News – Page 2 – JW Child Abuse

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

2017: Jehovah’s Witnesses Release New Child Abuse Reporting Policy, and it’s Business as Usual

Published September 6th, 2017

In a letter dated September 1, 2017, the Governing Body of Jehovah’s Witnesses approved the release of a new Body of Elders letter in the United States, Australia, the U.K., Ghana, and across the globe.

This letter is intended to refine and clarify the language and procedures used by all elders when they encounter an allegation of child sexual abuse. It is a revision of the August 1, 2016 letter to elders, which was a revision of the October 1st 2012 letter.

(click here for the August 4th 2016 review and comparison between the 2016 and 2012 letters)

The latest directive is in no way regional in nature but is a global response to the growing publicity and civil lawsuits being filed in the United States, Canada, the U.K. and elsewhere.

While the table of contents of the 2017 and 2016 letters are identical, there are minor differences in a few of the 27 sections of each letter which reflect the ongoing efforts of the Jehovah’s Witness organization (A.K.A. the Christian Congregation of Jehovah’s Witnesses) to deflect attention from their long-standing policy of handling allegations of abuse internally, with the protection of the organization’s reputation of prime concern. Victims and their families are placed in the awkward position of facing intense pressure to let the elders handle matters “Jehovah’s way.”

The Jehovah’s Witness organization has been very careful to avoid writing statements such as “Never tell a victim to go immediately to the police” – instead they have deceptively created a double negative expression inside their secretive Shepherd the Flock of God elder’s manual, which states:

“Never suggest to anyone that they should not report an allegation of child abuse to the police or other authorities.”

-Jehovah’s Witness elders’ manual

According to this latest September 1st letter, the above statement must be immediately deleted from the Elders manual, along with the 2 subsequent paragraphs that were already excluded per instructions from the 2016 Body of Elders letter.

Why? It is obvious to anyone of intelligence that not telling someone not to report a crime is clearly the absence of action rather than a directive to take positive action. Poorly educated elders generally have a difficult time interpreting such ambiguous language, and the organization is beginning to understand this.

Secondly, It’s no secret that the Governing Body is closely monitoring “apostate” posts and websites, which have shed a considerably bright spotlight upon the unsavory and ambiguous doublespeak, which has become a hallmark of the Jehovah’s Witness writing department.

For example, The Governing Body dispatched a July 2016 memo marked APPROVED in response to Australian Branch Coordinator Terry O’Brien’s plea to the Governing Body, which included the following statement:

“No doubt it will be much better if the [Australian Royal Commission] receives this information from the branch, rather than from apostate opposers.” – Terry O’Brien

Governing Body Memo Response to Australia Branch

The Governing Body has lost control of its once tightly monitored network of elders and circuit overseers, and other key members of this religious institution. The letters referenced in this article were actually leaked days in advance of the September 1st release date, a fact that has sent the Watchtower legal department in search of the sources of these leaks.

Watchtower’s Compromise?

The most immediate and apparent compromise which appears in the September 1st, 2017 revised letter involves what appears to be a directive to clearly inform a victim or her parents that they have the right to inform the secular authorities when an abuse allegation takes place. The added sentences read:

The congregation’s handling of an accusation of child sexual abuse is not intended to replace the secular authority’s handling of the matter. Therefore, the victim, her parents, or anyone else who reports such an allegation to the elders should be clearly informed that they have the right to report the matter to the secular authorities. Elders do not criticize anyone who chooses to make such a report

These words, while on face value might appear to offer some improvement to the abominable failure of Jehovah’s Witness elders and parents to inform the police and Child Protection Authorities of an allegation of abuse, they are designed to protect the organization rather than the victim. One must conclude that these are once again passive words, and are not instructions to immediately contact the police or CPA. If they were, the statement would read:

“The victim, her parents, or anyone else aware of an abuse allegation should immediately report such allegations to the police and CPA, and follow the directions of the authorities who are fully trained to handle such cases”

The reality is, that what is placed in print and what is practiced in reality are two entirely different things. Watchtower is in an awkward defensive position right now and is struggling to find a balance between obeying “Caesar’s law” and maintaining their internal system of justice, based upon an interpretation of Biblical verses that serves to elevate their own hierarchy above that of the laws which govern every nation.

During the February 2017 public jury trial of Fessler v. Watchtower, attorneys for abuse victim Stephanie Fessler subpoenaed a former elder from Pennsylvania, who was scheduled to testify under oath on the matter of whether reporting child abuse was permitted or encouraged.

In pre-trial motions, Fessler’s attorney advised Justice Mary Collins:

“That this man will come in and say, hey, I was told do not report this to the police or to authorities. So that’s what I’m saying. It’s both notice and the fact that there are instructions given to elders and circuit overseers not to report abuse”

The judge responded:

“Will he testify as to who told him this?”

Attorney for Stephanie Fessler answered:

“Well, it’s firsthand. He has contacted Watchtower headquarters.”

Despite vehement objections from Watchtower’s team of defense attorneys, the judge overruled the objection to this testimony. Before this former elder had the opportunity to testify, Watchtower agreed to a substantial settlement with victim Stephanie Fessler following four days of trial.

“Child Abuse is a Crime”

Another key difference between the 2016 and 2017 letters to elders is found in section 5, titled “Legal Considerations.” Note the 2016 letter:

“Legal Considerations: In some jurisdictions, individuals who learn of an allegation of child abuse may be obligated by law to report the allegation to the secular authorities. In all cases, the victim and her parents have the absolute right to report an allegation to the authorities.”

Compare this to the 2017 letter:

“Legal Considerations: Child abuse is a crime. In some jurisdictions, individuals who learn of an allegation of child abuse may be obligated by law to report the allegation to the secular authorities.”

Watchtower has faced intense scrutiny for failing to emphasize the criminal nature of child abuse. It has first and foremost categorized child abuse as a sin, which is the reason Witness elders find themselves involved in abuse cases where they have no training or expertise. Such matters should always be referred to law enforcement and child protection agencies. The revised wording of the 2017 letter is purely intended to create the illusion that Jehovah’s Witnesses identify child abuse foremost as a crime. They don’t.

Also very noteworthy is the elimination of the phrase “absolute right” – a term which Watchtower has used repeatedly in multiple abuse cases worldwide as a legal method of placing the burden of reporting abuse upon victims and their families, deflecting attention from the obligation of the Jehovah’s Witness clergy (the elders) to report abuse. For a detailed analysis of the term “absolute right” – see the 2016 JW Survey article summarizing the 2016 elder’s letter pertaining to abuse.

The Judicial Committee

Further emphasizing the importance placed upon internal investigations by Jehovah’s Witness elders are statements made in paragraph 14 of the updated 2017 letter to elders. Nowhere do we find any mention of legal guilt or criminal prosecution as the impetus for judicial action within a Witness congregation. Based upon this principle, a Jehovah’s Witness convicted of murder in a court of law would evade disfellowshipping for lack of two baptized Jehovah’s Witnesses who could establish guilt under their notorious “Two Witness” rule. Note the intentional ambiguity embedded within the Shepherd the Flock elders manual, 2010 edition:

“Manslaughter: Aside from deliberate murder, bloodguilt may be incurred if a person causes loss of Life through carelessness or because of violating a traffic law or other safety law of Caesar. The elders should investigate and if warranted appoint a judicial committee to hear the matter. The committee should base its decision on clearly established facts, not simply on a decision that may have been made by secular authorities.”. – Shepherd the Flock manual, chapter 5, section 3.

What exactly are “clearly established facts” – and who supply these facts? Congregation elders are advised to “not simply” base their decisions upon the professional authorities whose sole occupation is that of determining and judging the facts of any given case. While the justice systems of most countries are imperfect and flawed, they are clearly superior to the decisions rendered by men who wash windows, clean toilets, or work as tradesmen for a living.

When we examine the procedures followed by Jehovah’s Witnesses, there is an implied superiority of their “Theocratic” methods which always trumps the civil authorities in our society. They strictly adhere to the philosophy that “We must obey God as ruler rather than men” – a quote from Acts 5:29. This Biblical reference is frequently used to draw a line in the sand when a JW policy conflicts with a legal requirement of any given country.

A second issue with paragraph 14 of the revised letter is the following statement, which also appears in the 2016 letter:

“If wrongdoing is established and the wrongdoer is not repentant, he should be disfellowshipped. (ks10 chap. 7 par. 26) On the other hand, if the wrongdoer is repentant and is reproved, the reproof should be announced to the congregation. (ks10 chap. 7 pars. 20-21) This announcement will serve as a protection for the congregation”

While disfellowshipping might appear to be an appropriate measure to protect Jehovah’s Witness children, what of those who are not Witnesses? Criminal courts frequently enforce restrictions on child molesters, including such actions as requiring them to register as sex offenders, which effectively notifies residents in various communities that an offender is in their midst. In the case of Jehovah’s Witnesses, there is effectively nothing stopping an individual from moving to another state under an assumed name, and molesting a child before anyone finds out who this criminal really is. Jehovah’s Witnesses are not required to show proof of identification when attending a congregation, and there are a multitude of ways to bypass the measures which would inform a congregation that a convicted felon is in their midst.

Of greater concern is the fact that a JW judicial committee is given the authority to judge an abuser as “repentant” – as seen above. For those of us who study child abuse very closely, an abuser rarely if ever is “repentant.” Child abuse is a sickness which must be dealt with by the police and trained mental health counselors. The mere consideration that a perpetrator might be simply “reproved” instead of disfellowshipped is at best a slap in the face to an abuse victim, and at worse a free pass for an abuser to continue seeking potential victims.

The statement that “This announcement will serve as a protection to the congregation” is a toothless claim that Jehovah’s Witness elders have no real authority to support or enforce. I remember a few years back, while serving as a Ministerial Servant, I was assigned to conduct a one hour “bookstudy” each week at my local Kingdom Hall. One elder informed me that a female Witness was under “reproof” for a serious infraction, but did not reveal the nature of her “sin.” She was allowed to come to the meeting and associate freely with everyone, her only restriction being that she was barred from “commenting” – which means to raise one’s hand and offer a testimonial or comment on the discussion.

A few months ago I was contacted following one of my articles on the Fessler v Watchtower case – by a female victim of the reproved woman. I was literally sick when I discovered that she had sexually assaulted the victim in the women’s room of my own Kingdom Hall, in a way that disturbs me more than you can imagine. The elders were aware of the incident – as were the parents of the victim, but following the customary practice engineered by the Governing Body of Jehovah’s Witnesses, neither the police nor CPA authorities were notified. It appears that “reproof” was their solution to this sexual attack on a female victim who was four years old at the time.

Thanks to the bravery of Stephanie Fessler and her willingness to take her case to trial, many victims have come forward and are seeking the professional help they deserve. For now, the perpetrator of this horrific abuse roams freely among several congregations of Jehovah’s Witnesses. This case is currently under investigation by multiple competent detectives in the Child Sex Crimes unit where the offense occurred.

Finally, we come to one further statement in Paragraph 14 of the 2017 BOE letter:

“Victims of child sexual abuse are not handled judicially. However, if the body of elders believes that congregation action may be warranted in the case of a mature minor who was a willing participant in wrongdoing, two elders should call the Service Department before proceeding.”

Again we encounter a disturbing policy which on the surface appears to be an improvement in policy. However, the first sentence is immediately undermined by the ambiguity of the term “mature minor” – and suggests that an abuse victim could indeed be treated to a hostile judicial committee if they are judged by Jehovah’s Witness elders to be a mature minor, and a willing participant.

It seems that if there is any doubt whether a victim is a mature minor, the answer is to be supplied by the Service Department of Jehovah’s Witnesses, located in New York. But don’t lose sight of the fact that it is the local body of elders who choose to “believe” whether congregation action is warranted.

Once again, the statement that “Victims of child sexual abuse are not handled judicially” is merely an empty promise which serves only as an attempt to placate the civil authorities worldwide who are ramping up their criticism of organizations who place children in harm’s way – all the while receiving tax-exempt status as a “charitable” organization.

What’s the Bottom Line?

The reality is that nothing has changed. A few words here and there, drafted only to protect the organization and not the victims of abuse.

The final paragraph of the latest letter states:

“It is imperative to adhere to the direction in this letter each time a matter involving child abuse comes to your attention. This will serve to uphold the sanctity of Jehovah’s name and to protect minors. (1 Pet. 2:12) Your full cooperation with this direction is appreciated.”

