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

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

Published January 11th, 2020

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

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

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

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

Justice Baker’s opening statement says:

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

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

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

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

Enter Douglas “Dave” Chappel

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Undeniable Admission

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

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

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

Confidentiality

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Let’s Not Forget

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

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

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

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

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

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

The Enigmatic 1998 Report

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

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

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

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

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

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

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

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

The Net Outcome

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

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

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

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

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

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

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

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

Lexi Nunez Speaks Out

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

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

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

-Lexi

Resources, Documents, and Media:

Read the Montana Supreme Court Decision HERE

Montana Mandatory Reporting Code HERE

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

Posted on July 25, 2022July 27, 2022 by Mark O'Donnell — Leave a comment

Jehovah’s Witnesses Found Guilty of Malice And Negligence: Victim Awarded $35 Million in Montana Lawsuit

Published October 22nd, 2018

On September 26th, 2018, a Montana jury of seven men and two women handed down the largest-ever punitive damages award for a single abuse victim.

The Watchtower Bible and Tract Society of New York, together with the Christian Congregation of Jehovah’s Witnesses were found guilty of both negligence and malice in connection with the intentional failure to file police reports on behalf of plaintiff Alexis Nunez and two additional victims. A combined total of 35 million dollars was assessed following detailed instructions given to the jury by Judge James A. Manley.

Four million dollars was awarded to plaintiff Nunez on the count of negligence, followed by a 31 million dollar punitive verdict, the result of the jury’s decision that Watchtower and its affiliates acted out of malice.

The case, originally filed November 2016, was placed in the hands of a Montana jury after multiple pre-trial attempts by Watchtower to have the case dismissed. In the September 11th, 2018 filing with the court, Watchtower claimed that they are an institution, and institutions are not individuals, or persons – and only persons are mandated reporters. By making this claim, Watchtower used semantics to misdirect the court. It was an outright attempt to avoid accountability for the policies which directed elders to remain silent when they discovered allegations of horrific and repeated sexual abuse of three members of the congregation by one perpetrator.

The statute lists persons (i.e., members of the clergy) as mandated reporters, Montana Code Annotated § 41-3-201, but does not include religions or entities religions use to perform their operations. – September 11, 2018 Motion by Watchtower attempting to halt the Montana trial

This article is the first in a series of articles documenting the events of the trial which might prove to be among the most significant child abuse trials in modern times.

I would like to thank Neil Smith, Ross Leonoudakis, and Tracy Rector of the law firm of Nix Patterson LLP, whose dedicated efforts on behalf of victims of abuse have sent a powerful message to the corporations whose flawed policies have not only broken laws, but broken lives.

The Opening Statements

[The following account combines the opening statements of this trial with the visual aids displayed by the plaintiff’s legal team for the jury. Every effort was made to reproduce this portion of the trial with extreme accuracy]

Monday, September 24th, 2018

Attorney for the plaintiffs, Neil Smith:

“If it pleases the court, thank you your honor. Ladies and gentlemen, if you’ll remember, I told you this morning about the different parts of the case. And I told you that during jury selection, that is not the opportunity for us to talk about the evidence (when) you hear the evidence. We are now at opening statements and opening statements provide me with an opportunity to tell you about the evidence that you will hear, and what the evidence will show, during the trial of this case. The evidence in this case will show that this is the case about a church that knew about a known child molester. When I say that the church knew about a known child molester, the church knew who he was, they knew who his victims were, and the evidence will show that they knew the sick things he did. Now, what do we all know about child molesters? We know that child molesters prey on children.

That is their victims. And if we do not protect children, from people we know to be a child molester, children will get sexually abused. You’re going to hear in this case, about how Montana law requires clergy members to report child abuse to the authorities. But in this particular case, the church you’re going to hear about, and their clergy, refused to follow the law. And they refused to follow the law because they favored the secrecy of their church over the safety of children. Now we talked a lot about the mandatory reporter law and what it is, and I want to be clear, the judge will ultimately instruct you on what the law is. And you will see that at some point in the case, you’ll see it come from the court. So I’m gonna put up right now what I expect the court will instruct you as to what the law is. This is what I expect the court will instruct you is Montana’s mandatory reporters’ statute. And here’s the reason I put this up here: I put it up here because sometimes when we talk about the law and what the law is, we get a little intimidated by it, and think “ah, that’s for lawyers.”

By putting it up here right now, so that you can get familiar with it, and you’ll recognize what this is when the court instructs you on the law. So let’s just walk through it – This is what you’ll see. It says:

When the professionals and officials listed in subsection 2, and down here in subsection 2 it says professionals and officials required to report are clergy. All right. There’s some other folks who are reporters, but for purposes of this trial, you need to know, you need to look for this when the court instructs you that it applies to clergy.

It says, when those professionals know or have reasonable cause to suspect, as a result of the information they receive in their professional or official capacity, that a child is abused or neglected, they shall report the matter promptly to the department of public health and human services or its local affiliate.

