{"id":2980,"date":"2023-07-27T20:18:53","date_gmt":"2023-07-27T20:18:53","guid":{"rendered":"http:\/\/jwchildabuse.org\/xqllht\/document\/23-0-answer-to-new-matter\/"},"modified":"2023-07-29T04:28:24","modified_gmt":"2023-07-29T04:28:24","slug":"23-0-answer-to-new-matter","status":"publish","type":"dlp_document","link":"https:\/\/jwchildabuse.org\/xqllht\/document\/23-0-answer-to-new-matter\/","title":{"rendered":"23-0 Answer to New Matter"},"content":{"rendered":"<p><strong>July 27th, 2021<\/strong><\/p>\n<p>&nbsp;<\/p>\n<p>PETITIONER\u2019S REPLY TO NEW MATTER<\/p>\n<p>&nbsp;<\/p>\n<p>Petitioner Ivy Hill Congregation of Jehovah\u2019s Witnesses, by and through its undersigned counsel, hereby submits this Reply to New Matter, and in support thereof, avers as follows:<\/p>\n<p>88. Denied. The allegations contained in this paragraph constitute conclusions of law to which no response is required; as such, they are denied. By way of further response, the Commonwealth Court has already expressly concluded this legal defense is without merit, see Memorandum Opinion (Pa. Cmwlth. June 17, 2021).<\/p>\n<p>89. Denied. The allegations contained in this paragraph constitute conclusions of law to which no response is required; as such,\u00a0they are denied. By way of further response, Exhibit A, being in writing, speaks for itself, and all characterizations thereof are denied.<\/p>\n<p>90. Denied. The allegations contained in this paragraph constitute conclusions of law to which no response is required; as such, they are denied. By way of further response, the Commonwealth Court has already expressly concluded this legal defense is without merit, see Memorandum Opinion (Pa. Cmwlth. June 17, 2021).<\/p>\n<p>91. Denied. The allegations contained in this paragraph constitute conclusions of law to which no response is required; as such, they are denied. By way of further response, the Commonwealth Court has already expressly concluded this legal defense is without merit, see Memorandum Opinion (Pa. Cmwlth. June 17, 2021).<\/p>\n<p>92. Denied. The allegations contained in this paragraph constitute conclusions of law to which no response is required; as such, they are denied. By way of further response, the Commonwealth Court has already expressly concluded this legal defense is without merit, see Memorandum Opinion (Pa. Cmwlth. June 17, 2021).<\/p>\n<p>93. Denied. The allegations contained in this paragraph constitute conclusions of law to which no response is required; as such, they are denied.<\/p>\n<p>WHEREFORE, Petitioner Ivy Hill Congregation respectfully requests that the Court enter judgment in Petitioner\u2019s favor.<\/p>\n<p>Respectfully submitted,<br \/>\nDated: July 27, 2021 \/s\/ Joshua J. Voss<\/p>\n<p>&nbsp;<\/p>\n","protected":false},"excerpt":{"rendered":"<p>23-0 Answer to New Matter<\/p>\n","protected":false},"author":1,"featured_media":1239,"comment_status":"open","ping_status":"closed","template":"","meta":{"_acf_changed":false},"doc_categories":[141],"doc_tags":[142],"doc_author":[],"file_type":[14],"class_list":["post-2980","dlp_document","type-dlp_document","status-publish","has-post-thumbnail","hentry","doc_categories-ivy-hill-congregation-versus-pennsylvania-dhs","doc_tags-ivy-hill-congregation-of-jws-versus-pennsylvania","file_type-pdf"],"download_url":"https:\/\/jwchildabuse.org\/xqllht\/wp-content\/uploads\/2023\/07\/23-0-Answer-to-New-Matter.pdf","file_size":"128 KB","filename":"23-0-Answer-to-New-Matter.pdf","download_count":"","version_history":[],"acf":[],"_links":{"self":[{"href":"https:\/\/jwchildabuse.org\/xqllht\/wp-json\/wp\/v2\/dlp_document\/2980","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/jwchildabuse.org\/xqllht\/wp-json\/wp\/v2\/dlp_document"}],"about":[{"href":"https:\/\/jwchildabuse.org\/xqllht\/wp-json\/wp\/v2\/types\/dlp_document"}],"author":[{"embeddable":true,"href":"https:\/\/jwchildabuse.org\/xqllht\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/jwchildabuse.org\/xqllht\/wp-json\/wp\/v2\/comments?post=2980"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/jwchildabuse.org\/xqllht\/wp-json\/wp\/v2\/media\/1239"}],"wp:attachment":[{"href":"https:\/\/jwchildabuse.org\/xqllht\/wp-json\/wp\/v2\/media?parent=2980"}],"wp:term":[{"taxonomy":"doc_categories","embeddable":true,"href":"https:\/\/jwchildabuse.org\/xqllht\/wp-json\/wp\/v2\/doc_categories?post=2980"},{"taxonomy":"doc_tags","embeddable":true,"href":"https:\/\/jwchildabuse.org\/xqllht\/wp-json\/wp\/v2\/doc_tags?post=2980"},{"taxonomy":"doc_author","embeddable":true,"href":"https:\/\/jwchildabuse.org\/xqllht\/wp-json\/wp\/v2\/doc_author?post=2980"},{"taxonomy":"file_type","embeddable":true,"href":"https:\/\/jwchildabuse.org\/xqllht\/wp-json\/wp\/v2\/file_type?post=2980"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}