Notice the sequence of importance in this statement:

Adhere to the Governing Body’s direction
Uphold the sanctity of Jehovah’s Name (meaning the organization)
Protect minors
See number 1 (FULL cooperation with this direction)

Nothing has changed. Nowhere have the elders been instructed to comply with mandatory reporting of child abuse, without first consulting with the Watchtower legal department in Patterson New York. There is never a reason for an abuse allegation to not be reported to the police; clergymen, teachers, guidance counselors, medical professionals and others are generally required to contact the authorities when an allegation comes to light. Elders do not need a Legal Department or a Service Department to do the right thing; nor should they fear reprisals for immediately contacting the police and CPA when they learn of an abuse allegation.

In fairness, I will say that there are individual Jehovah’s Witness elders who do not agree with the policies they are required to enforce. The JW religion is by no means an a-la-carte system of beliefs. It is all or nothing, and for most Witnesses, “nothing” is an impossible alternative. Objecting to and speaking against any one policy of the Governing Body will result in the most severe penalty of all – complete ostracism from friends and family, which for most is a price too high to pay.

But times are changing, and an increasing number of Jehovah’s Witness elders and circuit overseers have seen fit to declare themselves “PIMO” – or Physically In, Mentally Out. While change happens systematically, in a subtle but positive way, we can be thankful for the widespread courage of survivors of abuse, advocates for change, and countless other supporters of victims.

Given the widespread and ongoing civil cases filed against the Watchtower organization on behalf of abuse survivors in multiple countries, it is still sobering that the Governing Body refuses to back down and permit the elders to immediately report allegations of abuse to the police and child protection agencies. In many cases, time is of the essence when abuse occurs, and the intervention of the legal and service department of Jehovah’s Witnesses represents an extraordinarily self-serving position.

I urge everyone who may read this, including Jehovah’s Witnesses and the Governing Body, to eliminate the bureaucracy which has caused undue pain and suffering for decades to countless victims of abuse. To Jehovah’s Witnesses I say: Please stand up for the what is right, what is fair, what is just, and what is kind. Your children are at risk, and we want them to grow up in a safe environment where they can choose the life they wish to live, safe from predators from within and outside of the Jehovah’s Witness religion.

We know that you abhor child abuse, but that is not the issue. The concern is how allegations of abuse are handled. They must be treated as the most serious of all allegations, as the consequences of failing to report such matters to the police and CPA will last a lifetime, both for your children and those of other victims of the same predators.

Posted on July 26, 2022July 27, 2022 by Mark O'Donnell — Leave a comment

California Appellate Court Slams Watchtower, Jehovah’s Witnesses Fined, Ordered To Produce Child Abuse Docs

Published November 14th, 2017

“Watchtower has abused the discovery process. It has zealously advocated its position and lost multiple times. Yet, it cavalierly refuses to acknowledge the consequences of these losses and the validity of the court’s orders requiring it to produce documents…And, in a further act of defiance, Watchtower informed the court that it would not comply with the March 25, 2016 order requiring it to produce documents…”

So stated the California Fourth Court of Appeal in a decision where the Watchtower organization has been held responsible for refusal to hand over its database of child abuse files, specifically those it has been collecting since March of 2001. The court penalized Watchtower in the amount of $4,000 per day, a fine which has been accruing for over a year, and which may surpass two million dollars.

This is in addition to significant legal fees paid by Watchtower to Morris Polich & Purdy, the California firm retained for their defense. The November 9th ruling further stipulates that Watchtower must pay the legal costs incurred as a result of their appeal, a hefty price to pay for their adamant refusal to turn over child abuse files.

The Case

Abuse victim Osbaldo Padron filed suit against the Watchtower Organization following the discovery that Congregation elders in the Playa Pacifica Spanish Congregation, along with Watchtower officials in New York, had known for more than a decade that Gonzalo Campos had molested multiple boys. Neither the police nor child protective services were contacted by church elders, or by Watchtower. Instead, Campos was elevated from congregant, to Ministerial Servant, and finally to Elder by June of 1993.

Not long after Campos’ appointment, Padron was molested at just 7-8 years of age.

In 2011, Campos admitted on camera to allegations of pedophilia, but has since fled to Mexico and is presumed to be an active Jehovah’s Witness. The congregation elders who protected Campos, along with the Watchtower Bible and Tract Society are being held responsible for the willful neglect which led to the sexual abuse of multiple victims.

While some victims have already settled with Watchtower in private, undisclosed agreements, two victims of Campos opted to file civil lawsuits in an attempt to hold the Jehovah’s Witness organization accountable both financially and legally. The two victims are Jose Lopez and Osbaldo Padron.

Jose Lopez filed a civil suit in February of 2013, in which attorney Irwin Zalkin and his team obtained subpoenas for documents related to Watchtower’s knowledge of the prevalence of childhood sexual abuse within its organization. Additionally, Zalkin obtained an order to depose Governing Body Member Gerrit Losch as the Person Most Qualified (PMQ) to testify for Watchtower.

Watchtower refused to cooperate, failing to produce the requested documents in full, and Losch denied that he had any legal connection to Watchtower. In 2001, Watchtower removed Governing Body members from their New York and Pennsylvania corporations to insulate them from legal responsibility. The Superior Court of the State of California did not find this tactic amusing, and issued a default judgment for Lopez, awarding him 13.5 million dollars.

Watchtower’s Costly Mistake

Watchtower appealed the Lopez verdict and argued that the terminating judgment was unfair, that it did not give them a chance to defend their position. The court agreed that lesser sanctions should have been tried first in an attempt to pry loose those documents. Watchtower eventually released four years’ worth of heavily redacted files, from March 1997 to March 2001.

Why only four years?

Watchtower made a costly and damaging decision when it released a letter to all congregations dated March 14, 1997, in which congregation elders were advised to submit reports on all “former” or “known” child molesters who had relocated from a different congregation.

Congregations were instructed to allow all elders access to information regarding child molesters, while also forwarding details to Watchtower Headquarters inside a “special blue envelope.” Elders were instructed not to discuss this information with any congregation member.

This official edict from Watchtower provides the legal starting point for the document discovery process, despite the fact that Jehovah’s Witnesses had been collecting child abuse and other sensitive documents at headquarters for decades.

Faced with the choice of compliance or writing a check for 13.2 million dollars, Watchtower released those documents, but redacted them excessively, and stopped with March 2001. This was the year that the Christian Congregation of Jehovah’s Witnesses (CCJW) was formed. Watchtower’s legal team argues that once CCJW was formed, they no longer had access to or control over child abuse documents.

Osbaldo Padron

Meanwhile, victim Osbaldo Padron filed suit against Watchtower in September of 2013. Among the allegations were negligence; negligent supervision/failure to warn; negligent hiring/retention; negligent failure to warn, train, or educate; sexual battery; and sexual harassment.

Watchtower officials and multiple congregation elders had significant knowledge that Gonzalo Campos was a sexual predator, yet did nothing to protect Osbaldo Padron, the congregation, or the local community.

As with Lopez, Padron demanded that Watchtower release all of it’s child abuse documentation from March 1997 forward. Watchtower refused to comply, arguing 1st amendment protection, clergy-penitent privilege, and attorney-client privilege as a basis for non-compliance.

Senior Watchtower Service Department official Richard Ashe declared that Padron’s request for these documents was unreasonable and that it would take a full-time worker at headquarters up to 28 years to search through the files of over 14,400 congregations, and retrieve the abuse cases demanded by the plaintiff. The court rejected Watchtower’s arguments, including the attempt to disclose only documents from the state of California.

As mentioned earlier, Watchtower released redacted documents from the period of March 1997 to March 2001. Watchtower continued to maintain that it had no obligation to produce documents after March 2001, claiming that Watchtower and CCJW are separate entities.

The court-appointed discovery referee disagreed, describing Watchtower and CCJW as “alter egos.” The court agreed with the referee and issued an order dated March 25th, 2016, demanding a complete document release by Watchtower.

Watchtower refused.

The legal battle continued, with the court ultimately deciding that sanctions against Watchtower were both justified and necessary. The court stated:

“In this case, there is a clear failure to comply with a discovery order on the part of Watchtower. First, Watchtower failed to properly comply with the court’s March 13, 2015 [order] and produced documents with excessive redactions. After the court adopted the Discovery Referee’s Recommendation as an order, Watchtower has unequivocally stated it will not comply. By the time of the hearing on the motion for sanctions, it will have been over a year since the initial order and almost three months since the Recommendation was adopted. In the period since the Recommendation was adopted, Watchtower has shown no effort or willingness to comply with the discovery order.“Based upon the history in this case and Watchtower’s statements at the April 8, 2016 [hearing], the court finds that Watchtower’s failure to comply is willful. Watchtower argues that its failure is not willful because it has no control over CCJW documents. However, Watchtower clearly has control over the documents it has already produced and could revise the redactions with regard to those documents. This is obviously and clearly within the scope of Watchtower’s powers which it chooses not to exercise. Continuing to repeat its prior unsuccessful arguments in opposition to the discovery order further illustrates Watchtower’s obstinacy in compliance. Further, based upon the unambiguous statements made by Watchtower’s counsel, there is no reasonable dispute that Watchtower is simply refusing even to attempt to comply with the court’s order.”

With this declaration, the court decided to punish Watchtower in the following manner:

The court therefore sanctioned Watchtower $2,000 per day for every day Watchtower did not produce responsive documents and $2,000 per day for every day Watchtower did not search for responsive documents.

This fine was deemed fair and just in consideration of the court’s awareness of more than 1.3 billion dollars worth of real estate owned by the Watchtower organization.

Estoppel Traps Watchtower

Not surprisingly, Watchtower strongly objected to being fined $4,000 per day for failure to produce documents related to child abuse. Unfortunately this objection violated the legal principle known as estoppel. According to the court:

“Judicial estoppel precludes a party from gaining an advantage by taking one position, and then seeking a second advantage by taking an incompatible position.The doctrine’s dual goals are to maintain the integrity of the judicial system and to protect parties from opponents’ unfair strategies.”

The court explained further how Watchtower violated this legal principle:

“Here, we find all the elements of judicial estoppel present. Watchtower has taken two positions. In Lopez, supra, 266 Cal.App.4th 566, it argued monetary sanctions, untethered to the plaintiff’s reasonable costs, were appropriate. In the instant matter, Watchtower now claims the superior court was not authorized to issue such sanctions. Watchtower has taken these contrary positions in two separate cases before this court.”

The reality of the situation is that Watchtower’s attorneys were boxed in due to the $13.2 million dollar judgment in the Lopez case, and felt they had no other recourse but to claim that the court should have fined them a lesser penalty. But when they were assessed this lesser penalty in the Padron case, they strongly objected. The patience of California’s justice system had run thin, as the court finally declared:

“Here, it is beyond debate that Watchtower has abused the litigation process and has shown little respect for the superior court’s authority.”

Reaffirming that the financial penalties imposed by the Superior Court of California were justifiable, the court declared:

“Nonetheless, Watchtower refuses to comply with the court order and maintains the court was just wrong. In this sense, it refuses to acknowledge the authority of the court and repudiates the procedures and rules all litigants are supposed to follow in superior court. In these extreme circumstances, we conclude the superior court was authorized to issue the monetary sanctions”

It is clear that the California appellate court was well aware of Watchtower’s intentional obfuscation when it blurred the lines between the Watchtower Organization and the Christian Congregation of Jehovah’s Witnesses (CCJW). The attempt to claim that Watchtower had no access or control of documents possessed by CCJW was an attempt to mislead the court.

“The representations of Watchtower’s counsel as well as the declarations of Watchtower agents clearly indicate that Watchtower has access to responsive documents from 1997 to present. We thus conclude substantial evidence supports the discovery referee’s finding, adopted by the court, that Watchtower was in “custody and control” of responsive documents beyond the March 2001 creation of CCJW.”

Watchtower Versus Watchtower

Further substantiating the legal gamesmanship taking place in an attempt to circumvent justice and mislead the court, Watchtower sent a letter to its alter ego, CCJW, in a measure feigning compliance with the document production order of March 25th 2016.