Alright let’s break that down and look at what the elements are of this lawsuit. We see it, you can look at it and say ok – I know what the elements are that Mr Smith talked about. First element, is that it applies to clergy. And we’re going to talk about in this case who are clergy, who meet that legal definition. The next element you’ll want to be familiar with is when is the law triggered. And that’s this part where it says “when professionals know or have reasonable cause to suspect” and it talks about a child being abused or neglected. So it’s triggered when a clergy member knows or suspects child abuse. The next element, it’s the third one, – there’s three parts to it – it says “what happens when the law is triggered?” And notice I have underlined, it says: They shall report. And the reason I underlined that language is because it’s really important because it doesn’t say you might report, or maybe report – it says “You shall report.”

It’s mandatory, and that’s the reason why this is called the mandatory reporter law. It requires that the abuse be reported to the department of public health and human services or its local affiliate. And that makes sense, we report it to someone who can take action. We report it to someone who can take action, and so that kids are protected. Let’s talk specifically about what happened in this case.

You now know in hearing about this case, that this case is about the Jehovah’s Witnesses. You see, the Jehovah’s Witnesses knew that a church member was molesting children. Now Neil, I know you’re thinking – what do you mean when you say that the evidence is going to show that they knew? I want you to listen for these things. The evidence is going to show that the victims reported to the church and to its clergy. They knew because it was reported. I want you to listen to how the church conducted an investigation and confirmed themselves that the abuse took place. The second way they knew.

And then the third thing I want you to listen for (if the evidence comes in this case???) is that the child molester actually admitted to the church that he was a child molester and he molested children. And then another thing I want you to pay attention to, is when you heard somebody say “this is a molester that wasn’t part of our organization” – I want you to listen for this: that known child molester was a member of the Jehovah’s Witness church, and attended that church with his victims. So listen for that as well.

Ok, we’re going to get into the details of what happened, and I need to give you just a little quick background about who the Jehovah’s Witnesses are. We don’t cover everything about them, just what’s important. Alright- So some of you noticed I have a typo here. First of all, the Jehovah’s Witnesses are a worldwide global religion. They have eight and a half million followers worldwide. They have a hundred twenty thousand churches. And the organization is run by people who are called “elders” – real important term, you’re going to hear a lot of talk about that, and we’ll talk about who the elders are, and what they do. Here’s what the most important thing you need to know about elders is: Elders are clergy. That’s the most important thing you need to know. And we’re going to be talking about elders; we’re going to talk about the law that applies to clergy, and the thing you need to know is that elders are clergy.

Ok, let’s shift gears, and talk about who are the defendants in this case. Right. You say hang on Neil, I thought we were talking about the Jehovah’s Witnesses, and now you’ve got some different names up here. Let me explain why this is the case. There are three defendants, and I’m going to walk you through who they are and tell you why they are defendants.

The first one is Watchtower Bible and Tract Society of New York Incorporated – that is their full name and it is a mouthful. So everybody abbreviates that they are Watchtower, or Watchtower New York. So when you hear that term, I want you to know we’re talking about one of the defendants. OK, the next one, and you already heard Mrs. DeSoto mention this, is a defendant called the Christian Congregation of Jehovah’s Witnesses. Another mouthful, and so we abbreviate that as CCJW. When you hear talk about CCJW, that’s another defendant. And the last one is Thompson Falls Congregation, that one’s easy to understand, that’s the local church, here in Thompson Falls, the local Jehovah’s Witness church.

Ok, so you’re next question is, Hey Neil, why are you talking about the corporations when this is about the Jehovah’s Witnesses. It’s a good question. You see, the Jehovah’s Witnesses are a big organization, and they have office building headquarters in New York. The evidence will show they have dormitories where they house their elders and feed them and provide them for all their needs. They have to be able to enter into contracts, they have to be able to open bank accounts, and to do that, they had to set up these legal corporations – and that’s their choice. That’s how they choose to run their religion, through these corporations, and that’s why these corporations are defendants. And you’re going to hear, and I’m going to show you and outline, and explain to you how these two corporations, Watchtower and CCJW, and I want you to hear this: These two specifically knew about Max Reyes, right here in Thompson Falls, what he was doing, and who he had been with.

These corporations, all the way in New York, had the exact details, the evidence will show, of what was happening in Thompson Falls; who the victims were. And the evidence is going to show that there were elders in these corporations that knew these things.

Ok, that’s who the defendants are. Now I need to just very briefly talk to you about some important beliefs that the Jehovah’s Witnesses have. Now remember, people can have beliefs, but this case is about the actions they took, the decisions they made, and their failure to follow the law. Two important beliefs you need to know about, of the Jehovah’s Witnesses, first one you need to know about is called the two witness rule. The two witness rule is a belief that they have turned into a policy, and it is their belief that their church can take no action against a member based upon the testimony of one witness. You gotta have two.

I’m bringing this up to you now because the evidence is going to show they applied that rule even in an instance of child sex abuse. When one child is coming forward saying “I’m a victim, please help me” – the two witness rule says “sorry – you’re only one witness.” That’s why I bring that up, so listen for it.

