally revealed to his parents that he was being abused by Humberto Ramirez. His parents reported the allegations to congregation elders, who discouraged the family from reporting the matter to the police.

Congregation elders opted not to pass on the allegations to law enforcement officials, despite being mandated reporters. The filing also revealed:

“Humberto used his position with Defendants to ingratiate himself with Plaintiff’s family. Without Humberto’s position with Defendants, he would not have had access to Plaintiff or the ability to commit the acts of molestation alleged herein. Humberto threatened that Plaintiff would not be accepted into paradise if he did not allow the molestations to occur. Indeed, Humberto used his position to molest multiple boys in Defendant Congregation”

All of the cases filed represent a growing cross-section of the Jehovah’s Witness community, a place where trust for congregation elders, ministerial servants, and the underlying organization has become increasingly dangerous.

The Governing Body of Jehovah’s Witnesses is principally silent on the matter of child sexual abuse, but in 2015, Stephen Lett issued the following statement:

“Think about the apostate-driven lies and dishonesties that Jehovah’s organization is permissive toward pedophiles. I mean, that is ridiculous, isn’t it? If anybody takes action against someone who would threaten our young ones, and takes action to protect our young ones, it is Jehovah’s organization. We reject outright such lies.”

Posted on July 31, 2022 by Mark O'Donnell — Leave a comment

2020: Montana Supreme Court Rules Church Doctrine Trumps Mandatory Abuse Reporting Law, Nunez Verdict Reversed

Published January 11th, 2020

In a shocking reversal of a 2018 Judicial civil verdict, the Montana Supreme court has ruled that Jehovah’s Witnesses were under no obligation to report the sexual molestation of three minors.

Justice Beth Baker penned the 18-page decision, which overturns a 35 million dollar jury verdict against defendants Watchtower of New York and the Thompson Falls congregation of Jehovah’s Witnesses. The decision was filed on January 8th, 2020.

In 2018, District Judge James Manley determined that Watchtower, the governing corporation of Jehovah’s Witnesses, and Thompson Falls congregation elders violated Montana’s annotated code, which requires that mandatory reporters notify police following allegations of child sexual abuse. The case went to trial, and a jury awarded Alexis Nunez $35 million dollars as a penalty for the Church’s negligence and malice.

While both sides stipulated that Witness elders are members of the clergy and are mandated reporters, the Supreme Court of Montana has applied the clergy-confidentiality exception [41-3-201(6)(c)] to this case. This reporting loophole effectively states that if a church declares its internal child abuse investigations as confidential, they are exempt from the reporting requirement.

Justice Baker’s opening statement says:

“Watchtower Bible and Tract Society of New York, Inc., Christian Congregation of Jehovah’s Witnesses, and Thompson Falls Congregation of Jehovah’s Witnesses (collectively, “Jehovah’s Witnesses”) appeal the Twentieth Judicial District Court’s ruling that they violated Montana’s mandatory child abuse reporting statute, § 41-3-201, MCA, and its order granting summary judgment to Plaintiff Alexis Nunez on her negligence per se claim. They also appeal the court’s award of punitive damages following a jury trial. We hold that Jehovah’s Witnesses are excepted from the mandatory reporting statute under § 41-3-201(6)(c), MCA, because the undisputed material facts in the record show that Jehovah’s Witnesses canon law, church doctrine, or established church practice required that the reports of abuse in this case be kept confidential. We therefore reverse the District Court’s grant of summary judgment to Alexis and remand for entry of summary judgment in favor of Jehovah’s Witnesses. Because this issue is dispositive, we do not reach the punitive damages award or the Jehovah’s Witnesses’ other arguments.”

This proclamation from the highest court in Montana reveals the sinister and calamitous power wielded by religious institutions, which are permitted to self-immunize their ranking elders from obeying abuse reporting laws, while every other organization is required to comply.

In reaching its decision, the Montana Supreme Court evaluated the claims of both sides, then compared deposition and trial transcripts with Montana’s child abuse reporting laws.

It was not contested by either side that congregation elders fall within the category of clergy under Montana law. It was also not disputed that Watchtower’s legal department in Patterson New York gave explicit instructions to the Thompson Falls elders not to report the sexual abuse allegations to law enforcement.

Enter Douglas “Dave” Chappel

Prior to, and during the September 2018 civil trial, Watchtower produced representative Douglas Chappel, an elder designated to represent both Watchtower and the Christian Congregation of Jehovah’s Witnesses.

Chappel’s testimony was nebulous and deceptive, a fact that seems irrelevant to Montana’s Supreme Court. According to the ruling, “Dave [sic] Chappel’s testimony clarifies that disclosing reports of abuse to secular authorities, while ultimately within each elder’s discretion, constitutes a breach of church canon or practice. As he stated in his declaration: “While not every breach of confidentiality by an elder will result in his removal, each elder is accountable before God, the ultimate judge, for his adherence to the Bible’s command to maintain confidentiality.”

At this point, we would be remiss if we did not clarify that Watchtower’s representative is, in fact, Douglas Chappel, not “Dave Chappel” as stated by Supreme Court Justice Beth Baker.

With a significant verdict of 35 million dollars on the line, and given the fact that each Supreme Court justice concurred with this ruling, it is appalling that not one Justice noted the obvious blunder, replicated throughout the 18-page decision. Careful attention to detail lacking, one can only ponder whether Justice Baker spent more time watching Dave Chappelle on Saturday Night Live recently than she did in scrutinizing this case.

The Montana Supreme Court relied heavily upon Chappel’s testimony, stating that both sides supported his claims that it’s the practice of congregation elders and Watchtower’s supervisory New York corporations to keep their investigations confidential.

At trial, plaintiff Nunez’s attorney Neil Smith caught representative Chappel contradicting his own pre-trial deposition testimony taken during the summer of 2018. Chappel had previously stated that when the Watchtower legal department advised elders not to report an incident, those elders must maintain strict confidentiality in relation to the case.

However, during the trial, Chappel implied that the confidentiality seal would be broken if Watchtower Headquarters advised elders not to report. This would take the form of “deferring” to or informing the victim’s parents of the crime.

SMITH: “You’re saying that’s not true. Elders are not taught if legal tells you “you don’t have to report,” you’ve got to keep the information confidential?”

CHAPPEL: “We have to defer to the parents at that point. In the lack or absence of law, the parents need to be told.”

Attorney Smith engaged in a protracted exchange with Chappel at trial, pointing out that by Chappel’s own admission, elders might break the confidence of a victim and inform a parent that a minor has made an allegation of child abuse.

On the surface, this might seem logical, but in the Nunez case, elders took the allegations of sexual assault, not to the police, but to the perpetrator himself, Max Reyes. Attorney Smith argued that this was a clear violation of confidentiality.

However, the Montana Supreme Court has ruled that whether a church has broken its own confidentiality policy is irrelevant. Justice Baker, in her concluding remarks, says:

Finally, both the state and federal constitutions prohibit this Court ‘from considering whether certain religious conduct conformed to the standards of a particular religious group.

What Baker is saying is that it is completely irrelevant whether the Jehovah’s Witness elders violated any expectations of confidentiality. The Montana Supreme Court is only interested in whether the church actually has a policy- not whether they follow it.

To support this position, Justice Baker cites Rasmussen v. Bennett, a 1987 Montana case involving a Jehovah’s Witness couple disfellowshipped because the church ruled that their marriage was not “scriptural.”

In reviewing this case, the Montana Supreme Court acknowledged that Jehovah’s Witnesses have complex internal processes involving internal investigations into marriage and child abuse, but is obligated to repel any intrusions into church policy, no matter how malicious or damaging the policies. The decision continues:

“Here, as in Davis and Rasmussen, we decline to conduct further inquiry into the validity of Jehovah’s Witnesses’ tenets and doctrines, including its canon and practice for adherence to a requirement of confidentiality in handling child abuse reports. Jehovah’s Witnesses representatives testified that its process for addressing these reports is strictly confidential, notwithstanding the involvement of numerous church clergy and congregants. “It is not within this Court’s power to question [the religious institution’s] determination.” Rasmussen, 228 Mont. at 112, 741 P.2d at 759.”

In other words, if the Jehovah’s Witnesses say they have a policy of confidentiality, the court must take them at their word.

The Undeniable Admission

Justice Baker authors a particularly chilling statement that serves to discharge the Witnesses from the Montana verdict, while simultaneously revealing Watchtower’s penchant for collecting and covering up sexual abuse documentation:

“The summary judgment record demonstrates that Jehovah’s Witnesses have an established process for receiving and investigating reports of child abuse within their congregations; that they consider this process confidential; and that the process necessarily involves multiple elders and congregation members, including the accused, CCJW elders who provide spiritual guidance, and local elders who conduct the investigation.”

Montana’s Supreme Court confirms that Jehovah’s Witnesses direct broadscale investigations of child sexual abuse and report their findings, not to law enforcement agents, but to their own headquarters compound in New York State. This evidence is filed away in a secret database of child molesters, while victims like Lexi Nunez are denied the benefit of mandatory reporting laws.

Confidentiality

Justice Baker goes on to address what seems to be the focal point of this case: the definition of “confidentiality.”

Nonetheless, Alexis argues that allowing each religion to define “confidential” as it sees fit will eviscerate the mandatory reporting statute. But her restrictive definition of confidentiality contravenes the plain language of the reporting statute and the intent of the Legislature and would raise potential constitutional concerns. [bold ours]

It would appear that the underlying principle cited here is the Constitutional exercise of religion, free of the entanglements from civil authorities. The Montana Supreme Court stepped carefully around this issue, focusing more attention on the consequences of upholding the 2018 Nunez verdict than on the core issue of failure to report abuse.

The Court examined the historical evolution of the reporting statute, stating: “This Court’s task is to interpret what is contained in the reporting statute as written by the Legislature. We do not opine whether that body could have made a different policy choice that would afford greater protection to child victims. The Legislature is the appropriate body to entertain such policy arguments.” [bold ours]

The Montana legislature did indeed opine on the mandatory child abuse reporting issue back in 1991 when it Adopted House Bill 391, which added members of clergy to the list of individuals required to report. This new Bill as originally written included language stating that the law was “not intended to interfere with the practice of religion.”

Not surprisingly, the law raised immediate concerns with members of several religious groups, who voiced their objections on January 30, 1991, during the 52nd Legislative session. Pastor Doug Kelley of the Helena community church strongly opposed the bill, saying:

“I would submit to you that this is absurd. You cannot include us and at the same time say it will not interfere with our practice. Part of the practice of religion is confidentiality. To mandate that you are going to include clergy in all mandatory reporting you are going cause a tremendous conflict between the church and the state.”

Ultimately HB 391 was revised to appease the outcry from various church officials. Justice Baker comments:

After hearing concern from numerous clergy members that the bill would entangle the State in the affairs of the church, the bill was amended to add the specific exceptions now contained in subsections (6)(b) and (6)(c).

Subsection 6c states: “A member of the clergy or a priest is not required to make a report under this section if the communication is required to be confidential by canon law, church doctrine, or established church practice. “

These added subsections effectively obliterated the mandated clergy reporting statute, adding language so broad that any church could argue that its own definition of confidentiality falls under “established church practice.”

Justice Baker stipulates in her ruling that Jehovah’s Witnesses claim that by narrowly defining confidentiality, they are being discriminated against. The Witnesses are quick to point out that while the Catholic Church has one priest, the Jehovah’s Witnesses have multiple priests- or elders- who are all entitled to the “confidential” details in question. Considering that some congregations have up to 15 or even 20 elders, and the New York Service Department elders are likewise informed, the concept of confidentiality stretches the bounds of reality.

The Supreme Court’s opinion further clarifies why it will not uphold Judge Manley’s ruling against Jehovah’s Witnesses by citing the Establishment Clause of the First Amendment.

“The Establishment Clause ensures that ‘one religious denomination [will] not be officially preferred over another.’”

Given the fact that Jehovah’s Witnesses are known for litigating their Constitutional claims vigorously in the U.S. Supreme Court, it makes one contemplate whether Montana’s highest court simply opted to placate religious freedom laws over the rights of individual victims. It was the legal path of least resistance.

In concluding her Opinion, Justice Baker summarized the unexpected result:

“We hold accordingly that the undisputed material facts in the summary judgment record demonstrate as a matter of law that Jehovah’s Witnesses were not mandatory reporters under § 41-3-201, MCA, in this case because their church doctrine, canon, or practice required that clergy keep reports of child abuse confidential, thus entitling the Defendants to the exception of § 41-3-201(6)(c), MCA. The reporting statute as written accommodates Jehovah’s Witnesses’ definition and practice of confidentiality.” [bold ours]

The obvious question raised here is whether the need to “accommodate” the Jehovah’s Witnesses’ practice of conducting intensive internal child abuse investigations outweighs the duty to report acts of unspeakable sexual abuse to children.

The reaction to this ruling has already generated widespread shock and anger among victims of child abuse and supporters of mandatory reporting law.

In an exclusive statement reporter Mark O’Donnell, plaintiff’s attorney Neil Smith said:

This is a sad day for victims of child abuse in Montana. Instead of treating individuals and businesses equally in the eyes of the law, this opinion gives preferential treatment to churches, especially the Jehovah’s Witnesses, because it allows the Jehovah’s Witnesses to write their own laws about when they will and will not report child abuse.

Let’s Not Forget

As the Montana Supreme Court justices navigate the interpretation of the law and the Constitution, let’s not forget what really happened here.

On March 19th, 2004, Lexi Nunez’s aunt Holly wrote a letter to the body of elders of Thompson Falls Montana in which she described horrific and detailed accounts of multiple sexual assaults by her stepfather Max Reyes. This took place over many years, beginning in 1994. After confessing to the abuse of her brother Peter, Max Reyes was disfellowshipped by congregation elders.

The elders wrote that they believed the sexual abuse allegations of Holly and Peter. The elders were aware that Holly’s niece Lexi was in the care of Max Reyes both before Reyes was disfellowshipped, while he was disfellowshipped, and after he was reinstated. Watchtower’s legal department instructed the elders not to report, knowing very well the potential implications of covering up these crimes.

As a result, the cycle of abuse continued, and Lexi was sexually molested by Max Reyes, who fled to Mexico before the 2018 trial.

Let’s never forget that Montana’s law did not prevent elders from contacting the police. It was Watchtower’s legal department that blocked the report.

The law gives religion the opportunity to claim privilege, but it does not require it. Watchtower commands the use of privilege to escape reporting.

The Enigmatic 1998 Report

In reviewing the Montana Supreme Court decision rendered on January 8th, it did not go unnoticed that in the opening paragraphs of the opinion, Justice Baker erroneously stipulated to a fact that Watchtower categorically denied from the outset of this case.

Baker writes: “In 1998, Holly told Don Herberger, a local elder at the Thompson Falls Congregation, that her step-father Maximo had inappropriately touched and fondled her.”

The opinion goes on to state the details of the 1998 report, which Watchtower attorney Joel Taylor categorically denied.

Joel Taylor Whiteboard — Re-Creation of the handwritten whiteboard “exhibit” used by Joel Taylor

In opening arguments, Taylor told the jury that Holly’s claim that she approached elders in 1998 was a complete fabrication, and that the sole purpose of the claim was to extract monetary damages from Watchtower. In somewhat dramatic fashion, Taylor wrote “1998” on a whiteboard, then drew a line to dollar signs, stating:

“So this 1998 meeting is for one singular purpose. One singular purpose. That’s what it’s for. It didn’t happen. It didn’t happen.”

During deliberations, the jury agreed that there was not sufficient evidence to prove that the 1998 report occurred, which prevented them from awarding Holly McGowan a portion of the judgment.

While testimony and circumstantial evidence clearly suggest that McGowan was telling the truth, the Montana Supreme Court appears to break established legal procedure by taking disputed testimony and presenting it as fact.

The Net Outcome

While there is no question that the Montana Supreme Court ruling has failed the victims and shocked the public, there are a number of important impacts of this case that cannot be ignored.

Following the 2018 judgment against Watchtower, the Montana Legislature adopted a number of changes, described by the Montana Law Review Online:

“During the 2019 legislative session, Governor Bullock signed HB 640, which updated laws relating to childhood sexual abuse, namely Montana’s child abuse reporting statute. The Legislature made the punishment for failure to report sexual abuse a felony, and applied it retroactively”

While the clergy confidentiality exemption still exists, these changes still represent progress.

In 2019, the Montana Trial Lawyers Association honored plaintiffs Holly McGowan and Lexi Nunez with the Citizen of the Year award for their courage and willingness to seek justice and demand accountability.

National media coverage, coupled with the efforts of Nunez, McGowan, and their legal team, has shed considerable light upon the flawed practices of Jehovah’s Witnesses. It has enabled and inspired a notable number of additional survivors of abuse to come forward and speak out, to reclaim their voices amidst a culture of secrecy and cover-up.

Cases like Nunez v. Watchtower have drawn the attention of legislators and top State Attorneys throughout the United States, leading to a reexamination of current law, and has opened up religions like Jehovah’s Witnesses to criminal investigations.

Those criminal investigations will be the subject of upcoming JW Child Abuse articles.

Lexi Nunez Speaks Out

The Montana case is not a win for Watchtower. In the process of dodging a $35 million dollar bullet, they have exposed their arrogant and caustic policies which have muzzled the cries of victims of abuse. You won’t find the Montana ruling on the Jehovah’s Witness website, because the acknowledgment of this ruling is also a concession of their own guilt.

I’ve spoken with plaintiff Lexi Nunez about the sudden and unexpected Montana Supreme Court decision, which tipped the scales of justice in favor of the religion which covered up her abuse. She’s brave, courageous, and hopeful. And she deserves the final word:

“Please don’t let this case discourage you. Sometimes we have to fail before we succeed but we should not lose heart. To all victims past and present, we see you, we hear you, please, let us help you. Despite what our abusers would have us think, we are not alone! But the only way we fight this is by shining a light on the truth. Be brave and make a difference, not just for yourself but also for other victims who are struggling to find help. Our solidarity comes from the strength in our numbers. Keep fighting!”

-Lexi

Resources, Documents, and Media:

Read the Montana Supreme Court Decision HERE

Montana Mandatory Reporting Code HERE

NPR Report: https://www.npr.org/2020/01/09/795019348/montana-court-reverses-35-million-child-abuse-verdict-against-jehovahs-witnesses

Posted on July 31, 2022July 31, 2022 by Mark O'Donnell — Leave a comment

2019: New York Law Means Justice for Survivors: The Child Victims Act

Published July 9th, 2019

On February 14, 2019, New York Governor Andrew Cuomo delivered a powerful speech at the New York Daily News headquarters, moments before signing what might be the most significant piece of legislation involving survivors of child abuse to date.

The legislation has become known as the Child Victims Act.

As stated by New York’s Government Web Site, this new law:

Provides that the statute of limitations for criminal prosecution of a sexual offense committed against a child shall not begin to run until the child turns 23 years of age.

Provides that a civil action for conduct constituting a sexual offense against a child shall be brought before the child turns 55 years of age.

Revives previously barred actions related to sexual abuse of children.

Grants civil trial preference to such actions.

Eliminates the notice of claim requirements for such actions when the action is brought against a municipality, the state or a school district.

Requires judicial training relating to child abuse and the establishment of rules relating to civil actions brought for sexual offenses committed against children.

These stipulations represent landmark changes to New York laws protecting minors, which previously placed unrealistic limits on the time given for victims to come forward and report abuse, or file a civil lawsuit seeking justice.

Experts in the field now recognize that it may take 25, 30, 35 years or even longer before a victim of childhood abuse is able to disclose the crimes committed against them.

According to veteran Psychotherapist Beverly Engel,

“Many of us are familiar with the reasons why children do not come forward to report child sexual abuse, but many don’t understand why adults continue to carry this secret, sometimes to their graves.” – from the article Why Adult Victims of Childhood Sexual Abuse Don’t Disclose, Psychology Today.

Thanks to brilliant investigative reporting of the past 20 years, journalists have given a voice to survivors, while exposing the corrupt and flawed organizations which so often suppressed reports of abuse, or protected these pedophiles.

This collective voice has empowered thousands to come forward seeking justice- not just for themselves- but for the vast number of at-risk children left unprotected because of organizational secrecy and lack of respect for mandatory reporting laws.

Why Significant for Jehovah’s Witnesses?

In addition to extending the age for reporting abuse both criminally and civilly, the most potent legislative change gives all abuse survivors the opportunity to seek help and representation even if they were previously barred due to the Statute of Limitations.

The new law is commonly referred to as a “Window to Justice” – a term that refers to the time period survivors now have to file charges or civil lawsuits in the State of New York. For New York, the window is one year, and the clock begins ticking from August 14, 2019 and will run through July 2020.

While civil cases often take several years to process and resolve, as long as the initial filing takes place within the specified window, victims who file can be assured that they will see their day in court.

For the majority of survivors of abuse, the new law is a welcome legal tool, but only for citizens of New York State. However, for Jehovah’s Witness victims, the legislation is far more significant. The Witness organization is headquartered in New York, which means that any and all cases from all 50 States are eligible where the Watchtower Organization is a defendant.

The key to filing such cases revolves around Watchtower’s decades-old policy in which allegations of sexual abuse are handled internally as matters of “sin”- but are rarely if ever reported to law enforcement.

While Jehovah’s Witnesses publicly claim to abide by and follow mandatory reporting statutes, they deliberately obstruct justice by claiming that clergy-penitent privilege applies to nearly every allegation of abuse reported.

The distortion or corruption of clergy privilege has effectively become a JW corporate policy directed at self-preservation rather than child-preservation. Such procedures hinder trained law enforcement experts from addressing these crimes.

The Child Victims Act permits victims of abuse to hold accountable the institutions which intensified their injuries through negligence and malice.

A driving factor in the exposure of these flawed policies has been the heroic and tireless efforts of investigating and reporting journalists, beginning with the Catholic Church inquiries.

True Journalism Matters

At the outset of Governor Cuomo’s February speech at the Daily News headquarters, he stated:

“Why are we at the Daily News today? Because one lesson is that true journalism still matters. It’s not enough to have facts and righteousness on your side. If one is trying to take on major institutions, and challenge the status quo, and raise an ugly reality, the first step is still exposure…”

“The first step is to tell the truth, that citizens must understand the problem, and it’s the citizens that must demand change before the political process will act. Theoretically, traditionally…that is the role of journalists: “

“To reveal the facts, to paint the picture, to tell the truth, even when ugly, even when uncomfortable, to comfort the afflicted and to afflict the comfortable, to challenge the abuse of big institutions.”

Cuomo went on to explain how the Daily News started the drumbeat for justice by writing 252 articles on the Child Victims Act since 2009, including 223 articles and 29 editorials.

“That my friends is real journalism, and that’s how we make change,” said Cuomo.

If you are a victim, what can you do?

For those who have been affected by the cruel act of child abuse, it may take decades or longer to heal from the wounds inflicted during childhood. There are many pathways to recovery, and there is no one-size-fits-all solution.

If you are at the point in your life where you wish to come to terms with your abuse, the Child Victims Act might prove to be just what is needed.

If you choose to speak to a qualified, competent attorney, rest assured they will help guide you through the process with courtesy, kindness, and professionalism. Coming forward may seem overwhelming at first, but the resources available now are more dependable than ever.

Holding institutions accountable for failure to report abuse sends a strong message: You can’t maintain child protection policies, then fail to protect children.

The welfare of children far outweighs the reputation and interests of global corporations like Jehovah’s Witnesses.

The Child Victims Act will make sure of that.

Additional Resources:

New York Senate Bill S2440

Mandatory Child Abuse Reporting Laws- by State

Child USA

CNN: Report on Child Victims Act

Posted on July 30, 2022July 30, 2022 by Mark O'Donnell — 2 Comments

2016: Watchtower Releases Updated Child Abuse Directive to Elders

Published August 4th, 2016

In a newly released letter to all elders dated August 1st 2016, The Christian Congregation of Jehovah’s Witnesses has once again revised its instructions to elders on dealing with allegations of child abuse.

Unfortunately, the changes are completely inert, failing to address the flaws which have resulted in unprecedented numbers of lawsuits against JW congregations and their worldwide headquarters in New York.

This leaked, internal document is a modification of the October 1st 2012 letter to elders, which served as a guideline for Jehovah’s Witness elders who have come to obtain knowledge of an accusation of the physical or sexual abuse of a minor.

For those unfamiliar with this ongoing saga, Jehovah’s Witnesses maintain a rigidly controlled central network of elders who are required to make first contact with the JW legal department instead of local police or child protection authorities when they become aware of child abuse allegations.

The letter, deceptively titled “Protecting Minors from Abuse” is a 6-page document that contains the terms “legal” or “legal department” no less than 17 different times, and functions as an organizational tool that should be more accurately titled “Protecting the Jehovah’s Witness Organization from Liability and Negative Publicity.”

Legal Considerations

Following a descriptive definition of the term “child abuse,” Watchtower’s instructions waste no time reminding elders that they may be obligated to report an allegation of child abuse to local authorities.

This is significant because this statement offers no proactive protection for victims, only a reactive reminder that elders might be forced to comply with state laws. And who is responsible for informing elders of state laws in their jurisdiction? The Watchtower Legal Department.

“To ensure that elders comply with child-abuse reporting laws, two elders should immediately call the Legal Department for legal advice when the elders learn of an accusation of child abuse. (Rom. 13:1-4)” – Paragraph 6 August 1, 2016 Letter.

Using the example of the United States, it might seem logical that with 50 independent state governments, a centralized legal department would simplify the process for local elders, who are generally uninformed in legal matters. Unfortunately, the cold reality is that once the call is placed to Watchtower’s legal department, the focus shifts from the protection of the victim to the protection of the Watchtower Bible and Tract Society, and their internal investigation of the accused.

Absolute Right

As stated in paragraph 5 of the Watchtower letter, “In all cases, the victim and her parents have the absolute right to report an allegation to the authorities.” The term “absolute right” does not originate with Watchtower, but is a legal term defined this way:

an unqualified right : a legally enforceable right to take some action or to refrain from acting at the sole discretion of the person having the right” (Merriam Webster)

The term appears in the final chapter of the JW elders’s handbook “Shepherd the Flock of God” under “Clarifications and Guidelines on Handling Certain Matters”

“Child abuse is a crime. Never suggest to anyone that they should not report an allegation of child abuse to the police or other authorities. If you are asked, make it clear that whether to report the matter to the authorities or not is a personal decision for each individual to make and that there are no congregation sanctions for either decision. Elders will not criticize anyone who reports such an allegation to the authorities. If the victim wishes to make a report, it is his or her absolute right to do so.” – Shepherd the Flock of God, pages 131- 32

Clearly, Watchtower has purposefully muddied the waters of justice by issuing a confusing statement in the very book which should be relied upon to clarify the handling of serious matters. Instead, they obfuscate procedures by suggesting inaction on the part of elders, and shifting the burden of reporting abuse to the victim. There is a substantial difference between never telling someone not to report, and actively telling someone they should report.