The first letter, dated July 2nd 2016 was sent from Watchtower’s California law firm, Morris, Polich & Purdy, to Anthony P. La Rocco, attorney for CCJW:

July 2, 2016 Letter from Watchtower Attorneys to CCJW

This letter was followed by a reply from the firm representing CCJW, in which Watchtower’s California counsel was informed that CCJW was not a party to the Padron Case and had no obligation or duty to respond to the document production order:

July 11th 2016 Letter from CCJW to Watchtower

Once again, the court was not tricked by these tactics, and called attention to Watchtower’s inconsistent stance:

“We find it curious that the existence of CCJW and the March 2001 cut off only became an issue after Watchtower produced documents and Padron complained that the production was not sufficient. It appears Watchtower argued that it had access to the documents after March 2001 when it was to its benefit to support its burden argument, but only after losing that argument, it claimed to not have access to documents after a certain point of time to justify its limited production. Such gamesmanship has no place in civil discovery. “

In other words – Watchtower originally claimed that it was excessively burdensome to search ALL their documents from 1997 to the present, revealing that they did indeed have possession of these documents. They then attempted an alternate strategy by declaring that they did NOT have access to these documents, and that CCJW could not legally produce them.

Judgment Day

As a result of the proceedings outlined above, the Fourth Appellate District Court of Appeal has affirmed the lower court’s ruling that the Watchtower Bible and Tract Society of New York, Inc. is responsible for the payment of the $4,000 per day fine assessed back in 2016, along with all costs associated with this appeal.

The court concluded its judgment by stating:

“On the record before us, we are satisfied that the superior court’s order was not arbitrary, capricious, or whimsical. To the contrary, the superior court has shown great patience and flexibility in dealing with a recalcitrant litigant who refuses to follow valid orders and merely reiterates losing arguments. We therefore affirm.” [bold ours]

The judgment was entered November 9th 2017. Watchtower has 40 days to file a petition for review with the California Supreme Court. Jose Lopez and Osbaldo Padron continue their civil cases against Watchtower in the Superior Court of California, County of San Diego.

Read the complete appellate court judgment here

Posted on July 26, 2022July 27, 2022 by Mark O'Donnell — Leave a comment

Jehovah’s Witness Elders Fined for Failure to Report Child Abuse: Watchtower Settles with Delaware

Published July 17th, 2018

Jehovah’s Witnesses in Delaware paid $19,500 in fines for failure to report child abuse.

On January 18th, 2018, attorneys representing Jehovah’s WItnesses signed a formal settlement agreement with the State of Delaware, concluding a historic case in which two elders and one congregation were held responsible for withholding detailed knowledge of a sexual relationship between an adult and a 14-year-old minor.

This case is unique, profound, and will likely set a precedent for other States.

According to the terms of the settlement, Jehovah’s Witnesses paid a total of $19,500 to the Delaware Department of Justice, and the body of elders from the Laurel Delaware congregation was required to attend the Stewards of Children training program and pay associated costs.

A third requirement mandated by Delaware included the signing of an affidavit stipulating that Jehovah’s Witness elders must comply with all Delaware statutes involving the reporting of child abuse. Among the itemized requirements, the Coordinator of the Body of Elders, William Perkins, agreed that communications with minors related to matters of abuse would not be treated as “penitential confessions.” This is significant, since attorneys for Jehovah’s Witnesses attempted to claim clergy privilege as their defense for failure to report.

On January 26, 2016, Justice Mary M. Johnston threw out Watchtower’s motion for summary judgment. Johnston pointed out that the elders’ sworn statements suggested that the victim and the perpetrator did not seek out the elders for private confession, which is the basic definition of penitential confession.

The case, formally called the State of Delaware versus Laurel Congregation of Jehovah’s Witnesses, Joel Mulchansingh, and William Perkins, was filed November 9th, 2015. It was brought by the Delaware Attorney General’s office following the discovery that 35-Year-old Katheryn Carmean-White had been arrested for engaging in at least 40 incidents of sexual intercourse with a 14-year-old boy. Both were baptized members of the Jehovah’s Witness religion.

Deputy Attorney General Janice Tigani became aware of this case from police reports, which had been filed in 2011. The mother of the 14-year-old victim contacted local authorities. A warrant was issued for Katheryn L. Carmean-White, who was arrested on 10 counts of third-degree rape, continuous sexual abuse of a child and endangering the welfare of a child. Carmean-White is currently incarcerated in the Baylor Women’s Correctional Institution of Delaware, serving a 6-year prison sentence.

Neither William Perkins nor Joel Mulchansingh contacted the police.

Instead, both elders initiated internal Jehovah’s Witness judicial proceedings which resulted in the disfellowshipping of both Carmean-White and her victim. Despite his age, the victim was considered a willing participant in consensual sexual acts. The repetitive nature of these sexual encounters was the foundation for disfellowshipping action by the church.

Delaware Sets the Example

Until now, the national epidemic of child abuse has been brought to light primarily through the efforts of mainstream media and numerous documented civil lawsuits. Such cases have resulted in hundreds of millions of dollars in settlements against the Catholic Church and Jehovah’s Witnesses, the religions most notorious for their mishandling of abuse allegations.

While individual states have codified laws penalizing mandated reporters for failure to report child abuse, almost none have brought charges against clergymen, or elders. Tackling religious organizations is often seen as trampling the First Amendment rights of these groups.

According to Deputy Attorney General Tigani, the Delaware case was about to go to trial when Watchtower lawyers opted for a private settlement. In part, the agreement stated:

“WHEREAS this agreement is made solely for the purpose of avoiding the time and expense of further protracted litigation”

Tigani agreed that Watchtower benefitted by conforming to the stipulations of the State of Delaware, in lieu of a protracted public trial. Evidence presented on both sides, including depositions from the two Witness elders, clearly pointed to gross infraction of Delaware law.

The progressive nature of Delaware’s punitive measures for violation of mandatory reporting laws comes on the heels of the worst case of child sexual abuse in United States history. Pediatrician Earl Bradley was sentenced to seven consecutive life terms, plus 165 years in prison for the molestation of hundreds of child patients, whose average age was three. The Bradley case was so egregious that Attorney General Beau Biden abandoned his bid for his father’s vacated Senate seat to funnel all energies into the prosecution of this case.

As Delaware prosecuted and jailed the notorious Bradley, lawmakers began to question how this man could have abused so many children for more than a decade, evading detection and prosecution. In 2010, Governor Jack Markell commissioned the Dean of Widener University Law School, Linda L. Ammons, to investigate what went wrong, and to itemize necessary changes. One key discovery involved the lack of proper reporting of abuse allegations to law enforcement or other state officials. Under the topic “Mandatory Reporters,” Ammons stated:

“It is my finding that no law enforcement agency, health professional or anyone else reported the allegations regarding Dr. Bradley to any administrative or regulatory body in accordance with current Delaware law. “

Families of victims were shocked to discover that allegations against Bradley stemmed back to 1994 in Pennsylvania, where the doctor had completed his residency. Layers of bureaucracy stymied the reporting process. Plausible deniability was contagious, and without enforcement of reporting laws, organizations, members of clergy, and ordinary citizens are without incentive to abide by these statutes. Professor Ammon made numerous recommendations to the Governor of Delaware, including the following:

“Increase penalties for violating the mandatory reporting requirements in the Medical Practices Act.”

Delaware agreed. Enforceable penalties were signed into law. Delaware code 914 states:

914 Penalty for violation. (a) Whoever violates § 903 of this title shall be liable for a civil penalty not to exceed $10,000 for the first violation, and not to exceed $50,000 for any subsequent violation.

This code enforcement is not limited to the medical practices field. In fact, every Delaware citizen is expected to report, regardless of their occupation. The Professionals’ Guide to Reporting Child Abuse and Neglect says:

“Professional reporters are often referred to as mandated reporters, although all citizens of Delaware are required to report child abuse and neglect.” [bold, italics ours]

Jehovah’s Witness elders Joel Mulchansingh, and William Perkins were found liable, both as professional mandated reporters, and as citizens of the State of Delaware. The congregation body of elders was also named as a responsible party.

The Settlement

In addition to financial penalties paid, the Laurel Congregation body of elders was required to attend the Stewards of Children training program, an initiative sponsored by the Beau Biden Foundation for the Protection of Children. The Biden foundation is a non-profit organization created in 2015 to further the goals of the late Biden in ensuring that children are afforded every possible protection from predators.

I spoke to a representative of the Stewards of Children program, who confirmed that their educational materials have been sanctioned by courts across the United States on the basis of competent, peer-reviewed research.

The third and final settlement term involved a multi-part affidavit, signed by the Laurel Coordinator of Body of Elders, and distributed to all congregations within the State of Delaware. Terms included:

Communications with individual involving acts of abuse shall not be considered as “penitential confessions”
Communications with minors involving acts of abuse shall not be considered as “penitential confessions”
Elders and the Congregation will comply with the law in accordance with the two items above
A copy of the signed and notarized affidavit will be provided by Jehovah’s Witnesses’ attorneys to all congregations within the state of Delaware

While Jehovah’s Witnesses have been forced to comply with the terms of this settlement, there is no evidence to suggest that this organization will participate in mandatory training programs in other states or countries. Currently, Witness policy dictates that the first notification of allegations of child abuse must be made by local elders to the Jehovah’s Witness legal department in Patterson New York. This policy has a profound chilling effect upon justice for victims and protection of the community.

Exterior Sign for Laurel and Seaford Congregations

Once their legal department advises elders whether they are in a mandatory reporting state or not, the call is handed over to the Service department, located inside the Witnesses’ Walkill New York compound. These men advise local elders of their internal judicial responsibility, such as whether to disfellowship a minor deemed as a willing participant in sexual acts.

Nowhere in Watchtower literature are victims or others encouraged to immediately contact civil authorities when allegations of abuse become known. By design, Jehovah’s Witnesses are trained to regard local elders as the primary authority, particularly when any sexual contact is discovered between two unmarried persons.

A Precedent Has Been Set

Delaware’s lawsuit against Jehovah’s Witnesses has broken the barrier which has, until now, protected churches from prosecution for failure to report child abuse.

In 2006, the Sonoma County Sheriff’s office recommended that charges be filed against Catholic Bishop Daniel Walsh. Walsh failed to file a timely report upon discovery that Catholic Priest Xavier Ochoa sexually abused at least three boys, the youngest being 12. The delay in reporting gave Ochoa the time he needed to escape to Mexico.

According to the San Francisco journal SFGATE:

“If prosecutors decide to charge Walsh, the case would appear to mark the first time a U.S. Catholic Church official has faced criminal prosecution for failing to properly report sexual abuse.”

Charges were dropped, however, in lieu of a plea agreement in which Bishop Walsh was required to attend a four-month counseling program.

The State of Delaware did not back down so quickly in its case against Jehovah’s Witnesses, leaving Watchtower attorneys little choice but to settle the case on Delaware’s terms.

Other states may soon follow suit, including Pennsylvania, where police are investigating the abuse of 4-year-old Abby Haugh in 2005. The assault occurred inside the local Kingdom Hall and was reported to congregation elders by the victim’s father, Martin Haugh. Local elders did not contact law enforcement.

Police are not commenting on this case, as the investigation is currently ongoing.

The terms of the Delaware settlement stipulated that once Jehovah’s Witnesses paid the agreed-upon fines, the State would dismiss civil action with prejudice. The settlement agreement was obtained by filing a Freedom of Information Act request.

Court Documents:

State of Delaware V Laurel Congregation, with Motion to Dismiss Ruling

Stipulation of Dismissal

Depositions from William Perkins and Joel Mulchansingh

***Final Settlement agreement, with affidavit

Additional Research Documents:

State of Delaware Child Abuse Laws

Delaware Hotline for Reporting Child Abuse

Delaware Professional Guide to Reporting Abuse and Neglect

Mandatory Reporting Requirements for Delaware

How to Identify and Report Child Abuse and Neglect in Delaware

Penalties for Failure to Report Abuse- by State

Commission for Review of Bradley Case

Independent Review of the Earl Brian Bradley Case

Clergy as Mandated Reporters of Child Abuse

Editor’s Afterthoughts:

In the course of investigating the Delaware case against Jehovah’s Witnesses, it became apparent that the Witnesses settled for a variety of reasons. Aside from the inability to win the case, this civil matter was in the process of being scheduled for trial. Had the settlement not been reached, a protracted and public trial would have been publicized across Delaware and picked up by media outlets across the U.S.