The other important belief that you need to know about is that elders – they keep secrets. They keep secrets, even when the information they know is about a known child molester. So as we go through this case, you’re going to hear, and I’m going to walk you through how this happened, how there is a policy that comes down all the way to the elders right here in Thompson Falls, and it says: You know about child abuse, the very first thing you do – you call the legal department. That’s the first thing you do. And the legal department up in New York, it’s going to tell you what to do. And if the legal department tells you you don’t have to report – you better keep it a secret.

“The other important belief that you need to know about is that elders – they keep secrets. They keep secrets, even when the information they know is about a known child molester.” -Neil Smith, attorney for the plaintiffs

And that is their policy that elders keep secret. So listen for that as we go through it. We don’t have to get into all their beliefs – those are the two important ones to know about. Okay – now: I want to get into the exact details of the facts of this case, so if you have an outline and an understanding as we go through the witnesses, and to do that the first thing I need to do is tell you who some people are. Don’t be overwhelmed by this, okay – don’t feel like you need to memorize it,

This is a board we’re going to use throughout the trial You’ll always be able to look back on and and go “Oh I forgot who Joni is, I forgot who Max is – you’ll be able to look at this board…

Ok, this is a family tree. And I’m laying this out so when we talk about these names, you understand the family structure. At the top we’ve got Joni and Peter Sr, a married couple. There’s three layers, so we’re going to talk about them as being the grandparents. They had three children, Ivy, Holly, and Peter Jr…

The third level is the grandchildren, and that’s where we have Lexi. So this is a family unit over here – grandparents, children, and grandchildren. Over here to the side is Max. He is the known child molester. Why do I have him to the side connected with the dotted line? Joni and Peter divorced. Joni remarried Max. And Max attended the Jehovah’s Witness church with his children and grandchildren. OK – so that’s the family structure that some of the names- don’t worry, every time we come back to these folks, we’re going to put this chart up so that you can remember where everybody is.

Here in green, are some of the victims. When I say victims, it’s the people that Max sexually abused. We’ve got Holly- Max sexually abused her. Jehovah’s Witnesses knew about it. Max sexually abused Peter Jr. He’s not a plaintiff in this case, but he was a victim. You’ll hear evidence the church knew that Max sexually abused him. Then we have Lexi – I introduced you to her today, she’s sitting over here – she was a victim that Max sexually abused.

So, that is the, kind of the background, who we’re talking about, and you know what – I’m going to keep that one up there so as I walk through that, this, you can remember who it is.

All right- now – Neil has been saying that the church knew that Max Reyes was sexually abusing [kids]. They knew because twice- twice they were notified. We’re going to talk about the two times they were notified. saying that

One time they were notified was in 1998. Alright, so in your mind, put it in those compartments – we’re going to talk about the 1998 report; we’re going to talk about the 2004. Those are the two times – alright. As we go through those, let me start by talking about – first- about when and how they learned Max Reyes was a child abuser, in 2004. Start down here at the bottom. This is one of the times they were notified, you start down here at the bottom with Peter.

First thing that happened, you’re going to hear evidence, is that Peter went to elders at the Thompson Falls church, and told them “I’m being sexually abused- I’ve been sexually abused by Max Reyes.” But remember, Jehovah’s Witnesses have the two witness rule, Peter’s just one guy. Peter says – you know what? Holly – that’s his sister over here – one of the plaintiffs in the courtroom, Holly can be a second witness, she can back this up.

And you’re going to see this board when I walk through this with people involved – they’re going to confirm this. The Thompson Falls Elders, after they heard from Peter, they reach out to Holly, they place a phone call to Holly. And Holly tells them there’s another person Max Reyes, a member at your church, sexually abused me. Not only did she tell them that, she puts it in writing. And I think, you’re going to have a chance, during this trial, to see that letter.

Alright, so now we’ve got two people that have notified the elders in the local church. And this is very, very important right here, it’s over here in red, and I want you to pay very close attention to what happens here. And the reason I want you to pay close attention is you’re going to hear a bunch of talk during this trial from the defendants about confidentiality.

After Peter and Holly tell the elders what happened, the elders go to the child abuser. They go to Max Reyes. And they tell him what the kids have said. They alert him, they tip him off, they share that information. That’s really important, because they don’t keep the information confidential – they go tell somebody else. It’s also important because Max admits to the elders that he’s a child molester. Keep in mind why I’m telling you this. I’m telling you this because we’re talking about a statute that says clergy shall report abuse. Alright so if we go through this, listen to all the times that clergy know about this. Alright, so we’ve got elders at the local Thompson Falls church that have heard these reports from two victims, Peter and Holly. In 2004 they have an admission from Max. What did I tell you is the very first thing they are taught to do? Call the legal department. And that’s what they do.

They place a call to the legal department. Now, when I say the legal department, I’m not talking about calling the law firm, my firm, or a lawyer here in Thompson Falls for advice. They call the in-house lawyers at Watchtower. Watchtower is their national organization. It’s the people that control the elders and give them their instructions, tell them what to do, control whether they have their position. It is required that the elders do what the legal department says to do.