In a great majority of JW abuse cases, the victims are underage, emotionally devastated, embarrassed, and completely unable to comprehend or navigate the process of reporting their abuser and the crime itself. Watchtower has effectively told the victim “We won’t stop you from reporting this crime to the police if you really feel this is necessary; we are required to inform you that it is your legal ‘absolute right’ to do so, but we will not encourage this unless we as the body of elders are legally held responsible to contact the authorities.”

During the April 2013 Inquiry into the handling of child abuse by religious and other organisations, held in Victoria Australia (not the 2015 Australian Royal Commission,) Watchtower legal counsel Ms. Rachel Van Witsen regurgitated the “absolute right” phrase multiple times, including the following statement defending Watchtower’s position:

“On that, if I may add, as part of giving that advice, our instructions are that first and foremost is the protection of children in the organisation, whatever that takes. At the moment, because there is no mandatory reporting for ministers of religion in Victoria, then the victim, who has very often had their dignity removed, is then put in the driver’s seat. It is entirely their absolute right, and the elders are directed to tell the victim and their family that it is their absolute right, to report to the authorities, that they would be fully supported whichever decision they made and that the elders are also directed in that advice to fully cooperate with any police investigation.”

Ms. Van Witsen was reminded by the court that the Australian Evidence Act of 2008 makes a special allowance for elders of any religion to report details of criminal conduct to civil authorities with no penalty. Watchtower has flat out refused to comply with this allowance. This detail was revealed in the exchange between the honorable Nicholas Wakeling and acting Watchtower Australian Branch Overseer Terry O’Brien:

Mr. WAKELING — I am trying to be very clear here. If there was evidence of child abuse within the church that you are aware of, would you report that to the police?

Mr. T. O’BRIEN — Not if the victim did not want it reported.

Mr. WAKELING — No, I am not asking you about the victim. I am asking: would you as an organisation report that to the police if you became aware of child abuse within your organisation?

Mr. T. O’BRIEN — We do not have the authority to do that.

Mr. WAKELING — And why do you not have the authority?

Mr. T. O’BRIEN — Because of the mandatory reporting act.

Mr. WAKELING — And why do you say that?

Mr. T. O’BRIEN — Because the minister does not have the priority over the victim. It is the victim’s absolute right and privilege to decide whether they want the matter ——

Mr. WAKELING — Mr. O’Brien, if I may take you to the Evidence Act which we are talking about, section 127 of the Evidence Act states:

“(1) A person who is or was a member of the clergy of any church or religious denomination is entitled to refuse to divulge that a religious confession was made, or the contents of a religious confession made, to the person when a member of the clergy.” The law does not prevent the church from providing information. The law provides an exemption for the church, but the law does not prevent a church in this state from providing information. It is clearly within the province of the Jehovah’s Witnesses, if child sexual abuse is such a significant issue, for you as an organisation to waiver that and to report that.

Ms. VAN WITSEN — Absolutely.

[bold and italics ours]

It is clear that Watchtower Attorney Rachel Van Witsen was caught between a rock and a hard place, formally agreeing with the court, while at the same time defending a position that obstructs justice and puts victims at an extreme disadvantage.

She declared that “our instructions are that first and foremost is the protection of children in the organization, whatever that takes” while simultaneously refusing to do “whatever that takes.” The international courts of law have come to an agreement that it takes swift and immediate contact with law enforcement and child protection authorities to protect our community and children from abusers, and this action in no way violates the scriptural and religious beliefs of those who belong to Christian organizations.

Congregation Considerations

Following the section on legal concerns, the newly released Watchtower letter focuses a great amount of attention on the internal investigations of any accusations of physical or sexual abuse of a minor. It is significant that an organization that directs so much effort into its internal religious justice system has been the subject of worldwide investigations by the very secular authorities which Witnesses claim to obey.

The Watchtower organization suggests that their own due process protects minors, positing that the reproving or disfellowshipping of an offender warns the congregation about a predator in their midst. However, this premise is deceptively weak. In a great number of sexual abuse cases, the victims have come forward only after extreme damage has been inflicted by the perpetrator on not one, but in most cases, multiple victims, often numbering double digits. The Australian Royal Commission on Child Abuse found that of the 1,006 known cases of child abuse uncovered among Jehovah’s Witnesses in Australia, the number of actually reported victims exceeded 1,730.

Predators associated with the Jehovah’s Witness religion know very well that the lack of cooperation with civil authorities coupled with the infamous JW “Two Witness” rule allows an environment of tolerance to exist inside this religion which has paved the way for many sexual encounters between these predators and innocent Witness children.

What many may not realize is that disfellowshipping for child abuse is a somewhat rare occurrence. [In many cases, elders have disfellowshipped on the grounds of “lying” rather than the actual crime of child abuse.] Obviously most abusers will flat out deny an accusation of abuse, and justice is further prevented because wrongdoing is usually not “established” without two credible witnesses. Aside from the ultra-rare confession of a molester, the only way an abuser can be convicted by a judicial committee would be when at least 2 independent victims come forward accusing the perpetrator of the same crime. Again, this is extraordinarily rare. The fact that Witness victims are effectively discouraged from contacting the authorities makes the chance of additional victims coming forward even more unlikely.

The list of policies and procedures for elders involved in processing an accused child molester is seemingly endless, as evidenced by the release of the new August 1st letter. What is absolutely horrific is that an accused and convicted child molester may not only attend meetings of Jehovah’s Witnesses but engage in the public door-to-door ministry and become baptized (or reinstated) as an approved congregant.

This letter mandates that “restrictions” will be placed on the abuser, stating that:

“The elders will be directed to caution the individual never to be alone with a minor, not to cultivate friendships with minors, not to display affection for minors, and so forth.”

Is this really a restriction? No, it is not. It is a suggestion to “caution” this predator to avoid circumstances that might lead to abuse. Any concerned parent would find absolutely no comfort whatsoever in the knowledge that a Jehovah’s Witness elder “cautioned” a sick individual to avoid contact with their child. Abusers have severe personality disorders and are manipulative and controlling. When a deviant urge rises to the surface, there is no “caution” in the world which will prevent an abuser from manipulating circumstances to his sick, sexual advantage.

It is noteworthy that Jehovah’s Witnesses offer absolutely no professional counseling either to the victims of sexual abuse or to predators seeking religious asylum within this organization. This is because, as an organization, they support or sanction no approved treatments for either group. In the case of offenders, even the suggestion of obtaining professional help is conspicuously absent from JW policy. They seem to have no problem reinstating, baptizing, or even offering “privileges” to offenders in some cases, but refuse to encourage consultation with a mental health professional.

No Help for Victims

For as long as I was associated with the Jehovah’s Witness organization, there was a notable reluctance to recommend professional counseling for any individual suffering from mental illness, depression, alcoholism, or the effects of child abuse. They believe the first authority in all such matters is the Bible, but only as interpreted by the Jehovah’s Witness Governing Body.

This is yet another obstruction of justice, particularly for victims of child abuse who, more often than not, have already been denied civil justice or the benefit of child protection advocates.

Just as with their reluctance to contact the police when learning of alleged abuse, they are equally remiss in establishing a welfare plan where victims can make contact with appropriate professionals who are trained to deal with physical or sexual abuse. The only mention of professional counseling occurs in section 11 of the Watchtower letter, which says:

“In addition to the spiritual shepherding provided by the elders, the victim or her family may desire other assistance. For example, the victim or her family may decide to consult a mental-health professional. This would be a personal decision for them to make.”

Once again, “spiritual shepherding” comes first, and is performed by window washers, carpenters, contractors, and other men who have absolutely no qualifications to handle counseling of any kind. Making matters worse, they are by design always men, further exacerbating an already sensitive situation for female abuse victims.

The suggestion that victims “may” decide to consult a mental health professional, and that this would be a “personal decision” demonstrates the well-known opposition among Jehovah’s Witnesses to opening their minds and deepest thoughts to “worldly” individuals and persons they would refer to as “so-called experts” who do not have the “best interests” of Jehovah’s Witnesses at heart.

Evidence of this position can be found in countless Watchtower and Awake! articles, such as the September 8th, 1986 issue of the Awake! which covered the subject of mental illness:

“Medical science today is likewise limited. True, one can take reasonable steps to attain a measure of relief. But rather than getting trapped on a treadmill of searching for an elusive cure, some may simply have to learn to live with and endure the problem.”

The August 8th 1982 Awake! magazine article titled “Making Wise Health Decisions” stated:

“A wise objective is to try to go through as much of life as possible free from pills or therapy. The number of persons who can say they live a pill-free life is becoming increasingly smaller”

Non-Jehovah’s Witness Parents Excluded

The Jehovah’s Witness organization governs its members on the principle that families should all accept the “truth” and describes anyone who has not accepted this religion as an “unbeliever.” It stands to reason that if a husband and wife do not share the Witness theology, this detail would be irrelevant when it is discovered that one of their children has been abused. However, Jehovah’s Witness leadership makes no mention of the involvement of a non-Witness parent during an abuse investigation, either in the updated 2016 letter to elders, or in the elder’s handbook “Shepherd the Flock.”

“In the case of any discussion with a child abuse victim who is still a minor, an elder should never meet alone with the minor but should always involve another elder and another adult member of the congregation, preferably the minor’s parent(s).” August 1st 2016 Letter to Elders, Par. 11

This is a very subtle point, but the use of the term “preferably” opens the door for the involvement of a non-parent in cases where one of the parents is either deceased, the accused, or a non-Witness. This is a reminder that the investigations performed by JW elders have no relevance in the real world, and are only used to execute their religious tribunal.

A non-Witness parent is likely already aware that his presence at a JW judicial meeting is completely undesired. He is deemed worthy of death according to the Watchtower. When discussing the consequences of marrying an unbeliever, the May 1st, 2002 Watchtower says:

“God’s view of marrying an unbeliever is expressed at Malachi 2:12: “Jehovah will cut off each one that does it.” Christians are urged to marry “only in the Lord.” (1 Corinthians 7:39) Under the Christian system of things, a believer is not “cut off” for marrying an unbeliever. Still, if the unbeliever stays in his or her unbelief, what will happen to that one when God shortly brings this system to an end?—Psalm 37:37, 38.”

In case you are unfamiliar with the Biblical term “cut off,” it means execution by God. Watchtower emphasizes that in pre-Christian days, marrying an unbeliever would result in death. They harness fear in the 21st Century by stating that the same behavior will result in death by Jehovah at Armageddon.

Summary of Changes

It has been nearly four years since the release of the October 1st, 2012 letter to elders, and while Watchtower’s policy on handling child abuse allegations has remained stagnant, for legal and administrative reasons the JW organization has seen fit to publish the following changes as noted in the August 1st, 2016 letter

The term “two witnesses” has been eliminated, but the policy itself has not changed
The statement that the “branch office” determines who shall be deemed a “predator” has been eliminated
The direction of what to do when an adult has been viewing child pornography has been eliminated
The statement that the Watchtower “branch office” determines whether an abuser shall be known as a “child molester” has been eliminated
Internal investigations with a victim do not need to proceed in the presence of the accused molester
Elders are instructed to DELETE paragraphs 20 and 21 of chapter 12 of their Shepherd the Flock elders manual

With reference to the last item, Watchtower has eliminated some grossly damaging direction, particularly regarding how it handles the testimony of the accuser (the victim) It part, the 2012 letter stated:

“The following questions should be answered with regard to the accuser: (1) What is the level of maturity of the child or youth? (2) Is he (or she) describing conduct that one his age would not normally know about? (3) Is the child or his parents known to be serious, mature? (4) Is his memory consistent, or is it intermittent, or does it involve repressed memories? (w95 11/1 pp. 25-26) (5) What is the reputation of the parents? (6) Are they spiritually and emotionally mature? After carefully considering the matter, the branch office will then give you direction as to what information about the allegation should be shared, if any, with the elders of the new congregation.”

Not only did Watchtower refuse to defer accusations of child abuse to the proper authorities, it scrutinized the victims, suggesting that some might be immature, have faulty memories, unstable parents, or may even be guilty of fabricating their claims. These disgusting and inappropriate questions have disappeared from the written edicts governing Jehovah’s Witness elders, but you can be sure that they will be asked in private when the legal and service departments are contacted by elders.

Internal Investigations

While the changes to the 2016 child abuse handling letter are primarily omissions, one addition is the newly minted policy which states the following:

“Elders should remember that during the investigation process and during the judicial committee process, a victim of child sexual abuse is not required to make her allegation in the presence of the alleged abuser.”

Jehovah’s Witness children have been traumatized by the very thought of revealing that someone touched or abused them, let alone reliving this horror in front of a group of Witness elders. Even worse, they were until now required to face their abuser in a religious tribunal.

While some might argue that eliminating the “face your abuser” madness is a step in the right direction, we must not forget that the victim must STILL spell out the details of their sexual abuse to Jehovah’s Witness investigating elders. Unless the victim is a minor, the new Watchtower directive STILL requires full disclosure to the very same men who preach that Armageddon is around the corner, and who would deny a life-saving blood transfusion to an innocent child.

The nature of these judicial proceedings is embarrassing, humiliating, and enormously stressful for the person required to recount the sordid details of the physical or sexual abuse. Remember, the men in the room are tradesmen, salesmen, pin-stripers and plumbers – anything but qualified therapists.

We must not forget that elders are required to contact the JW legal and service departments first in any cases of abuse, which means that their policies have remained essentially the same; Witness elders almost always get the first crack at interviewing the victims of child sexual abuse.

This is a significant obstruction of the child protective and civil processes which govern most countries. From the moment abuse is mentioned or reported, only trained professionals should be consulted. There are severe consequences that result from the unethical and unprofessional mishandling of abuse allegations.

In a 2013 paper on the subject of forensic interviews, the US National Institutes of Health published a paper describing the implications of multiple interviews and the fragility of victim testimony:

“Sexually abused children may have trouble disclosing¹ their abuse despite the fact that the child’s history may be the most important part of the diagnostic evaluation and may lead to conviction of the perpetrator(s) (Berkoff, Zolotor, Thackeray, Shapiro, & Runyan, 2008). The Child Sexual Abuse Accommodation Syndrome (CSAAS) model suggests that children react to their sexual abuse in the form of secrecy, helplessness, entrapment and accommodation, delayed and unconvincing disclosure, and retraction (Summit, 1983). Sense of responsibility for abuse, shame and social stigma, and fear of the consequences for the perpetrator, self, siblings, or non-involved parent all may hinder a child’s ability to disclose (Goodman-Brown, Edelstein, Goodman, Jones, & Gordon, 2003; Summit, 1983). Older children may further fear a parent’s incarceration, siblings’ removal from the home, or the loss of financial security (Block, Oran, Oran, Baumrind, & Goodman, 2010). Thus, children might not disclose abuse that has occurred for any of several reasons.”

The conclusion any reasonable person would reach is that the victim of child abuse is often in an extremely fragile state, and the interviews conducted with such persons need to be performed only by educated and qualified child protection agents and the special victims departments of law enforcement. Elders who intervene and interfere under the premise of spiritual guidance or internal investigations may cause irreversible damage to the victim, and obstruct justice.

How Have Other Religions Responded?

In noticeable contrast with the gross mishandling of child abuse cases by Jehovah’s Witness elders, other religions who have experienced similar tragedies have learned their lesson, apologized, and have put in place effective policies which favor the protection of children and have instituted a zero tolerance policy for child abusers.

For example, the Catholic Church’s Archdiocese of Baltimore Maryland has published a FAQ page on its web site titled “How the Church Responds to Sexual Abuse Allegations.”

Their published policies include the following statements:

“The Archdiocese of Baltimore is committed to healthy ministry, and seeks to utilize only competent, qualified, and responsible personnel. All clergy and Archdiocesan employees as well as all volunteers who work with children undergo criminal background checks. They also receive training on how to create a safe environment and how to recognize and report abuse. Children – including those in Catholic schools and religious education programs – are educated about healthy relationships and boundaries in the context of Catholic moral teaching.”

By contrast, the Jehovah’s Witness organization continues to appoint elders and ministerial servants (deacons) to positions of responsibility with absolutely NO BACKGROUND CHECKS whatsoever. Any male Jehovah’s Witness can work his way into a position of authority in the congregation, receiving no professional training, and has no authority to vet fellow appointed elders and servants.

The site further states:

“The Archdiocese complies with Maryland laws requiring that suspected child abuse be reported to civil authorities. Under Maryland law any person who has reason to believe a child has been subjected to abuse must report the suspected abuse to civil authorities, even if the potential victim is now over 18-year-old and even in cases where the alleged perpetrator is deceased. If Church personnel are suspected of abuse, then the suspected abuse must also be reported to the Archdiocese’s Office of Child & Youth Protection.”

Jehovah’s Witness elders continue to evade the responsibility to report abuse to civil authorities proactively, only doing so under duress.

How does the Catholic Church currently help victims?

“The Archdiocese of Baltimore has long been committed to the treatment and healing of those who have been harmed through abuse. We apologize and offer counseling assistance and pastoral services. The Archdiocese also recognizes the importance of offering support to family members. We do this for as long as it is helpful, and regardless of the age of the incident. We provide this support regardless of lawsuits and statutes of limitations. We have paid $2.8 million in victim counseling, and more than $7.6 million in direct payments to victims/survivors. The Archdiocese continues to spend hundreds of thousands of dollars annually to assist victims and protect children.”

While the Watchtower organization continues to malign all other religions as corrupt and “false” – one can’t ignore the candor of the Archdiocese, which has simply stated that “We apologize” and follow up by offering counseling and financial settlements to victims. What this means is that the Catholic organization has acknowledged that they were wrong, and they have taken responsibility for failing to protect children.

What is their current policy for handling accusations of abuse?

“Today, as it has done for many years, the Archdiocese offers assistance and healing to a victim who reports an allegation of abuse. The Church immediately reports the matter to civil authorities. When given permission by the local authorities, the Archdiocese conducts an investigation, presuming the accused is alive, and remains in ongoing communication with law enforcement. If the allegation is deemed credible, the accused is permanently barred from ministry and from serving in any capacity on behalf of the Archdiocese or any Catholic institution.” [bold is ours]

While this site does not endorse or recommend any religion or set of beliefs, we applaud those organizations that have at the very least, apologized for their mishandling of child abuse accusations, and have taken drastic steps to reverse the processes which caused the problem in the first place.

Filing immediate reports with the civil authorities and permanently banning any individual who has perpetrated a crime of sexual misconduct proves that change is possible no matter how large the organization or how widespread the problem was.

As I write this article, Jehovah’s Witnesses are facing a tidal wave of litigation and negative press due to their destructive organizational policies. In the end, they will find that they did not serve themselves very well. Their legal departments worldwide are being taxed, and they are forced to retain outside counsel from third party law firms to defend themselves in the United States, Canada, Australia, the UK, and numerous additional countries.

Watchtower continues to amass a vast database of child abuse reports within their organization, but has refused to produce these documents under court order, and has exhausted every possible legal strategy to insulate their organization from accountability.

At this moment, the Superior Court of California has levied a $4,000 per day fine against the Watchtower organization for failure to comply with the court’s discovery order. This fine has been deemed by the court as a “lesser sanction” designed to motivate Watchtower’s compliance, and is a very small fraction of the terminating sanctions which will be levied in a matter of weeks against this organization.

All of this is the sad consequence of unyielding and disastrous policies which have crippled the lives of countless abuse victims, and is being financed by the unsuspecting members of the Jehovah’s Witness organization, who have little knowledge of the legal perils of their religion.

The JW.ORG web site news section features frequent articles on the legal battles being fought in defense of their religious freedoms, but never once have they posted a story explaining their highly publicized battles on the subject of child abuse.

Even the elders who carry out these policies and orders have almost no understanding of the underlying meaning of all of this. They follow directions, completely trusting the Governing Body and its legal department.

I take no delight in reporting on these issues, as they expose a systemic crack in our society that has permitted Jehovah’s Witnesses to exploit legal loopholes to elevate their internal justice system above the very secular authorities which they claim to respect. Witnesses state that they obey civil leaders except when their laws conflict with God’s laws, yet obedience to child protection laws violates no Christian principles.

Watchtower has fought so hard to protect its secretive database of child abuse accusations that it raises suspicions of not only how many cases appear on that list, but whose names might surface once this list is exposed. The fallout might just be more than this organization can bear.

Posted on July 28, 2022July 28, 2022 by Mark O'Donnell — Leave a comment

2017: Fessler Prevails in Jehovah’s Witness Child Abuse Trial, Elder Admits Shredding Files – Part 2

Spring Grove Kingdom Hall of Jehovah's Witnesses

Published February 28th, 2017

Trial Summary – Part Two

On a blistering summer morning in Reading Pennsylvania. I crossed the railroad tracks, then Penn Street – coffee, briefcase, and boxed lunch in hand.

Just a few steps away from the Sovereign Convention Center, something caught my eye. On the corner of Penn and 7th avenue, a solitary man stood quietly with a large poster that read: “A Jehovah’s Witness elder molested me.”

It was 8.30 a.m. Thousands of badge-wearing, convention-bound Jehovah’s Witnesses streamed into the main entrance, sliding past this man as though he were invisible.

His sign quietly proclaimed that he had suffered the ultimate injustice, but no one stopped. No one seemed to care; their minds were intently focused on entering the air-conditioned building, escaping the heat which was building outside.

I don’t remember what I wore that day. I don’t remember which restaurant I went to that evening. I don’t recall which hotel I stayed in. But I remember the man with the sign.

His presence haunted me. Why was he there? Why would no one speak to him? What had he done wrong? Why was he treated as a man with leprosy?

Meanwhile, just a short distance away, a young girl named Stephanie Fessler was being abused by a Jehovah’s Witness woman more than three times her age. When the relationship was discovered, congregation elders in two states were informed. These elders contacted their legal department in Patterson New York. The elders privately, then publicly reprimanded both Stephanie, and her assailant, Terry Monheim. The police were never notified. Child protective services was never informed. The parents of Fessler were caught between the rock of their religion and doing the right thing. Stephanie’s father, Kevin Fessler, was an elder. Unfortunately, no one did the right thing.

Seven years later, Stephanie Fessler, at the age of 22, summoned the courage to tell her story to the police. As a result, Monheim was arrested, pleaded guilty to multiple charges, and was sentenced to prison and probation. Monheim was placed on Megan’s list.

Unfortunately, the damage was done. The mental anguish, the destruction of a childhood, the lack of protection from her own parents and congregation elders left Stephanie Fessler traumatized and permanently injured. Unless you are a victim of childhood sexual abuse, you may never fully understand what she has been through.

Stephanie did not want to see this happen to anyone else. The elders for Jehovah’s Witnesses along with their managing corporations, the Watchtower Bible and Tract Society of New York, and the Christian Congregation of Jehovah’s Witnesses, were served notice in a civil trial which began February 7th, 2017.

On February 13th, the Witness corporations, together with the Spring Grove Congregation of Jehovah’s Witnesses, reached a financial agreement with Fessler after just four days of testimony.

Using Watchtower’s own language, Fessler’s attorney Jeffrey Fritz stated “The matter with the Jehovah’s Witnesses has been resolved.”

Trial Day 2: Enter, Eric Hoffman

It is difficult to fathom which is worse – an elder molesting a young child, or an entire group of elders learning of an accusation, but ignoring their responsibility to inform the authorities and get help for a victim. As I sat on the rickety wooden chair at City Hall in Philadelphia, that question entered my mind. My pondering was interrupted at 1:15 PM, when Spring Grove PA elder Eric Hoffman entered the room, and was sworn in by the court officer.

Attorney for Ms. Fessler, Gregg Zeff, wasted no time in questioning Mr. Hoffman, beginning with his position as a Jehovah’s Witness elder. Hoffman has been an elder since 1994.

Zeff: An elder is a member of the clergy?

Hoffman: We are not labeled clergy. We are not paid.

Despite the denial that elders are clergymen, Zeff continues his questioning:

Zeff: Sir, would you agree that clergy must report sexual abuse of children to protect the victim from additional harm?

Hoffman: Yes.

Zeff: Would you agree that clergy may never keep sexual assault of a child a secret to protect the congregation?

Hoffman: Yes

Zeff: You don’t have any training in interviewing children who are victims of sexual abuse, do you?

Hoffman: No.

As our readers may recall from a prior article on this case, Watchtower representative Thomas Jefferson had testified for 2 consecutive days that Jehovah’s Witness elders are not clergymen, with the implication that the laws which apply to members of the clergy do not apply to Witness elders. Mr. Hoffman upheld that statement. Zeff began a new line of questions related to elders’ strict requirement to follow the direction of their corporate headquarters, or face consequences:

Zeff: You received the letters from the Watchtower, don’t you?

Hoffman: That’s on their letterhead, correct.

Zeff: And you rely on those letters of instruction from the Watchtower to perform your
duties as an elder, don’t you?

Hoffman: We do.

Zeff: Okay. If you don’t follow the letters of instruction the Watchtower may remove you as an elder; isn’t that true?

Hoffman: They could, yes.

Zeff: And the Watchtower directs the activity of elders, doesn’t it?

Hoffman: We receive direction from them, correct.

Zeff: You don’t receive direction from anyone else, do you?

Hoffman: No.

Establishing that elder Hoffman took his marching orders directly from Watchtower headquarters, Zeff then asked a critical question which revealed that Hoffman was well aware of the allegation of child abuse:

Zeff: In the fall of 2005, you knew that there was suspected child abuse involving Stephanie Fessler, didn’t you?

Hoffman: In the fall of 2005?

Zeff: Yes

Hoffman: Yes.

Zeff: Okay. And you, along with Neal Cluck, who was another elder, learned of this and a committee was formed, wasn’t it?

Hoffman: I believe, yes, it was.

Zeff: Okay. And you don’t really remember anything specific that Stephanie’s father or mother told you, do you?

Hoffman: That’s correct.

Zeff: Okay. During the first meeting — you had two meetings, didn’t you?

Hoffman: Yes.

Zeff: Okay. So, you don’t really remember when the first meeting was?

Hoffman: According to my notes, the first meeting was towards the end of September in 2005.

Zeff: Okay. Well, what note are you talking about, Sir?

Hoffman: We had a few notes written down.

Zeff: Let’s look at those notes.

At this point, attorney Zeff called for the notes of Eric Hoffman to be projected on screen for the jury. As stated by the defense in opening arguments, Watchtower had hoped their elders would testify that they had no real knowledge of any physical or sexual relationship between Fessler and Seipp [Monheim] in 2004, and did not learn of the relationship until 2005.