The monetary fines would not have differed much from the current result, with a maximum penalty of $10,000 per elder (for two elders) along with a $10,000 fine for the collective elder body, resulting in a $30,000 fine, plus court costs and legal fees. The most significant advantage of settling this case with Delaware was the fact that Watchtower was able to pay the fines without admission of guilt.

In the eyes of the public, anyone who reads the court docket for this case will note that the final act of Delaware was to dismiss this case. While dismissal was the net result, it obscures the fact that Watchtower was held accountable for failure to report child abuse. For this reason, I found it necessary to file a Freedom of Information Act request from the State of Delaware, to obtain the documents which prove that Watchtower paid the fines for failure to report, and was forced to agree to compliance with State reporting laws. Additionally, they were required to disperse mandatory reporting materials to all congregations in Delaware.

I hope that the public has a better understanding of what it means when a case is dismissed, and how private, behind-the-scenes settlements often reveal what actually happened.

It is my goal to make such cases transparent, for the benefit of the public.

Mark O’Donnell

I would like to thank the following individuals who were both supportive and informative during the course of my research:

Janice R Tigani, Deputy Attorney General for Delaware

Novene Tate, Case Manager for Justice Johnston

Kim Siegel, FOIA Coordinator for the State of Delaware

Jeffrey Fritz, Attorney, Soloff and Zervanos

Irwin Zalkin, Attorney, Zalkin Law Firm

Michael Rezendez, Boston Globe Spotlight Team

David Gambacorta, Philadelphia Enquirer

Carrie Teegardin, Atlanta Journal Constitution

Professor Marci Hamilton

Natalie Batten, Darkness to Light, Stewards of Children

Scrappy, the cat

Posted on July 24, 2022November 14, 2022 by Mark O'Donnell — Leave a comment

Jehovah’s Witness Elder Arrested on Four Counts of Felony Sexual Assault of Minors, Criminal Trial Set

Published May 31st, 2019

A former Jehovah’s Witness Elder and Headquarters member is scheduled to stand trial in July after his arrest on four counts of second-degree felony sexual assault. Roderick G. Watkins, 56, of Heber Springs Arkansas, was taken into custody following a November 21st 2018 arrest warrant issued by the Cleburne County Circuit Court.

The charges against Watkins stem from allegations of sexual assault of at least four minor victims, claims which were brought to the attention of Detective Jenifer Osborn of the Cleburne County Sheriff’s Department.

All of the victims interviewed appear to be connected to Watkins through the local Arkansas Jehovah’s Witness congregations where he was a known and respected elder. Reports indicate that the children assaulted ranged in age from 6 to 16 years at the time of the crimes.

Detective Osborn documented the timeline leading up to the arrest, which begins with a detailed conversation with a local resident and mother of the first victim named.

The following police report by Osborn has been redacted by JWChildAbuse.org to protect the names of the victims and their immediate family members.

The Police Report, Victim #1

“On October 9th, 2018, [The mother of victim #1] contacted the Sheriff’s office regarding sexual abuse of her son. [She] sounded distraught as she explained that her 12-year-old son named [victim #1] had disclosed to her, one week ago, that a trusted family friend had touched him inappropriately on his inner thigh. [She] said that the family friend is Roderick Watkins [who] lives in Heber Springs.”

“[The Mother of victim #1] told me that she had reported her son’s disclosure to her pastor and her pastor had told her he was reporting the incident to the child abuse hotline. [She] said that today, her son told her that Watkins had touched his privates. [She] told how this shocked her because she had thought her son had only been touched on the leg. She said she asked her son to tell her exactly what happened and she said her son told her that he had been at “Rod’s house”, downstairs, which is located in, Cleburne County, at 1310 N Broadway, Apt 13. Her son reported they watched a movie and Rod came in and rubbed his feet. She said her son, [victim #1] , said Watkins stopped rubbing his feet and ran his hand up his shorts and into his underwear. He said Watkins then rubbed his private parts for a few seconds. [The mother] said [victim #1] told her he got up and walked away. She said her son told her this had happened only that one time and it had been about a year ago.”

“[The mother] said that she doesn’t know what to do and said that she just wanted to let someone know that he had disclosed additional information. I asked her if she has spoken to anyone from CACD or DCFS since the pastor made the call and she said she had not I advised her that I would call and report this information and that I will be opening a criminal investigation. Case # 18-01126.”

“On October 11th, 2018, a forensic interview was conducted and recorded with [victim #1] . [victim #1] gives a detailed discloser [sic] about being touched on his genitals by Roderick Watkins at Watkins’ home. He tells how Watkins is a trusted family friend, babysitter and is a member of his Kingdom Hall. Watkins is trusted by everyone because he is a church elder.”

The Second Victim

“On October 12th, 2018, I was contacted by CACD and advised that another report of sexual contact by Roderick Watkins was called into the hot line and a forensic Interview was being scheduled for this victim, 15-year-old [victim #2]. [victim #2] disclosed touching of his genitalia and other sexual contact by Roderick Watkins that continued for years on multiple occasions at Watkins’ home and at [victim #2] ‘s home. [victim #2] disclosed threats by Watkins to [victim #2] ‘s dog, electronic toys, and a young friend if he disclosed the sexual contact. The circumstances surrounding the incident were similar to those of [victim #1] in that his family was also in the same church and had a close relationship with Watkins and Watkin’s wife.”

“On October 19th, 2018,[The parents of victim #2] came to the Sheriffs Office to file an official report on the behalf of their 15-year-old son [victim #2]. Report# 18-01220. The [parents] advised that Roderick Watkins was an Elder of their congregation and a Pioneer. They said he was very involved in the congregation and helped everyone. They also advise that Watkins is [victim #2]’s uncle by marriage and he has been a strong influence to [victim #2] for most of his young life. The [parents] do not know the details of [victim #2] ‘s disclosure, which I had already reviewed. They tell me that [victim #2] ‘s behavior and demeanor changed drastically when he was about 7 years old. This matches [victim #2]’s account of the first incident [victim #2] had with Watkins in 2010.”

“On October 19th, 2018, Roderick Watkins and his wife agreed to come in to discuss the allegations. Later this same day, instead of the Watkins’ coming, an attorney called and advised he was representing Watkins who declined to make a statement. Also, on this day, a search warrant for the residence of Roderick Watkins was executed and items of evidence were collected.”

The Third Victim

“On October 21st, 2018, [mother of the second victim] came to the Sheriffs Office with her 18-year-old daughter, [victim #3]. CCSO report # 18-01225. [victim #3] told me how when she was approximately 9 years old, she was sitting on Roderick Watkins’ Lap under a blanket at Watkin’s home in Cleburne County, and he touched her genitalia under her clothes. She said Watkins was a trusted member of their church congregation. She said she told no one about that incident and a few months later, it happened again the same way in Independence County at her home on [redacted address], Arkansas.”

“[The mother of victim #3] tells how even though her daughter had not told her about this incident until about a year ago, she had noticed her 9-year-old daughter sitting on Watkins’ lap and he had his hands under her blanket. [victim #3] said she told another member of the congregation about it at that time and this member confronted Watkins about not letting the child sit on his lap anymore.[The mother] goes on to say that once her daughter told her what happened to her, they reported it to the Elders and an investigation began. She said they were told by church elders that Watkins had done this unintentionally. She said nothing was done at first other than some suspension of his duties, but then when another unknown child came forward later, Watkins was disfellowshipped from the congregation.”

“As the investigation progressed, several people called in and came by the office and gave statements about seeing Watkins touch the above-mentioned victims inappropriately. Many of them tell how Watkins is a very affectionate touchy person towards children. They all agree that Watkins had a large influence and authority over this congregation of Jehovah’s Witnesses.”

The Fourth Victim

“On November 1st, 2018, [victim #4] came to the Office and CCSO. Report #18-01246. [victim #4] give detailed disclosure of being touched on his private areas under his clothes on two occasions back in 2011 when he was 16 years old by Roderick Watkins at [address redacted] in the summer and on November 2011 at War Memorial Stadium in Pulaski County during an event. The circumstances and actions of the two incidents with Watkins that [victim #4] detailed was similar to those of [victim #1] , [victim#2], and [victim #3]. [victim #4] tells how he reported his incidents to the Elders of his congregation soon after the second incident occurred. [victim #4] tells how he was not believed by the Elders and how he was told that he had “perceived” the incidents inaccurately. He said he and his family were treated differently after this. He said Watkins was one of the main Elders and he provided significant resources for the congregation. [victim #4] said when he turned 18 he stopped going to the meetings at the Kingdom Hall because he could not stand to watch as others continued to trust Watkins unconditionally.”

“At this point in the above-mentioned investigations, I believe probable cause exists to arrest Roderick Watkins for four counts of Sexual Assault in the 2nd degree. It is therefore prayed that a warrant to arrest be issued. “

“I swear the allegations contained herein are the truth, to the best of my knowledge, information and belief.”

Detective Jenifer Osborne (Signed)

Additional Revelations

Following the news of Watkins’ arrest, JWCA received additional details related to the investigation.

Shockingly, the mother of victim #1 told the police she had entrusted the care of her two young children to Rod and Becky Watkins while she underwent extensive hospital treatment for stage 4 breast cancer.

In her statement, the mother said: “They were very trusted friends and we spent a lot of time at their house cooking and hanging out. He had been a trusted pastor until the church removed him from that position last year when 3 kids said he had touched their upper leg, making them uncomfortable.”

“He fooled all of us, all of our friends into thinking that’s how he is with everyone. that he loves us and is very touchy-feely. My son [victim #1] said he rubbed his feet when my younger son [redacted] went to the bathroom, he put his hand up his leg and rubbed his penus.”

“He thought it was a mistake and pushed as hard as he could his hand away and moved to the end of the [couch].”

The distraught mother went on to tell police “He has always shown a sweet, concerned side of him. Two weeks ago when everything started coming out, he showed a very arrogant scary side of him. He has always driven by and walked around our house. [My son] is afraid he will do that again, and he’s afraid Rod will take him from his family.”

At the end of this police petition, the mother of victim #1 checked the box which says “There is an immediate and present danger of domestic abuse to [victim #1]”, adding “the investigation may take 45+ days and we don’t know where Rod is.”

The Proximity of Watkins to the Kingdom Hall

The investigation of Watkins has taken a few interesting turns. Court documents obtained reveal that the address provided by Roderick Watkins is directly linked with the Heber Springs Arkansas Kingdom Hall of Jehovah’s Witnesses.

Heber Springs Kingdom Hall of Jehovah's Witnesses — Heber Springs Kingdom Hall and Roderick Watkins Residence

The proximate location of Watkins to the local Kingdom Hall appears more than mere coincidence. Congregation Elders holding key positions sometimes use their own address as the Kingdom Hall address. This practice can lead to the mixing of Kingdom Hall locations with the home addresses of elders.

More importantly, if correspondence from other congregations or from Headquarters were sent to a home address, letters involving allegations of abuse from other locales could theoretically be intercepted before they ever reached the body of elders.

Whatever the case, it’s clear Watkins lived just a short distance from the church where his victims attended meetings.

Watkins, a Transient Elder

Diverse sources report that Watkins was a career Jehovah’s Witness Elder who migrated from the Southern United States to multiple congregations around the country.

A North Carolina native, Rod “Roddy” Watkins arrived in Brooklyn New York in the mid-1980s where he served as a dining room waiter to the expanding Bethel family. In 1988, Watkins left Watchtower headquarters, married, and eventually settled in Sedalia Missouri where he and wife Becky began their newlywed life together. The Watkins shared a residence building with other Witnesses who relocated to help the local congregation.

Having left Missouri for unknown reasons, Watkins and his wife made their way to Indiana, where they attended the congregation in West Harrison, on the Ohio border. Roderick and Becky were considered by Indiana Witnesses as pillars of the organization.

A Reddit user who prefers to remain anonymous remembers Watkins’ going-away party in Indiana, where according to this former Witness, “[He] was considered the finest elder from the Indiana circuit.”

A second Indiana source said “We went to the same congregation near Lawrenceburg, Indiana during my teen years. I never would have imagined this about him. He and his wife Becky were the pillars of the congregation.”

After 2000, the couple decided to move to Arkansas, presumably to be near his wife Becky’s family in Mountain View. Rod and Becky eventually settled into the Heber Springs Kingdom Hall of Jehovah’s Witnesses.

Watkins, a distinguished Elder, and Pioneer minister, served in the special capacity of Service Overseer, a position that placed him on the “Service Committee” along with the Presiding Overseer and Secretary.