And the evidence you will hear in this case is that the legal department says “You don’t have to report.” Not only do you not have to report, remember we’ve got our secrecy policy, so if you don’t have to report, you keep it quiet. That’s what the elders do. And they then are instructed to document what they know with their administrative offices over here at the other defendant, CCJW.

So you’re going to hear witnesses talk about witnesses calling watchtower and being told not to report. And you’re going to see, I think, some of the documents that goes to the other defendant, a defendant run by elders, where they document what they know and when they know it.

Through this lawsuit, we’ve been able to obtain some of the defendants’ secret documents, and I think you’ll have a chance to see those as evidence in this case. And as you look at those documents, these are the things I want you to watch for, as you see them. I want you to watch for, does it have the identity of a child molester? Does it have dates? Does it have details about what the guy did? And I think you’ll see that they have that information. Now, this is what happened in 2004. We all know what somebody is supposed to do next. With a law without a law, what do you do? You know, you’ve got a known child molester – you report him. You report him to the authorities so you can prevent other kids from being sexually abused by him.

But that is not what they did. Instead, these three defendants chose, the evidence will show, they made a conscious decision that they were not going to report him. They made a conscious decision to not follow the law. Now, if you heard, during the court’s instructions, one of the instructions that he gave you was that the court has already ruled on 2004. He instructed you during those instructions that the defendants violated the law, and they are liable.

You’ll be asked to decide what damages they caused, by failing to report this guy and for choosing not to follow the law. That is 2004. Ok – talking about two elements…

Of course, the defendants dispute what they knew, and when they knew. And you’re also going to hear about a 98 report, In 1998 the evidence will show Holly, she was 12 years old at the time. She went to elders at the local church, the local Thompson Falls church, and she told them that Max was sexually abusing her, but she’s just one witness. And so the church took no action, and of course they now say that that never happened.

The reason I put this up here is you’re going to hear that in 1998, CCJW over here did not exist. That’s why we break these into 2004 which the court has already ruled on, and you’ll just be deciding damages, and we talk about 1998 separately, because in 1998, you only have Watchtower. And what the evidence will show is that Watchtower sent the policies to the elders in Thompson Falls, that told them what they had to do, and they had the ability to kick these elders out if they didn’t follow their rules. Ok, And I put this up here because these elders in Thompson Falls were the people that were the agents, the evidence will show, for Watchtower.

That is the 1998 report. Let’s tie this all together and put it in a big picture real fast with our timeline. This is a timeline that begins in 1994, and it goes to 2007. Here’s what I’m showing to you on this timeline. On this timeline, you have first the window of time when Holly was sexually abused. She is sexually abused from 1994 until 1999, that is from the time when she is aged 15, I’m sorry, aged 10 until 15. Her abuse involved every kind of touching, and penetration you can imagine. It occurred on a regular basis. It was intercourse, it was oral sex, it was fondling, from the time she was aged 10 until the time she was aged 15.

The reason I have this up here is so that you can see that during the time that Max Reyes is sexually abusing her, that is when she made the 1998 report. That’s when it occurred.

Over here, between 2002 and 2007, we have the window of time when Lexi is being abused – that’s our other plaintiff. This is from the time she is aged 6 until age 11. Here’s how she was sexually abused.

Max Reyes fondled her, he forced Lexi to fondle him, and to pleasure him. She’ll give you the details of it. The reason this is up here, report #2 happened while Lexi was being abused. The 2004 report happened during that window of time. And the court has ruled the defendants violated the law right here, and you’ll be asked ‘what damages occurred after, and as a result of them violating the law?’

I point all this out to you because the law is very clear on what clergy members must do when they know a child has been sexually abused. But this law is only enforced through a trial like this, by a jury like you. That law that you’re going to hear about, it has to apply equally to all religions. And it must protect all children from known child molesters.

Thank you your honor.”

[Following opening arguments by plaintiff’s attorney Neil Smith, Watchtower attorney Joel Taylor addresses the jury in defense of Watchtower and the Christian Congregation of Jehovah’s Witnesses]

The Defense Opens

Attorney for the Defense, Joel Taylor:

“Ladies and gentlemen of the jury, my name is Joel Taylor. I have been in the courtroom for voir dire, sitting alongside Katie, but I have not yet addressed you. So let me first begin by saying thank you, thank you very much for taking this responsibility to be jurors so seriously. And thank you for having the wherewithal to hear these serious allegations. Now, I just want to express my appreciation for your sacrifice, but also describe a little bit to you who the defendants are in this case. Now, I don’t have a lot of charts, but I am going to use this whiteboard, and hopefully between the whiteboard and the evidence, you won’t need a fancy chart. Ok? And so first let me talk to you about the Thompson Falls Congregation.

The Thompson Falls Congregation was established in the 1950s, and in fact we see some of the members here right now in this courtroom. These are regular Montana folks, they work in the mill, some of them are loggers, and some of them do home repair, some are carpenters, and they’re trying to care for their families, and they decide that they want to draw close to God, and they accept the faith known as Jehovah’s Witnesses. And then they formed this congregation, and they fellowship and worship together.