Zeff: And are you aware that Stephanie Fessler and Terry Seipp are anticipated to both testify that they were reproved and disciplined in 2004?

Hoffman: No, I did not.

Zeff: Okay. So, when you say you have two meetings, are you sure that your first meeting took place in 2004 — 2005 rather than 2004?

Hoffman: Correct.

Zeff presses Hoffman harder:

Zeff: Are you aware that Jodee Fessler has testified or will testify in this case that the
first meeting occurred in 2004?

Hoffman: May have, but I have no notes and I have no recollection of any meeting in 2004.

Hoffman begins to weaken, his memory suddenly becomes fuzzy:

Zeff: So, it’s possible that happened, she might be right?

Hoffman: Could be, but I do not remember anything about it.

Zeff: Okay. And the second meeting, the meeting that took place in 2005, you have notes from that one?

Hoffman: Correct.

Zeff: So, if Stephanie Fessler, Jodee Fessler and Terry Seipp all testified that they were
involved with judicial committees in 2004, you wouldn’t have any reason to doubt them, would you?

Hoffman: Yes, because there’s no notes from a judicial committee in 2004.

Zeff: Well, aren’t you told to destroy any unnecessary notes?

Hoffman: The only notes I have are what’s there.

Hoffman, clearly rattled by the barrage of questions, is unable to recall Watchtower’s policy related to what they can and can’t destroy – so Zeff focuses on the one thing that becomes crystal clear to the jury – Hoffman knew that Stephanie was being abused:

Zeff: So, in 2005, at least, you were told that a 16-year-old girl was making out with a 50-year-old woman?

Hoffman: Correct

Zeff: Okay. You were suspicious, at that point, that this might be child abuse, weren’t you?

Hoffman: We were suspicious that something was going on that shouldn’t be.

While Hoffman attempted to evade the admission that this was a sexual relationship, Zeff put it to him in a slightly different way:

Zeff: It was explained that they were kissing romantically?

Hoffman: Right.

Zeff: Like a boyfriend and girlfriend might, right?

Hoffman: Um-hum.

Zeff: Like a husband and wife might?

Hoffman: Right.

Zeff: And you didn’t find that to be suspicious of child abuse?

Hoffman: Well, that’s why we formed the committee then.

Zeff: Okay. So, you formed the committee because you were suspicious?

Hoffman: Because we were suspicious.

The testimony of Hoffman flowed like a math problem where so many different equations all pointed to the same undisputed answer. But there were more parties involved, and attorney Zeff brought them into the equation:

Zeff: When you formed the committee, did you contact the Watchtower about it?

Hoffman: We contacted the legal department.

Zeff: Okay. Well, that’s after you learned whatever you learned. But in forming the committee, did you seek any guidance from anyone regarding what you should do and how you should ask questions?

Hoffman: No.

Attorney Zeff next questions inconsistencies in Hoffman’s previous testimony when he was deposed prior to trial, but when Hoffman fails to provide a concise recollection of his deposition, Zeff finally tells the court: “I’ll move on, Your Honor.” Instead of quietly accepting this statement, the attorney for Spring Grove Congregation, Jud Arron makes the mistake of joking with the court:

Aaron: No objection.

Judge Mary C. Collins: No. Enough! I don’t want any snide, unnecessary irrelevant comments from any lawyers participating in this trial.

Jud Aaron, embarrassed and red-faced, apologizes to the judge and the court.

Zeff gets Hoffman to admit that he had consulted the elders’ letters and the elders’ manual when handling the Fessler case, then says:

Zeff: In addition to the kissing and making out, Stephanie Fessler told you that there was some improper hugging, didn’t she?

Hoffman: Yes:

Zeff: And touching of the breasts?

Hoffman: Yes.

Zeff follows these questions by asking Hoffman to read his notes from the 2005 Spring Grove judicial meeting, where among other details, Hoffman wrote:

“It was later learned during the meeting that there was touching of the breasts on more than one occasion..”

Zeff: Did you have a concern that there was a 50-year-old woman in another congregation that was making out and touching the breasts of a 16-year-old?

Hoffman: We did.

Zeff: Okay. Did you warn anybody about that?

Hoffman: Just talked to Stephanie.

Zeff: Okay. You didn’t tell the other congregation that Stephanie said that her breasts were touched and that she was making out with a 50-year-old woman?

Hoffman: I believe we had conversation with them just to make sure the stories were the same.

Zeff: Did you let the Watchtower know?

Hoffman: Yes. We called the legal department.

Tensions escalated as testimony from Hoffman had just clearly shown that elders in two congregations were aware of the abuse, that the relationship was undisputed, and that Watchtower was a party to this knowledge. It was further revealed that while all of this was going on, Terry Seipp [Monheim’s] husband Dana had hired a private investigator to follow Terry, suspecting what his wife was doing.

Suddenly, in a desperate move, Watchtower attorney John Miller cuts in and calls for a sidebar with the judge:

Miller: I’m sorry, Your Honor. You already ruled. I was too late to ask, but
unless this is breaching the attorney/client privilege, that’s the format you followed, the
instruction you got from the legal department. That’s asking for the legal advice given.

Zeff: Judge, it’s been waived. It was asked in deposition and answered. These
questions were asked. They were answered in deposition. You can’t turn around after not asserting the privilege and turn around and assert the privilege at trial, when it’s already been waived. There is plenty case law on that.

Miller: We didn’t raise it there?

Zeff: Nope. It wasn’t raised at all. I can show you the pages, 19, 20, 21, 23 of the
deposition.

Miller: I’ll trust you if you’re —

Zeff: Here they are — where are the numbers on the pages?

Miller: So, we missed it on him great. Well, then, I’m wasting your time.

Judge Collins: All right. Let’s go back.

Fessler’s attorney Zeff left no stone unturned, as he pressed Hoffman even harder:

Zeff: The reason you contacted the legal department was regarding trying to find out what your obligations were regarding reporting sexual abuse. Isn’t that correct?

Hoffman: Yes.

Zeff: And after you spoke to the legal department, you didn’t report sexual abuse to any
authority in Pennsylvania, did you?

Hoffman: We did not report to the police, no.

Zeff: You never received any instruction that there was any legal authority in Pennsylvania to report suspected child abuse, did you?

Hoffman: No.

Zeff: And you didn’t tell Stephanie Fessler’s parents that they could go to the police either, did you?

Hoffman: We may not have, no.

Zeff: Okay. You didn’t. Thank you. I have nothing further.

Zeff, satisfied that he had extracted enough truth from Hoffman to make his case, yielded the floor to Spring Grove’s hired trial attorney Jud Aaron. Aaron proceeds to discuss Hoffman’s prior deposition in which Thomas Jefferson was mentioned – with little effect – then asks Hoffman about his position as elder, and gets Hoffman to describe the humble simplicity of a typical Kingdom Hall.

In Aaron’s examination of Hoffman, it was interesting that he mentioned that Stephanie’s parents came to him in 2005 seeking help in his position as an ordained elder of Jehovah’s Witnesses. At this point in the trial, this is of consequence since Hoffman and Watchtower were still claiming on the 2nd day of trial that elders were not members of the clergy. It seems he was reasoning that if Hoffman were not a clergyman, then he would have no obligation to report the relationship to the police.

Aaron: Were they [the Fesslers] coming to you as an elder?

Hoffman: Yes.

Aaron: Okay. Did they tell you that Stephanie Fessler and Terry Seipp were having some sort of a relationship?

Hoffman: That’s the way I remember it, some sort of a relationship, correct.

Aaron: And what were you expected to do? What did you do as an elder?

Hoffman: First time we met with Stephanie just to determine what was going on, to give her some biblical help, some counsel to, hopefully, help her change her ways, to find out what was going on.

Aaron: What do you mean “biblical help,” generally?

Hoffman: I’m just showing her some scriptures, some verses on the type of conduct she was leading, that it was going against biblical principles and how to help to — how to go against that.

Jud Aaron next gets Hoffman to testify that in 2005, the Fesslers never told him that there was a sexual relationship between Stephanie and Terry. This was clearly a conflict given that it would be somewhat unusual for Witness parents to seek help from elders if the relationship was a routine mother-daughter type relationship. Aaron attempts to prove that Hoffman knew nothing until he personally confronted Stephanie in 2005.

Aaron: You said that you met with Stephanie in the fall of 2005?

Hoffman: Yes.

Aaron: Okay. Did you try to determine what the nature of the relationship was?

Hoffman: Yes, we did.

Aaron: Did you try to determine whether or not it was sexual?

Hoffman: Yes, we did.

Aaron: And in the course of meeting with Miss Fessler in the fall of 2005, did you learn that there had been some sexual contact between them?

Hoffman: Yes, we did.

Of interest, Aaron questions Hoffman on whether he had asked the victim if she had been naked with Monheim, or had participated in oral sex. Incredibly, Hoffman states that he had no information from Fessler that there had been any touching of the genitals, or that the two had been naked together, despite having just testified that he knew there was an ongoing sexual relationship.

Aaron returns once again to his 2014 argument, this time asking a hypothetical question:

Aaron: If, a year earlier, 2004 — I’m asking about your practice now — a year earlier in 2004, a 15-year-old female congregant had told you that she and a 49 or 50-year-old woman were involved in a relationship that involved intimate kissing, open-mouth kissing, french kissing, romantic kissing, whatever you want to call it, would you
have called the legal department for advice?

Hoffman: Yes, we would have.

Aaron: Okay. Do you have any recollection of doing so a year earlier, in the fall of 2004?

Hoffman: No.

Aaron: Well, let me ask you about yourself. Did you ever tell Mr. and Mrs. Fessler that they should not report this relationship to authorities?

Hoffman: No.

Aaron decides to conclude his questioning of the witness, and yields the floor. John Miller from Watchtower has no questions for Mr. Hoffman, and redirect returns to the plaintiff, and Mr. Zeff.

Zeff: Did you have a specific memory, sitting here today — what is it, ten, eleven,
eleven-and-a-half years later of asking Stephanie Fessler whether or not she had oral sex?

Hoffman: Well, according to my notes, we asked her if there was anything else involved and she said no.

Zeff: Okay. So, you asked her if there was anything else involved?

Hoffman: Right.

Zeff: You didn’t ask her if she had oral sex. You didn’t ask her if she was naked?

Hoffman: We may not have, no.

Zeff: And do you consider making out and touching breasts to be a sexual act?

Hoffman: Yes.

Zeff: And when you went to the legal department, you really weren’t sure what to do with this situation, were you?

Hoffman: That’s correct.

Zeff: And you relied on the legal department?

Hoffman: Yes, we did.

Zeff: And the legal department is part of the Watchtower?

Hoffman: Yes.

Zeff: Okay. If the legal department told you to report the matter, would you have done so?

Hoffman: Yes, we would have.

Zeff completes his examination by asking Hoffman to explain Stephanie Fessler’s public reproof by the congregation elders, then turns the witness over one last time to the defense. This time, Watchtower attorney Miller decides to ask Mr. Hoffman a question:

Miller: Mr. Hoffman, just briefly. You said that the legal department was part of the Watchtower. Do you know whether it was part of the Watchtower or the U.S. Branch or some other entity? Do you know?

Hoffman: We just get the information on the letterhead. I am not sure what department it’s with, what branch it’s with. It’s with the United States Branch.

Miller: Okay. That’s all. Thank you.

By the end of Hoffman’s testimony, he had admitted on the witness stand that a member of the clergy should report allegations of child sexual abuse, but he denied being a member of the clergy. He further admitted that his instructions came directly from the Watchtower, but seemed confused as to the difference between Watchtower and the US Branch. Hoffman acknowledged that he was well aware of a sexual relationship between Fessler and Monheim no later than 2005, but lost all recollection of the 2004 meeting with Fessler, in which she was privately reproved. Finally, Hoffman admitted that he failed to contact any authorities, and did not advise Fessler’s parents to contact these authorities. He yielded his decision-making power to the Watchtower legal department, testifying that if they had told him to go to the police, he would have. This never happened.

Elder #2: Donald Hollingworth

On the other side of the Mason-Dixon line lies the Freeland, Maryland congregation of Jehovah’s Witnesses. This small, tight-knit congregation in rural Baltimore County has little money, and a simple Kingdom Hall. I recall donating and installing sound equipment at this location after congregation member Terry Monheim had abused Stephanie Fessler, but three years before her arrest. I was unaware that a predator lurked nearby.

Little did I know that in a few short years, I would sit inside a Philadelphia courtroom, observing legal powerhouse Jud Aaron attempt to defend the outrageous actions of elders Gary Neal, Scott Wagner, and Donald Hollingworth. In a thousand years, they could not summon the money to pay for his services, but there he was.

Donald Hollingworth is now elderly, wears a hearing aid, and lives in Toms River, New Jersey. A loyal Jehovah’s Witness for over 50 years, Hollingworth has been an elder for 40 of those years. But for all his loyalty to the Jehovah’s Witness religion, Donald and his fellow elders made a critical error in 2004 and 2005 which cost their parent corporation, Watchtower, a significant amount of money. It also damaged the reputation of Jehovah’s Witnesses, who are under intense global scrutiny for their mishandling of child abuse cases, and for their practice of shunning, and denying members the right to certain life-saving medical treatments.

Attorney for Stephanie Fessler, Gregg Zeff, began the questioning of Hollingworth with the same query he put to Eric Hoffman:

Zeff: I’d like to know would you agree that clergy must report sexual abuse in children to protect the victim from additional harm?

Hollingworth: Do I agree with that?

Zeff: Yes.

Hollingworth: Yes.

Zeff: And do you agree that clergy may never keep sexual abuse of a child the secret to protect the congregation?

Hollingworth: Oh, yes, yes.

Zeff: Thank you.

After confirming that Hollingworth has no professional training in the investigation of sexual abuse matters, Zeff gets specific:

Zeff: Okay. Did you have any understanding in 2004 or 2005 of your obligations regarding reporting suspected child abuse in Pennsylvania or in Maryland?

Hollingworth: Yes.

Zeff: What was your understanding back then?

Hollingworth: For — that there was no duty to report it as far as from a procedural standpoint. That doesn’t mean I don’t feel a duty, but there was no legal duty to report it.

Zeff: Sir, you received that understanding from the legal department?

Hollingworth: That’s correct.

Zeff: Okay, and the legal department of what?

Hollingworth: Jehovah’s Witnesses.

At this point, it is noteworthy that Hollingworth had testified that members of clergy must report sexual abuse allegations to the authorities and not keep them secret, but moments later stated that according to Watchtower’s legal department, he had no legal duty to report, despite his own feeling of duty to report. Hollingworth hid beneath the double cloak of justification – the notion that he was not a member of clergy, and the counsel from his own organization that he had no obligation to report.

It seems unthinkable that any Witness elder could make the statement that church leaders from other religions have an obligation to report, but Jehovah’s Witnesses are somehow exempt. Witnesses teach that all religions are “false” religions, except theirs. It must have baffled members of the jury to reconcile how an organization that claims to abhor child abuse could be so delinquent in helping victims.

Zeff continued his questioning of Hollingworth, describing the letters from Watchtower to the elders. Hollingworth seemed confused when Zeff stated that prior to 2001, these letters came from the Watchtower corporation. Hollingworth said “I’m not sure of that…Right now I wasn’t prepared for that question, sir.”

When pressed about the relationship between Monheim and Fessler, Zeff asked:

Zeff: You never found out the age of the girl she was kissing, did you?

Hollingworth: I knew she was a teenager, and the approximate age of this other lady’s children, because she associated with them. I knew she wasn’t 19. I knew she wasn’t 13, but somewhere in between.

Zeff: And when you learned of this, a committee was formed, wasn’t it, a judicial committee?

Hollingworth: Yes.

Zeff: Okay. You were the chairman of that committee?

Hollingworth: It wasn’t me. It was either one of the other two brothers. I can’t tell you for a certainty today.

Zeff: Okay.

Hollingworth: I believe it was Gary Neal, but that’s not for a certainty.

Zeff: And one of the primary functions of your committee was to determine whether or not you had an obligation to legal authorities relating to this matter.

Hollingworth: An obligation to do what?

Zeff: To report to legal authorities in this matter.

Hollingworth: I don’t know if I had that — I don’t know if that — I went in to find out what was going on, and so I didn’t start thinking about a lot of other things I’d have to do until I could find out what was going on.

Zeff: But you did consult with the legal department?

Hollingworth: Yes, I did.

Zeff: And you were told you didn’t have any duty under Maryland law, correct?

Hollingworth: I didn’t have any duty to report; is that what you asked me?

Zeff: Yes. You had no duty to report?

Hollingworth: No legal duty.

Zeff: Right.

Hollingworth: There was no law that said I had to report.

Zeff: And, in fact, you didn’t report anything, did you?

Hollingworth: No, I didn’t.

Zeff: And neither did any member of your committee, to your knowledge?

Hollingworth: To my knowledge.

Hollingworth Admits to Shredding Notes

The examination by Zeff then took an interesting turn. Zeff calls for the presentation of Hollingworth’s notes, taken in 2005 when meeting with the abuser, Terry Seipp:

Zeff: Why did you take these notes?

Hollingworth: Because I don’t have a very good memory over the years, business and meetings that I go to, and so I take notes in case there’s a reason to recall, in case there’s a discussion later, in case there’s another meeting. I always take notes. It’s my habit as a businessman, I always took notes.

Zeff: And with regard to being an elder, you had a practice of making notes and tearing them up and shredding them on occasion, didn’t you?

Hollingworth: Yeah, shredding is in a — yeah, I had a shredder, but I don’t know. I — yeah, I didn’t keep them. I didn’t keep them. I didn’t want them laying around or anything.

Zeff: That was something that the letters to elders suggest that you do or instructed you to do, in fact, don’t leave notes around, destroy them if they’re not necessary?

Hollingworth: Well, that’s possible. I always, even be — I, if a confidential nature, I would have enough sense not to leave them laying around.

Hollingworth revealed a critical detail that the Watchtower organization does not want the public to know – that elders often discard, shred, move, hide, and destroy notes, not only in cases where lesser offenses are concerned, but even when accusations of child abuse are on the record, contrary to their official policy.

Hollingworth Invokes Clergy Privilege – He Learned it on Television

Attorney Zeff continued to gain momentum as he called attention to his next exhibit: the notes taken by Donald Hollingworth during the Jehovah’s Witness judicial hearing for Terry Monheim. Zeff displayed the notes for the jury:

Hollingworth: (reading his notes) It says: “After assurance the committee members would not testify in a legal case, she was relieved and more forthcoming.”

Zeff: So, did you tell Terry Seipp that no member of the committee was going to testify against her?

Hollingworth: Well, I think you know — you’re thinking of something different than I’m thinking of. The legal case we’re talking about and she was worried about her husband divorcing her or thinking she would — and we were telling her that anything that she told us, we wouldn’t use in her divorce case against her husband, or vice versa. And we had thought we had a right to do that.

Zeff: Did you learn that from the legal department?

Hollingworth: Pardon?

Zeff: Did you learn that from the legal department?

Hollingworth: No. I learned that from watching television, I guess…

Zeff: You learned from watching television that if she tells you something in your committee that you don’t have to testify in a divorce proceeding?

Hollingworth: Well, not as member of the clergy, I would think it would become — well, you know, maybe I’m wrong but I would think it would be confidential.

At this point, Hollingworth is trapped- painting himself into a very tiny corner with no way out, without making a mess. In 2005, he interviewed a sexual predator, but instead of contacting the authorities, he assured Terry Monheim that her admissions to the elders would not be used against her in any divorce proceedings. Somehow he invoked clergy privilege while denying that he is a member of clergy. Furthermore, he is completely unaware that clergy privilege does not exist when a sizable group of elders and additional individuals have been made aware of Monheim’s crimes.

To be blunt, Hollingworth appeared extraordinarily ignorant. What is more bizarre is that he claims Watchtower’s legal department advised him that he had no duty to report such allegations, or confessions of sexual abuse. Maryland law at the time mandated the reporting of child abuse, but the exemptions for members of clergy were somewhat vague, which likely prompted Watchtower’s legal department to suggest that he had no obligation to report the abuse. In most states, child abuse exemptions become null and void once clergymen broadcast the private confessions to other members of the elder body, along with the additional individuals, i.e. the legal and service departments of the Jehovah’s Witness organization.

The questioning continued as attorney Zeff called attention to Hollingworth’s notes from his phone call to Watchtower’s legal department

Zeff: What are they about?

Hollingworth: That was my notes about when I had — I called, contacted the legal department to discuss the matter with them and I wrote down some notes with regard to that call.

Zeff: Okay. Did you ever contact or did anybody on your committee ever contact the Spring Grove congregation where Stephanie Fessler was a member?

Hollingworth: No.

Zeff: Did anybody on your committee contact them to let —

Hollingworth: Yes

Zeff: Okay. And they let them know there was an investigation into a possible sexual abuse?

Hollingworth: You’d have to ask them what they let them know.

Zeff: Okay. I want to go to the section toward the bottom where it says “want us to review society’s letters with all seven elders.” Do you see that?

Hollingworth: Yes, I do.

Zeff: What do you mean by that?

Hollingworth: What it says, review the letters –with the whole body of elders, all of
the elders in the congregation.

Zeff: It says “with all seven elders,” is that everybody?

Hollingworth: What does it say?

Zeff: It says “Want us to review society’s letters with all seven elders.”

Hollingworth: Yes, that would be our elder body at the time.

Zeff: Okay. And that has to do with your investigation into Terry Seipp?

Hollingworth: Well, it’s in — my telephone call was an investigation that had to deal with that, yes. And what exactly they told me to read those letters for, I don’t remember.

Zeff: Who told you to read those letters?

Hollingworth: Whoever I was talking to at the legal department. And I am assuming that because, that’s the notes of that. I don’t know for a fact today who told me to do it, but I’m assuming that’s what it would be. And I shouldn’t be making assumptions, should I?

Zeff states that he has copies of those letters, and tells Hollingworth that he will now review them, beginning with the July 1, 1989 letter to the body of elders. Hollingworth admits that he likely would have reviewed this letter at that time, acknowledging that it was a very important document to review.

Another revelation came when Zeff references the January 1, 1997 Watchtower article titled “Let us abhor what is wicked.” Under the topic “What of a Child Molester?” the Watchtower stated:

If, for example, an individual makes immoral advances to another adult, the adult should be able to resist his or her advances. Children are much easier to deceive, confuse, or terrorize. The Bible speaks of a child’s lack of wisdom. (Proverbs 22:15; 1 Corinthians 13:11) Jesus used children as an example of humble innocence. (Matthew 18:4; Luke 18:16, 17) The innocence of a child includes a complete lack of experience. Most children are open, eager to please, and thus vulnerable to abuse by a scheming adult whom they know and trust. Therefore, the congregation has a responsibility before Jehovah to protect its children.

Zeff questions Hollingworth:

Zeff: Okay. Do you remember reviewing this? And I’ll read it to you so you
understand it. Do you remember reviewing this at the time of the judicial committee? It says “Children are much easier to deceive, confuse or terrorize.”

Hollingworth: I don’t remember at the time of the committee but, sir, I mentioned before, I had a lot of children and I’m very conscious of this need.

Zeff: Okay. And had the legal department told you to, you would have called the police, called child services?

Hollingworth: I don’t need to be told.

Zeff: Okay.

Hollingworth: I — I don’t mean to be fresh or anything but, no, I told you, I — abhor is a word that’s worse than hatred and I don’t like this thing and I don’t like being involved in it even now, to come being asked about it.

Zeff: Right. You don’t really need to be told to call the police, do you? You could have done it anyway?

Hollingworth: Would I what?

Zeff: You could have called the police even if the legal department told you not to?

Hollingworth: Yes. In hindsight, yes.

Zeff: But you didn’t?

Hollingworth: Pardon?

Zeff: You did not?

Hollingworth: It’s already been answered.

Zeff: Okay. You didn’t talk to Stephanie Fessler’s congregation about her version of the
story, did you?

Hollingworth: I said no, I didn’t talk to anybody.

Zeff questioned whether the Maryland congregation had any meaningful discussions with the Spring Grove Pennsylvania congregation regarding the welfare of Stephanie Fessler:

Zeff: One more time, Sir. You had concerns about the welfare of the teenaged girl that was involved with Terry Seipp? You were concerned about her?

Hollingworth: Yeah, I have concerns with all young people, absolute — yes. Would I say no? Of course, I would be an ogre to say no to that.

Zeff: And but you wanted to follow the legal department’s advise rather than doing anything else; isn’t that correct?

Hollingworth: You know, I wasn’t dealing with a teenage girl. We were dealing with Terry Seipp at our congregation. Please, there was — another congregation was dealing with the teenage girl. It doesn’t mean — my feelings in the matter and my thoughts in the matter don’t apply to what would have been — how it would have been handled. So, you’re confusing me and you’re confusing the issue.

It seems that the invisible boundary between Maryland and Pennsylvania, along with Hollingworth’s instructions from the Watchtower legal department overruled his better judgment, permitting him to ignore the fact that a crime had taken place, and that he was obligated to report this crime. Hollingworth admitted that he was also aware that Terry Seipp [Monheim’s] husband Dana had learned of the relationship, and hired a private investigator to confirm his suspicions. Mr. Seipp wasted no time in sharing this information with the Freeland elders:

Zeff: You had a suspicion that she might be abusing a child?

Hollingworth: I wanted to know the facts.

Zeff: Okay. Well —

Hollingworth: Her husband wouldn’t say, and he was not a member of our congregation. I only knew him once to say hello to him. He comes up and says “I’ve got pictures, but I won’t tell you what they’re about, but you’d better do something about it,” that kind of — what are we supposed to do?

Zeff: Call the police?

Despite a sustained objection from defense attorney Jud Aaron, Zeff had landed a knockout punch with this last question, which lingered in the courtroom while Mr. Aaron made his way to the lectern to cross-examine Mr. Hollingworth.

In what seemed to be a desperate move, Aaron rested his argument of the claim that elders are, in double-negative fashion, not told not to report:

Aaron: Are you aware of any Jehovah’s Witness policy not to report child sexual abuse to authorities? Are you aware of any such policy?

Hollingworth: No.

Aaron: In any of the letters to elders that you read or KS schools that you’ve attended — have you attended those schools?

Hollingworth: Yes, Sir.

Aaron: In any of those letters in those KS schools, have you ever been instructed or directed not to report sexual abuse to authorities?

Hollingworth: No way. No way.

Aaron: What have you been instructed to do if a report of sexual abuse comes to your attention?

Hollingworth: Contact the legal department.

Aaron never once asks Hollingworth if elders are instructed to report any allegations of suspected child abuse; instead he diverts attention from that critical question – first by allowing Hollingworth to testify that he is a family man, with many children and grandchildren. Aaron questions Hollingworth on what he recalls Terry Seipp admitting during the elder’s judicial hearing with Seipp, then goes back to the procedure these men followed after that hearing:

Aaron: After the judicial committee met with Terry Seipp, you reported to legal?