Roderick and Becky Watkins with Children from Indiana

The Service Committee of Jehovah’s Witness Congregations governs the activity of each congregation, and is responsible for making sure Watchtower policies are carried out, including the formation of judicial committees and the handling of child abuse allegations by congregants or appointed elders. Watkins’ position created a deeply disturbing conflict of interest within the elder body.

Several sources with knowledge of the case suggested that the number of victims may well exceed the four who gave statements to the police in Heber Springs. They said: “there was a previous [Kingdom] Hall in Arkansas where an accusation was made and the 2 witness rule kept it from going further.”

If the allegations are correct, Watkins could be implicated in the cover-up of his own crimes, since letters of introduction from other Congregations he attended would necessarily follow his transfer into Heber Springs Arkansas.

As a long-time Elder in the church, he would be well aware of the July 1, 1989, and March 14th, 1997 letters from Brooklyn Headquarters. The 1997 letter specifically required all congregations to submit any instances of known child abusers to the religions New York office, as reported in the Atlantic article from March 2019.

The organization continues to compile data related to child abuse cases using its secure internal computer network.

One Family’s Plea for Help

The wake of devastation left by Roderick Watkins is significant. One Arkansas family has placed their home up for sale after victim #2 attempted suicide. Just 15 years old at the time of Watkins’ arrest, victim #2 described sexual abuse spanning half his young life, and which included threats to his dog, his toys, and even his friends if he ever told anyone what happened.

A GoFundMe account has been set up to cover $100,000 in expenses for the therapy and treatment of this young victim. Both Witnesses and Ex-Witnesses have contributed.

The father of victim #2 posted: “Our son, [redacted], spent most of January in the hospital for suicidal thoughts/attempts. He could not see past the depression that he has been suffering from because of some horrible acts towards him. “

Who Reported the Abuse?

It is unclear at this stage whether any elders in any congregation ever reported the accusations of abuse to local or state law enforcement. All indications from the police report suggest that it was the families of the victims themselves who compared notes, then decided to speak to Arkansas police.

Details are still emerging in the case, but an analysis of the police report and other evidence indicates that Watkins was only disfellowshipped from the congregation following at least three reports of sexual assault by Watkins. The mother of victim #3 states that Watkins was disfellowshipped after another child reported abuse “later”- but victim #4 – the oldest victim – had already reported his abuse to the elders.

This provides substantial cause to conclude that congregation elders not only hampered this investigation, but their obstruction of their own internal policies led to the sexual abuse of a minimum of two additional children in Heber Springs.

Of course, it did not help that Watkins remained an appointed elder in the congregation until he was reportedly defrocked as elder in 2017, then disfellowshipped in 2018.

What’s the Reporting Law?

Arkansas law currently states that “Clergy must report suspected child maltreatment except to the extent the clergy member has acquired knowledge of suspected child maltreatment through communications required to be kept confidential pursuant to the religious discipline of the relevant denomination or faith ” – Ark. Code Ann. § 12-18-402

While Jehovah’s Witness elders are mandated reporters, in every case they seek out the loophole which permits them not to report pursuant to their own “religious discipline.” In other words, if their internal practices declare communications with any congregation member as “confidential,” they immediately take the position that they are under no obligation to report.

Elders are instructed not to report abuse whenever this loophole exists, rendering mandatory reporting laws useless and toothless. Any elder who defies Watchtower’s procedural edicts are subject to deletion as elders, or worse.

If ever there were a reason for the Jehovah’s Witness organization to maintain secrecy with regards to their growing database of child abusers, this case highlights their disturbing concern. Watkins was a trusted, appointed servant to Watchtower, having passed multiple layers of theocratic oversight in his rise to authority and prominence.

He was described as well-respected- a pillar in the congregation – so much so that families frequently left their children with this man, only to have their world shattered by these shocking discoveries.

The sect of Jehovah’s Witnesses is guided by the belief that these men are appointed by “God’s Holy Spirit”, and that congregation elders act upon this force, which weeds out that which is unholy or in opposition to God’s will. Yet the cold reality is that no artificial “spirit” has ever prevented a child from being molested.

In fact, the religion itself appears to harbor these individuals while twisting and obstructing the very civil laws designed to give clergy members the ability to report child abuse and protect their congregations and the community.

Pending a plea bargain, Watkins criminal trial is set for July 17th-19th, 2019 and will be closed off to the public and reporters.

[Editor’s note: the trial was rescheduled for October 2019 and was open to the public]

Update: On October 3rd, 2019 a jury convicted Roderick Watkins on all counts and sentenced him to a total of 80 years in an Arkansas State prison for his crimes. Watkins appealed and lost.

Editor’s Note: In keeping with the policy of JWCA, the names of minor victims have been redacted, even though court documents reveal such information. Adult survivors of abuse are welcome to share their stories if they wish, but we do not solicit survivors for information. Victims are encouraged to immediately contact law enforcement and qualified, professional therapists to protect the public and assist in recovery.

Anyone with information regarding allegations of sexual abuse by Roderick Watkins should contact the Cleburne County Sheriff’s Office in Arkansas, or the police jurisdiction where the crimes may have occurred. If in doubt, call 911 immediately to be transferred to the appropriate law enforcement office.

Additional Resources:

Children’s Advocacy Center of Arkansas: https://www.cacarkansas.org/
Child Welfare Information Gateway: https://www.childwelfare.gov/

Court Documents:

Please note that JWCA will not publish the Affidavit for Arrest Warrant for Roderick Watkins as it contains the names of minor victims of Watkins as well as family members. While it is a publicly available document, it is our policy to protect the identities of these individuals.

Posted on July 21, 2022July 24, 2022 by Mark O'Donnell — Leave a comment

Love and Justice in the Face of Wickedness

Child Abuse in the Courts - Jehovah's Witnesses

A Review of Jehovah’s Witnesses’ Public Claims Concerning Child Protection

Editor’s Note: After reviewing this article, you may use the following links to jump directly to the discussion of specific paragraphs.

Paragraph 1 Paragraph 2 Paragraph 3 Paragraph 4 Paragraph 5 Paragraph 6 Paragraph 7 Paragraph 8 Paragraph 9 Paragraph 10 Paragraph 11 Paragraph 12 Paragraph 13 Paragraph 14 Paragraph 15 Paragraph 16 Paragraph 17 Paragraph 18 Paragraph 19 Paragraph 20 Paragraph 21 Paragraph 22 Paragraph 23 |

Why don’t Witness Elders Report? | The Two Witness Rule | Elders “Endeavor” to Comply

“Jehovah God hates all forms of wickedness,” says the ohttps://jwchildabuse.org/xqllht/news/love-and-justice-in-the-face-of-wickedness#whypening line of the May 2019 study article of the Watchtower. It bears the title “Love and Justice in the Face of Wickedness.”

This opening sentence reveals the difficulty in examining religious beliefs and practices, and the language used to support such beliefs. Often, it is subjective. What is wickedness? Who is responsible for its definition?

For the vast majority of humanity, wickedness might be identified with genocide, murder, prejudice, homophobia, or even killing animals. Yet for fundamentalist religions, these societal ills somehow become “God’s will” when defined by the men who lead such religions.

This column reviews the carefully scripted language of the Watchtower article discussed in Jehovah’s Witness congregations worldwide on Sunday, July 14, 2019.

The world has changed rapidly in the past 20 years. Social media, technology, and investigative journalism have merged into a powerful and undeniable force for exposing child abuse and the massive global cover-up by religious and other institutions.

Jehovah’s Witnesses are currently under investigation in multiple countries and jurisdictions for their role in harboring documents that reveal that elders and senior officials have failed to report child abuse since the inception of their religion.

Paragraph 1

As expected, Watchtower uses its stock child abuse policy claim in the opening paragraph: “Jehovah’s Witnesses abhor child abuse.” Largely, aside from the abusers themselves, this statement is true. But it is immediately followed with “[they] do not tolerate it in the Christian Congregation.”

This is where they mislead the public and their own members.

The very nature of the religion’s infamous “Two-Witness” edict mandates that no congregation action be taken against an accused offender unless there are two corroborating witnesses to the abuse. Any individual of modest intelligence would agree that there are almost never witnesses to child abuse.

By declining to take congregational action against an offender, Witness elders “tolerate” child abuse.

Paragraph 2

“Child abuse is a selfish, unjust act that makes a child feel unsafe and unloved”

This statement might appear correct at first glance, but for those who study the psychology of child abuse, it is a dangerous oversimplification of a complex problem, and it is the reason so many victims of abuse take years or even decades to come forward.

Watchtower’s writers have no training or expertise in this area. They are anonymous men, and the criteria for becoming a Watchtower writer does not include education.

An abused child does not always feel “unsafe and unloved.” In many cases, just the opposite. Abusers create a “special” relationship with their victims where they feel exceptional, loved, and worthy of attention from a respected adult. This is confusing for a young mind, but the clever child molester knows just how to make a child feel that their relationship is somehow normal.

A predator knows that a child may have little knowledge of their sexual organs, but he seeks to find a way to elicit the sensation of pleasure in his victims, creating a very dangerous connection between abuser and victim.

Survivors of abuse are often tormented with guilt for having experienced some measure of pleasure at the hands of an adult abuser. They are not equipped to process the complexity of these interactions. Due to the extreme insularity of Jehovah’s Witnesses, coming forward to a school counselor or other non-Witness authority figure is almost always out of the question.

Similar insularity and complexities are associated with the claims made against deceased pop-star Michael Jackson, whose victims have often been maligned for failing to come forward at the time of the abuse.

As reported in the Guardian in 2005,

“At no stage did any witness or victim report Jackson to the police. Or try to stop the alleged abuse. They went to lawyers, tabloid editors and television reporters, but never to social services.”

Jackson’s victims were much like Witness children- they were insulated, showered with love and attention by their abuser, and reminded by the Jackson organization that confidentiality was not to be broken.

Paragraph 3

“Sadly, child sexual abuse is a worldwide plague, and true Christians have been affected by this plague.”

It is noteworthy that after stating the obvious- that abuse is a global plague, the Watchtower makes an odd confession:

“some professing to be a part of the congregation have succumbed to perverted fleshly desires and have sexually abused children.”

The language used implies that the Jehovah’s Witness (JW) congregation is somehow pure, and only those “professing” to be part of the congregation would fall into the practice of abusing children.

The clever use of “professing” implies that the sexual predators who have abused Jehovah’s Witness children over the decades were somehow never part of the religion- that they only professed to be so.

This language is deceptive and disguises the fact that a great number of JW abusers were quite well-respected, dedicated Witnesses of Jehovah, and were given positions of authority which extended over years, even decades- all while they sexually molested Witness children.

JW Survey reported on a recent case brought to light with the arrest of former elder and Service Overseer Roderick Watkins. Watkins was arrested in 2018 following at least four different police reports filed in Heber Springs Arkansas- not by congregation elders – but by the families of the victims.

Upon further investigation, it was discovered that Watkins was a longtime, prominent elder who served at Brooklyn headquarters during the 1980s, and was subsequently sent to serve as Elder-Pioneer in multiple congregations throughout Missouri, Indiana, and Arkansas. Following our Survey article from May 31, 2019, additional victims have come forward from Indiana, with estimates of sexual abuse ranging from dozens of children, up to one hundred. Only time will tell the full extent of damage caused by this elder.

Given the extensive and lengthy history of Watkins inside the Witness organization, it’s clear he was more than just a “professed” Christian.

Paragraph 4

The identification of child abuse as a “grave sin” might be the understatement of the year. While is seems wholly unnecessary to mention this, it is part of Watchtower’s policy and strategy to convince members that elders have little or no obligation to pursue criminal reporting when allegations of abuse are made.

Paragraph 5 – “A sin against the victim”

“Children must be protected from such a wicked deed…”

Such a true statement should be followed up with recommendations for engagement with law enforcement, professional therapists, and other trained and educated individuals who specialize in the investigation and treatment for victims of abuse, but these recommendations are absent.

Does Watchtower Believe the Victims are Innocent?

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Among the most disturbing revelations about Jehovah’s Witness mishandling of child abuse reports are the treatment of young, minor children as willing participants in sexual acts with adults.

Police reports, court documents, and civil cases have unmasked the sinister policy whereby young, minor victims of sexual abuse have been harshly disfellowshipped from the Jehovah’s Witness religion following sexual contact with adults 3 or 4 times the victim’s age.

