244-2 Exhibit C – 2015 Deposition Excerpt of Gary Breaux From Doe v. Watchtower

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June 2nd, 2023

Full docket text for document 244:

NOTICE of Filing Exhibits re: [243] Response to Motion,, (Attachments:

# (1) Exhibit A Excerpts from 2012-03-27 Transcript of Depo of Allen Shuster,

# (2) Exhibit C Excerpts from 2015-05-29 Transcript of Depo of Gary Breaux Vol I) (Shaffer, Ryan)

 

Plaintiffs, Tracey Caekaert and Camillia Mapley, hereby submit this Notice of Filing Exhibits in Support of their Response Brief to Defendant WTNY’s Motion for Protective Order (Doc. 234). Plaintiffs submit excerpts from the Deposition of Allen Shuster, Dorman and Gamboa v. Does 1-100, et al. (Mar. 27, 2012) (No. 37-2010-92450-CU-PO-CTL) as Exhibit A and excerpts from the Deposition of Gary Breaux at 11, Doe v. Watchtower (May 29, 2015) (No. DC-14-12402) as Exhibit C. These transcripts were not filed with the response on June 1, 2023 (Doc. 243) as they had been marked by Defendant WTNY as “Confidential” pursuant to the Protective Order entered on January 26, 2022 (Docs. No. 110-1 and 111). WTNY has since granted Plaintiffs permission to file these transcript excerpts in the public record.

243-4 Exhibit D – October 2006 Declaration of Gary Breaux

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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, Ryan)

160-2 Declaration of Gary Breaux

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Document Filed: October 20th, 2022

 

This is the declaration of Gary Breaux, the Vice-President of the Christian Congregation of Jehovah’s Witnesses (CCJW).

160-0 Watchtower Response Opposing Motion to Compel Depositions

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Document Filed: October 20th, 2022

 

Document Title: DEFENDANT WATCHTOWER BIBLE AND TRACT SOCIETY OF NEW YORK, INC.’S RESPONSE BRIEF IN OPPOSITION TO PLAINTIFFS’ MOTION TO COMPEL DEPOSITIONS

 

In this document, Watchtower Bible and Tract Society of New York responds to the Plaintiff’s Motion, document #153 and document #154, the Brief supporting the motion to compel testimony.

This motion comes in the wake of financial fines and sanctions against Watchtower’s chief counsel, Philip Brumley after Brumley submitted two affidavits early in this case in which he argued that Watch Tower Pennsylvania should not be a defendant. Brumley’s statements triggered a legal battle that was sustained over a 17-month period and resulted in court-ordered sanctions. The plaintiffs have submitted their fees and expenses in an amount exceeding $190,000. Judge Watters will issue her ruling on the final amount of penalties following Watch Tower’s upcoming reply to the financial affidavits issued by the Plaintiff’s law firm.

Document 160-1 Declaration of Allen Shuster

Document 160-2 Declaration of Gary Breaux

Document 160-3 Declaration of Gene Smalley