Hollingworth: Yes.

Aaron: Did you feel that you were following the correct procedure and doing that?

Hollingworth: Yes.

After referring to the March 23, 1992 Letter to Elders regarding child abuse, Aaron calls attention to page 3 of that letter where further abuse of children can be prevented by contacting the legal department of the Watchtower organization.

He then links “further protection” to Hollingworth’s earlier statement that elders are not told not to report abuse:

Aaron: Have you ever been advised as an elder or are you aware of any direction that, in order to protect the Jehovah’s Witness religion, child abuse should not be reported to authorities?

Hollingworth: To the contrary. The reason I’m a Jehovah’s Witness today — I wasn’t always one — was because of their concern for the truthfulness and taking care of people and taking — the whole thing, it just made so much sense. No, that would
never happen.

Aaron: Thank you.

Aaron rests his line of questioning and yields the floor to his fellow defense team members. Watchtower’s Miller has no questions, and CCJW attorney Louis Lombardi continues his legal vow of silence by offering nothing. The plaintiff is offered redirect.

Victims Discouraged from Group Therapy

Attorney Zeff directs attention back to the March 23rd Letter to Elders, this time to the section where Jehovah’s Witnesses are cautioned against participation in group therapy as a means to help victims of child abuse.

Zeff: Sir, can I direct your attention to the very last paragraph of the page that we just put in front of you where it says “Some medical professionals,” and it goes onto the next page. I just wanted to ask you some questions about that, because you just said some
things that, I guess, were a little disturbing to me. “Some medical professionals and therapists offer group therapy to those suffering from the effects of child abuse. While participating in group therapy by a professional therapist is a personal decision, there could be problems of revealing confidential facts about other members of the Christian Congregation during such therapy if a Christian does not exercise discretion. Thus,
elders can give cautions to their brothers and sisters, just as outlined in October 15, 2008 issue of Watchtower, page 29, under the subheading Talking Therapy. “They can be helped to see that talking indiscriminately to others about child abuse may result in circulating damaging and harmful talk.” Sir, what do you understand that to mean?

Hollingworth: I may be missing some details here, but my — I’m focusing on the last sentence here. We don’t go talking about it and gossiping about it and –It’s not something to be broadcasting.

Zeff: Sir, my question is talking about child abuse may result in circulating damaging and harmful talk, so they don’t — isn’t this telling you — by the way, this is one of the documents you had that were referred to? What do you understand – they can be helped to see that talking indiscriminately to others about child abuse may result in circulating damaging and harmful talk? What do you understand that to mean?

Hollingworth: To be careful and think about it. Think before you speak. It makes sense to me.

Hollingworth dodges the question, reflecting his inability to comment on Watchtower’s position on group therapy, so Zeff moves on. Zeff next asks Hollingworth to explain “KS” schools, and Hollingworth describes the elder’s training program. Zeff then asks:

Zeff: On the occasions is the issue of child abuse brought up at those schools?

Hollingworth: I’m sure it has.

Zeff: And these schools are conducted by the Watchtower?

Hollingworth: They’re conducted by a Jehovah’s Witness. I’m not sure why — they’re conducted by a Jehovah’s Witness instructor.

Zeff: Okay. And where does that instructor come from?

Hollingworth: They come from a lot of different places. Sometimes it’s our circuit overseer who comes from — we have apartments for them in the local Kingdom Halls. Different instructors, different times over the years, there’s been — they come from a lot of different places.

Zeff: Do the documents that you review in these schools come from the Watchtower?

Hollingworth: I don’t know. I don’t know that the Watchtower sends out documents. They give us literature. They give us some literature. We get — they take care of our printing of our literature. I don’t know. I just can’t answer that question. You would have to ask somebody that comes from there. Would it be all right if I have some
more water?

Zeff: I have nothing else, Your Honor.

In response to Hollingworth’s testimony, Watchtower attorney Miller cross-examined the witness to clarify just one thing: while warned against the dangers of group therapy, Jehovah’s Witness abuse survivors are not excluded from individual therapy. It seemed somewhat inconsequential to mention this, but Miller appeared intent on making the jury aware that Witnesses do accept some types of professional therapy.

Of course, Miller overlooks the fact that much of Stephanie Fessler’s extreme trauma was, in the first place, caused by the elders and the organization which treated her as a sinner and not a victim.

The tired and thirsty Hollingworth seemed confused and unwilling to give concise and lucid answers to questions that were quite simple – particularly for a man who has spent the past 40 years of his life as an appointed elder. To be fair, Watchtower’s key witness Thomas Jefferson was even more evasive, as seen from his testimony during the first two days of this trial.

As anyone who has studied Jehovah’s Witnesses understands all too well, leaders in the organization are less than willing to divulge information to anyone they feel is “not entitled to know” such information. How ironic for a religion that describes all of its teachings and practices as “The Truth.”

For readers of this site, whether they are Jehovah’s Witnesses or not, I can’t underestimate the value of this term, truth. At the outset of this trial, Judge Mary C. Collins told the jury that they are the sole determiners of truth in this case, and it was up to them to decide on which information is factual, based on the evidence presented.

While this case was settled after four days of testimony, we have, as global citizens, been given the opportunity to judge the evidence for ourselves, and draw our own conclusions. Thus far, we have covered the statements of three Jehovah’s witnesses, including two elders and one high-ranking member of the organization. In our next article on the Fessler case, I will review the testimony of the abuser, Terry Monheim, and the detective who charged her for her crimes, Lisa Layden.

Having seen the evidence presented in this case, I think back to that hot summer morning in Reading Pennsylvania, when I saw the man with the sign which read “A Jehovah’s Witness elder molested me” – and if there was ever a doubt that he was telling the truth, that doubt no longer exists.

Posted on July 28, 2022July 28, 2022 by Mark O'Donnell — Leave a comment

2017: Fessler Prevails in Jehovah’s Witness Child Abuse Trial, Elder Admits Shredding Files – Part 1

Published February 19th, 2017

Trial Summary – Part One

“The matter with the Jehovah’s Witnesses has been resolved”

-Jeffrey Fritz, attorney for abuse victim Stephanie Fessler.

Using language echoing the public announcements that Stephanie Fessler, now 28, was subjected to as a teenager, Fessler and her legal team have effectively turned the tables on Watchtower and issued a “public reproof” to Jehovah’s Witnesses. Witnesses notoriously reprove and disfellowship members of their faith, even if that member is a child, and has experienced a sexual encounter. Following four days of intense testimony at City Hall in Philadelphia Pennsylvania, Watchtower’s defense strategies collapsed. Despite spending tens of thousands of dollars and nearly 3 years in preparation for this case, by noon on Monday February 13th, Watchtower yielded to the plaintiff, packed up their briefcases, and agreed to an undisclosed settlement.

A strong message has been sent to the Watchtower organization: You can’t break the law when you learn of an accusation of inappropriate behavior with a minor. It must be reported to the police and child protection authorities.

Jehovah’s Witness leadership dismiss nearly every opportunity to report suspected abuse. Witness clergy mandate that when “wrongdoing” is discovered, they must immediately convene an internal tribunal of several elders, who are briefed on what happened. If the “sin” is serious, they form a Judicial Committee of three elders, then bring the victim before this committee to answer for her involvement. In this case, trial evidence showed that Jehovah’s Witness elders in the Spring Grove PA congregation were aware of a “consensual” relationship between 49-51 year old Terry Seipp, who attended the Freeland Maryland Congregation, and the victim, Stephanie Fessler. For 3 years Seipp played the role of surrogate mother to Fessler, all the while taking sexual advantage of Stephanie, a matter brazenly overlooked by both congregations.

Or did they overlook it? In 2004, elders were informed that there was inappropriate kissing and touching between Seipp and Fessler, yet they failed to report this under the Pennsylvania mandatory reporting laws which apply to all clergy, or elders who learn of suspected abuse. By 2005, elders had significant evidence of extensive sexual encounters between the victim and her abuser, yet continued to apply their own internal measures – a decision which forever damaged Stephanie Fessler, preventing her abuser from facing justice and ending the relationship.

Detective Lisa Layden of the Southwestern Regional Police department in York County PA testified that any physical contact which might rise to the level of sexual abuse must be reported to the authorities, including Pennsylvania’s Childline, a well-organized resource for victims and potential victims. But that is not how Jehovah’s Witnesses operate. All matters of “sin” are referred to the congregation elders, who then contact the legal department at Watchtower’s Patterson New York complex if a case of sexual abuse comes to light.

Watchtower claims to inform congregation elders of individual state child abuse reporting laws, but seldom if ever do elders contact the police and file a report. To say that elders rarely reports such matters is a significant understatement.

Thomas Jefferson Beffudles Jury

On the afternoon of February 7th, 2017, plaintiff co-counsel Gregg Zeff called the first witness, Mr. Thomas Jefferson Jr. This was a significant moment in the first day of trial, only the second time in Watchtower’s history that its organization has faced a jury in a child abuse trial.

And it did not go well.

From the moment Thomas Jefferson took the stand on behalf of Watchtower and the Christian Congregation of Jehovah’s Witnesses (CCJW), there was an air of bedlam, confusion, and frustration. The jury of seven women and three men sat facing Jefferson in disbelief, as he struggled to answer questions – and the ones he did answer left the entire courtroom scratching their heads. Jefferson replied to questions from plaintiff’s attorneys with a defensively arrogant stance, speaking in a slow and deliberate manner, repetitively ending his answers with the word “counselor.” Attorney Gregg Zeff pounded Jefferson with question after question in an attempt to clarify the tangled web of corporations and committees which manage the affairs of Jehovah’s Witnesses.

Jefferson admitted that he was a member of the CCJW, the US Branch Committee, and the Worldwide Order of Special Full-Time Servants of Jehovah’s Witnesses, but denied any involvement in the Watchtower Bible and Tract Society of New York. When asked for the name of the president of Watchtower New York, he told the court “I don’t recall” despite admitting he was sent to represent CCJW and Watchtower. Jefferson spoke in circles and riddles when asked about leadership of the JW organization, refusing to answer the simple question “Who is in charge?” The day one exchange with Jefferson was so outrageous, Judge Mary C. Collins was seen restraining both anger and laughter at the same time. Mr. Zeff, in a moment of exasperation raised his voice to Jefferson and asked whether there were “human beings” in charge of this organization.

Jefferson replied:- “Are you serious?”

The questioning intensified when Mr. Zeff pressed Jefferson on the source of all of the letters sent to bodies of elders, asking him again whether any “human beings” actually wrote these letters, and if so-who are these persons. Jefferson once again dodged the question and stated that anonymous persons compose these letters, and that the persons involved may or may not be a part of the Watchtower or CCJW corporations.

Attorney Zeff, visibly irritated by the intentional obfuscation, asked Jefferson whether the CCJW was responsible for ANYTHING; Jefferson responded by asking what he meant by “responsible.” Judge Collins was unable to restrain herself any longer and turned to the witness and demanded that he answer the question. Shaken and nervous, Jefferson told the court that he must take time to pause…and think. Following a lengthy silence, Zeff posed the question once again, to which Jefferson said “I imagine they have to.”

Before changing his line of questioning, Zeff displayed the signature on an elder’s letter which read “Watchtower Bible and Tract Society,” forcing Jefferson to acknowledge the corporation responsible for the policies enforced by Jehovah’s Witnesses prior to the 2001 creation of the Christian Co

Attorney Gregg Zeffngregation of Jehovah’s Witnesses. Zeff linked multiple Watchtower documents with policies that have restricted Witness elders from reporting child abuse to the proper authorities, making it clear which organization is responsible.

Moments later, Thomas Jefferson unbelievably denied that Watchtower writes anything, stating that they only “publish” and distribute these letters, but have nothing to do with their production. (referring to all letters before 2001)

Zeff questioned Jefferson on whether elders are sanctioned if they disobey the contents of these letters, which was followed by a song and dance from Jefferson and the indecisive and false statement that elders “may or may not” be censured for disobedience. When Jefferson mentioned that a Governing Body-appointed Circuit Overseer may be involved in disqualifying an elder, Zeff did not miss the opportunity to ask whether the Jehovah’s Witness Governing Body are associated with Watchtower or the Christian Congregation. Jefferson’s response: NO.

As if to say “I’m not done scrambling your brains just yet, jury” – Jefferson responds to the next seemingly simple question posed by Zeff, which was ‘should clergy report child abuse?’ After an objection from the Watchtower defense team, Jefferson states that he cannot answer the question because Jehovah’s Witness elders are not clergymen. This question set off a debate that lasted for two days. (more on that later)

Attorney Zeff then followed a line of questioning forcing Jefferson to admit that elders investigate accusations of child abuse using their own judicial process. Jefferson further had to confess that Witness elders have no professional training in counseling, psychology, or other relevant levels of expertise; yet amazingly he insisted that they did receive “training.” Zeff followed up by telling Jefferson that elders are in no way qualified to judge the genuineness or seriousness of an allegation of child abuse.

Jefferson arrogantly replied: “incorrect”

Zeff asked Jefferson whether he had any evidence from Watchtower publications to back that statement up. After a non-answer from junk-testimony Jefferson, Judge Collins stepped in and scolded Jefferson, telling him the question is “perfectly clear”. Zeff pressed the witness hard, asking him for his beliefs on this subject, to which Jefferson replied: “Are my beliefs on trial?”

Again, Judge Collins rebuked Jefferson adamantly and warned him to refrain from making any such comments, advising him to just answer the question. Unbelievably, Jefferson responds by saying that Watchtower is a corporate entity and does not “believe” anything.

Continuing his salvo of questions, Zeff asks Jefferson if he is aware that professionals exist in the field of child abuse detection and counseling, to which Jefferson reluctantly agrees. He then asks Jefferson if he is aware that the state of Pennsylvania wants those professionals involved whenever an accusation of child abuse occurs. Jefferson states that he was not aware of this, aside from when Judge Collins stated this to the jury at the outset of this trial. I remember thinking that Jefferson testified that he was in court on behalf of the legal department of Jehovah’s Witnesses, and to defend Watchtower and the CCJW – yet somehow after years of preparation for this trial, having been prepped by Watchtower’s extensive legal team, he is suddenly unaware that Pennsylvania has a mandatory law requiring the reporting of accusations of child abuse. Clearly the jury was not buying this.

Attorney Zeff then puts Jefferson on the spot regarding the matter of elders reading all letters from Watchtower; Jefferson stated that reading all letters is not required, but that elders would be expected to read all directions on child abuse from Watchtower prior to beginning an investigation. He was then asked whether elders could be sanctioned or stripped of their positions if they failed to follow Watchtower’s counsel. Reluctantly, Jefferson admitted that this is “possible.” Zeff followed by asking “has this ever happened?” Jefferson’s reply: “I don’t know.” As anyone with any experience in the Jehovah’s Witness organization knows very well, if an elder fails to follow directions from headquarters, his position as an elder will vanish instantly. Jefferson knows this very well.

Nearing the end of the first day of trial, Zeff calls Jefferson’s attention to one of the most damaging pieces of evidence in this case, the July 1, 1989 letter to elders. This six-page letter was stamped CONFIDENTIAL – and Watchtower meant it. This letter was so damaging to the defense, that when it was subpoenaed, Watchtower redacted nearly the entire document, with few exceptions. The plaintiff’s legal team only learned of the full contents of this letter by searching sources outside of Watchtower, and when the contents were revealed, this case was sealed.

Zeff calls Jefferson’s attention to the purpose of this letter, as stated on page 2:

“Hence, a growing number of vindictive or disgruntled ones, as well as opposers, have initiated lawsuits to inflict financial penalties on the individual, the congregation, or the Society. Many of these lawsuits are the result of the misuse of the tongue.”

He rephrased this paragraph by emphatically telling Jefferson that the real meaning is “Keep you mouth shut or you might get sued.” Jefferson disagreed, but the damage was done. The jury begins to understand the cloak of secrecy surrounding Watchtower. Protection of the organization and its assets has increasingly become the motivation behind the Jehovah’s Witnesses’ legal strategy, placing corporations ahead of the welfare of its own children. Day one ends in disaster for Watchtower, with final testimony from Jefferson looming on the horizon.

Day 2 – The Return of Thomas Jefferson

Wednesday morning brought Thomas Jefferson Jr. right back to the witness stand, but not before Spring Grove defense attorney Jud Aaron strongly objected to the presence of Detective Lisa Layden, who was scheduled to testify the next day. Aaron cried “Unfair,” claiming that the presence of the detective on day 2 would affect her day 3 testimony. Judge Collins rejected the sequestration order and stated “I’m done with this issue, I’ve ruled on it. It’s a clear issue.”

Trial resumes with Plaintiff’s attorney Gregg Zeff calling attention again to Exhibit 18B, the July 1, 1989 elder’s letter on confidentiality. Watchtower attorney John Miller immediately objects on “First Amendment” grounds but is overruled by the judge. Zeff looks at Miller, then the judge, and says “First Amendment your honor?” – Judge Collins tells Zeff to move on. Zeff grills Jefferson on the meaning behind the letter, the intended secrecy, and confidentiality, and the prevention of lawsuits due to “misuse of the tongue.” Zeff makes his point, and Jefferson is left offering no concise explanation.

The subject now changed to the persons in charge of Jehovah’s Witnesses:

Zeff: Do you remember when I asked you for the names
of the humans?

Jefferson: I do

Zeff: You didn’t give me the name of any, did you, sir?

Jefferson: I did not

Zeff: Is the reason you didn’t give me the names of any humans is because they’re secret?

Jefferson: No. The answer to that question —

Zeff: That’s all I asked you, sir. Is the reason you didn’t give me the
names of any humans is because you wanted to protect them from lawsuits?

Jefferson: No

Zeff then re-introduces Jefferson’s prior testimony on the matter of whether Witness elders are clergymen:

Zeff: Do you remember earlier in the questioning I asked you about this statement: Clergy must report sexual abuse of children to protect the victim from
additional harm?

Jefferson: I do, counselor.

Zeff: And your answer was you could not agree with that?

Jefferson: That’s correct, counselor.

Zeff: And you said you couldn’t agree with that because elders are not clergy. Is that a fair statement?

Jefferson: That’s a correct statement.

Zeff: Okay. What is your definition of clergy?

Jefferson: Clergy meant, as I understand it, are those who are recognized, if you will, as the leader of a church or an organization and that is something that elders are not.

Zeff follows up by displaying Websters dictionary on screen, then says:

Zeff: Can I show you Webster’s Dictionary’s definition of elder and see if you agree with that? The first definition is a group of ordained to perform pastoral or sacerdotal functions in a Christian church. Is that a reasonable definition of a clergy?

Jefferson: I don’t know the answer to that.

Zeff now proceeds to connect Jehovah’s Witness elders to the clergy using Jefferson’s own words:

Zeff: Can you define for me what an elder is?

Jefferson: Sure. An elder is a man who is appointed by means of the Holy Spirit to care for the interests of the sheep entrusted to him. Those responsibilities are described
in various places in the Bible. For example, first Peter 5, one and two, where elders are urged to care for the interests of the flock entrusted to them.

Zeff: Elders act as shepherds in the local congregations?

Jefferson: They do.

Zeff: And provide spiritual education and assistance from the Bible to congregants?

Jefferson: They do

Zeff: And they oversee the congregational meetings?

Jefferson: They do

Zeff: And they lead?

Jefferson: They take the lead also.

Zeff then brings up confession, and forces Jefferson to admit that elders are responsible for listening to confession from members of the congregation.

Zeff: And elders then receive confession of sort?

Jefferson: Elders listen to the confessions of those who may have been involved and wronged, yes.

Zeff now calls up on screen the definition of clergy once again:

Zeff: Looking at that the rule one more time, I would just like to know if you have changed your answer at all or if you think elders are clergy?

Jefferson: NO

Zeff digs deeper into the Jehovah’s Witness judicial process, hammering Jefferson with questions about the function of a judicial committee of elders.

Zeff: So wouldn’t your judicial committee, your rules, and by you, I’m not even sure who I’m talking about. Who is it that tells the elders, this is how a judicial committee should operate? Is it a governing body?

Jefferson: A group of spiritually qualified men, who remain anonymous, are selected to prepare material that’s reviewed and approved by the governing body. And then after that, it is published.

Zeff: So these anonymous men have told the elders that when there’s a matter that needs a judicial committee, here is how the committee should be set up, here is who should be on the committee, and here are the types of things you should look for. And
once you’ve done that, here is what you do if wrong has been committed. Is that a fair summary?

Jefferson: Not totally.

Zeff: Okay. Didn’t think so.

Zeff presses the uncooperative Jefferson further, asking him to define what the S-77 form is, to which Jefferson replied:

“S-77 form is a document that’s used to report concisely the events of that judicial hearing.”

It is of interest that his answer was misleading, as the S-77 is the “notice of disfellowshipping or disassociation” – filled out when the outcome of a judicial hearing is disfellowshipping, or if a person formally disassociates themselves. The form itself states:

“It is not necessary to provide a summary of the case. If anything of significance regarding the case needs to be shared with the branch office, please do so in a separate letter.”

Jefferson’s testimony was utterly confusing, filled with misleading and inaccurate data; he was placed on the witness stand by Watchtower’s own legal department, yet was self-destructing with every word. The jury appeared confused by his remarks, his demeanor, and his inability to answer simple questions without offering long-winded verbal detours.

Attorney Zeff now turned his attention back to the July 1989 confidential letter to elders:

Zeff: We talked briefly about section D, which was the child abuse, many states have child abuse reporting laws. When elders receive reports of physical or sexual abuse of a child, they should contact the society’s legal department immediately. Victims of such abuse need to be protected from further danger. That’s what it says?

Jefferson: That’s correct, counselor.

Zeff: In this document anywhere does it discuss how to protect children?

Jefferson: I’m not aware of any place in the document.

Zeff: But it does tell you to keep as many things secret as possible, doesn’t it?

Jefferson: It does urge confidentiality, counselor, correct.

You Can’t Have it Both Ways, Watchtower

It is of great interest that the Watchtower organization urges elders to maintain confidentiality, when they legally impale themselves by breaking confidentiality the moment they share a confession with other elders. In the Fessler case, there were at least ten elders and others who were informed of the allegations of sexual abuse, not to mention those in Watchtower’s legal and service department who learned of the case from local elders. Watchtower attempted to claim clergy privilege to protect themselves, but this was denied multiple times by the court. Evidence was presented that no confidentiality was maintained whatsoever.

Explained legally, Watchtower is subject to the legal principle of estoppel. This axiom bars a person from claiming one position, then intentionally taking the opposite position when it suits their legal case. Using Fessler versus Watchtower as an example, the defense adamantly attempted to use clergy privilege from the outset, yet denied in court for two straight days that elders are clergymen.

In lay terms, this means you can’t have it both ways.

During further intense questioning of Jefferson, Zeff pointed right back to the July 1989 letter to elders and asked:

Zeff: Let me break the question up for you. Wouldn’t you agree with me that an elder who has limited knowledge of child abuse laws, limited knowledge of criminal law, would have a difficult time understanding the difference between keeping it secret and going to the police based on this document?

Jefferson: If I answer about an elder’s limited knowledge, I’d only have to speculate. So I don’t know the answer to that question

Zeff: Sir, you’re here on behalf of Watchtower and the Christian Congregation to talk about the documents and the instructions that you’ve given to them. Would you agree that that’s confusing?

Jefferson: No, sir.

Zeff: Crystal clear to you?

Jefferson: Quite.

Zeff: And would you agree with me that the legal department, when called, should know the law in every state?

Jefferson: Again, I can’t speak for the legal department, counselor. I don’t work there.

[Now bear in mind that Jefferson has testified that he is here on behalf of a request from the Watchtower and CCJW legal department, leaving one to wonder how it is possible that Jefferson has no clue that the legal department is aware of state laws regarding mandatory reporting]

Zeff: Well, in writing this document, isn’t there an assumption by the Watchtower that the legal department is going to do the right thing by state law?

Jefferson: As for assumption, again, I can’t speculate, but what I can say with a fair degree of certainty is that when elders follow the instruction in this letter or other letters and call the legal department, they will receive appropriate legal advice.

Zeff continues his line of questioning regarding the Fessler case, and states that he has no knowledge whatsoever of the two Spring Grove PA elders, Eric Hoffman and Donald Hollingworth, except that they may have called Watchtower’s legal department. Referring once again to the July 1989 letter to elders, Zeff asks:

Zeff: There’s nothing in that document that says do what’s in the best interest of the child, is there?

Jefferson: I don’t believe that statement appears in the document, counselor.

Zeff: There’s nothing in the document that says when in doubt, protect the child?

Jefferson: That statement doesn’t appear in the document, counselor, no.

Zeff: Is there any document that you’re aware of that’s given to elders in the United States that says elders shouldn’t lose sight of the fact that victims urgently need to be protected from further abuse and that abusers need to be prevented from finding other victims?

Jefferson: Counselor, several documents which you’ve shown here have been printed. I can’t point to any specific one in response to your question. My memory doesn’t bring up one right now.

Zeff: Will you agree there’s no instruction in any Watchtower or Christian Congregation document that says if there’s an allegation of sexual abuse, contact an overseer?

Jefferson: If there’s an allegation of sexual abuse, contact the overseer. I’m not aware of that specific statement, counselor.

Zeff then draws Jefferson’s attention to the February 15th, 2002 letter to elders, where child abuse is mentioned, and which also references the July 1, 1989 letter]

Zeff: I want to take you to number four on this document. It says: “Child abuse is a crime. Never suggest to anyone that they should not report an allegation of child abuse to the police or other authorities.” So that says, correct me if I’m wrong, that elders should never say don’t report it. That would be wrong.

Jefferson: That’s correct, counselor.

Zeff: Then it says: If you’re asked, make it clear that whether to report the matter to the authorities or not is a personal decision for each individual to make and that there are no congregational sanctions for either decision. So it says, if you’re asked there, and I presume that these authors chose their words carefully… Do you know why they said if you’re asked instead of tell them?

Jefferson: I don’t know why it was exactly worded this way, counselor. I was not a part of the group that composed the letter, so I would only speculate to say why they might have worded it that way.

Zeff: So on behalf of Watchtower and Christian Congregation, your answer is why they ordered it that way is you don’t know because it would be speculation?

Jefferson: I don’t know exactly why the author worded it that way.

Zeff continued his questioning, with Jefferson only able to state that Watchtower’s position is “Never tell anyone that they can’t report it.” and “If they ask you, by all means, please do what you feel is right and report it, if you feel you should. ” Zeff continued:

Zeff: Would you agree with me that this instruction does not inform elders that they must, in Pennsylvania and Maryland, report suspected child abuse?