In 2017, NBC Philadelphia reported on the case of Katheryn L. Carmean-White, a Jehovah’s Witness woman who sexually abused a 14-year-old Jehovah’s Witness boy in a Delaware congregation. White was sentenced to 6 years incarceration, while she and her victim were both disfellowshipped from Jehovah’s Witnesses.

JW Survey reported on the outcome of this case in 2018, unveiling the settlement agreement signed between the State of Delaware and the Laurel Congregation of Jehovah’s Witnesses.

Witness elders Joel Mulchansingh and William Perkins were among the Judicial Committee elders which disfellowshipped the victim of this crime, ostracizing him from the congregation and treating him as a consensual sexual partner of his convicted predator, Ms. White.

Paragraph 6

“When someone who is a part of the congregation becomes guilty of child abuse, he brings reproach on the congregation.”

The word “reproach” has been part of the Jehovah’s Witness lexicon for decades. It is used to inhibit conduct or stigmatize certain behaviors. It reveals the true nature of Watchtower’s reluctance to discuss their epidemic of child abuse: Negative publicity.

It has always been the contention of Jehovah’s Witnesses that “reproach” upon the organization drives interested persons away, and those responsible for such reproach become “bloodguilty” – causing their death at Armageddon. Somehow, God has exited the picture with no control or influence over the lives of “interested” persons.

Paragraph 7

“A sin against the secular authorities.”

Here is where we get to the core of the sexual abuse scandal within the Jehovah’s Witness Church. The Organization’s position is:

‘We know it’s a crime, and we normally obey the law- but in this case, we will collect the data regarding these crimes and use it for our internal parallel judicial courts, and we have no duty to report to the police.’

Or, as this Watchtower subtly states:

“While the elders are not authorized to enforce the law of the land, they do not shield any perpetrator of child abuse from the legal consequences of his sin.” [bold, italics ours]

This is a deceptive and blatant deception, for which the average Witness- even the average elder- has no understanding.

The reality is that the elders are authorized to enforce the law of the land. As members of the clergy in the United States, they are obligated to obey all mandatory child abuse reporting laws in each state where such laws apply.

So Why Don’t They Report?

Witnesses who study this article will walk away believing that elders do comply with civil authorities, but the shocking reality is that they don’t, and here’s how they get away with it:

In the United States, while nearly every state requires members of clergy, teachers and medical professionals to report all allegations of abuse, there is a very clever technique used by Witnesses to avoid contacting authorities. It’s called the clergy-penitent exemption.

This ‘privilege’ was intended to give penitent (guilty) individuals the privacy to confess sins to their priest without fear that his disclosure would be shared with anyone.

What Jehovah’s Witnesses have done is take the clergy privilege exception and applied it not just to the penitent (the abuser) – but to all individuals associated with reports of child abuse within the congregation.

This includes the abused victim, the victim’s family members, and all of the elders who become aware of the reported abuse. The claim is made that every one of these individuals is covered by privilege, and because of this, elders have neither the duty nor the right to report child abuse.

Paragraph 8

“Above all, a sin against God”

It is reasonable to conclude that those who revere Scripture might agree with this statement. The article continues:

“The Law said that a man who robbed or defrauded his neighbor was behaving “unfaithfully toward Jehovah.” (Lev. 6:2-4)”

Evidently, there is no objection from Jehovah’s Witness elders when it comes to reporting fraud or robbery to the authorities. Yet they take extensive measures to circumvent mandatory reporting laws, even when they have been held liable in dozens of civil lawsuits over the past 25 years.

The paragraph concludes: “For that reason, abuse must be condemned for what it is—a gross sin against God.”

For Jehovah’s Witnesses, condemnation does not include calling the police.

Paragraph 9

“Elders have received detailed Scriptural training on how to handle the sin of child abuse.”

This deceptively worded paragraph suggests that Witness elders are well-equipped to handle reports of abuse. They aren’t.

Elders are instructed by fellow Witness elders in an organization comprised of self-appointed men with no secular or civil requirements. This presents a serious dilemma for ill-equipped men bestowed with criminal allegations of child abuse.

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Paragraph 10

“Handling Instances of Serious Wrongdoing”

“The elders are primarily concerned with maintaining the sanctity of God’s name…They are also deeply concerned with the spiritual welfare of their brothers and sisters in the congregation.”

It cannot be overstated that Witnesses sell their procedures as insurance policies to protect God, listing this objective as the first priority. Placed second is the welfare of congregation members, including victims.

The unusual emphasis on the protection of God’s name seems to beg the question: Why does the organization feel its Creator is unable to defend his own reputation?

Paragraph 11

“In addition, if the wrongdoer is a part of the congregation, elders are concerned with trying to restore him if that is possible.”

While it might seem noble to restore troubled individuals to a congregation, the matter is much more dangerous and complex when dealing with child molesters. Elders are not equipped to counsel or “restore” an individual with a sickness which demands professional attention.

Handling such matters internally places many children at risk, particularly when a repeat offender enters a congregation.

“Their Scriptural counsel can help him to restore his relationship with God, but this is only possible if he is genuinely repentant.”

The issues at play with child abuse are extremely serious. These abusers are not persons dealing with issues such as smoking or petty theft. A child molester frequently repeats his crime, and there are no religious sanctions or counsel which can change the nature of this sickness. It must be handled professionally.

Paragraph 12

“Clearly, elders have a weighty responsibility…For that reason, they act promptly when they receive a report of serious wrongdoing, including child abuse.”

Acting “promptly” means launching an internal investigation, and does not include an immediate call to local authorities.

Paragraph 13

“Do elders comply with secular laws about reporting an allegation of child abuse to the secular authorities? Yes.”

This answer should be changed to “No.”

“In places where such laws exist, elders endeavor to comply with secular laws about reporting allegations of abuse.” [italics ours]

The sentence above clearly modifies the opening sentence, revealing that Jehovah’s Witness elders do not comply with laws in any location where there are not clergy mandated reporting laws in place.

Furthermore, in states where such laws do exist, elders still fail to report, citing the clergy-penitent loophole. As stated earlier, when a religion claims it is their accepted practice to keep allegations of child abuse private, they ignore mandatory reporting laws.

“So when they learn of an allegation, elders immediately seek direction on how they can comply with laws about reporting it.”

To be accurate, this statement should read “elders immediately seek direction on whether they can escape mandatory reporting laws and leave it to a family member or concerned citizen to report.”

Paragraph 14

“Elders assure victims and their parents and others with knowledge of the matter that they are free to report an allegation of abuse to the secular authorities.”

Being free to report a matter to the secular authorities and encouraging a person to contact the authorities are two completely different things.

Under no circumstances are elders advised to contact law enforcement, nor do they advise families to report. They are told to take a passive stance in this regard. Reporting has never been encouraged.

Paragraph 15 – The Two Witness Rule

“In the congregation, before the elders take judicial action, why are at least two witnesses required?”

After describing the parallel system of justice practiced within the Witness organization, Watchtower asks:

This is where reality takes a hard-right turn from the publicly stated policy of Jehovah’s Witnesses. The mere suggestion that elders can theoretically contact law enforcement even when there are not two or more witnesses to child abuse is just that: theoretical.

“Does this mean that before an allegation of abuse can be reported to the authorities, two witnesses are required? No.”

Elders are never permitted to contact law enforcement following allegations of child abuse. Their instructions are very specific: They must call Watchtower’s legal department first.

The legal department of Watchtower then advises elders of two things:

Whether they are in a mandatory reporting state or country
Whether there is a clergy-penitent loophole

In every single case, even when there is a mandatory reporting law, elders are not permitted to contact local authorities when they are told they can use clergy privilege as a way to avoid reporting.

In countries such as the United Kingdom, where clergy mandated reporting laws do not yet exist, reports are never made.

Paragraph 16 – Elders “Endeavor” to Comply

“When they learn that someone in the congregation is accused of child abuse, elders endeavor to comply with any secular laws about reporting the matter….” [bold, italics ours]

The use of the word “endeavor” in this Watchtower article has great significance. The anonymous Watchtower writers are driven, not by the desire for accuracy, but by the necessity for obfuscation.

In other words, Watchtower knows it can’t say “Elders always comply with any secular laws about reporting child abuse.” Instead, they must insert the word “endeavor” to avoid the obvious repercussions from lying to the public. By using this word, they can claim that when they fail to report, at least they “endeavored” to do so.

“In addition, the elders remain alert regarding the alleged abuser to protect the congregation from potential danger.”

Jehovah’s Witness elders are in no position to protect even their own congregation from the crimes committed by a pedophile. These men are ill-equipped and untrained to deal with these crimes.

It is doubtful that any elder would attempt to assume the highly technical role of murder investigator- yet when it comes to the crime of child abuse, Witness elders immediately launch their own isolated investigation, which includes delving into the sexual and intimate details surrounding the abuse of a minor child- matters which should be left to the police.

If a man commits murder, the elders will disfellowship such a man on the basis of his conviction by secular authorities, whom they trust have done a thorough investigation of the murder, arriving at a guilty conviction. This raises the question, if Jehovah’s Witnesses accept the civil authorities’ conviction on a murder charge, why would Witnesses need to launch their own private investigation of child sexual abuse?

Shouldn’t they accept the decision of the civil authorities, who have spent most of their lives studying and executing investigations into child abuse?

The answer to this question should leave the public stunned and shocked:

Jehovah’s Witnesses investigate child abuse allegations to determine whether the child was a willing participant in the sexual acts.

As disturbing as this sounds, it is a solid reality which reveals that Witnesses consider both baptized and unbaptized minors as fully capable of having consensual sexual affairs with grown adults, and they hold these children accountable for their “sins.”

My first experience with disfellowshipping came in the 1980s, when a teenage girl in my congregation was disfellowshipped for having sex with the husband of a local Witness woman. She was treated harshly, as a willing participant in the act of coercing and seducing a minor child, and paid dearly as a victim of this pedophile. She was branded a fornicator, with no consideration for the manner in which she was seduced and abused.

The man was sentenced to a heavy prison term, but only after the victim’s family notified the authorities. The elders had no intention of involving the police, as is their policy to this day.

Paragraph 17

“What is the role of the judicial committee?”

“The elders do not interfere with law enforcement; they leave criminal matters to the secular authorities.”

Jehovah’s Witness elders have been judged guilty of interfering with law enforcement for decades. As recently as 2018, the Attorney General for Delaware imposed a fine of $10,000 per elder for failure to report the abuse of a 14-year-old baptized Witness boy who attended the Laurel Congregation of Jehovah’s Witnesses.

Watchtower’s legal team attempted to save their reputation by signing an out-of-court settlement agreement with Delaware, hoping that the public would not discover their concession, which took place immediately before the scheduled trial.

JW Survey obtained the settlement agreement with the cooperation of State Government officials.

In September 2018, a Montana jury found Jehovah’s Witnesses guilty of obstructing Montana’s mandatory abuse reporting statutes and awarded the victim 35 million dollars. Four million was awarded for negligence, with the additional 31 million awarded for intentional malice in non-compliance with the law.

To claim that elders do not interfere with law enforcement is a blatant and significant lie.

Paragraph 18

“If he is repentant, he may remain in the congregation. However, the elders will inform him that he may never qualify to receive any congregation privileges or to serve in any position of responsibility in the congregation.” [bold, italics ours]

When elders take on the role of spiritual policemen of the congregation, they tread on very dangerous ground.

First, a child abuser will never be disfellowshipped from any congregation without a second witness to the crime- and there is almost never a second witness.

When accusations are made, they are effectively not taken seriously. Police are never called, and without corroborating evidence, elders tell congregation members and victims to “leave the matter in Jehovah’s hands.”

Abusers remain in the congregation, and at best, a handful of parents might be warned about an individual who was found guilty of child abuse- not by civil authorities, but by congregation elders. Hence, this situation is quite rare.

Another matter of concern is the idea that serial pedophiles can “repent” and may be given responsibility in the congregation at a future time.

The use of the term “may” indicates the reality that elders have little understanding of the psychological sickness of pedophilia, and would consider reappointing a man after their unqualified elders come to a decision that this person is no longer a danger to children.

Pedophiles will always be a danger to children.

Paragraph 19

“Who have the responsibility to protect children from harm? Parents do.”