Now, I don’t have a lot of charts, but I am going to use this whiteboard, and hopefully between the whiteboard and the evidence, you won’t need a fancy chart. – Watchtower Attorney Joel Taylor

Now one of the hallmarks of what the Thompson Falls congregation does is that they go door to door. And they knock on people’s doors, they knock on may of your doors, you know, sometimes it’s at an inconvenient time, but they do it only because they love you. And they do it because they believe that salvation is through Jesus Christ. And they want to tell other people about it. Many of you are bible readers, and you know that when Jesus was on the earth, that’s what he did. He talked to people who were not of his faith, about his own faith. And that’s what Jehovah’s Witnesses here in the Thompson Falls Congregation endeavor to do. They come from T Falls, Plains, they also come from Trout Creek, and Hot Springs.

Presently as I mentioned, the congregation has about 70 members. Now in addition to the congregation, you’ve heard about two corporations. One of them is called Watchtower, and the other is called Christian Congregation of Jehovah’s Witnesses, or CCJW. Those corporations assist the faith of Jehovah’s Witnesses. And so, just like some of you might be Pentecostal, or otherwise you might be Baptist, you might be Catholic, so Jehovah’s Witnesses is a faith, but then there are corporations that assist the faith. And those two corporations, Watchtower and CCJW do that.

CCJW did not exist prior to 2001, but today CCJW is primarily used as a non-profit corporation that communicates with congregations. Watchtower is primarily the owner of property, and is also a printer. That’s probably why you’ve seen those journals that the friends here from the Thompson Falls congregation are often putting out and asking you if you’d like to read them. So those are just a few of the defendants, and a little bit about them. I should tell you this though, that as with most religions, the structure of many religions is confusing. And so, throughout our conversation and throughout this trial, you may hear terms that you don’t understand, and I’m going to do my best to make sure that I explain those religious terms to you.

In fact, there may be occasions even when counsel for the plaintiff uses a term incorrectly. And you may hear me object. But that’s only to make sure that we identify which victim that we’re talking about. You may even hear from the witnesses, some of whom are Jehovah’s Witnesses, and they may confuse which corporation…sometimes these things are confusing, but ultimately at the end of the day, you’re going to know who did what, and when.

Before we go any further, I think it’s important that we acknowledge the harm that the two plaintiffs have suffered. It is beyond question that child abuse is an abomination. It’s beyond question. It’s a serious and gross sin, against God, and against the victims. There’s no question about that. That is a bible teaching. While we acknowledge the heinousness of the sin, Thompson Falls, Watchtower, CCJW, deny responsibility.

And as we go throughout this trial, you’re going to see that the responsibility really does lie, not with these individuals. So what are we asking of you jurors over the next two or three days? We’re simply asking, not for the benefit of the doubt, My clients, they don’t need the benefit…of a doubt. They just ask that you reserve judgment until you’ve heard the entire story.

Sometimes when we hear stories, for example, you might hear a story that begins “Once upon a time…” And right away your mind can take you to the end, and you say “well, they lived happily ever after.” Well, this trial is not really like a fairy tale. It’s more like a complex novel. It’s going to take a number of turns and twists, and all we ask is that you reserve judgment until you’ve heard all of the evidence. And then at that point, the judge will charge you as to the law, and you will be able to… make a decision.

And that’s in line with something the Bible says. In the book of Proverbs, the Bible says that “The first to state his case seems right, until the other party comes and cross-examines him.” So you need to hear the whole truth. And unfortunately in that opening, you did not hear the whole truth. And as you listen to the plaintiffs, although they’ve been injured, you’re not going to hear the whole truth. What you’re going to hear is embellishing around the edges. And it may even go to the point of outright spin. And you’re going to hear facts taken out of context You’re going to hear memories that were not what it were, what they were, when they occurred. And you should reject it.

You know, today there’s a lot of misinformation out there. If you watch the news media, they take one fact, and depending on their political leaning they take that fact and they change it. Some people refer to that as fake news. We don’t listen to fake news when it comes on the television, and we ought not listen to it in this courtroom…

Attorney Joel Taylor Fish Illustration — Watchtower Attorney Joel Taylor compared the victims’ account of abuse to the storied exaggerations of catching a fish. (photo © https://www.prawnsoda.co.uk)

And you should hear the whole story before you make any decision. In fact, sometimes people can just exaggerate because of the passage of time. For example, maybe you’ve been fishing down in the reservoir, right – and you go down fishing in the reservoir with your buddies, you catch a ten-pound pike. And then five years later that ten-pound pike is now 20 pounds. Ten years later that pike is now 30 pounds. But lo and behold, someone says, “you know I have a photograph of when we went fishing.” And when you compare the photograph to the story, you realize that the person, their memory has been affected by the passage of time. And in this case, we have documents, we have evidence to show that memories have been affected by the passage of time.