Jefferson: That’s a correct statement, counselor.

The Anonymous Men

Concluding his examination of Watchtower representative Jefferson, attorney Zeff probes Jefferson as to the very source of the judicial rules governing Jehovah’s Witness elders:

Zeff: And the rules that are followed by the elders relating to the judicial committee come from whom?

Jefferson: As stated, a group of men, spiritually mature men are appointed to prepare this material under the direction of the governing body. And after it is approved, it is published.

Zeff: And they’re anonymous?

Jefferson: The are.

Zeff: And do you know whether any of these anonymous people have any qualifications of any kind to deal with issues of child abuse?

Jefferson: If they’re anonymous and I don’t know them, then I don’t answer that question

Zeff: I have nothing further, thank you, Your Honor.

Following two days of examination by the plaintiff’s counsel, it was time for the defense to cross-examine Mr. Jefferson.

Jefferson Cross-Examined

First up was Jud Aaron, a non-Jehovah’s Witness attorney representing the Spring Grove Congregation of Jehovah’s Witnesses. Mr. Aaron began his questioning by referring to the state mandate for clergy to report suspected child abuse:

Aaron: “Clergy must report sexual abuse of children to protect the victim from additional harm. And yet there was some questions about it.” If I were to substitute the word clergy, remove the word clergy and put Jehovah’s Witnesses elders, let me read it. “Jehovah’s Witnesses elders must report sexual abuse of children to protect the victim from additional harm.” Would you agree with that?

Jefferson: I do in certain areas of municipalities and so forth, yes.

This brief and bizarre exchange echoed the earlier line of questioning in which Jefferson refused to acknowledge that Jehovah’s Witness elders are clergy, which in his mind exempted him entirely from answering these questions. Incredibly, when Aaron substituted “Jehovah’s Witness elders” for “clergy,” Jefferson still suggested that elders only have the obligation to report “in certain municipalities.”

By now, most readers will have thrown a brick through their computer monitor, or discarded their smartphone in the nearest lake when reading the lengths to which the Jehovah’s Witness organization will go to protect their own interests, instead of those of the victims of abuse. Their destructive doctrines are stuck like barnacles on a sinking ship, and Watchtower has no desire to scrape free the decades-old requirements which have ruined the lives of thousands.

As Aaron continued his examination of Jefferson, he restated the policy whereby elders were required to contact Watchtower’s legal department in cases involving suspected abuse. However, this line of reasoning was ineffective since it was clear that Jefferson was defending an organization which fails to report abuse as a practice unless they would receive sanctions and penalty for not reporting the matter in certain “municipalities.”

Mr. Aaron further attempted to minimize the child abuse issue when he questioned Jefferson on his experience in handling child abuse cases:

Aaron: And in the 35 years that you’ve sat on judicial committees, about seven
congregations of Jehovah’s Witnesses, have you sat on one that involved allegations of child sexual abuse?

Jefferson: No.

As an added “strategy”, defense attorney Aaron went so far as to imply that since there were only five lines (dealing with child abuse) out of six pages in the July 1 1989 Letter to elders, the relevance of this letter was minimal and that it was not intended to protect child abusers. Aaron then asked Jefferson to testify about the nature of the multitude of Watchtower and Awake! articles on a variety of subjects, including child abuse.

Aaron: Let me ask you something, Mr. Jefferson, why do these publications, the Jehovah’s Witness publication, Watchtower magazine, Awake magazine, why do they address repeatedly the issue of child abuse, sexual abuse, physical abuse, that type of
thing you just referred to?

Jefferson: Because in society in general, many, many people are adversely affected by the crime of child abuse and it’s the desire of the organization that I’m a part of to do everything possible to make people aware of this horrible, heinous crime and to
do everything possible to help victims first of child abuse and to assist them and assist their parents to shoulder their responsibility to protect their children. And that’s why the articles are published.

As any victim of child abuse in the Jehovah’s Witness organization will tell you, the organization and the elders obstruct justice in every possible way. The failure to report abuse to police and other civil authorities is fast becoming one of the most insidious crimes in the past 50 years. It was clear that the jury was not buying into Watchtower’s statement that they “abhor” child abuse. It is a weak and meaningless defense, when the facts show that the very authorities who are qualified to help children are almost never contacted.

Enter John Miller, for Watchtower

In his first appearance in this trial, Mr. John Miller, attorney for Watchtower New York, and a devout Jehovah’s Witness, stepped up to question Mr. Jefferson on behalf of the defense. Miller opens by acknowledging that he and Mr. Jefferson are old friends, for at least 20 years.

One of the more interesting contradictions in testimony came when Mr. Jefferson, under examination from Miller, suddenly acknowledged that both he and Watchtower’s legal department are very familiar with differences in state laws on mandatory child abuse reporting. Note the exchange:

Miller: You testified that the laws of the states vary; is that true?

Jefferson: That’s true.

Miller: And have you worked with lawyers in the branch’s legal department to render advice to elders who call about the laws of their particular state?

Jefferson: I have.

Miller: And is it in your working with those lawyers that you have become familiar with differences of laws of different states?

Jefferson: I have.

Thomas Jefferson had just testified when questioned by the plaintiff’s attorney Gregg Zeff that he was unaware of Watchtower’s knowledge of state laws for reporting abuse. Note his earlier testimony:

Zeff: And would you agree with me that the legal department, when called, should know the law in every state?

Jefferson: Again, I can’t speak for the legal department, counselor. I don’t work there.

Incredibly, Jefferson changed his testimony, suddenly becoming aware of state mandatory reporting laws.

Jefferson was lying to the court

Further evidence of defensive backpedaling came when John Miller, for Watchtower, referred to questions posed by Mr. Zeff the day before, when Jefferson was embarrassed by not being able to recall even the name of the President of the Watchtower Bible and Tract Society of New York. In an attempt to salvage Jefferson’s reputation, Miller asked:

Miller: You were asked if you could name some of the people in Watchtower Bible and Tract Society of New York, Incorporated and you were unable to do so. Are you a member on the executive board of that corporation?

Jefferson: I am not.

Miller: Are you a member or on the executive board of the corporation Christian Congregation of Jehovah’s Witnesses?

Jefferson: I am.

Miller: Can you name any of the people with that organization?

Jefferson: I can.

Miller: Go ahead. Name some.

Jefferson: The president, Allen Shuster; vice president, Anthony Griffin; secretary/treasurer, William Nonkes.

Miller: What is your role?

Jefferson: Assistant secretary/treasurer, I believe.

He believes? Jefferson seemed very unsure of his position within the CCJW organization – but his testimony continued to disintegrate as Watchtower attorney Miller then asked him to name Members of the United States Branch Committee.

Miller: Can you name a few of them for us?

Jefferson: Allen Shuster, Anthony Griffin, just to name two.

Miller: Was Leon Weaver a member of that branch committee?

Jefferson: He is.

Miller: So are the names of those persons who serve in the U.S. Branch kept secret anywhere?

Jefferson: Not at all.

Miller: Aren’t they published on the website?

Jefferson: That could very well be.

Miller: Have you seen them published in some of magazines that are sent to the public?

Jefferson: Yes, they are. The president is published every month in the Watchtower and Awake.

Miller: So there’s no secret about who is there?

Jefferson: No.

As a note to our readers, the questioning by Miller and responses of Jefferson reveal that they themselves are not fully aware of who manages and operates Watchtower, CCJW, and the United States Branch Committee. Not only was Jefferson unsure of his own position in CCJW, but his statement “The president is published every month in the Watchtower and Awake” was false, as he was discussing the US Branch Committee and not the Watchtower Society. A simple check of the inside cover of current Watchtower and Awake magazines reveals that it is the Watchtower president who is listed inside this cover, and not any of the US Branch Committee members.

Jefferson Says: No Responsibility to Protect the Community

After testifying once again that elders are not clergymen, the defense yielded to Mr Gregg Zeff for a re-cross examination of Mr. Jefferson. Zeff asked Jefferson whether the elders have a responsibility to protect the community from predators:

Jefferson: Well, the elders have responsibility of protecting children, yes, and all the flock.

Zeff: And the entire community from predators, not just the flock?

Jefferson: What do you mean by entire community?

Zeff: Well, doesn’t an elder have a responsibility if they know there’s a sexual predator in their midst to let the entire community, the State of Pennsylvania, the people of Philadelphia, know that there’s a sexual predator in their midst?

[Watchtower attorney Miller objects to this question. Objection overruled]

Jefferson: NO.

In one of the most insidious and outrageous statements of the trial, Thomas Jefferson admitted what so many victims of child abuse already know – that Jehovah’s Witnesses have no regard for the community at large, and their failure to report suspected child abuse places the entire community at risk by failing to report a predator.

While Witnesses are an insular community, the harboring or non-reporting of a sexual predator permits such an individual to roam free, unobstructed and undetected by unsuspecting parents and children. Most “worldly” or non-Jehovah’s Witness persons are unaware that a religious organization resides in their midst, completely insensitive to the protection of their family. Not only have tens of thousands of Jehovah’s Witness children suffered, but evidence shows that scores of sexual assaults have occurred throughout the global community because the offender was not reported to the authorities. This affects everyone, regardless of religious affiliation.

Thomas Jefferson single-handedly embarrassed the entire Watchtower organization, destroying his own credibility and that of the religion he represents. But this was a good thing. This was not a closed-door, behind the scenes, cloaked meeting, but an open, civil trial which will forever be a part of the public record. It is an insight into the inner workings of Jehovah’s Witnesses, who are largely ignorant of the issues related to child abuse, and the tactics employed by their elders, their Governing Body, and the legal team which defends the absurd.

Please stay tuned for further reports on the testimony in this case, including that of two elders, the abuser of Stephanie Fessler, and the detective who ended any chance of Watchtower winning this case.

Posted on July 28, 2022 by Mark O'Donnell — Leave a comment

2017: Fessler versus Watchtower – Opening Statements in Jehovah’s Witness Child Abuse Trial

Published February 12th, 2017

It was a cold Philadelphia morning on the 7th of February, 2017. Stephanie Fessler walked into the Court of Common Pleas of Pennsylvania, First Judicial District, Civil Trial Division. The time was 9.45 a.m. according to the clock which sits atop the historic City Hall courthouse in the center of Philadelphia. But there was another clock running – it was the clock of justice, the timepiece which measures just how long it takes for a person or organization which has damaged another person’s life to be called to account for what they have done, or possibly what they have not done.

It has been 13 years since congregation elders in Spring Grove Pennsylvania first learned of the inappropriate relationship and abuse perpetrated by Terry Monheim, aged 49, and her victim, Stephanie Fessler, who was just 14 years of age when the abuse began. Stephanie was dragged before elders in 2004 and 2005 to answer for her relationship with her abuser, but with grotesque disregard for the law, elders knowingly failed to report the suspected abuse to the police, to Pennsylvania’s Childline, or any other authority. Instead, they forwarded what they knew to Watchtower’s legal department, who wantonly disregarded Pennsylvania State law, and also failed to report.

Instead of protecting the victim from further harm, local elders in Pennsylvania issued a private reproof in 2004, then another public reproof in 2005. The victim, Stephanie was crucified and devastated, having been denied protection from the authorities who are trained to protect minors and prevent further injury and mental distress. The local elders and the Watchtower organization victimized Stephanie, and more than once. Her participation in the abuse was viewed as a sin, and not a crime. Stephanie was a sinner, they said.

At 9:52 a.m. 25 Jurors entered the court of Mary C. Collins, and were instructed regarding the nature of this case, and were read the list of witnesses who would likely testify. By 10:25 a.m. all but 10 jurors were dismissed, and the final jury was complete. Eight jurors with two alternates will decide the fate of the Watchtower Bible and Tract Society of New York, The Christian Congregation of Jehovah’s Witnesses, the Spring Grove Congregation of JWs – and to a lesser extent, the abuser Terry Monheim.

Pre-Trial Motions

Just prior to opening arguments, without the jury present, the attorneys for the plaintiff, Stephanie Fessler, and the defense battled out more than a dozen motions before Judge Collins. These motions set the stage for which evidence can be introduced during trial, and that which can’t.

The battle did not take long to become heated when Spring Grove defense attorney Jud Aaron argued vocally against the introduction of a new witness, who was an elder in York County PA. Mr. Arron argued that this was a “bombshell” witness introduced by the plaintiff, whose testimony is irrelevant, and who had not been deposed by defense. Judge Collins agreed with the defense that his evidence would not be permitted during the initial phase of the trial, but will be allowed during the punitive stage of the trial. The stage was already beginning to set for Watchtower’s inevitable defeat, even before the jurors heard a single witness testify.

In another motion, the defense attempted to preclude the testimony of detective Lisa Layden, an expert witness, stating that her testimony is “just an opinion” and should not be permitted. After a concise rebuttal from counsel Jeffrey Fritz, Judge Collins agreed, and the defense motion was denied. Lisa Layden will testify.

It was no surprise that the defense attempted to argue that the statements made to elders by the plaintiff were privileged, and entering them into testimony would violate clergy privilege laws, which protect confessions made to clergymen. This claim erupted in a furious rebuttal by Stephanie’s attorney Jeffrey Fritz, in which he informed the judge that clergy privilege has no application in this case, as there was no expectation of confidentiality when the elders hauled Fessler into an elder’s meeting and questioned her about her relationship with Monheim. When elder Eric Hoffman was deposed over 2 years ago, he never once advised counsel that he would like to invoke clergy privilege, and in fact, he violated that anyway by spreading every aspect of Stephanie’s testimony to multiple elders as well as the Watchtower legal department in New York. As the steam settled from Mr. Fritz’ forehead, Judge Collins told counsel that Fritz was “right on point” about this issue, and that clergy privilege could not be invoked. As Watchtower has attempted to claim clergy privilege in the past, this was another defeat for the Jehovah’s Witness organization.

In a somewhat surprising defense strategy, defense attorney Jud Aaron claimed that the plaintiff’s counsel is putting the religion of Jehovah’s Witnesses on trial by introducing dozens of Watchtower and Awake articles into evidence. It was a desperate move, but Judge Collins did not fall for it.

The Trial Begins

From the private, backrooms of the courthouse, the jury entered the room. Three black men, two white women, and five black women entered and took their assigned seats. Judge Collins congratulated them for their service to the court, then reminded them that during the trial, she decides on all matters of law, and they must obey her decision. However, she reminded the jury that they are the sole determiners of the facts of this case. Collins explained the definition of “preponderance of the evidence,” then gave the jury an illustration of a scale, with the plaintiff and defense on either side of center. She stated that if the scale tips ever so slightly in favor of the plaintiff, then the plaintiff has met her burden of proof, and defense will be found guilty.

Following a lunch break, the court reconvened at 1.45 p.m., at which point Judge Collins read the statute for mandatory reporting of suspected child abuse to the jury of 10. The plaintiff was now given the floor, and attorney Gregg Zeff made his opening statement to the jury. Mr. Zeff explained that a member of clergy must report suspected abuse of a minor, and that elders should never keep suspected abuse secret to protect the Jehovah’s Witness organization. Zeff introduced a letter to the body of elders, dated July 1, 1989, which reminds elders that due to lawsuits, the strictest confidence must be maintained by elders. The letter advised elders against the “improper use of the tongue”

Zeff explains the timeline in which the elders first learned of the suspected abuse of Fessler in 2004, activity which included hugging and kissing. Elders from both the Spring Grove congregation (Stephanie’s congregation) a those from the Freeland Maryland congregation (Terry Seipp-Monheim’s congregation) were aware of the relationship but failed to contact the authorities. Instead, they formed their own committee and reproved both the victim and her abuser.

Attorney Zeff then played a video deposition taken a few years ago when this case was filed, in which the plaintiff’s mother Jodie Fessler stated that elder Eric Hoffman never once advised her that authorities must be contacted.

It was not until 2011 that Stephanie Fessler was finally able to contact the police, at which point Monheim was arrested and jailed. Testimony from detective Layden will advise the jury that elders should have immediately obeyed the law and contacted the police and Childline. Instead, Zeff stated that rules were broken to protect the congregation and keep it out of harm’s way.

Evidence will show that Stephanie, at 14 years of age attended public school, but was otherwise completely insulated from after-school activities and association with non-Witness youths. Instead, she was left to care for her Jehovah’s Witness mom, who had a history of mental illness. Stephanie looked to Terry Seipp (Monheim) for emotional support, but Seipp soon broke that trust by entering into a sexual relationship with Stephanie. Stephanie had no prior relationships. The plaintiff will examine professional therapist Debbie Bauer, who will discuss the damages to Stephanie, not only for the initial abuse but for the protracted relationship of over two years which caused Stephanie permanent psychological damage. Co-Defendant Terry Monheim was remorseful, having served her time in jail, but the plaintiff will argue that the defendants, Watchtower, the Christian Congregation of Jehovah’s Witnesses, and the Spring Grove congregation are to be held responsible for their failure to report the suspected sexual abuse of a minor.

Defense Opening

Attorney for the defense of Spring Grove congregation opened with the statement “In life, there are consequences for not telling the truth.” Jud Aaron argued that therapist Lori Barton’s notes will prove that there was NOT a sexual relationship occurring at the time elders in Spring Grove first learned of the affair between Fessler and Terry Seipp (Monheim). As a result, Aaron said, “You can’t report what you don’t know.”

Aaron further stated that by 2005, the “relationship” between Fessler and Seipp was over. In a moment of great emotion, the plaintiff Stephanie Fessler sat just a few feet away from Jud Aaron as he then stated “Stephanie Fessler did not tell the truth…As a consequence, no report was made.

As if to hammer this point down to the jury, Mr. Aaron replicated his earlier comment in a final statement: One thing is crystal clear – Stephanie did not tell the truth, so the elders had nothing to report. The elders could not protect Stephanie Fessler because she did not tell the truth.”

Next up was Mr. John Miller, attorney for the Watchtower Bible and Tract Society. Miller, a Jehovah’s Witness elder himself and a member of the Patterson New York JW legal department, explained that Jehovah’s Witness are a Christian religion, and that the jury will here that Watchtower “owns some things up there” in New York. After offering his explanation for the various Witness-owned corporations, he then echoed the words of his co-counsel Jud Aaron and stated that Terry Monheim will not show up in court to defend herself here. He further stated that the Watchtower and CCJW did not have any duty to report what they had heard from congregation elders.

Miller also reiterated that the key to the defense is contained in the notes of therapist Lori Barton. Miller in his best courtroom dramatics stated emphatically “Records don’t lie.”

Attorney Miller intensified his plea to the jury, closing with the statement: “We (the Watchtower) have nothing to do with this case.” Miller quipped that elders are “just lay persons,” closing his remarks with “Watchtower and CCJW don’t even belong here.”

Attorney for CCJW (Christian Congregation of Jehovah’s Witnesses) Louis Lombardi made no opening statements to the jury. He sat silently between Aaron and Miller at the defense counsel table, leaving one to wonder if he will ever make an appearance in the defense of the Jehovah’s Witness organization.

Stay tuned for more as we report on the ongoing defense strategy, and the courtroom antics of Watchtower’s first witness, Thomas Jefferson, Jr.

Posted on July 27, 2022July 28, 2022 by Mark O'Donnell — Leave a comment

2017: Jury Selection Complete in Fessler Versus Watchtower Child Abuse Case – Trial Date Set

Published February 3rd, 2017

For the first time since the 2012 landmark ruling in the case of Candace Conti versus the Watchtower Bible and Tract Society of New York, a jury will decide the outcome of a sexual abuse case in which multiple Jehovah’s Witness elders in two states knowingly failed to report the abuse of a 14-year-old girl, even after reporting the matter to Watchtower’s legal department.

According to court documents, the Spring Grove elders interrogated the victim, Stephanie Fessler, but did not question the 49-year-old Terry Seipp (Monheim), and made no attempt to contact the police or child protection authorities. Instead of offering protection, Stephanie was slapped with a private “reproof” from her elders. Under deposition, Witness elder Eric Hoffman admitted that he knew of suspected abuse, but failed to contact the authorities.

Elders from the Freeland Maryland congregation were informed of the sexual abuse accusations against their member, Terry Seipp (Monheim), but as with the Spring Grove elders, they too failed to contact any legal authorities and rather also issued a private reproof. Elders from the Spring Grove congregation did, however, contact Watchtower’s legal department in Patterson, New York, but court records indicate that despite their inquiry regarding possible police notification, the failure to make a report of suspected abuse violated Pennsylvania’s Child Protective Services Laws (CPSL).

As a direct result of the defendants’ collective unwillingness to comply with both Pennsylvania and Maryland law, the plaintiff suffered abuse for yet another year, until the defendant’s husband hired a private investigator, who provided photographic proof of the relationship between Fessler, aged 15, and Monheim, who was now 50 years old. Elders were again notified following this disclosure, but they still refused to contact police or Childline. They punished Stephanie again by now publicly reproving her; a formal announcement was made to the entire congregation.

Abuser Charged, Victims Suffers

It was not until 2011 that Stephanie Fessler, aged 22 was able to report her abuser directly to the police, who arrested and charged Terry Seipp (Monheim) with multiple criminal violations. Seipp pled guilty to corrupting the morals of a minor and indecent assault and was sentenced to prison and probation.

Meanwhile, Fessler suffered severe PTSD which presented in extreme anxiety, insomnia, flashbacks, nightmares, and multiple additional symptoms which required professional therapy. It is clear that the Jehovah’s Witness organization not only obstructed justice, but by violating Pennsylvania and Maryland Law, they subsequently deprived Stephanie of the counseling services which would have been available to her at the right time. The added layer of stress caused by her private and public reproof caused additional damage, forcing her to deal with the stigma of being considered “bad association” by all of her Witness friends.

Stephanie was baptized as one of Jehovah’s Witnesses at the age of 10, a decision that rendered her permanently accountable to the Witness organization and its elders. While non-Witness children have the benefit of practical support and encouragement if they are abused or taken advantage of, a baptized Witness child will often find themselves seated before a body of all male elders, forced to relive their trauma, then punished with no recourse.

Stephanie stated:

“it’s robbed years of my childhood because I was a child at the time. I did not know about sex… to be abused by somebody and then to be blamed for it, the damage that’s caused me and done to me mentally and emotionally, it’s beyond words”

The Lawsuit

The primary defendant in this case is the Watchtower Bible and Tract Society of New York, and the CCJW (Christian Congregation of Jehovah’s Witness). Fessler’s attorney Jeffrey P. Fritz of Soloff & Zervanos, P.C. will demonstrate to the jury that Watchtower’s legal department failed to instruct the elders involved in this case to follow the mandatory child abuse reporting laws which govern Maryland and Pennsylvania.

This is in spite of Watchtower’s own written and published documentation which openly acknowledged that child abuse is a crime, and that “no elder will criticize anyone who reports such an allegation to authorities.” (February 15th, 2002 Letter to Elders)

February 15th, 2002 Letter to Elders Excerpt

However, in line with Watchtower’s conflicting legal recommendations, elders are not specifically instructed to report matters of child abuse to legal authorities, but to only do so as the last resort in states where mandatory reporting is strictly enforced. Watchtower relies heavily upon the use of clergy privilege, despite exemptions in place which permit a member of the clergy (an elder) to report accusations of abuse to the proper authorities.

As we have reported in past articles, Watchtower attorneys frequently use the term “absolute right” when describing their desire for victims to handle abuse reports themselves – a practice designed to make them appear to favor victims rights while making no effort to actively involve congregation elders in the reporting process. This strategy results in grossly under-reported cases of abuse. Most victims and their families are so traumatized by the abuse, they usually decline to report. Another reason they fail to report is that elders encourage Jehovah’s Witnesses to do nothing which would “bring reproach upon Jehovah’s name” – a well-known Witness policy designed to protect the organization’s reputation rather than seek the highest level of care for victims.

The jury has been selected, and the trial is set to commence Tuesday, February 7th at City Hall in Philadelphia, Pennsylvania.