This statement completely bypasses the issue at hand. The cornerstone issue is obedience to the law, which states that members of clergy have the obligation to report child abuse to the police.

Watchtower is effectively changing the subject, diverting attention from the obligation of elders to comply with mandatory reporting laws.

Child abuse cases are deeply complex, and in some cases involve parents or step-parents, as well as siblings of the victims.

Placing the expectation of reporting on parents completely ignores these complexities. For example, the spouse of an abuser is often frozen in their tracks- unable to report that their spouse has abused a child. Why? Because that spouse may be financially dependent on their mate- or worse, they may fear for their own safety.

This is why members of clergy are generally required to report all allegations of abuse. Their separation from the family should be unbiased, and if they respect “Caesar’s law”- they must report.

Paragraph 20

“First, educate yourself about abuse.”

This is good advice- except that the education should not come from Watchtower publications. Page 12 of this Watchtower article features all of the information deemed by Jehovah’s Witness leaders as “education.”

Sadly, none of these resources have been written by anyone with professional training. It is a hodge-podge collection of Watchtower-only material, much of which is outdated even by Witness standards.

Paragraph 21

“Maintain good communication with your children.”

This is good advice. What should be added to this is “If your child reveals that someone touched them in a sexual manner, contact the authorities immediately”- and not local elders.

Paragraph 22

“Educate your children.”

Again, this is a good suggestion. However, it is followed by:

“Use the information that God’s organization has provided on how to protect your children.”

Not once does this Watchtower article recommend that parents avail themselves of professional resources, counseling, or meeting with law enforcement officials. By placing such devoted trust in the Watchtower organization, parents are trusting an organization found guilty of covering up decades of child abuse.

The cover-up, it is said, is worse than the crime itself.

Paragraph 23

“As Jehovah’s Witnesses, we view child sexual abuse as a gross sin and a wicked deed…our congregations do not shield perpetrators of abuse from the consequences of their sins.”

The final paragraph sums up the emphasis Jehovah’s Witnesses place on sin, as opposed to crime. While we do not deny religious organizations the right to declare certain behaviors as sinful, they do not have the right to obstruct justice by advising elders not to report allegations of child abuse to the authorities.

Love and Justice in the Face of Wickedness

While sexual predation and evil exist in our world, we are a global village with a collective obligation to take action against any who would harm our children.

The complexity and nature of child abuse require that it be investigated by trained professionals – skilled women and men who care deeply for children.

If you or a family member has been abused by someone inside or out of the Jehovah’s Witness organization, please seek immediate assistance from law enforcement and professional counselors, and be sure to obtain legal representation.

While some might feel apprehensive about asking for legal advice, there is nothing to fear. Attorneys have been able to obtain settlements for survivors of abuse, and those funds help pay for the medical bills and counseling which can bring a survivor back to life.

Love requires we protect our children; justice demands it.

Posted on July 20, 2022July 20, 2022 by Mark O'Donnell — Leave a comment

Child Abuse Records Reveal Extensive Data Collection by Jehovah’s Witnesses

Jehovah's Witness Child Abuse Data Collection

Published April 30th, 2021

Attorneys representing Alexis Nunez have filed a motion to compel the Watchtower Bible and Tract Society of New York to turn over at least 10 pages of detailed database records involving abuser Max Reyes and three of his victims, including plaintiff Nunez.

According to documents tendered to the Sanders County Montana Court, Watchtower attorney Joel Taylor emailed three of the ten pages in question to the Nunez team on the eve of the final day of the 2018 trial held in Thompson Falls Montana. Taylor purportedly presented the sensitive documents as part of his strategy for closing arguments the next day.

The three pages in question have now been released in court filings, but attorneys for Nunez are demanding the entire 10-page dossier.

The database pages reveal the shocking extent of Watchtower’s internal child abuse investigations, including the disclosure that Watchtower Legal Department directors register whether or not victims of child abuse are “willing participants” in their own sexual abuse.

The documents combine notes taken by Jehovah’s Witness elders with answers to questions posed by the Watchtower Legal Department in New York, blended with additional data used by the Witnesses’ Service Department to determine how abusers and victims should be managed inside the congregation.

Minor victims designated as “willing participants” are treated as adults and subjected to judicial hearings and disfellowshipping.

Watchtower Star Witness Identified As Additional Abuser of Nunez

In the 112-page motion to compel Watchtower to produce database documents, Nunez’s legal team revealed that Watchtower’s star trial witness, Peter McGowan, had confessed in 2014 to elders in Polson Montana that he too had molested the plaintiff, Alexis Nunez.

This information was not made public until now.

During the 2018 trial, Peter McGowan testified as a witness for Watchtower, stating that in 2004 he disclosed to his sister that he had been sexually abused by his stepfather Max Reyes. Watchtower attorney Joel Taylor elicited testimony from Peter to establish that his communications with Thompson Falls elder Don Herberger were confidential. Taylor also asked Peter about a conversation with his sister Holly McGowan in which Holly mentioned a possible lawsuit against Max Reyes.

Peter stated: “She called me and she wanted to participate in a lawsuit that her and my father were trying to put forward against Max. And I didn’t really feel comfortable. I just wanted — I told her I wanted to leave everything in the past and move on with my life.”

Peter McGowan’s trial testimony in 2018 appears to shed considerable light on the reasons Peter declined to participate in any litigation against the Watchtower organization. Notwithstanding the fact that he chose to remain in the church, his admission that he sexually abused his own niece places him in an untenable position.

The jury in the 2018 trial never heard evidence that Peter McGowan had molested the defendant. This information was outside the scope of legal negligence argued by Nunez, where the issue was Watchtower’s failure to report under Montana law. The circumstances have changed now that the case is back in the Sanders County Court where plaintiff Nunez is suing Watchtower for common law negligence.

The 2018 trial focused on evidence that Thompson Falls elders had violated Montana’s abuse reporting laws when they learned of the abuse of Holly and Peter McGowan, the aunt and uncle of Nunez. Nunez argued that this failure led to her own abuse before, during, and after the disfellowshipping of Max Reyes, her step-grandfather. Watchtower appealed the verdict, and in January of 2020, the Montana Supreme Court ruled that the Jehovah’s Witness elders were legally exempted by the reporting requirement. Jehovah’s Witnesses argued that their church could take advantage of a confidentiality exception in the Montana law.

Nunez immediately brought the case back before the Sanders County Court, contending that since Judge Manly had ruled in 2018 that elders violated the reporting laws, she never had the opportunity to argue her claims of common law negligence. In other words, while Watchtower’s elders were legally exempted from reporting Nunez’s abuse, the congregation and Watchtower can still be held liable for their negligence.

Why Demand the CM Database Pages?

As the Watchtower Organization continues to collect vast amounts of data related to sexual crimes, criminals, and victims, survivors are demanding answers for why this information is held by a religious institution and not promptly turned over to the relevant authorities.

Jehovah’s Witnesses currently subscribe to a policy where local elders are prevented from reporting child abuse unless the parent corporation Watchtower is unable to find a legal exception to the reporting requirement. The Church’s Legal Department has taken the position that what’s good enough for the Catholic Church is good enough for Jehovah’s Witnesses. The Witnesses believe they can project the Catholic confessional model upon all communications between members and their elders, regardless of whether the communications occurred in a confessional setting.

The Catholic model was originally set up to protect communications between a single confessor and his priest, but the Jehovah’s Witnesses expand the definition of protected communications to include their entire body of elders and all conversations with anyone involved in alleged wrongdoing.

In addition to the clergy-penitent confidentiality claims argued by the Witnesses, attorney-client privilege has become a decisive factor and key reason why Witness elders are instructed to promptly call Watchtower’s Legal Department when they learn of child abuse allegations – instead of calling the police.

In Montana, attorneys for Nunez demonstrated that Watchtower attorney Joel Taylor waived attorney-client privilege when he emailed 3 pages of Child Maltreatment (CM) data records just before midnight on September 25th, 2018. The strategy involved a last-minute attempt to support his closing arguments, but this tactic exposed the existence of 7 additional pages of comprehensive data including the abuse of Lexi Nunez by Watchtower’s key witness, Peter McGowan.

In the April 2021 Motion to Compel, Nunez argues:

“During the discovery phase of this case (before trial), Defendants refused to produce a certain ten-page document from their CM database on the basis that it was protected by the attorney work product and attorney client privilege… However, during trial, Defendants chose to waive their privilege claim by voluntarily disclosing privileged content from the document. Defendants produced substantial portions of the document to Plaintiff, hopeful that Defendants could use part of the document to benefit their case while withholding the remainder of the document that harms their case. Despite their voluntary waiver, Defendants now claim all ten pages are still privileged, including the three pages they produced.”

Watchtower Plays Semantics

Despite overwhelming evidence to the contrary, the Watchtower organization continues to deny that it maintains a database of child molesters and victims by arguing over the very definition of the word “database.”

On February 4th 2021, plaintiff Nunez ordered the discovery of multiple documents from Watchtower files, including a description of the “CM Database.”

The Jehovah’s Witness legal department responded by declaring that the documents demanded are not part of any kind of database, and that labeling it a database is a mischaracterization of the facts. Court records disclose Watchtower’s responses to the requests:

“INTERROGATORY NO. 1:

Describe the CM database by providing the following information. What is the name or designation the JW Defendants give to the database?

Generally describe the information contained in the database.

When was the database created?

ANSWER: [from Watchtower] Defendants object to this request because it is vague and ambiguous in that the term “CM database” is defined by a mischaracterization of what the documents attached as Exhibit A are: entries from the Watchtower Legal Department’ s electronic telephone record keeping system reflecting privileged communications with clients. Defendants further object to this interrogatory on the grounds that it is not reasonably calculated to lead to the discovery of admissible information.”

It is difficult to imagine that the Court will not see past the semantics game played by Watchtower, given the awareness that the information collected by this “electronic telephonic record keeping system” is shared with the Service Department of Watchtower. The Service Department of Jehovah’s Witnesses maintains a “Hub” database of Jehovah’s Witness information that is designed to consolidate member data for more than 8 million adherents, known as “publishers.” That information contains extensive personal information about each member, including internal judicial documents such as the S-77 Notice of Disfellowshipping or Disassociation.

Jehovah’s Witness Data Collection, where Publisher Identification is incorporated into the HuB database. Image: Leaked Jehovah’s Witness video

In 2017, sensitive documents and videos were leaked from inside Watchtower headquarters, revealing the extent of their data collection schemes. A program called HuB (Headquarters-unity-Branch) was announced as the replacement for their preceding global database and management system known as “Admin.”

Also announced was the “Records Management” system for maintaining vast amounts of organizational data in a centralized database. Old paper records were scanned into this new system using highly sophisticated equipment and character-recognition software, further enhancing the Organization’s ability to track every aspect of the Witnesses’ corporate empire, including sensitive personal data.

Judge Elizabeth Best now presides over the Montana case and will rule whether or not Watchtower will be compelled to turn over the 7 pages of data in question. The release of those documents may well have an adverse impact on the Jehovah’s Witness defense.

The trial date has been set for September, 2022.

UPDATE: On August 31st, 2021, both sides settled the case for an undisclosed amount and signed a Stipulation for Dismissal With Prejudice.

Posted on July 20, 2022July 20, 2022 by Mark O'Donnell — Leave a comment

Watchtower Defies Court Order; Montana Judge Fines and Sanctions Jehovah’s Witnesses

Published July 28th, 2021

“The Court concludes that Watchtower has been deliberate in its violations of the Court’s orders, and the Plaintiffs’ right to discovery. Its claims that it could not understand the plain language in the Court’s orders are absurd and frivolous. Its decision to obstruct has wasted many hours of scarce time and resources for the Plaintiffs, and for the Court itself, and has prevented Nunez from preparing for trial, which is obviously Watchtower’s intent.”

-Judge Elizabeth Best, Montana Seventh Judicial District Court, July 22nd, 2021

On July 22nd, 2021, Montana Judge Elizabeth Best ordered a combination of fines and sanctions against the Watchtower Bible and Tract Society of New York, a corporation operated by Jehovah’s Witnesses since 1909.

According to the 9-page order issued by Judge Best, Jehovah’s Witnesses must pay $11,075 in legal fees along with a $500 per day fine for each day it violates the orders of the court to produce critical documents in the Nunez v. Watchtower civil case. The court ruled that Watchtower has been intentionally obstructive in its defiance of orders from May 28th and June 23rd of this year, and must retroactively pay the daily fine until it complies with the order.

