155-0 Subpoena Duces Tecum
May 25th, 2021
DEFINITIONS – The term “documents” means any and all writings and recorded materials, of any kind whatsoever, whether originals or copies, including, but not limited to, contracts, notes, rough drafts, inter-office memoranda, memoranda for the files, letters, communications (as defined below), diaries, forms, bank statements, card files, books of account, journals, ledgers, invoices, blueprints, diagrams, drawings, computer printouts or tapes, electronic data compilations and records (including, but not limited to, computer files of all kinds, e-mail messages, text messages, messages posted on electronic bulletin boards or other sites and list serves, and computer back-up files and documents only available in electronic or an “on line” format), reports, surveys, statistical computations, studies, pictures, maps, graphs, charts, minutes, manuals, pamphlets, or books of any nature or kind whatsoever; and all other materials handwritten, printed, typed, mimeographed, photocopied, imaged, photographed, or otherwise reproduced; and slides, videos or motion pictures, television recordings, all digital or mechanical recordings or other written or printed matter or tangible things on which data, images, words or phrases are affixed or encoded. The terms “communication” and “communications” mean any and all forms of communication between or among two or more persons, including, but not limited to, in-person meetings and conversations, telephone calls, voicemail or answering machine messages, letters, notes, memoranda, e-mails, text messages, and facsimile forms as applicable.
DOCUMENTS REQUESTED
1. Any and all documents relating in any way to any allegations of sexual abuse, including investigations and findings thereof, by Kenneth Apana.
2. Any and all documents relating in any way to any sexual abuse incidents or allegations in the Makaha, Hawaii Congregation of Jehovah’s Witnesses in Hawaii (hereinafter “Makaha Congregation”).
3. Any and all documents relating in any way to any disciplinary action, including documents relating to reproval, disfellowship, and/or disassociation, taken against Kenneth Apana by Kaloko Congregation – Jehovah’s Witnesses Holualoa Hawaii/Kingdom Hall of Jehovah’s Witnesses) (hereinafter referred to as “Kaloko Congregation”) and/or any other Jehovah’s Witnesses congregations and/or organizations, including Watchtower Bible and Tract Society of New York, Inc. and Christian Congregation of Jehovah’s Witnesses. This request also includes any and all documents relating to any reinstatement of Kenneth Apana as a member of Kaloko Congregation.
4. Any and all documents received from and/or sent to Service Department of Watchtower Bible and Tract Society of New York, Inc. and/or Christian Congregation of Jehovah’s Witnesses relating in any way to any allegation, investigation and/or report on sexual abuse incidents involving Kenneth Apana.
5. Any and all communications with Service Department of Watchtower Bible and Tract Society of New York, Inc. and/or Christian Congregation of Jehovah’s Witnesses relating in any way to any allegation, investigation and/or report on sexual abuse incidents involving Kenneth Apana.
6. Any and all communications with any member/elder of Makaha Congregation, including, but not limited to, Philip Main, John Gray, and David Shima, relating in any way to any allegations of sexual abuse by Kenneth Apana, including investigations and findings thereof, and any disciplinary action taken against Kenneth Apana.
7. Any and all communications with any circuit overseer and/or district overseer for Kaloko Congregation relating in any way to any allegations of sexual abuse by Kenneth Apana, including investigations and findings thereof, and any disciplinary action taken against Kenneth Apana.