More on Fessler v. Watchtower:

2017: Fessler versus Watchtower – Opening Statements in Jehovah’s Witness Child Abuse Trial

Title	Summary	hf:doc_categories	hf:doc_tags
Document 10-0 Hines versus Watchtower	Stipulation agreement	hines-versus-watchtower child-victims-act-cases-new-york civil-lawsuits-united-states	child-victims-act-new-york hines-versus-watchtower
Document 27-0 Hines versus Watchtower	April 12th, 2022 – Reply Memorandum of Law from …	hines-versus-watchtower child-victims-act-cases-new-york civil-lawsuits-united-states	hines-versus-watchtower jehovahs-witnesses-child-abuse
Document 6-0 Hines versus Watchtower	August 31st, 2021 – Decision and Order RE: Confidentiality …	hines-versus-watchtower child-victims-act-cases-new-york civil-lawsuits-united-states	hines-versus-watchtower
Document 9-0 Hines versus Watchtower	October 29th, 2021 – Stipulation for Attorney Carl J. Schaerf to Accept Summons and Verified Complaint for Governing Body of Jehovah’s …	hines-versus-watchtower child-victims-act-cases-new-york civil-lawsuits-united-states	child-victims-act-new-york hines-versus-watchtower
1-0 Deborah Hines versus Watchtower – Complaint	Case 520772 2021 New York Child Victims …	hines-versus-watchtower child-victims-act-cases-new-york civil-lawsuits-united-states	hines-versus-watchtower
1-0 Complaint and Demand For Jury Trial	1-0 Complaint and Demand for Trial	hawaii nd-versus-watchtower civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
1-0 Complaint and Jury Demand	1-0 Original Complaint	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
Document 1-0 Denise Jackson versus Watchtower	Document 1-0	denise-jackson-versus-watchtower child-victims-act-cases-new-york civil-lawsuits-united-states
1-0 Petition for Review Filed	1-0 Petition for Review Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
1-0 Philp Brumley Appeal in Ninth Circuit Court of Appeals	1-0 General Appeal Documents	philip-brumley-sanctions-appeal montana civil-lawsuits-united-states	philip-brumley philip-brumley-sanctions-appeal
1-1 Affidavit of Shirley Gibson	Doc 1-1 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
1-2 Affidavit of James Rowland	Doc 1-2 Exhibit B	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
1-3 Affidavit of Mark O’Donnell	Doc 1-3 Exhibit C	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
1-4 1975 Montana Reporting Code	Doc 1-4 Exhibit D	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
1-5 Civil Cover Sheet	Civil Cover Sheet	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
10-0 Answer to Application to Strike	10-0 Answer to Application to Strike	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
10-0 Appellee’s Reply Brief Supporting Their Motion to Dismiss Appeal	10-0 Appellees Reply Brief	philip-brumley-sanctions-appeal montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley philip-brumley-sanctions-appeal
10-0 Summons Served on Bruce Mapley Sr.	Bruce Mapley Summons	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
100.0 Watch Tower Answer to First Amended Complaint	Watch Tower PA Answer	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
101-0 Plaintiff’s Motion for Sanctions	101-0 Plaintiff’s Motion for Sanctions Against Watch Tower and Philip Brumley	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower jehovahs-witnesses-child-abuse
106-1 Defendant’s copies of Rule 11 Motions by Plaintiffs	Defendant’s Copies of Motions	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower jehovahs-witnesses-child-abuse
106-2 Watch Tower Responses to First Set of Jurisdictional Discovery	Watch Tower Pennsylvania Responses	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower jehovahs-witnesses-child-abuse
106-0 Watch Tower Response Opposing Motions	Watch Tower Pennsylvania’s Response Opposing Motions for Sanctions	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower jehovahs-witnesses-child-abuse
109-1 Defendant’s Exhibit 1	Defendant’s Exhibit 1	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower jehovahs-witnesses-child-abuse
109-2 Plaintiff’s Exhibit 2	Plaintiff’s Exhibit 2	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower jehovahs-witnesses-child-abuse
109-0 Plaintiff’s Reply Brief in Support of Their Motion for Sanctions	109-0 Plaintiff’s Reply Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower jehovahs-witnesses-child-abuse
11-0 Letter from Bruce Mapley Sr to Court Entered June 1st 2020	Bruce Mapley Letter	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
11-0 Order Granting Application to Strike	11-0 Order Granting Application to Strike	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
115-0 Defendants Responsive Pretrial Statement	115-0 Defendants Responsive Pretrial Statement	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
12-0 Letter from Bruce Mapley Sr.	Bruce Mapley Letter	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
12-0 Petitioner’s Brief Filed	12-0 Petitioner’s Brief Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
12-0 Philip Brumley Motion to Consolidate Appeals	12-0 Philip Brumley Motion to Consolidate Appeals	philip-brumley-sanctions-appeal montana civil-lawsuits-united-states	philip-brumley philip-brumley-sanctions-appeal
13-0 Petitioner’s Brief Filed	13-0 Petitioner’s Brief Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
13-0 Watch Tower Motion to Dismiss	Motion to Dismiss	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
132-0 Plaintiff’s Motion to Compel RE Waived Privilege	132-0 Plaintiffs Motion to Compel	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
133-0 Plaintiff’s Brief RE: Motion to Compel	133-0 Plaintiffs Brief for Motion to Compel	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
136-1 Shirley Gibson Excerpt	136-1 Shirley Gibson Excerpt	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
136-2 Plaintiff’s Letter to Bruce Mapley	136-2 Plaintiff’s Letter to Bruce Mapley	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
136-0 Watchtower Response to Plaintiffs’ Motion to Compel	Watchtower Response to Plaintiffs’ Motion to Compel	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower jehovahs-witnesses-child-abuse
137-0 Watchtower New York Joinder With Watch Tower Pennsylvania	137-0 Watchtower NY Joinder With Watch Tower PA	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower jehovahs-witnesses-child-abuse
14-0 520772_2021_Deborah_Hines_v_Deborah_Hines_ANSWER_14	Defendant Watchtower’s Answer to Complaint	hines-versus-watchtower child-victims-act-cases-new-york civil-lawsuits-united-states	hines-versus-watchtower
14-0 Order Denying Motion to Dismiss Appeal	14-0 Order Denying Motion to Dismiss Appeal	philip-brumley-sanctions-appeal montana civil-lawsuits-united-states	philip-brumley philip-brumley-sanctions-appeal
14-0 Respondent’s Brief Filed	14-0 Respondent’s Brief Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
14-0 Watch Tower Pennsylvania Brief in Support of Motion to Dismiss	Defense Motion to Dismiss	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
14-1 Affidavit of Philip Brumley	Affidavit of Philip Brumley, June 22nd, 2020	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley
144-0 Affidavit of Ryan Shaffer	Affidavit of Costs	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
144-1 Declaration of Patti L. Gruwell	Doc 144-1 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
144-2 Declaration of Ryan R. Shaffer	Doc 144-2 Exhibit B	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
144-3 Declaration of Robert L. Stepans	144-3 Exhibit C	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
144-4 Declaration of James C. Murnion	Doc 144-4 Exhibit D	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
144-5 Declaration of Matthew L. Merrill	Doc 144-5 Exhibit E	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
144-6 Declaration of Jessica Yuhas	Doc 144-6 Exhibit F	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
149-0 Brief in Support of Scheduling Order Motion	Plaintiff’s Brief on Scheduling	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
15-0 520772_2021_Deborah_Hines_v_Deborah_Hines_NOTICE_OF_APPEARANC_15	Notice of Appearance for Defendants	hines-versus-watchtower child-victims-act-cases-new-york civil-lawsuits-united-states	hines-versus-watchtower
15-0 Order Approving Consolidation of Appeals	15-0 Order Approving Consolidation	philip-brumley-sanctions-appeal montana civil-lawsuits-united-states	philip-brumley philip-brumley-sanctions-appeal
15-0 Petitioner’s Reply Brief Filed	15-0 Petitioner’s Reply Brief Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
15-0 Watch Tower Answer and Cross Claim Filed	Watchtower Answer	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
150-0 Transcript Order	150-0 Transcript Order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
151-0 Watch Tower Brief in Response	151-0 Watch Tower Brief in Response	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
152-0 Watchtower New York Response	152-0 Watchtower New York Response	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
153-0 Plaintiffs Motions to Compel Depositions	Motion to Compel Depositions	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
154-0 Plaintiff’s Brief Supporting Motion to Compel Depositions	Brief Supporting Motion to Compel	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
155-0 Plaintiffs Reply Brief	Plaintiffs Reply Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
155-0 Subpoena Duces Tecum for Kaloko Congregation of Jehovahs Witnesses	155-0 Subpoena Duces Tecum	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
156-0 Watch Tower Motion for Extension	WT Motion for Extension	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
156-1 Proposed Order for Extension	Proposed Order for Extension	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
16-0 520772_2021_Deborah_Hines_v_Deborah_Hines_NOTICE_OF_APPEARANC_16	Notice of Appearance for Defendants	hines-versus-watchtower child-victims-act-cases-new-york civil-lawsuits-united-states	hines-versus-watchtower
16-0 Joint Notice of Related Case	Notice of related case	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
16-0 Respondent’s Reply Brief Filed	16-0 Respondent’s Reply Brief Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
160-0 Watchtower Response Opposing Motion to Compel Depositions	160-0 Watchtower Response	caecaert-v-watchtower montana civil-lawsuits-united-states	allen-shuster caekaert-v-watchtower gary-breaux gene-smalley
160-1 Declaration of Allen Shuster	160-1 Decl. of Allen Shuster	caecaert-v-watchtower montana civil-lawsuits-united-states	allen-shuster caekaert-v-watchtower
160-2 Declaration of Gary Breaux	160-2 Decl. of Gary Breaux	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower gary-breaux
160-3 Declaration of Marvin Gene Smalley	Document Filed: October 20th, 2022 Excerpt: “I am a voting member of WTNY and co-defendant Watch Tower Bible and Tract Society of Pennsylvania (“WTPA”) and have been for decades, but I do not recall when my memberships …	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower gene-smalley
161-0 Foundational Affidavit of Jon A. Wilson	161-0 Affidavit of Jon Wilson	caecaert-v-watchtower privilege-logs montana civil-lawsuits-united-states	caekaert-v-watchtower
161-1 Watchtower New York Privilege Log served March 25th, 2022	WTNY Privilege Log March 25, 2022	caecaert-v-watchtower privilege-logs montana civil-lawsuits-united-states	caekaert-v-watchtower privilege-log
161-10 Exhibit 10 2022-09-12 Shaffer email to Wilson	Exhibit 10 – Shaffer email to Wilson	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
161-11 Exhibit 11 2022-09-15 Wilson LT Shaffer	Exhibit 11 2022-09-15 Wilson LT Shaffer	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
161-12 Exhibit 12 2022-09-23 Shaffer LT Wilson	Exhibit 12 – Shaffer LT Wilson	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
161-13 Exhibit 13 2022-09-26 Wilson LT Shaffer w 2nd Supp PL	Exhibit 13 – Wilson LT Shaffer w 2nd Supp PL	caecaert-v-watchtower privilege-logs montana civil-lawsuits-united-states	caekaert-v-watchtower
161-14 Exhibit 14 2022-09-27 Shaffer email to Wilson	Exhibit 14 – Shaffer email to Wilson	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
161-15 Exhibit 15 2022-09-28 Sweeney email to Shaffer-copy to Wilson	Exhibit 15 – Sweeney email to Shaffer-copy to Wilson	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
161-16 Exhibit 16 2022-09-28 Shaffer email to Sweeney-copy to Wilson	Exhibit 16 – Shaffer email to Sweeney-copy to Wilson	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
161-17 Exhibit 17 2022-09-29 Shaffer LT Wilson and Sweeney	Exhibit 17 – Shaffer LT Wilson and Sweeney	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
161-18 Exhibit 18 2022-10-05 Jensen email to Shaffer and Sweeney	Exhibit 18 – Jensen email to Shaffer and Sweeney	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
161-19 Exhibit 19 2022-10-05 Shaffer email to Wilson and Sweeney) (Wilson, Jon)	Exhibit 19 – Shaffer email to Wilson and Sweeney) (Wilson, Jon)	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
161-2 Letter from Plaintiff’s Counsel to WTYN dated April 13th, 2022	Letter dated April 13, 2022	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
161-3 Exhibit 3 2022-05-02 Wilson LT Shaffer	Exhibit 3	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
161-4 2022-06-29 Shaffer email to Wilson	Exhibit 4 – Shaffer email to Wilson	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
161-5 Exhibit 5 2022-07-22 Jensen email to Shaffer	Exhibit 5 – Jensen email to Shaffer	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
161-6 Exhibit 6 2022-08-15 Wilson LT Shaffer	Exhibit 6- 5 Wilson LT Shaffer	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
161-7 Exhibit 7 2022-08-18 Shaffer LT Wilson	Exhibit 7 – Shaffer LT Wilson	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
161-8 Exhibit 8 2022-08-30 Shaffer LT Wilson	Exhibit 8 – Shaffer LT Wilson	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
161-9 Exhibit 9 2022-09-09 Shaffer LT Wilson	Exhibit 9 2022-09-09 Shaffer LT Wilson	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
162-0 Foundational Affidavit of Jon A. Wilson	162-0 Foundational Affidavit of Jon A. Wilson	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
163-0 Watch Tower Joinder	…	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
165-0 Watch Tower Brief in Response to Plaintiffs Affidavit RE: Philip Brumley Sanctions	Document 165-0 Watch Tower Brief RE: Sanctions	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley
165-1 Montana Codes from 1975	165-1 Montana Codes	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
165-2 March 10, 1983 Watchtower Letter to Elders RE: Blue Envelopes	165-2 Watchtower Letter Blue Envelopes	caecaert-v-watchtower watchtower-policy-documents montana civil-lawsuits-united-states	blue-envelopes caekaert-v-watchtower
165-3 Third Affidavit of Phillip Brumley	165-3 Third Affidavit of Philip Brumley	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley
167-0 Watchtower Notice of Submission of Documents	167-0 Watchtower Notice	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
168-0 Order on Plaintiffs Motion for new Scheduling Order	168-0 Order on Plaintiff’s Motion	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
169-0 Watch Tower Notice of Errata	169-0 Watch Tower Notice of Errata	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
17-0 Defendants Motion to Dismiss Complaint	17-0 Defendants Motion to Dismiss Complaint	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
17-0 Joint Discovery Plan Filed	Joint Discovery Plan	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
17-0 Order Filed	17-0 Order Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
170-0 Plaintiffs Reply in Support of Motion to Compel Depositions	170-0 Plaintiffs Reply RE Depositions	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
170-1 Exhibit A – Declaration of Ryan Shaffer	170-1 Ryan Shaffer Declaration	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
170-2 Exhibit B – Charissa Nicole v Watchtower Case	170-2 Exhibit B	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
170-3 Exhibit C – 2009 Watchtower Charter – Gary Breaux	170-3 Exhibit C	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower gary-breaux
170-4 Exhibit D – 2011 Affidavit of Allen Shuster	170-4 Affidavit of Allen Shuster	caecaert-v-watchtower montana civil-lawsuits-united-states	allen-shuster caekaert-v-watchtower
170-5 Exhibit E – 2012 Affidavit of Allen Shuster	170-5 Exhibit E	caecaert-v-watchtower montana civil-lawsuits-united-states	all allen-shuster caekaert-v-watchtower
171-0 Plaintiff’s Request for Hearing on Motion to Compel Depositions	171-0 Plaintiffs Hearing Request	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
171-1 Plaintiff’s Proposed Order on Request for Hearing	171-1 Plaintiffs Proposed Order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
172-0 Plaintiff’s Notice RE: Additional Motions to Compel	172-0 Plaintiffs Notice	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
173-1 Plaintiff’s Proposed Order Granting Extension	173-1 Plaintiffs Proposed Order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
173-0 Plaintiffs Motion to Extend Expert Witness Disclosure and Discovery Deadlines	173-0 Motion for Extensions	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
177-0 Watchtower New York Motion to Amend Answer	177-0 WT NY Motion	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
177-1 Watchtower Draft of Amended Answer	177-1 Draft of Amended Answer	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
178-1 Exhibit A – Watch Tower Pennsylvania Proposed Amended Answer	178-1 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
178-0 Watch Tower Pennsylvania Motion to File Amended Answer to 1st Amended Complaint	178-0 Watch Tower PA Motion	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
179-0 Plaintiff’s Opposition to Watchtower New York Motion	179-0 Plaintiffs Opposition to WTNY	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
179-1 Exhibit A – Deposition Excerpt from Camila Mapley	179-1 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
179-2 Exhibit B – Declaration of Ryan R. Shaffer	179-2 Exhibit B	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
18-0 Application for Relief	18-0 Application for Relief	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
18-0 Inability to Stipulate to Any Facts – Joint Statement	Inability to Stipulate	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
180-0 Plaintiff’s Opposition to Watch Tower Pennsylvania Motion to Amend Answer to Complaint	180-0 Plaintiffs Opposition to WTPA	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
180-0 Subpoena Duces Tecum for Kaloko Congregation of Jehovahs Witnesses	180-0 Subpoena Duces Tecum	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
180-1 Exhibit A – Deposition Excerpt from Camila Mapley	180-1 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
180-2 Exhibit B – Declaration of Ryan R. Shaffer	180-2 Exhibit B	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
181-0 Watchtower Motion for Extension	181-0 WT Motion for Extension	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
181-1 Proposed Order for Extension	181-1 Proposed Order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
182-0 Watch Tower Motion for Time Extension	182-0 Watch Tower Motion for Time Extension	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
182-1 Proposed Order for Time Extension	182-1 Proposed Order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
183-0 Order on Watch Tower Time Extension	183-0 Order on WT PA Extension	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
184-0 Court Order on Extension	184-0 Order on Extension	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
185-0 Watchtower Brief on Motion to Amend Answer	185-0 Watchtower Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
185-1 Exhibit – A Camila Mapley Deposition Excerpt	185-1 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
186-0 Watch Tower Reply to Amend Answer to Amended Complaint	186-0 Watch Tower Reply	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
186-1 Exhibit A – Camila Mapley Deposition Excerpts	186-1 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
187-0 Plaintiff’s Motion to Compel Document Production	187-0 Plaintiff’s Motion to Compel	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
188-0 Plaintiff’s Brief Supporting Motion to Compel Documents	188-0 Plaintiffs Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
188-1 Exhibit A – Deposition of Shirley Gibson	188-1 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
188-2 Exhibit B – Deposition of James Rowland	188-2 Exhibit B – Deposition of James Rowland	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
188-3 Exhibit C – Documents Withheld by Watchtower New York	188-3 Exhibit C	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
188-4 Exhibit D – March 14th, 1997 Letter to Jehovah’s Witness Elders	188-4 Exhibit D	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
188-5 Exhibit E – 1991 Elder’s Manual Excerpt	188-5 Exhibit E – Elder’s Manual 1991	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
188-6 Exhibit F – July 20th, 1998 Letter to Jehovah’s Witness Elders	188-6 Exhibit F	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
188-7 Exhibit G – December 1989 S-77 Disfellowshipping Notice	188-7 Exhibit G	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower disfellowshipping s-77
189-0 Plaintiff’s Motion to Amend Complaint	189-0 Motion to Amend Complaint	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
189-1 Exhibit A – Second Amended Complaint	189-1 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
19-0 Answer Filed	19-0 Answer Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
19-0 Defendant Watchtower Preliminary Pretrial Statement	Defendant preliminary statement	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
190-0 Plaintiff’s Brief in Support of Motion to Amend Complaint	190-0 Plaintiffs Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
190-1 Exhibit 1 – Redlined Second Amended Complaint	190-1 Exhibit 1	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
191-0 Plaintiff’s Motion to Compel All Discoverable Docs from Watchtower New York	191-0 Plaintiffs Motion to Compel Docs	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
191-1 Watchtower Responses to First Set of Discovery	191-1 Watchtower Responses to Discovery	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
192-0 Plaintiff’s Brief Supporting Motion to Compel All Discoverable Documents	192-0 Plaintiffs Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
192-1 Exhibit A – 1972 Kingdom Ministry School Course Excerpt	192-1 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower kingdom-ministry-school
192-10 Exhibit J – Memorandum Letter from Philip Brumley to Watch Tower Pennsylvania	192-10 Exhibit J	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley
192-11 Exhibit K – Gary Breaux Declaration from Vigue v Watchtower Case	192-11 Exhibit K	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower gary-breaux
192-12 Exhibit L – 2021 Service Department Document	192-12 Exhibit L	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower service-department
192-13 Exhibit M – Watchtower New York Corporation Document, Gary Breaux	192-13 Exhibit M	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower gary-breaux
192-14 Exhibit N – Declaration of Douglas Chappel from Lewis v Bellows Falls Case	192-14 Exhibit N	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower douglas-chappel
192-15 Exhibit O – Letter from Brown Law to MSS Law Firm	192-15 Exhibit O	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
192-16 Exhibit P Watch Tower 2nd Supplemental Responses to Plaintiff’s 2nd Set of Jurisditional Discovery	192-16 Exhibit P WT Responses	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
192-17 Exhibit Q – 1982 Watchtower NY Incorporation Docs	192-17 Watchtower Inc. Docs 1982	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
192-2 Exhibit B -1978 Circuit Overseer Report	192-2 Exhibit B	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower circuit-overseer
192-3 Exhibit C – Watchtower Response to 2nd Set of Request for Productions and Interrogatories	192-3 Exhibit C	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
192-4 Exhibit D – Mario Moreno Deposition Excerpt from Jose Lopez Case	192-4 Exhibit D	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower mario-moreno
192-5 Exhibit E – Allen Shuster Deposition Excerpt from Doe v Watchtower Case	192-5 Exhibit E	caecaert-v-watchtower montana civil-lawsuits-united-states	allen-shuster caekaert-v-watchtower
192-6 Exhibit F – Jehovah’s Witness Governing Body and Helpers List	192-6 Exhibit F	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower govern
192-7 Exhibit G – Mario Moreno Deposition from Delgado v Jehovah’s Witnesses Case	192-7 Exhibit G	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower mario-moreno
192-8 Exhibit H – Mario Moreno Deposition from Charissa v Watchtower Case	192-8 Exhibit H	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower mario-moreno
192-9 Exhibit I – Philip Brumley Affidavit from Does v Watchtower Texas	192-9 Exhibit I	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley
193-0 Watchtower Response Brief in Opposition to Motion to Compel	193-0 Watchtower Response Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
193-1 Exhibit A – January 1st, 1997 Watchtower	193-1 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
193-2 Exhibit B – March 14th 1997 Letter to Jehovah’s Witness Elders	193-2 Exhibit B	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
193-3 Exhibit C – July 20th, 1998 Letter to JW Elders	193-3 Exhibit C	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
194-0 Affidavit of Thomas Jefferson Jr.	194-0 Thomas Jefferson Jr. Affidavit	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower thomas-jefferson-jr
195-0 Plaintiffs Motion to Compel In Camera Review of Documents	195-0 Plaintiffs Motion for In Camera Review	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
196-0 Plaintiff’s Brief Supporting Motion for In Camera Review of Documents	196-0 Plaintiffs Brief for Doc Review	caecaert-v-watchtower montana civil-lawsuits-united-states	c caekaert-v-watchtower
196-1 Exhibit A – July 1st 1989 Letter to Elders	196-1 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
196-2 Exhibit B Documents Withheld by WTNY for Attorney Client Privilege	196-2 Exhibit B Docs Withheld by WTNY	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
196-3 Exhibit C – Email and Privilege Log	196-3 Exhibit C	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower privilege-log
196-4 Exhibit D – Defendant’s Responses to Fourth Set of Request for Production	196-4 Exhibit D	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
196-5 Exhibit E – Defendant’s Responses to Third Set of RFPs	196-5 Exhibit E	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
197-0 Plaintiffs Motion for Status Conference	197-0 Plaintiffs Motion for Status Conference	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
197-1 Proposed Order for Status Conference	197-1 Proposed Order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
198-0 Watchtower Response Brief Opposing Plaintiffs Motion to Amend Complaint	198-0 Watch Tower Response Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
198-1 Watch Tower Pennsylvania Responses to 1st Set of Jurisdictional Discovery	198-1 Watch Tower Responses	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
198-2 Watch Tower Pennsylvania Responses to Plaintiffs 2nd Set of Jurisdictional Discovery	198-2 Watch Tower Responses	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
198-3 Watch Tower PA First Supplemental Responses to Plaintiffs 2nd Set of Jurisdictional Discovery	198-3 Watch Tower PA Responses	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
199-0 Watchtower Response to Motion to file 2nd Amended Complaint	199-0 Watchtower Response	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
Document 2-0	Document 2-0	denise-jackson-versus-watchtower child-victims-act-cases-new-york civil-lawsuits-united-states	jackson-v-watchtower
2-0 520772_2021_Deborah_Hines_v_Deborah_Hines_ORDER___ADMINISTRAT_2	…	hines-versus-watchtower child-victims-act-cases-new-york civil-lawsuits-united-states	hines-versus-watchtower
2-0 Application for Summary Relief	2-0 Application for Summary Relief	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
2-0 Philip Brumley Mediation Questionnaire	2-0 Mediation Questionnaire	philip-brumley-sanctions-appeal montana civil-lawsuits-united-states	philip-brumley philip-brumley-sanctions-appeal
20-0 Notice of Errate to Complaint and Jury Demand	Notice of Errate	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
20-0 Order Filed	20-0 Order Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
20-1 Affidavit of Mark O’Donnell and July 1989 WT Letter to Elders	Mark O’Donnell Affidavit	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
200-0 Order on Conference and Scheduling	200-0 Conference Order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
201-0 Plaintiff’s Reply in Support of their Motion to Amend	201-0 Plaintiffs Reply	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
202-0 Watchtower Response Brief Opposing Motion to Compel	202-0 Watchtower Response Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
202-1 Watch Tower Responses to Plaintiff’s First Set of Jurisdictional Discovery	202-1 Watch Tower Responses Nov. 2020	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley
203-0 Plaintiffs Reply Brief RE Motion to Compel Non Privileged Documents	203-0 Plaintiffs Reply Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
204-0 Watchtower Response Brief Opposing In Camera Document Review	204-0 Watchtower Response	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
204-1 Affidavit of Mario Moreno	…	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower mario-moreno
204-2 Privilege Log	204-2 Privilege Log	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
206-0 Plaintiff’s Reply Brief Supporting Motion to Compel	206-0 Plaintiffs Reply Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
206-1 Exhibit A – Watchtower New York Corporation Document – 1982	206-2 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
206-2 Exhibit B – US Branch Office Brochure	206-2 Exhibit B	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
207-0 Plaintiff’s Reply in Support of Motion to Amend	207-0 Plaintiffs Reply	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
207-1 Exhibit A – Watchtower New York Corporation Document -1982	207-1 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
207-2 Exhibit B – US Branch Office Brochure	207-2 Exhibit B	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
208-0 Plaintiff’s Reply Supporting Motion to Compel Documents Withheld	208-0 Plaintiffs Reply, Motion to Compel	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
208-1 Exhibit A – Ethics Opinion	201-1 Exhibit A – Ethics Opinion	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
208-2 Exhibit B – Michael Penkava Judgment – Illinois	208-2 Exhibit B – Penkava Judgment	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
208-3 Exhibit C – Colin Scott Motion, Illinois	208-3 Exhibit C – Colin Scott Motion	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
209-0 Errata, Correction of Document 207	209-0 Errata for Doc 207	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
21-0 Answer and New Matter	21-0 Answer and New Matter	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
21-0 Plaintiff’s Response to Motion to Dismiss	Plaintiffs response to motion	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
21-1 Jehovah’s Witness FAQ Page	Doc 21-1 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
21-2 July 1st, 1989 BOE Letter and 1975 KM	Doc 21-2 Exhibit B	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
21-3 September 18th, 1970 Watch Tower Letter	Doc 21-3 Exhibit C	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
21-4 Watch Tower Letter to BBC reporter Betsan Powys	Doc 21-4 Exhibit D	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
210-0 Plaintiff’s Notice of Fully Briefed Motions	210-0 Plaintiffs Notice	caecaert-v-watchtower privilege-logs montana civil-lawsuits-united-states	caekaert-v-watchtower
211-0 Watchtower Motion for Leave to File Surreply	211-0 Watchtower Motion for Leave	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
212-0 Watchtower Brief Supporting Motion to File Surreply	February 28th, 2023 …	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
213-0 Notice of Appearance – Victoria Gannon	213-0 Notice of Appearance	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
215-0 Plaintiffs Opposition to Watchtower New York Motion for Leave	215-0 Plaintiffs Opposition to Motion for Leave	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
216-0 Subpoena Duces Tecum for Kona English Congregation of Jehovahs Witnesses	216-0 Subpoena Duces Tecum	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
217-0 Order on Motion to Compel	217-0 Order on Motion to Compel	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
218-0 Certificate of Service	218-0 Certificate of Service	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
218-0 Watchtower Reply Brief in Support of Motion for Leave to File Surreply	218-0 Watchtower Reply Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
218-1 – Exhibit A: Hardin Privilege Log	218-1 Exhibit A – Hardin Privilege Log	caecaert-v-watchtower privilege-logs montana civil-lawsuits-united-states	caekaert-v-watchtower
218-2 Exhibit B: West Laurel Privilege Log and Affidavit of Marty Merrifield	218-2 Exhibit B – West Laurel Privilege Log	caecaert-v-watchtower privilege-logs montana civil-lawsuits-united-states	caekaert-v-watchtower
218-3 – Exhibit C: Watchtower Draft Surreply Brief Opposing Motion to Compel	218-3 Exhibit C – WT Draft Surreply	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
219-0 Order on Sanctions Against Watch Tower Attorney Phillip Brumley	219-0 Order on Sanctions Against Phillip Brumley	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley
22-0 First Amended Complaint and Jury Demand	First Amended Complaint	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
22-0 Order Filed	22-0 Order Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
22-1 Affidavit of Shirley Gibson	Doc 22-1 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
22-2 Affidavit of James Rowland	Doc 22-2 Exhibit B	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
22-3 Affidavit of Mark ODonnell and July 1989 BOE Letter	Doc 22-3 Exhibit C	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
22-4 1975 Montana Reporting Codes	Doc 22-4 Exhibit 4	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
220-0 Order on Motion to Amend Settled Party Defense	220-0 Order on WTNY Motion	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
220-0 Plaintiffs Notice of Taking Rule 30(b)(6) Depositions	220-0 Plaintiffs Notice of Depositions	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
221-0 Order on Watch Tower Motion to Amend Answer	221-0 Order on WT PA Motion to Amend Answer	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
222-0 Order on Motions to Compel Depositions	222-0 Order on Plaintiffs Motions	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
223-0 Watchtower Motion to Compel Responses from Camillia Mapley	223-0 WT Motion to Compel	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
224-0 Watch Tower Pennsylvania Brief In Support of Motion to Compel Responses from Camillia Mapley	224-0 WT PA Brief in Support of Motion to Compel	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
225-0 Watchtower Amendment to Answer to First Amended Complaint	225-0 Watchtower Amendment to Answer	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
226-0 Watch Tower Pennsylvania Amended Answer to 1st Amended Complaint	226-0 WT PA Amended Answer	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
227-0 Notification of Satisfaction of Sanctions Order Against Philip Brumley	227-0 Brumley Sanctions Paid	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley
228-0 Notice of Appeal by Philip Brumley	228-0 Notice of Brumley Appeal	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley
228-1 Brumley Representation of Appeal 9th Circuit	228-1 Brumley Representation	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley
229-0 Plaintiff’s Response Brief Opposing Watch Tower Pennsylvania Motion to Compel Responses from Camillia Mapley	229-0 Plaintiffs Response Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
229-1 – Exhibit A: Deposition Excerpt Camillia Mapley	229-1 Exhibit A – Deposition Excerpt	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
229-2 Exhibit B: Proposed Stipulation	229-2 Exhibit B- Proposed Stipulation	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
23-0 Answer to New Matter	23-0 Answer to New Matter	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
23-0 Plaintiffs Preliminary Pretrial Statement	Plaintiffs pretrial statement	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
230-0 Notice of Appeal by Philip Brumley to US Court of Appeals, Ninth Circuit	230-0 Philip Brumley Notice of Appeal	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley
230-1 U.S. Court of Appeals Representation Statement of Philip Brumley	230-1 Representation Statement	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley
231-1 Watch Tower Proposed Order for Extension of Time	231-1 Proposed Order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
231-0 Watch Tower Pennsylvania Unopposed Motion for Reply Extension	231-0 WT PA Motion for Extension	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
232-0 Order on Watch Tower Pennsylvania Time Extension	232-0 Order on Extension	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
233-0 Time Schedule Order For Philip Brumley Appeal to Ninth Circuit Court	233-0 Brumley Appeal Schedule Order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley
234-0 Watchtower New York Motion for Protective Order	234-0 WT Motion for Protective Order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
235-0 Watchtower Brief in Support of Motion for Protective Order	235-0 WT Brief in Support of Protective Order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
236-0 Affidavit in Support of Watchtower Motion for Protective Order	236-0 WT Affidavit in Support of PO	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
237-0 Order on Motion to Compel Production of Documents	237-0 Order Compelling Production	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
238-0 Order On Plaintiffs Motion to Amend Complaint	238-0 Order on Motion to Amend Complaint	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
239-0 Order on Production of Non Privileged Documents Withheld by Watchtower New York	239-0 Order on Production of NP Documents	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
24-0 Application to Strike	24-0 Application to Strike	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
24-0 Scheduling Order	July 21st, 2020 Judge Watters issues scheduling order for Caekaert-Mapley versus …	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
240-0 Order on Production of Documents Withheld by Watchtower New York for Attorney-Client Privilege	240-0 Order on Production of AC Documents Withheld	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
241-0 Watch Tower Pennsylvania’s Reply Brief In Support of Motion to Compel Responses By Plaintiff	241-0 Watch Tower Reply Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
241-1 Exhibit A – April 27th 2023 Letter From Defendant’s Law Firm to Plaintiff’s Law Firm	241-1 Exhibit A – 4.27.23 Letter	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
241-2 Exhibit B – May 5th 2023 Letter from Defendant’s Law Firm to Plaintiff’s Law Firm	241-2 Exhibit B Letter	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
242-0 Redacted Plaintiffs Motion to Compel Documents from Watchtower	242-0 Plaintiffs Motion to Compel Documents	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
242-0 Watchtower Notice of Submission of Documents for In Camera Review	242-0 WT Notice of Doc. Submission	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
243-0 Exhibits 1-11 – CP Redacted	243-0 Exhibits 1-11 Redacted	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york s-77
243-0 Plaintiff’s Response Brief Opposing Watchtower Motion for Protective Order	243-0 Plaintiffs Opposition to WT Motion	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
243-1 Exhibit A – Excerpts from 2012 Transcript of Deposition of Allen Shuster	243-1 Exhibit A – Allen Shuster Excerpt	caecaert-v-watchtower montana civil-lawsuits-united-states	allen-shuster caekaert-v-watchtower
243-2 Exhibit B – Excerpts from February 2012 Allen Shuster Deposition Transcript	243-2 Exhibit B-Excerpt from Shuster Dep.	caecaert-v-watchtower montana civil-lawsuits-united-states	allen-shuster caekaert-v-watchtower
243-3 Exhibit C – Excerpts from May 2015 Transcript of Deposition of Gary Breaux Vol I	243-3 Exhibit C – Excerpt from Gary Breaux Dep.	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
243-4 Exhibit D – October 2006 Declaration of Gary Breaux	243-4 Exhibit D – Dec. of Gary Breaux	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower gary-breaux
243-5 Exhibit E – August 26th 2022 Watchtower New York’s Responses to Plaintiffs RFPs 40 and 38	June 1st, 2023 Full docket text for document 243: RESPONSE to Motion re [234] MOTION for Protective Order Pursuant to Fed. R. Civ. P 26(c) filed by Tracy Caekaert, Camillia Mapley. Attachments: # (1) Exhibit A Excerpts from 2012-03-27 Transcript of Depo of Allen Shuster, # (2) Exhibit B Excerpts from 2012-02-15 Allen Shuster Depo. Transcript, # (3) Exhibit C Excerpts from 2015-05-29 Transcript of Depo of Gary Breaux Vol I, # (4) Exhibit D 2006-10-03 Decl. of Gary Breaux, # (5) Exhibit E 2022-08-26 WTNY’s Responses to Pls’ RFPs 40 & 38, # (6) Exhibit F Doc. 18 2003-06-05 DFs’ Witness Disclsoures, # (7) Exhibit G WTPA & WTNY Answers to Discovery) (Shaffer, …	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
243-6 Exhibit F – Document 18 -June 5th 2003 Defendant’s Witness Disclosures	243-6 Exhibit F -Doc 18 Def. Disclosures	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
243-7 Exhibit G -WT Pennsylvania and WT New York Answers to Discovery	243-7 Exhibit G – WT Answers to Discovery	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
244-0 Plaintiffs Notice of Filing Exhibits Previously Protected by Order	244-0 Plaintiffs Notice of Exhibits	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
244-1 Exhibit A – 2012 Deposition of Allen Shuster From Dorman / Gamboa Case	244-1 Exhibit A – Dep. of Allen Shuster	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
244-2 Exhibit C – 2015 Deposition Excerpt of Gary Breaux From Doe v. Watchtower	Exhibit C – 2015 Dep. of Gary Breaux	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower gary-breaux
245-0 Order on Motion to Compel Responses from Plaintiffs	245-Order on Motion to Compel Responses	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
246-0 Watch Tower Pennsylvania Notice RE: No Transcripts Ordered for Appeal	246-0 Watch Tower Notice	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley
247-0 Watchtower Reply Brief in Support of Motion for Protective Order	247-0 Watchtower Reply Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