As an additional penalty against the Jehovah’s Witness defendants, Judge Best ruled that Watchtower and the Christian Congregation of Jehovah’s Witnesses (CCJW) are “prohibited from arguing, making innuendo, mentioning, offering evidence of any “advice of counsel” defense, and from offering any evidence about the advice their attorneys gave them at any time before trial.”

This order is directly related to documents that were privately shared by Watchtower in Judge Manley’s chambers during the 2018 trial in Thompson Falls.

Why was Watchtower Fined? A Brief Case History

In 2016, Lexi Nunez filed a civil lawsuit against Jehovah’s Witnesses for Negligence Per Se, arguing that church elders and their parent corporation, Watchtower, violated Montana’s mandatory child abuse reporting laws. Elders in Thompson Falls claimed they were advised by Watchtower’s New York Legal Department that they had no legal obligation to report Lexi’s step-grandfather, Max Reyes, when they learned that he had abused Lexi’s aunt Holly and uncle Peter.

By preventing church elders from contacting law enforcement, Nunez was subjected to continued abuse by Reyes, despite the fact that the church had disfellowshipped Reyes for over a year.

The case went to trial in September 2018. Judge James Manley ruled prior to trial that the Jehovah’s Witnesses had violated Montana’s statutory reporting code, and the jury was instructed to determine whether the defendants acted with malice. The jury found the defendants guilty, assessing a total of $35 million dollars as a civil award to Nunez.

In January of 2020, the Montana Supreme Court, while sympathetic to Nunez, ruled that Watchtower had successfully navigated a loophole in the mandatory reporting act. The Court decreed that while the facts of the case were disturbing, the Jehovah’s Witness elders were acting according to their “established church practice” when they sealed off reports about the abuser, Max Reyes. Thus, the 2018 judgment was reversed.

Soon after the reversal, Nunez filed an amended complaint, arguing that while statutory negligence was off the table, she could still argue common law negligence, which is independent of the issue of mandatory reporting. In other words, Nunez wanted her opportunity to demonstrate that Watchtower and the Thompson Falls elders were negligent on their own merits, after learning of Max Reyes’s propensity for abusing children.

The Court agreed and permitted Nunez to proceed on her assertions of common law negligence.

On April 16th, 2021, the case took a dramatic turn when attorneys for Nunez filed a motion to compel the Jehovah’s Witnesses to turn over documents that were disclosed on September 23rd, 2018, the night before closing arguments in the original trial.

Watchtower attorney Joel Taylor produced several pages of documents from a CM (Child Maltreatment) telephone log in an effort to persuade Judge Manley that Watchtower was justified in arguing lack of malice by congregation elders – because those pages purportedly revealed a good faith effort by elders to seek legal advice.

Later that evening, Taylor emailed Nunez’s attorneys just three of ten pages that resembled a case file on Max Reyes.

Those pages tipped off attorneys for Nunez that there was something more ominous lurking beneath the “telephonic log.” It was clear that a database of child abusers and victims is a tool used by Jehovah’s Witnesses in the management of their global religious organization.

This legal strategy proved to be a monumental challenge for Watchtower, as they never expected a second trial and the document discovery that would follow.

Consequently, Nunez initiated discovery in early 2021 on all 10 pages, along with any supplemental information related to a Child Abuse/Maltreatment database.

Those documents suggest the extent of data collected by Jehovah’s Witnesses about child abusers and their victims.

The April 16th motion to compel production of these documents launched a substantial legal battle between Nunez and Watchtower that has led to the disclosure that even more documents exist about the Nunez case. Watchtower insists that these documents are irrelevant and privileged and should not be disclosed to the Plaintiff.

Judge Elizabeth Best, assigned to the 2022 trial, disagreed.

On May 26th, 2021, Judge Best issued an 11-page order compelling production of all documents sought by Nunez, and chastised Watchtower for its abuse of the discovery process. Nunez’s attorneys had argued that Taylor could not selectively turn over 3 of 10 pages to the plaintiff at the 2018 trial, then claim attorney-client privilege on the other 7 pages.

On page 9 of the Order, the Court stated: “Defendants’ attempt, now, to obstruct disclosure of the entire document, which on the face of the previously disclosed three pages constitutes attorney-client communications and legal advice, by cloaking it as “privileged,” is, at best, disingenuous. Defendants may not cherry pick portions of documents for which they waive privilege because it works to their strategic advantage, while withholding other parts because it does not. Defendants have clearly waived any claim of privilege.”

The Judge also addressed Watchtower’s continued claims that the documents do not form a part of any database of information.

She continues:

“Defendants object that the discovery request is “vague and ambiguous,” representing that they do not know what the words “CM Database” mean. The Court finds this objection to be frivolous and interposed for an improper purpose. It is clear to the Court that the Defendants understand what the Plaintiff is seeking, regardless of whether they choose to call the information sought something different. The Defendants’ counsel discussed the “CM Database” with the Court during the Rule 16 conference, which led to the Court’s scheduling order, and never objected that they did not understand the term.”

Judge Best concluded her Order by advising Watchtower that the Court “will not tolerate further obstruction and will consider sanctions for similar conduct in the future”

Watchtower continued to defy the judge, and instead of producing the 10 pages to Nunez, they delayed the process further by submitting the pages to the Court itself for in camera review. (Inspection by judge)

On June 17th, 2021, Judge Best issued yet another court order, this time compelling production of the documents and issuing legal and financial penalties to Watchtower for their obstruction. In her 8-page order, the judge condemned Watchtower’s behavior and fined the religious organization all costs and attorneys fees associated with their motion to compel document production. The legal fees alone were $11,075.00.

Meanwhile, prior to the June 17th Order, Watchtower had complicated their case even further by submitting a supplemental privilege log to the court, a document that disclosed the existence of 22 new pages of documents previously unknown to Nunez. Many of the records concern legal advice provided to the Polson Montana congregation when elders conferred with Watchtower about Peter McGowan. Peter was not only a victim of Max Reyes, but he was also responsible for years of sexual abuse of his own niece, Lexi.

The existence of these documents raises serious questions about why this information was not turned over to Nunez’s attorneys in 2018. Watchtower’s position is that they are irrelevant to the case, and protected.

The Harshest of All Judgments

Finally, on July 22nd, 2021 the Montana Court imposed what might be one of the severest censures of a defendant and counsel in Montana history. The following is an excerpt from the Judge’s order:

“This Court issued Orders on May 28, 2021 (Doc. 210) and on June 23, 2021 (Doc. 214) in which it set forth relevant law on discovery and its expectations of all parties during discovery. The May 28, 2021, Order compelled production of certain specific documents by Watchtower. Watchtower not only flouted its disobedience of that Order, in subsequent pleadings it asserted that an order issued by Judge Manley (Doc. 116) was the “law of the case” and that, therefore, it is “confused” about this Court’s orders, and seeks “guidance” before producing documents the Court has ordered produced. The Court finds Watchtower’s arguments to be frivolous and specious, interposed solely to obstruct and delay.“

“Based on the Court’s review of Watchtower’s documents submitted for in camera review, the Court immediately recognized Watchtower’s obstruction and issued another Order, this time assessing sanctions. (Doc. 214). Watchtower defied that Order and continues to refuse to produce 22 pages of documents, and unabashedly misrepresents the truth. As to documents the Court expressly ordered it to produce, Watchtower asserts that it complied and is simply waiting for the Court to address its embellished claims of privilege, and its “confusion” and its claim that a previous order issued by Judge Manley, before the first trial, supersedes this Court’s Orders.”

“Watchtower’s representations raise other very serious concerns about its candor with the Court from the outset. Before the Court’s first Order of May 28, 2021, counsel Joel Taylor (Taylor), on behalf of Watchtower, signed and filed an affidavit in which he represented, inter alia, that the fourth page of one document at issue “contains no information.” The document, later reluctantly produced, contains information about Max Reyes abusing Peter McGowan, and notably contains blank spaces in response to a question, “Efforts to protect the victim?” which is obviously potentially probative of Nunez’s claims of breach of a duty to protect minors. Failure to answer such a question is, actually, “information,” which is apparent to any competent lawyer.”

“Likewise, Watchtower initially opposed the Motion to Compel by representing that withheld documents were “unrelated” to previously disclosed documents, and Taylor attested to the truth of this representation in his affidavit. It is clear that this representation was false. Documents 1a and 1b relate to Max’s abuse of Peter and Holly beginning in 1994. Watchtower pretended, in its initial briefing, not to understand the term, “database.” It turns out, from the few documents now produced, that they were indeed part of an “electronic database” -in Watchtower’s own words.“

“Nunez’s discovery requests were based on an email from Watchtower lawyer Taylor, in which he described them as “the other 7 pages involve Peter/Alexis” and “the remaining pages involve Peter Jr. ‘s confession [to] the Polson Congregation regarding his abuse of Alexis.”

Watchtower’s defiance is breathtaking and must, as the Montana Supreme Court has often said, not be dealt with leniently.

“After the Court’s first order to produce the documents, Watchtower produced only seven pages of documents, none of which relate to Peter abusing Alexis. Rather, the produced documents relate to evidence already known to Nunez, the abuse of Peter, Holly, and Alexis by Max Reyes. The missing pages regarding Peter’s abuse of Alexis have not been produced at all. In sum, then, Watchtower has misrepresented to the Court that it has even partially complied with the Court’s Order.”

“On June 11, 2021 (after the May 28, 2021, Order), Watchtower identified an additional 22 pages of documents that had, until that date, never been disclosed to Nunez or the Court. Simultaneously, it filed a new and improved privilege log listing documents in random order, many of which clearly refer to evidence of Peter abusing Alexis, which the Court had ordered produced. Appallingly, Watchtower continues to withhold documents about Peter’s abuse of Alexis, and appears to be attempting a sleight of hand by offering a modified privilege log.”

“Watchtower has reasserted its claims of privilege, ignored the Court’s Order overruling those claims, asserted “confusion” and lack of understanding of the Orders [asserting that it does not “understand” whether the Court’s Orders apply to congregations, even though they briefed that very issue and claimed privilege for congregations starting in February 2021], and simultaneously inconsistently asked the Court to alter or amend Orders which it feigns not to understand. These arguments are frivolous, neither based on fact or law, and will not be tolerated, as the Court has previously warned. Watchtower’s defiance is breathtaking and must, as the Montana Supreme Court has often said, not be dealt with leniently. Instead, courts are instructed to “intently punish transgressors rather than patiently encouraging their cooperation.””

“The Court concludes that Watchtower has been deliberate in its violations of the Court’s orders, and the Plaintiffs’ right to discovery. Its claims that it could not understand the plain language in the Court’s orders are absurd and frivolous. Its decision to obstruct has wasted many hours of scarce time and resources for the Plaintiffs, and for the Court itself, and has prevented Nunez from preparing for trial, which is obviously Watchtower’s intent. Every time a party chooses attrition and stonewalling, not only the opposing party in the case involved, but parties in numerous other cases lose opportunities to exercise their fundamental right to access to the Courts.”

[highlighted areas by JWChildAbuse.org]

The conduct and actions of Watchtower’s legal team are so grave that Judge Best warned the Jehovah’s Witnesses that such violations of court orders could lead to an order of judgment by default, where the defendants would lose the case without ever facing a jury. This could potentially cost Watchtower millions, if not tens of millions of dollars. In 2015, a California court awarded a judgment by default against Watchtower for similar violations of the discovery process.

After losing appeals to the California and U.S. Supreme Courts, Watchtower paid more than 6 million dollars to the victim in judgment and interest.

Montana Judge Elizabeth Best concluded her Order by enumerating both financial and legal sanctions against Watchtower. Aside from the economic penalties, Watchtower will be barred from offering evidence that elders relied upon “advice of counsel” as a defense, or that they believed they were complying with the law when they failed to protect Lexi Nunez from the sexual abuse by Max Reyes.

As of the date of this article, Watchtower continues in contempt of the court’s orders and has not provided Nunez any further documents.

UPDATE: On August 31st, 2021, both sides settled the case for an undisclosed amount and signed a Stipulation for Dismissal With Prejudice.

Documents:

July 22nd Order Assessing Sanctions and Attorneys Fees

June 23rd Order Compelling Production and Sanctions

May 28th Order Compelling Production

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