For example, Let’s go back to the chart they talked about – 1998. The weight of the testimonial evidence will show that the meeting in 1998 didn’t occur. Holly claims that in 1998, she went to Mr. Herberger’s home, to complain about sexual abuse at the hands of her stepfather. That’s what she claims. She says that when she went to Don Herberger’s house in 1998, she went to him as an elder, in the summer of 1998, and she also claims that she took her sister Ivy with her as well. She claims that she took her younger brother Peter as well. She also claims in her testimony that her aunt Iris drove her over to Don Herberger’s house.

“You know, today there’s a lot of misinformation out there. If you watch the news media, they take one fact, and depending on their political leaning they take that fact and they change it. Some people refer to that as fake news. We don’t listen to fake news when it comes on the television, and we ought not listen to it in this courtroom…” – Watchtower attorney Joel Taylor

So now, let’s unpack this 98 meeting. Here are the problems with the 98 meeting. In the summer of 1998, Mr. Herberger was not an elder in the faith of Jehovah’s Witnesses. He wasn’t. He just wasn’t an elder. What is more, you’re going to hear from Peter, Holly’s sister, he’s going to say he never went over there. What is more, You’re going to hear from Iris, and Iris is going to say that never happened. They’re going to say that. Now in 1998, Holly alleges that after going over Don Herberger’s house, he took her to meet with two elders. And then the three of them met at the Kingdom Hall after one of the meetings. You’re going to hear the congregation testify that that meeting never occurred, and that no one ever met with Holly.

They’re also going to testify that their church practice would have been to make a notation of any meeting involving serious sin, and that there is no documentary evidence. You’re also going to hear the representative for Watchtower testify that in 1998, if an allegation of abuse had come up, they would have called the legal department right away. And that the legal department has no records related to any call from 1998. And that’s because…the 1998 meeting never happened.

And of course, CCJW could not have participated in the 1998 meeting – it didn’t exist until 2001. Now, let’s talk about 2004. They are correct, the elders were alerted to a serious sin in the congregation. In 2004, Peter came forward to the elders. At the time, and you did not hear this in the opening, at the time, Peter was 17 ½ years old when he came to the elders in 2004. And he told the elders in a confidential setting, that he will testify himself, that he intended the communication to be confidential. That his stepfather, Max, had abused him four and a half years earlier. That’s what his testimony will be.

See, we don’t want you to operate under the impression that some little children came to the elders, and they were told about the abuse and the elders looked the other way. No, no – Max was 17 ½, I’m sorry, Peter was 17 ½ when he came to the elders. He’s going to tell you that he wanted elders to handle the sin, that’s what he wanted. But child abuse is unique, and I’ll explain it to you this way.

(Joel Taylor writes on whiteboard)

Unlike some sins that happened, and we’ve all made mistakes, child abuse is a sin and a crime. It’s both. It’s both a sin and a crime.

(Taylor continues to write on whiteboard)

And this is what the plaintiffs will confuse repeatedly, and they’re not going to want you to understand this, but as it relates to the crime, Jehovah’s Witnesses follow the law. As it relates to the sin, they follow the bible. Now some sin is not a crime. For example, you’re drinking in your home to an excess, and you get drunk a lot, and it’s always in the privacy of your home, why it’s a sin, you just follow the Bible, elders might give you some scriptural guidance and counsel. But other sins are both sins and crime. And when Jehovah’s Witnesses deal with child abuse, they follow the law. So when Peter comes forward in 2004, the elders contact the legal department.

You have to ask yourself, why would they contact the legal department? Well, they contact the legal department because they want legal direction. These reporting laws are quite complex. And they change often. So there is one central location to call and ask and find out what my obligation is under the law. And so elders called the legal department, and they got direction on the law.

Now, it is true, it is true, that the judge has ruled that the exception does not apply. But this explains why the elders did what they did. And I’ll read to you the exception under Montana’s law. You might have noticed a chart that had Montana’s law – well it did not include the exception. This is the actual language of the exception. “A member of the clergy or a priest is not required to make a report under this section if the communication is required to be confidential by canon law, church doctrine, or established church practices. Now we all have our own individual beliefs what should happen when there’s an allegation of child abuse. We might feel, “well look- report everything.”

Well honestly, that is an oversimplification of a very complex problem. One, not every victim wants it reported, because victims are concerned about being re-traumatized by a criminal justice system that at times doesn’t even believe them. And so, you can over-simplify and say “We must report.” But I tell you, anyone who says that has never spoken to a victim. Because victims are individuals, they all have their own feelings on the matter. And so, here’s what happens in the faith of Jehovah’s Witnesses: If the law says report, Jehovah’s Witnesses report. In the absence of a law that says report, Jehovah’s Witnesses follow the Bible. And the Bible says that parents have the right to choose what’s in the best interests of their children. Parents have that right.

Well at 17 ½, Peter was already capable of determining what was in his best interests. After he made his report in 2004 to the elders, he moved out. In fact, he moved into the home of another member of the congregation. And then about a couple months later, he moved in with his sister Ivy. That’s what happened in 2004. When that occurred in 2004, there were no children in the home. It was Max and his wife Joni. Now in addition, in connection with this 2004 meeting, contact was made with Holly. Indeed it was. And in the faith of Jehovah’s Witnesses, it differs somewhat from the Catholic model. The Catholic model, there’s a priest and a penitent. But in the faith of Jehovah’s Witnesses, we have a communal approach to handling serious sin.