248-0 Plaintiff’s Motion to Strike and Order Depositions Taken As Noticed	248-0 Plaintiffs Motion to Strike	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
249-0 SUPPLEMENTAL DECLARATION OF ASHLEY A. ESCUDERO IN SUPPORT OF EX PARTE APPLICATION FOR ADMISSION OF DONALD T. RIDLEY, ESQ. PRO HAC VICE	249-0 Declaration of Ashley Escudaro	lopez-v-watchtower california civil-lawsuits-united-states	jose-lopez-versus-watchtower
249-0 Order Regarding Confidentiality of Discovery	249-0 Order Regarding Confidentiality of Discovery	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
249-0 Plaintiff’s Brief in Support of Motion to Strike and Order Depositions Taken as Noticed	249-0 Plaintiffs Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
249-1 Exhibit A – September 27th 2022 Email from R. Shaffer to J. Wilson	249-1 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
249-10 Exhibit J 2023 05 17 Letter to Counsel Providing Breaux, Smalley and Shuster NODs	249-10 Exhibit J	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
249-11 Exhibit K – September 28th 2022 Email from R. Shaffer to C. Sweeney	249-11 Exhibit K	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
249-12 Exhibit L – September 29th 2022 Email from J. Wilson to R. Shaffer	249-12 Exhibit L	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
249-13 Exhibit M – Ethics Opinion 940430	249-13 Exhibit M	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
249-14 Exhibit N Rule 4.2	249-14 Exhibit N	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
249-2 Exhibit B – September 28th 2022 Email from C. Sweeney to R. Shaffer	249-2 Exhibit B	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
249-3 Exhibit C – September 29th 2022 Letter to DFs re Depositions	249-3 Exhibit C	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
249-4 Exhibit D October 4th 2022 Letter to Counsel re Depos	249-4 Exhibit D	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
249-5 Exhibit E October 5th 2022 Email from B. Jensen to R. Shaffer	249-5 Exhibit E	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
249-6 Exhibit F April 19th, 2023 Email from R. Shaffer to J. Wilson	249-6 Exhibit F	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
249-7 Exhibit G April 26th 2023 JM Email to WTNY re Deps of Shuster, Breaux, Smalley	249-7 Exhibit G	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
249-8 Exhibit H May 1st 2023 – WTNY’s Resp. Letter re: Shuster, Breaux, & Smalley Depos.	249-8 Exhibit H	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
249-9 Exhibit I May 3rd 2023 WTNY’s Resp. Letter re Shuster, Breaux, & Smalley Depos.	249-9 Exhibit I	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
25-0 Brief in Support of Watch Tower PA Motion to Dismiss	WT PA Reply Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
25-0 Order Filed	25-0 Order Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
25-0 Plaintiffs Memorandum Opposing Motion to Dismiss Complaint	25-0 Plaintiffs Memorandum	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
250-0 Watchtower Response Brief RE: Plaintiff’s Motion to Strike and Order Depositions Taken as Noticed	250-0 Watchtower Response Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
250-1 Affidavit Jon W. Wilson	250-1 Affidavit Jon W. Wilson	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
250-2 Exhibit 1 – June 21st, 2023 Watchtower NY Counsel Letter to Plaintiffs Counsel	250-2 Exhibit 1	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
250-3 Exhibit 2 – April 26th 2023 Plaintiff’s Counsel Letter to WTNY Counsel	250-3 Exhibit 2	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
250-4 Exhibit 3 – May 1st, 2023 Plaintiff’s Counsel Letter to WTNY Counsel	250-4 Exhibit 3	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
250-5 Exhibit 4 – May 15th, 2023 Plaintiff’s Counsel Letter to WTNY	250-5 Exhibit 4	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
252-0 Plaintiff’s Reply Brief Supporting Motion to Strike and Order Depositions Taken as Noticed	252-0 Plaintiffs Reply Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
253-0 Order on Production of Documents	253-0 Order on Production	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
255-0 Order on Production of Documents and Order to Seal	255-0 Order On Docs and Seal	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
257-0 Transcript Order Form	257-0 Transcript Order Form	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
258-0 US Court of Appeals Notice re Philip Brumley Appeal	258-0 US Court of Appeals Notice	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley
26-0 Order Filed	26-0 Order Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
263-0 Defendants Memorandum in Opposition to Plaintiffs Motion to Compel Document Production	263-0 Defendants Memorandum	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york thomas-jefferson-jr
265-0 Plaintiff’s Reply Memorandum in Support of Motion to Compel Documents from Watchtower	265-0 Plaintiff’s Reply Memorandum	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
267-0 Motion to Quash Order Compelling Testimony of Gerrit Losch	267-0 Motion to Quash	lopez-v-watchtower california civil-lawsuits-united-states	gerrit-losch governing-body-of-jehovahs-witnesses jose-lopez-versus-watchtower
27-0 Order Granting Application to Strike	27-0 Order Granting Application to Strike	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
27-0 Watchtower New York Answer to First Amended Complaint	Watchtower Answer to Complaint	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
270-0 Defendants Notice of Submission for In Camera Review	270-0 Defendants Notice of Submission for In Camera Review	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
28-0	…	sort-test montana civil-lawsuits-united-states
28-0 Plaintiff’s Motion to Supplement Record	Motion to Supplement Record	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
Document 29-0 Hines versus Watchtower	Stipulation of Continuance	hines-versus-watchtower child-victims-act-cases-new-york civil-lawsuits-united-states	hines-versus-watchtower jehovahs-witnesses-child-abuse
29-0 Petitioner’s Brief Filed	29-0 Petitioner’s Brief Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
29-0 Plaintiff’s Brief Supporting Motion to Supplement Record	Brief Supporting Plaintiffs Motion	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
29-1 Letter from Writing Committee to Australia	Doc 29-1 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
29-2 Watch Tower PA London Letter on Ecclesiastical Privilege	Doc 29-2 Exhibit B	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
29-3 Watch Tower PA 1995 BOE Letter	Doc 29-3 Exhibit C	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
29-4 Watch Tower PA Nov 1st, 1995 BOE UK Letter	Doc 29-4 Exhibit D	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
29-5 Watch Tower PA Holocaust Letter by Carolyn R. Wah	Doc 29-5 Exhibit E	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
3-0 Bruce Mapley Letter to US District Court	Bruce Mapley Email	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
3-0 Order Filed	3-0 Order Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
3-1 Summons for Bruce Mapley	Bruce Mapley Summons	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
30-0	…	sort-test montana civil-lawsuits-united-states
30-0 Notice of Service of Previously Filed Documents to Unrepresented Party	Notice of Service	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
30-0 Order Filed	30-0 Order Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
31-0 Respondent’s Brief Filed	31-0 Respondent’s Brief Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
31-0 Watch Tower Response to Plaintiffs Motion to Supplement Record	Watch Tower Opposition Motion	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
319-0 Order Granting Plaintiffs Motion to Compel Document Production	319-0 Order Granting Plaintiffs Motion	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
32-0 Order Providing for Jurisdictional Discovery	Order for Jurisdictional Discovery	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
32-0 Petitioner’s Reply Brief Filed	32-0 Petitioner’s Reply Brief Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
321-0 Stipulated Protective Order	321-0 Stipulated Protective Order	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
329-0 Redacted Version of Defendants Memorandum in Support of Motion for Summary Judgment	329-0 Redacted Version of Defendants Memorandum	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
33-0 Defendants Pro Hac Vice Motion for Joel Taylor	Def. Pro Hac Vice Motion	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower joel-m-taylor
33-0 Letter	33-0 Letter	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
33-1 Declaration of Joel Taylor	Joel Taylor Declaration	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower joel-m-taylor
33-2 Proposed order on Joel Taylor	Proposed Order re: Joel Taylor	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
333-0 Plaintiffs Motion to Hold Defendants in Contempt and Imposition of Sanctions	333-0 Plaintiffs Motion for Contempt	nd-versus-watchtower hawaii civil-lawsuits-united-states	joel-m-taylor n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
34-0 Notice of Appeal to PA Supreme Court Filed	34-0 Notice of Appeal to PA Supreme Court	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
34-0 Order on Admission of Joel M. Taylor	Joel Taylor Admission	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower joel-m-taylor
35-0 District Court Letter to Joel Taylor	Letter to Joel Taylor	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower joel-m-taylor
36-0	…	sort-test montana civil-lawsuits-united-states
36-0 Joint Discovery Plan	Joint Discovery Plan	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
365-0 Defendants Opposition to Plaintiffs Motion to Hold Defendants in Contempt, and for Sanctions	365-0 Defendants Opposition to Plaintiffs Motion	nd-versus-watchtower hawaii civil-lawsuits-united-states	joel-m-taylor n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
366-0 Declaration of William S. Hunt	366-0 Declaration of William S. Hunt	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
37-0 Joint Statement of Inability to Stipulate to any Facts	Joint Statement re: Stipulation	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
38-0 Watch Tower Pennsylvania Preliminary Pretrial Statement	WT PA pretrial statement	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
380-0 Order Granting Defendants Ex Parte Motion to Seal Exhibits A and C	380-0 Order Granting Defendants Motion	nd-versus-watchtower hawaii civil-lawsuits-united-states	joel-m-taylor n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
382-0 Defendants Final Naming of Witnesses	382-0 Defendants Final Naming of Witnesses	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
384-0 Plaintiffs Reply in Support of Motion to Hold Defendants in Contempt and Sanctions	384-0 Plaintiffs Reply in Support of Motion	nd-versus-watchtower hawaii civil-lawsuits-united-states	joel-m-taylor n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
39-0 Watchtower New York Preliminary Pretrial Statement	WT NY pretrial statement	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
First Amended Summons and Complaint for Damages	First Amended Complaint	terril-enholm-versus-jehovahs-witnesses washington-state civil-lawsuits-united-states	deryk-terril-and-daniel-enholm-versus-watchtower john-earl-jones terril-and-enholm-v-ccjw
4-0 District Court Response to Bruce Mapley	May 20th, 2020 Letter from the Clerk of the US District Court to Bruce …	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
4-0 Motion to Dismiss Philip Brumley Appeal for Lack of Appellate Jurisdiction and for Sanctions	4-0 Motion to Dismiss Brumley Appeal	philip-brumley-sanctions-appeal montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley philip-brumley-sanctions-appeal
4-0 Preliminary Objections	4-0 Preliminary Objections	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
40-0 Plaintiff’s Preliminary Pretrial Statement	Plaintiff Pretrial Statement	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
416-0 Proposed Order Denying Plaintiffs Motion to Hold Defendants in Contempt	416-0 Proposed Order	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
42-0 Jurisdictional Discovery Scheduling Order	Discovery Scheduling Order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
427-0 Defendants Renewed Motion for Summary Judgment	427-0 Defendants Renewed Motion for Summary Judgment	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
43-0 Notice of Appearance of Aaron Dunn for Watch Tower	Notice of Appearance	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
434-0 Exhibit 1 in Support of Defendants Renewed Motion for Summary Judgment	434-0 Exhibit 1	nd-versus-watchtower hawaii civil-lawsuits-united-states	kenneth-apana n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
438-0 Order Denying Plaintiffs Motion to Hold Defendants in Contempt	438-0 Order Denying Plaintiffs Motion	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
44-0 Plaintiffs Brief RE: Scope of Jurisdictional Discovery	Jurisdictional Discovery Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
44-1 Exhibit A – Branch Organization 1977	Branch Organization 1977	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
44-2 Exhibit B – Kingdom Ministry School Course, 1972	KM School Manual for Elders	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
44-3 1989 Watchtower	44-3 Exhibit C	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
44-4 1989 Letter to Australia Branch	44-4 Exhibit D	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
45-0 Bruce Mapley Consent to Electronic Service	Mapley document consent	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
46-0 Letter from Bruce Mapley	Bruce Mapley Letter	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
47-0 Order Re: Scope of Jurisdictional Discovery	Order on Scope of Discovery	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
48-0 Motions RE: Discovery Scheduling Order	Motion on Scheduling Order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
48-1 Proposed Order	Proposed scheduling order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
49-0 Order on Discovery Scheduling	Order Granting Extension	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
5-0 Answer Filed	5-0 Answer Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
5-0 Notice of Appearance for Defendants	Def. Notice of Appearance	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
5-1 Order Granting Defendants Time for Response	Proposed Order on Extension	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
50-0	…	sort-test montana civil-lawsuits-united-states
50-0 Motion for Protective Order	Motion for Protective Order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
50-1 Stipulated Protective Order	Protective Order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
50-2 Proposed Order on Protective Order	Proposed Order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
51-0 Order Granting Protective Order	Order Granting Prot. order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
52-0 Plaintiff’s motion for status conference	Motion for Status Conference	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
52-1 Proposed Order	Proposed Status Conf Order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
53-0 Order Setting Status Conference for April 13th, 2021	Order setting conference	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
54-0 Plaintiff’s Notice of Discovery	Plaintiff’s Discovery Notice	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
55-0 Order RE: Deposition Completions	Order RE: deposition deadline	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
56-0 Motion to Compel Discovery Responses	Motion to Compel Watchtower	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
57-0 Plaintiff’s Brief Supporting Motions to Compel	Plaintiff’s Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
57-1 March 8th, 2021 Watch Tower PA Resp. to RFP 61	Doc 57 Exhibit A	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
57-10 March 8th, 2021 Watch Tower Responses	Doc 57-10 Exhibit J	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
57-11 December 29th, 2020 Watch Tower Responses	Doc 57-11 Exhibit K	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
57-12 March 8th, 2021 Watch Tower Responses	Doc 57-12 Exhibit L	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
57-2 March 22nd, 2021 Brown Law Correspondence	Doc 57-2 Exhibit B	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
57-3 1972 Kingdom Ministry School Course	Doc 57-3 Exhibit C	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
57-4 November 1st 1995 Watch Tower Letter	Doc 57-4 Exhibit D	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
57-5 March and April 2021 WT PA Resp. to RFPs	Doc 57-5 Exhibit E	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
57-6 Watchtower New York Answer to Plaintiffs Ints 6,7	Doc 57-6 Exhibit F	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
57-7 Branch Organization Excerpt	Doc 57-7 Exhibit G	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
57-8 WT New York and PA Answers to Ints	Doc 57-8 Exhibit H	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
57-9 S-2b Forms – Servant Recommendations	Doc 57-9 Exhibit I	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
58-0 Plaintiff’s Motion to Compel	Plaintiffs Motion to Compel	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
59-0 Plaintiff’s Brief Supporting Motion to Compel	Plaintiffs Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
59-1 Subpoena Duces Tecum	Subpoena to Hardin Congregation	caecaert-v-watchtower subpoenas montana civil-lawsuits-united-states	caekaert-v-watchtower subpoena-duces-tecum
59-2 Hardin Response to Subpoena	Hardin Response to Subpoena	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
59-3 Hardin Congregation Privilege Log	Hardin Privilege Log	caecaert-v-watchtower privilege-logs montana civil-lawsuits-united-states	caekaert-v-watchtower privilege-log
6-0 Answer to Preliminary Objections	6-0 Answer to Preliminary Objections	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
6-0 Order Granting Extension to Watchtower	Order Granting Extension	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
6-0 Summons Served on Watch Tower Pennsylvania	6-0 Summons	rowland-v-watchtower montana civil-lawsuits-united-states
60-0 Certificate of Service	Certificate of Service	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
61-0 Watch Tower Motion for Extension	Motion for Time Extension	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
61 1 Order Granting Watch Tower Extension	Proposed order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
614-0 Opposition to Motion to Modify Protective Order	Opposition to Modify Protective Order	lopez-v-watchtower california civil-lawsuits-united-states	jose-lopez-versus-watchtower
62-0 Order Denying Motion to Dismiss	62-0 Order Denying Mot. to Dismiss	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
62-0 Order Granting Motion for Extension	Order granting extension	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
628-0 Order Granting Plaintiffs Motion to File Memorandum Under Seal	628-0 Order Granting Plaintiffs Motion	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
63-0 Hardin Congregation Motion to Intervene	Hardin Congregation Motion	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
63-1 Brief Opposing Motion to Compel	Hardin Opposition Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
64-0 Hardin Congregation Brief	Hardin Congregation Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
65-0 Order Granting Hardin Congregation Motion	Order Granting Hardin Motion	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
654-0 Partial Stipulation for Dismissal With Prejudice of Claims against MCJW and WTNY	654-0 Partial Stipulation for Dismissal	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
655-0 Notice of Electronic Filing	655-0 Notice of Electronic Filing	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
66-0 Hardin Congregation Brief Opposing Plaintiffs Motion to Compel RE: Subpoena	Hardin Opposition Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
661-0 Plaintiffs Motion for Default Judgment Against Kenneth Apana	661-0 Plaintiffs Motion for DJ	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
665-0 Order Granting Plaintiffs Motion to File Exhibits 1-6 Under Seal	665-0 Order Granting Plaintiffs Motion	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
667-0 Notice of Disaffiliation and Appearance	667-0 Notice of Disaffiliation	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
67-1 Joint Jurisdictional Discovery Plan	Doc 67 Exhibit 1	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
67-2 – Letter to Plaintiffs Counsel	Doc 67-2 Exhibit 2	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
67-3 Letter to Plaintiffs Counsel February 12th, 2021	Doc 67-3 Exhibit 3	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
67-4 Letter to Plaintiffs Counsel March 22nd, 2021	Doc 67-4 Exhibit 4	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
67-5 Letter to Plaintiffs Counsel April 8th, 2021	Doc 67-5 Exhibit 5	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
67-6 Pages from Watchtower NY Responses	Doc 67-6 Exhibit 6	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
67-7 Pages from Watch Tower PA Responses	Doc 67-7 Exhibit 7	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
67-8 Pages from Watchtower NY Responses 2	Doc 67-8 Exhibit 8	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
67-9 Pages from Watch Tower PA Responses 2	Doc 67-9 Exhibit 9	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
67-0 Watch Tower Response Brief	Watch Tower Response Brief	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
670-0 Prop Findings of Facts, Conclusions of Law and Order	670-0 Prop Findings of Facts	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
672-0 Notice of Electronic Filing	672-0 Notice of Electronic Filing	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
673-0 Findings of Fact ,Conclusions of Law and Order	673-0 Findings of Fact	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
675-0 Judgment Against Kenneth Apana	675-0 Judgment Against Kenneth Apana	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
68-0 Answer and Affirmative Defenses	68-0 Answer and Affirmative Defenses	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
68-0 Defendants Joinder in Hardin Brief	Watchtower Joinder with Hardin	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
69-0 Plaintiff’s Reply in Support of Motion to Compel RE: Hardin Subpoena	Plaintiffs Reply to Hardin Congregation	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
Document 7-0 Hines Versus Watchtower	August 31st, 2021 – Defendant’s Standard Combined Demands Directed at …	hines-versus-watchtower child-victims-act-cases-new-york civil-lawsuits-united-states	hines-versus-watchtower
7-0 Mailing of Consent Form 5 22 2020	7-0 Mailing of Consent Form	rowland-v-watchtower montana civil-lawsuits-united-states	rowland-v-watchtower
7-0 Order Filed	7-0 Order Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
7-0 Preliminary Pretrial Conference Order	Pretrial Conference Order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
70-0 Hardin Congregation Motion for Oral Argument RE Subpoena	Hardin motion for Oral Arguments	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
71-0 Order Granting Hardin Motion	Order granting Oral Arguments	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
72-0 Plaintiff’s Reply Supporting Motion to Compel Responses	Plaintiffs Reply RE: Jurisdiction	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
72-1 JW Organization Book	Doc 72: Exhibit 1: JW Org book	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
72-2 James Rowland Deposition	Doc 72: Ex. 2 James Rowland	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
72-3 Exhibit 3 – Watch Tower Responses	Doc 72: Exhibit 3	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
73-0 Defendants’ Request for Oral Arguments	Request for Oral Arguments	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
74-0 Order Setting Date for Oral Arguments	Order granting Oral Arguments	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
76-0 Watch Tower Motion RE: Oral Arguments – Joel Taylor	Motion RE: Joel Taylor	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
76-1 Proposed Order RE: Oral Arguments Joel Taylor	Proposed order RE: Oral Arguments	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
77-0 Order Granting Joel Taylor Appearance	Order on Taylor Remote App.	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
79-0 Certificate of Service	79-0 Certificate of Service	nd-versus-watchtower hawaii civil-lawsuits-united-states	n-d-versus-makara-congregation-of-jehovahs-witnesses-and-watchtower-new-york
79-0 Order Re: Motion to Compel Hardin Congregation’s Subpoena	Order on Motion to Compel	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
Document 8-0 Hines versus Watchtower	Discovery Demands	hines-versus-watchtower child-victims-act-cases-new-york civil-lawsuits-united-states	child-victims-act-new-york hines-versus-watchtower
8-0 Respondent’s Brief Filed	8-0 Respondent’s Brief Filed	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
8-0 Summons Served on Watchtower New York	Watchtower NY Summons	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
80-0 Notice of Hardin Submission for In Camera Review	Documents submitted to judge	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
82-0 Order on Motion to Compel	Order on document production	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
83-0 Motion to Clarify Hardin Subpoena	Hardin Request for Clarification	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
84-0 Plaintiffs Notice RE Hardin Documents	Notice RE: Hardin Documents	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
84-1 Plaintiffs Letter RE Hardin Documents	Plaintiff’s letter to Hardin counsel	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
84-2 Hardin Congregation Documents	Hardin Cong. Letters	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
85-0 Order Re: Motion to Compel Jurisdictional Discovery Responses and for costs and fees	Motion to Compel granted	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
86-0 Order Compelling Hardin Congregation to Unredact Names	Order to unredact documents	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
87-0 Defendants Notice of Substitution of Counsel	WT sub. of counsel	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
88-0 Plaintiff’s Statement of Attorneys Fees and Costs	Statement of Attorney Fees	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
88-1 Exhibit A Affidavit of Ryan Shaffer	Shaffer Affidavit RE: fees	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
88-2 Exhibit B – Affidavit of James C Murnion	Murnion Affidavit RE: Fees	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
89-0 Plaintiffs Motion for Scheduling Order	Motion for scheduling	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
89-1 Plaintiffs Proposed Scheduling Order	Proposed scheduling order	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
9-0 Philip Brumley Opposition to Motion to Dismiss Appeal	9-0 Brumley Opposition to Motion to Dismiss	philip-brumley-sanctions-appeal montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley philip-brumley-sanctions-appeal
9-0 Summons Served on Watch Tower Pennsylvania	WT Pennsylvania Summons	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
9-0 Application to Strike	September 21st, 2021 Excerpt: APPLICATION TO STRIKE PETITIONER’S BRIEF IN SUPPORT OF SUMMARY RELIEF AND NOW, comes Respondent, Department of Human Services, by and through counsel, and for the following reasons respectfully requests that the Brief in Support of Summary Relief filed by Petitioner be stricken from the record. 1. On May 20, 2020, Petitioner filed a Petition for Review in this Court’s original jurisdiction. 2. Soon thereafter, Petitioner filed an Application for Summary Relief. 3. Initially, the Court ordered Petitioner’s brief in support to be filed on or before July 17, 2020. 4. The Court granted Respondent’s initial request to extend the time to respond to both pleadings and Petitioner’s brief was ordered to be filed by August 17, 2020. 5. The Court also granted Petitioner’s request to extend the time to file a brief in support of summary relief and requested that their brief be filed no later than September 7, 2020 with Respondent’s brief due thirty-days thereafter. 6. Briefs filed in Commonwealth Court, whether in its original or appellate jurisdiction, must conform, as each case will permit, to the requirements set forth in Chapter 21 of the Rules of Appellate Procedure or risk being suppressed. See Pa.R.A.P. 2101. 7. While many of the identified requirements in Chapter 21 are for briefs submitted in cases involving an appeal, Rule 2135(a)(1) makes no such distinction. 8. In particular, Rule 2135(a)(1) states that the principal or initial brief of any party shall not exceed 14,000 words. See Pa.R.A.P. 2135(a)(1). 9. Further, the rule requires a party to file a certificate of compliance with the word count limit if the principal brief is longer than 30 pages. See id. 10. On September 4, 2020, Petitioner filed its brief in support of their application for summary relief. 11. The substantive portions of the brief are 90-pages in length and the brief fails to include a certificate of compliance with the word count limit as provided for in Appellate Rule 2135(d). 12. Undersigned counsel reached out to Petitioner’s counsel on September 8, 2020 concerning the length of the brief, but Petitioner’s counsel asserted that Appellate Rule 2135(a)(1) was not applicable to a brief filed in a matter before the Court in its original jurisdiction. 13. Respondent’s brief in opposition to the application for summary relief is due on or before October 2, 2020. 14. Respondent respectfully requests that this Court strike Petitioner’s brief in support of their application for summary relief as it fails to comply with Appellate Rule 2135. 15. A brief in support of this application shall only be filed if requested by the Court as all applicable details have been included within this application. WHEREFORE, Respondent respectfully requests that this Honorable Court strike Petitioner’s Brief in Support of their Application for Summary Relief as it fails to comply with Chapter 21 of the Rules of Appellate Procedure. Respectfully submitted, JOSH SHAPIRO Attorney General [Download the PDF document to read the remainder of this court …	ivy-hill-congregation-versus-pennsylvania-dhs pennsylvania-civil-lawsuits-united-states civil-lawsuits-united-states	ivy-hill-congregation-of-jws-versus-pennsylvania
90-0 Order Granting Plaintiffs Motion on Discovery	Scheduling motion granted	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
91-0 Stipulation for Remote Depositions	Stipulations for remote depositions	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
92-0 Defendants Response to Plaintiffs Statement of Fees and Costs	WT Response to fees and costs	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
93-0 Order Granting Attorneys Fees to Plaintiffs	Order granting fees to plaintiffs	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower court-ordered-sanctions
94-0 Watchtower Notice to Withdraw Motion to Dismiss Watchtower PA	WT PA withdraws motion to dismiss	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
95-0 Plaintiffs Notice RE Watch Tower Withdraw of Motion to Dismiss	Plaintiff’s Notice	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
95-1 MSS Letter to Watch Tower Attorneys	Letter to WT PA attorneys	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
96-0 Plaintiffs Response Brief Opposing Watch Tower Motion to Dismiss	Opposition to WT motion to dismiss	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
96-1 Appendix to Plaintiff’s Response Brief	Watch Tower PA Documents	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
98-0 Order Setting Conference for December 17th	Conference scheduled Dec 17th, 2021	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
99-0 Notice of Substitution of Counsel	Independent Counsel added for WT PA	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
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12-0	Excerpt 12	sort-test montana civil-lawsuits-united-states
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Document 135-0 Court Order on Sanctions against Philip Brumley	Court Order on Sanctions	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower jehovahs-witnesses-child-abuse philip-brumley
Document 25-0 – Plaintiff’s Motion to Compel Documents and Testimony From Defendants, and Memorandum in Support Thereof	25-0 Plaintiff’s Motion to Compel Documents	montana nunez-versus-watchtower civil-lawsuits-united-states	nunez-versus-watchtower
Document 102-0	102-0 Response to Plaintiff’s Motion	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 103-0	103-0 Order Granting Motion for Partial Summary Judgment	civil-lawsuits-united-states montana nunez-versus-watchtower	nunez-versus-watchtower
Document 104-0	August 30th, 2018 – Reply Re: Motion to Enforce Stipulation and Challenge to Confidential …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 105-0	105-0 Order Granting Plaintiff’s Motion for Partial Summary Judgment	civil-lawsuits-united-states nunez-versus-watchtower montana	nunez-versus-watchtower
Document 106-0	106-0 Order on Plaintiffs’ Motion	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 107-0	107-0 Order Denying Defendant’s Motion	montana nunez-versus-watchtower civil-lawsuits-united-states	nunez-versus-watchtower
Document 109-0	Sept 12th, 2018 Plaintiff’s Motion to Strike Defendant’s Expert Dr. Alan Newman’s Supplemental Expert …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 113.5-0	Sept 18th, 2018 Record of …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 119-0	Defendant’s Response to Plaintiff’s Motion to Strike Expert Dr. Alan Newman’s Supplemental …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 29-0	March 9th, 2018 Opposition to Motion to Compel Documents and …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 32-0	March 26th, 2018 – Plaintiff’s Reply in Support of their Motion to Compel Documents and Testimony from …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 33-0	April 10th, 2018 – Order on Motion to Compel Discovery	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower order
Document 34-0	April 19th, 2018 – Religious Defendants’ Motion for Clarification of Courts’ April 25th, 2018 …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 35-0	April 23rd, 2018 – Motion for Protective Order by Defendants Watchtower Bible and Tract Society of New York, Inc. and Christian Congregation of Jehovah’s Witnesses Regarding Requests for Production and Brief in …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 36-0	April 23rd, 2018 – Declaration of Joel M. Taylor in Support of Defendants’ Motion for Protective …	nunez-versus-watchtower montana civil-lawsuits-united-states	joel-m-taylor nunez-versus-watchtower
Document 37-0	April 25th, 2018 – Declaration of D. Chappel in Support of Defendants’ Motion for Protective …	nunez-versus-watchtower montana civil-lawsuits-united-states	douglas-chappel nunez-versus-watchtower
Document 38-0	April 25th, 2018 – Motion for Protective Order by Defendants Watchtower Bible and Tract Society of New York Inc. and Christian Congregation of Jehovah’s Witnesses Regarding Deposition Topics and Brief in …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 39-0	April 25th, 2018 – Declaration of Joel M. Taylor in Support of Defendants’ Motion for Protective Order Regarding Deposition …	nunez-versus-watchtower montana civil-lawsuits-united-states	joel-m-taylor nunez-versus-watchtower
Document 43-0	May 2nd, 2018 – Motion to Compel Production of Documents and Brief in …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 44-0	May 2nd, 2018 – Declaration of Joel M. Taylor in Support of Defendants’ Motion to …	nunez-versus-watchtower montana civil-lawsuits-united-states	joel-m-taylor nunez-versus-watchtower
Document 46-0	May 4th, 2018 – Plaintiffs’ Motion to Strike Defendants’ First Amended Third-Party Complaint Against Marco …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 49-0	May 9th, 2018 – Plaintiffs’ Response to Defendants’ Watchtower Bible and Tract Society of New York, Inc.’s and Christian Congregation of Jehovah’s Witnesses’ Motion for Protective Order Regarding Request for …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 51-0	May 17th, 2018 – Plaintiffs’ Motion for Partial Summary Judgment RE: Defendants’ Sixth Affirmative Defense and Memorandum in …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 52-0	May 18th, 2018 – Plaintiffs’ Response to Defendants’ Motion to Compel Production of …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 55-0	May 18th, 2018 – Reply Brief in Support of Motion for Protective Order By Defendants Watchtower Bible and Tract Society of New York, Inc. and Christian Congregation of Jehovah’s Witnesses Regarding Requests for …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 56-0	May 18th, 2018 – Reply in Support of Motion for …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 59-0	June 4th, 2018 – Order Denying Motion for Protective Order By Defendants Watchtower Bible and Tract Society of New York Inc. and Christian Congregation of Jehovah’s Witnesses Regarding Requests for …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 60-0	June 6th, 2018 – Reply to Plaintiffs’ Response to Defendants Motion to Compel Production of …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 62-0	June 8th, 2018 – Religious Defendants’ Opposition to Plaintiffs’ Motion for Partial Summary Judgment and Cross-Motion for Partial Summary …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 64-0	June 25th, 2018 – Order on Defendants’ Motion to Compel Production of …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 65-0	June 25th, 2018 – Plaintiffs’ Reply to Defendants’ Opposition to Plaintiffs’ Motion For Partial Summary …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 66-0	June 25th, 2018 – Plaintiffs’ Motion for Partial Summary Judgment as to Defendants’ Third-Party Claims Against Max Reyes and Marco Nunez and Defendants Third Affirmative …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 67-0	June 26th, 2018 – Motion for Summary Judgment as to the Claims Brought by Alexis Nunez, or in the Alternative, Motion for Summary Adjudication of Individual Claims and Supporting …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 72-0	June 27th, 2018 – Motion in Limine by Defendants’ Watchtower Bible and Tract Society of New York Inc., Christian Congregation of Jehovah’s Witnesses, and Thompson Falls Congregation of Jehovah’s Witnesses to Exclude All References to the Australian Royal …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 75-0	July 2nd, 2018 – Plaintiff Alexis Nunez’s Motion for Partial Summary Judgment as to Defendants’ Fourth Affirmative Defense and Cross-Motion for Summary Judgment As to Forseeability of Max Reyes’s …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 76-0	July 2nd, 2018 – Plaintiffs’ Motion for Partial Summary Judgment as to Defendants’ Third-Party Claims Against Ivy …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 77-0	July 9th, 2018 – Plaintiffs’ Brief in Opposition to Defendants’ Cross-Motion for Summary Judgment on Count …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 81-0	July 18th, 2018 – Response to Plaintiffs’ Motion for Partial Summary Judgment as to Defendants’ Third-Party Claims and Affirmative Action Against Max Reyes and Marco Nunez, by Defendants’ Watchtower Bible and Tract Society of New York Inc. and Christian Congregation of Jehovah’s …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 83-0	July 23rd, 2018 – Response to Plaintiff Alexis Nunez Motion for Partial Summary Judgment as to Defendants’ Fourth Affirmative Defense and Cross Motion for Summary Judgment as to Forseeability of Max Reyes’ Abuse, By Defendants Watchtower Bible and Tract Society of New York, Inc. And Christian Congregation of Jehovah’s …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 84-0	July 23rd, 2018 – Response to Plaintiffs’ Motion for Partial Summary Judgment as to Defendants’ Third-Party Claims against Ivy-McGowan Castleberry, by Defendants’ Watchtower Bible and Tract Society of New York, Inc. and Christian Congregation of Jehovah’s …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 86-0	July 23rd 2018, Plaintiffs’ Response to Defendants’ Motion for Summary Judgment as to the Claims Brought by Alexis Nunez, In the Alternative, Motion for Summary Adjudication of Individual …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 87-0	July 24th, 2018 – Reply to Plaintiffs’ Response to Defendants’ Motion for Partial Summary Judgment as to Plaintiffs’ Negligence Per Se Claim by Defendants’ Watchtower Bible and Tract Society of New York, Inc. and Christian Congregation of Jehovah’s …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 92-0	August 2nd, 2018 – Motion to Enforce Stipulation and Challenge to Confidential …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 93-0	August 2nd, 2018 – Plaintiffs’ Reply in Support of their Motion for Partial Summary Judgment as to Defendants’ Third-Party Claims against Max Reyes and Marco Nunez and Defendants’ Third Affirmative …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 95-0	August 7th, 2018 – Reply Brief in Support of Motion for Summary Judgment as to the Claims Brought By Alexis Nunez , or in the Alternative, Motion for Summary Adjudication of Individual …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 96-0	Notice of Filing	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 97-0	August 8th, 2018 – Plaintiffs’ Reply in Support of their Motion for Summary Judgment as to Defendants’ Third-Party Claims Against Ivy McGowan …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 98-0	August 8th, 2018 – Plaintiff Alexis Nunez’ Reply in Support of Motion for Partial Summary Judgment as to Defendant’s Fourth Affirmative Defense and Cross Motion for Summary Judgment as to Foreseeability of Max Reyes’s …	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Exhibit Index Page from 224-0, Watch Tower Brief In Support of Motion to Compel Responses	224-0 Exhibit Index Page	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower
106-3 Deposition of James Rowland	106-3 Defendant Watch Tower Pennsylvania’s Response in Opposition to Plaintiff’s Motion for Sanctions	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower jehovahs-witnesses-child-abuse
26-0 Second Affidavit of Philip Brumley	Second Affidavit of Philip Brumley	caecaert-v-watchtower montana civil-lawsuits-united-states	caekaert-v-watchtower philip-brumley
Terril and Enholm v. Christian Congregation of Jehovah’s Witnesses and South Hill Congregation – Washington State	Summons and complaint	terril-enholm-versus-jehovahs-witnesses washington-state civil-lawsuits-united-states	jehovahs-witnesses-child-abuse john-earl-jones terril-and-enholm-v-ccjw
Test upload	This is a test excerpt	rowland-v-watchtower montana civil-lawsuits-united-states

