Motion to Compel Depositions

Plaintiffs Caekaert and Rowland have submitted this motion to compel depositions from three elders with direct knowledge of the Jehovah’s Witness Organization and to secure testimony in the exploration of Watchtower New York’s claims of testimonial privilege in relation to the production of documents related to these cases.

The motion requests the following:

1. The deposition of three Jehovah’s Witness elders in New York who have worked at the Jehovah’s Witness Organization’s headquarters during all times relevant to Plaintiffs’ claims and who have substantial knowledge and information relevant to Plaintiffs’ case; and

2. A staggered deposition of WTNY whereby the first stage is to obtain testimony regarding WTNY’s sweeping claims of testimonial privilege, and the second stage is to obtain information bearing the substance of Plaintiffs’ claims after the scope of those privileges has been resolved.