And what do I mean by ‘communal approach’? Well the Bible says that in the multitude of counselors there is wisdom. And Jehovah’s Witnesses don’t have a paid clergy. So Don has a regular job. And he volunteers as an elder for four or five hours of each week. Don has a secular job. The other elders in the congregation have secular jobs. They are not paid clergy. And so, we make sure that in the multitude of counselors there is wisdom, so that we bring at least three other elders together to make sure that they handle the serious wrongdoing in the congregation properly. And so, when we do that process, it’s considered confidential. Except, if the law requires a report. If the law requires a report, we report. But in the absence of a directive saying report, we defer to parents and victims to know what’s in their best interests.

We do not try to insert ourselves into their decisions. We respect their individual right to choose. It’s not a policy of secrecy. It’s about respect, and understanding that not all victims are the same.

Now, interestingly, you’ve heard testimony today that when Holly came forward in 2004. It was because she wanted it reported. Well, you know, interestingly, the elders asked Holly to write a letter so that they could confront Max with those allegations, with a view to removing his membership in the congregation, because he had committed serious sin. And we have the letter, and I’ll show you the letter.

(Neil objects, discusses whether or not that letter has been admitted)

Joel Taylor: This is not evidence

Judge: discusses contents …Do you anticipate objections?

Joel Taylor: There was no objection on the uh…

Neil: I have no objection, the jury’s seen it now

Judge: As long as you’re not going to oppose it…

Joel Taylor continues:

“And so this is the letter that Holly wrote to the congregation in 2004. And it speaks to this issue of whether or not the 98 meeting actually occurred. So in 2004, obviously at this point, you weren’t told this, but in 2004, Holly was 20 years old. And she was living in Nebraska when it came to the elders’ attention. So Peter was 17 ½ moving out, Holly was 20 years old. Now Peter said, when he came forward, that the abuse had happened four or five years ago. And Holly admits that her abuse that happened ended in the 90s. And so this is 2004. She addresses the letter to the body of elders in the Thompson Falls congregation. She was asked by Don Herberger to write the letter. He called her in Nebraska and asked her to write the letter because they were evaluating Max’s membership in the congregation. They were doing so in a confidential setting.

In the faith of Jehovah’s Witnesses, we hear from the accused, we hear from the accusers, and any eyewitnesses. And those communications are established church practices that we maintain confidentiality on, unless, unless, the law says report. Otherwise, we defer to the parents. Now look at this letter, it says: “As you are aware, I have recently disclosed information regarding the sexual abuse received from my stepfather Max.”

“Recently disclosed” – see, when she wrote this in 2004, the fish was this big. (Shows hands)

When she filed this lawsuit, the fish is now this big (shows hands spread wide)

She’s saying, she’s going to tell you now that when she says she recently disclosed, she meant 1998. Now, all it takes is the smell test. She says ‘I have recently disclosed that Max was abusing me.’ Going further, she says it started when Max and Joni got married. That’s when it started, 1994. And he began to do these horrible things, she says, ‘being as I was too embarrassed to tell anyone…’ – too embarrassed to tell anyone; now you heard Mr. Smith say that in 1998 she was telling the elders. But her letter in 2004 says “being too embarrassed to tell anyone.”

So now, what you’re hearing today, is that pike weighs 60 pounds. But in 2004 when her memory was fresh, before she had any idea of suing, for money damages, it was ‘I have just disclosed this.” That’s what she says. And then she goes on to describe the abuse. She explains that “many times I have tried to tell my mother what was happening, but she was quick to defend him.”

In addition, on the last page, she says “I want to thank Jehovah’s shepherds” – shepherds is another term for elders – “I want to thank the elders for looking after his flock, and for taking care of this situation.” The language and tone of this letter is very different from the allegations you heard. In fact this letter was the first notice that the congregation in Thompson Falls had ever heard of Holly being abused by Max. Because the meeting in 1998 didn’t happen.

Now, why would you ask this question, why does there need to be a 1998 meeting? Here’s why: Because Holly’s abuse ended in 1999, and the law says, generally speaking, that you need to know something is wrong in order to prevent it. So, according to her testimony, the abuse ended in 1999. Now, if the congregation did not learn of it until 2004, which is what her own words suggest, then there was nothing the congregation had to do, could have done, or otherwise. So this 1998 meeting is for one singular purpose, one singular purpose.

(Joel Taylor writes on the whiteboard, 1998 at the top, 2004 in the middle, and $$ at the bottom. He circles 1998, then draws an arc from 1998 down to $$)

That’s what it’s for, that’s what it’s for. It didn’t happen, it didn’t happen. And her own words show evidence of that. Her own words. She never disclosed that abuse before, and at the time she disclosed it, she was already an adult, living in another state, and married. And, as a result, the elders handled Max, and removed him from the congregation, in accord with following the Bible, in connection with the sin.