Title	Summary	Categories	hf:doc_categories	hf:doc_tags
Document 25-0 – Plaintiff’s Motion to Compel Documents and Testimony From Defendants, and Memorandum in Support Thereof	25-0 Plaintiff’s Motion to Compel Documents	Montana, Nunez versus Watchtower	montana nunez-versus-watchtower civil-lawsuits-united-states	nunez-versus-watchtower
Document 29-0	March 9th, 2018 Opposition to Motion to Compel Documents and …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 32-0	March 26th, 2018 – Plaintiff’s Reply in Support of their Motion to Compel Documents and Testimony from …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 33-0	April 10th, 2018 – Order on Motion to Compel Discovery	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower order
Document 34-0	April 19th, 2018 – Religious Defendants’ Motion for Clarification of Courts’ April 25th, 2018 …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 35-0	April 23rd, 2018 – Motion for Protective Order by Defendants Watchtower Bible and Tract Society of New York, Inc. and Christian Congregation of Jehovah’s Witnesses Regarding Requests for Production and Brief in …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 36-0	April 23rd, 2018 – Declaration of Joel M. Taylor in Support of Defendants’ Motion for Protective …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	joel-m-taylor nunez-versus-watchtower
Document 37-0	April 25th, 2018 – Declaration of D. Chappel in Support of Defendants’ Motion for Protective …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	douglas-chappel nunez-versus-watchtower
Document 38-0	April 25th, 2018 – Motion for Protective Order by Defendants Watchtower Bible and Tract Society of New York Inc. and Christian Congregation of Jehovah’s Witnesses Regarding Deposition Topics and Brief in …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 39-0	April 25th, 2018 – Declaration of Joel M. Taylor in Support of Defendants’ Motion for Protective Order Regarding Deposition …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	joel-m-taylor nunez-versus-watchtower
Document 43-0	May 2nd, 2018 – Motion to Compel Production of Documents and Brief in …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 44-0	May 2nd, 2018 – Declaration of Joel M. Taylor in Support of Defendants’ Motion to …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	joel-m-taylor nunez-versus-watchtower
Document 46-0	May 4th, 2018 – Plaintiffs’ Motion to Strike Defendants’ First Amended Third-Party Complaint Against Marco …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 49-0	May 9th, 2018 – Plaintiffs’ Response to Defendants’ Watchtower Bible and Tract Society of New York, Inc.’s and Christian Congregation of Jehovah’s Witnesses’ Motion for Protective Order Regarding Request for …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 51-0	May 17th, 2018 – Plaintiffs’ Motion for Partial Summary Judgment RE: Defendants’ Sixth Affirmative Defense and Memorandum in …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 52-0	May 18th, 2018 – Plaintiffs’ Response to Defendants’ Motion to Compel Production of …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 55-0	May 18th, 2018 – Reply Brief in Support of Motion for Protective Order By Defendants Watchtower Bible and Tract Society of New York, Inc. and Christian Congregation of Jehovah’s Witnesses Regarding Requests for …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 56-0	May 18th, 2018 – Reply in Support of Motion for …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 59-0	June 4th, 2018 – Order Denying Motion for Protective Order By Defendants Watchtower Bible and Tract Society of New York Inc. and Christian Congregation of Jehovah’s Witnesses Regarding Requests for …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 60-0	June 6th, 2018 – Reply to Plaintiffs’ Response to Defendants Motion to Compel Production of …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 62-0	June 8th, 2018 – Religious Defendants’ Opposition to Plaintiffs’ Motion for Partial Summary Judgment and Cross-Motion for Partial Summary …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 64-0	June 25th, 2018 – Order on Defendants’ Motion to Compel Production of …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 65-0	June 25th, 2018 – Plaintiffs’ Reply to Defendants’ Opposition to Plaintiffs’ Motion For Partial Summary …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 66-0	June 25th, 2018 – Plaintiffs’ Motion for Partial Summary Judgment as to Defendants’ Third-Party Claims Against Max Reyes and Marco Nunez and Defendants Third Affirmative …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 67-0	June 26th, 2018 – Motion for Summary Judgment as to the Claims Brought by Alexis Nunez, or in the Alternative, Motion for Summary Adjudication of Individual Claims and Supporting …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 72-0	June 27th, 2018 – Motion in Limine by Defendants’ Watchtower Bible and Tract Society of New York Inc., Christian Congregation of Jehovah’s Witnesses, and Thompson Falls Congregation of Jehovah’s Witnesses to Exclude All References to the Australian Royal …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 75-0	July 2nd, 2018 – Plaintiff Alexis Nunez’s Motion for Partial Summary Judgment as to Defendants’ Fourth Affirmative Defense and Cross-Motion for Summary Judgment As to Forseeability of Max Reyes’s …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 76-0	July 2nd, 2018 – Plaintiffs’ Motion for Partial Summary Judgment as to Defendants’ Third-Party Claims Against Ivy …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 77-0	July 9th, 2018 – Plaintiffs’ Brief in Opposition to Defendants’ Cross-Motion for Summary Judgment on Count …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 81-0	July 18th, 2018 – Response to Plaintiffs’ Motion for Partial Summary Judgment as to Defendants’ Third-Party Claims and Affirmative Action Against Max Reyes and Marco Nunez, by Defendants’ Watchtower Bible and Tract Society of New York Inc. and Christian Congregation of Jehovah’s …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 83-0	July 23rd, 2018 – Response to Plaintiff Alexis Nunez Motion for Partial Summary Judgment as to Defendants’ Fourth Affirmative Defense and Cross Motion for Summary Judgment as to Forseeability of Max Reyes’ Abuse, By Defendants Watchtower Bible and Tract Society of New York, Inc. And Christian Congregation of Jehovah’s …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 84-0	July 23rd, 2018 – Response to Plaintiffs’ Motion for Partial Summary Judgment as to Defendants’ Third-Party Claims against Ivy-McGowan Castleberry, by Defendants’ Watchtower Bible and Tract Society of New York, Inc. and Christian Congregation of Jehovah’s …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 86-0	July 23rd 2018, Plaintiffs’ Response to Defendants’ Motion for Summary Judgment as to the Claims Brought by Alexis Nunez, In the Alternative, Motion for Summary Adjudication of Individual …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 87-0	July 24th, 2018 – Reply to Plaintiffs’ Response to Defendants’ Motion for Partial Summary Judgment as to Plaintiffs’ Negligence Per Se Claim by Defendants’ Watchtower Bible and Tract Society of New York, Inc. and Christian Congregation of Jehovah’s …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 92-0	August 2nd, 2018 – Motion to Enforce Stipulation and Challenge to Confidential …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 93-0	August 2nd, 2018 – Plaintiffs’ Reply in Support of their Motion for Partial Summary Judgment as to Defendants’ Third-Party Claims against Max Reyes and Marco Nunez and Defendants’ Third Affirmative …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 95-0	August 7th, 2018 – Reply Brief in Support of Motion for Summary Judgment as to the Claims Brought By Alexis Nunez , or in the Alternative, Motion for Summary Adjudication of Individual …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 96-0	Notice of Filing	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 97-0	August 8th, 2018 – Plaintiffs’ Reply in Support of their Motion for Summary Judgment as to Defendants’ Third-Party Claims Against Ivy McGowan …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 98-0	August 8th, 2018 – Plaintiff Alexis Nunez’ Reply in Support of Motion for Partial Summary Judgment as to Defendant’s Fourth Affirmative Defense and Cross Motion for Summary Judgment as to Foreseeability of Max Reyes’s …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 102-0	102-0 Response to Plaintiff’s Motion	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 103-0	103-0 Order Granting Motion for Partial Summary Judgment	Civil Lawsuits - United States, Montana, Nunez versus Watchtower	civil-lawsuits-united-states montana nunez-versus-watchtower	nunez-versus-watchtower
Document 104-0	August 30th, 2018 – Reply Re: Motion to Enforce Stipulation and Challenge to Confidential …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 105-0	105-0 Order Granting Plaintiff’s Motion for Partial Summary Judgment	Civil Lawsuits - United States, Nunez versus Watchtower	civil-lawsuits-united-states nunez-versus-watchtower montana	nunez-versus-watchtower
Document 106-0	106-0 Order on Plaintiffs’ Motion	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 107-0	107-0 Order Denying Defendant’s Motion	Montana, Nunez versus Watchtower	montana nunez-versus-watchtower civil-lawsuits-united-states	nunez-versus-watchtower
Document 109-0	Sept 12th, 2018 Plaintiff’s Motion to Strike Defendant’s Expert Dr. Alan Newman’s Supplemental Expert …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 113.5-0	Sept 18th, 2018 Record of …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower
Document 119-0	Defendant’s Response to Plaintiff’s Motion to Strike Expert Dr. Alan Newman’s Supplemental …	Nunez versus Watchtower	nunez-versus-watchtower montana civil-lawsuits-united-states	nunez-versus-watchtower