So this case is not about Bible principles, or a two-witness rule, it had nothing to do with that. By the time the elders learned of the abuse, they had already been four years removed from Peter, and at least six years removed from Holly. Just keep those things in mind as you deliberate and as you hear evidence in this case.

Now, let’s talk a little bit about Alexis, or Lexi. Lexi’s here too, and Lexi is a victim. There’s no question about it, that Lexi’s step-grandfather took advantage of her. And her testimony is that from 2002 to 2007, her step-grandfather abused her. That’s her testimony. We have no reason to doubt the truthfulness of what she says. We don’t. But here’s what you were not told. According to Holly’s testimony, and according to Ivy’s testimony, Ivy has always known, since 1998, that Max attempted to fondle Alexis, or Holly rather.

So, now understand, Ivy is Alexis’ mother. And in 1998, she says “I knew that Max attempted to fondle my sister.” And in 2002, she lets Alexis go and visit with Max… Mom does that. And then, it continues from 2002, 2003, and then in 2004, Peter comes forward to the elders for the first time, and explains what happened. And Holly comes forward to the elders for the first time – and then Max is removed from the congregation. Peter goes to live with Ivy, tells her “Look- step dad abused me too!” Of course, Ivy is already aware that Holly has been abused by Max. And, Ivy continues to let Alexis go and visit with Max, for three more years. Three more years. Mom- fully aware that Max had a propensity to abuse children, and she just lets her go and visit with him. Ivy had the ability, Ivy had the knowledge, but more importantly, Ivy had the responsibility to Lexi to stop this abuse. All she had to do was not allow her to visit with her step-grandfather.

But she continued, and as a result, Ivy is responsible for the harm that came to Lexi. I think all of you would agree that parents have to care. And in this case, a parent did…not…care. And as a result, the child was harmed. Now, there’s much more to this story, that we will discuss. You’re going to hear testimony about the statute of limitations, and the judge is going to instruct you as to the law. And you’re going to become aware that sad and as tragic as it may be, Holly has always known about her abuse, and the connection between it and her emotional challenges.

You’re going to hear from Holly’s first husband; he’s going to testify…

(Objection)

Neil Smith: Your honor, object based on spousal privilege, her husband cannot testify

Judge: It does sound like privileged communication counsel

Joel Taylor: Your honor I’m sure he was in Nebraska, which law are we applying?

Judge: Well, we’re applying Montana evidence law

Joel Taylor: Your honor, he can testify as to what she told him before they were married

Judge: Let’s not get into..

According to Watchtower, the victims’ stories were grossly exaggerated, like a 10-pound pike growing to 60 pounds © https://internationalfishingnews.blogspot.com

Joel Taylor: You will hear evidence that Holly has always known about the connection between her abuse and her emotional damages… Even if you could come up with some type of claim at law, the statute of limitations has long since expired. So, pay attention for those details. Just allow yourself to hear the whole truth, and as you sit there right now,ask yourself, how much did I just learn that the plaintiffs did not tell me. Ask yourself that. Because you will hear more, because we’re determined to tell you the whole truth, the pike really was just ten pounds.

And then you will see, that neither Thompson Falls, Christian Congregation of Jehovah’s Witnesses, nor Watchtower, is liable for the injuries that these plaintiffs have sustained.”

By mid-afternoon, Monday, September 24th, the selection of a jury, along with opening statements from both sides was complete. The stage was set for the remainder of the trial. As the burden of evidence lay with the plaintiff, their witnesses were called first. The first witness to be called was Watchtower representative Doug Chappel.

When laws are broken, lives are broken.

Additional Media Coverage and reports:

https://missoulian.com/news/state-and-regional/montana-jehovah-s-witness-sex-abuse-case-underscores-church-s/article_fddc41e5-536b-5843-af30-200cc14892d8.html

https://www.dailymail.co.uk/news/article-6224251/Jury-awards-35-million-woman-says-Jehovahs-Witnesses-covered-sexual-abuse-child.html

https://www.nbcnews.com/news/us-news/35-million-verdict-puts-spotlight-insular-jehovah-s-witness-community-n914841

https://www.greatfallstribune.com/story/news/2018/09/27/montana-jury-jehovahs-witnesses-must-pay-34-m-abuse-survivor/1443995002/

https://www.spokesman.com/stories/2018/sep/27/jury-jehovahs-witnesses-must-pay-35m-to-abuse-surv/

https://m.washingtontimes.com/news/2018/sep/27/jury-jehovahs-witnesses-must-pay-34m-to-abuse-surv/

https://www.scledger.net/story/2018/09/27/news/35-million-judgment-in-jehovahs-witnesses-case/1823.html

https://nypost.com/2018/09/29/jehovahs-witnesses-must-pay-35m-to-sex-abuse-survivor/

https://helenair.com/news/state-and-regional/jehovah-s-witnesses-accused-of-mishandling-abuse-in-montana/article_094e6570-0ac2-59fe-9eb1-8068a6213b76.html

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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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