161-0 Affidavit of Jon Wilson
Submitted: October 20th, 2022
Abbreviated List of Exhibits:
Full docket text for document 161:
AFFIDAVIT/DECLARATION re [160] Response to Motion, by Watchtower Bible and Tract Society of New York, Inc..
Attachments:
Exhibit 1 WTNY Initial Privilege Log
Exhibit 2 2022-04-13 Shaffer LT Wilson
Exhibit 3 2022-05-02 Wilson LT Shaffer
Exhibit 4 2022-06-29 Shaffer email to Wilson
Exhibit 5 2022-07-22 Jensen email to Shaffer
Exhibit 6 2022-08-15 Wilson LT Shaffer
Exhibit 7 2022-08-18 Shaffer LT Wilson
Exhibit 8 2022-08-30 Shaffer LT Wilson
Exhibit 9 2022-09-09 Shaffer LT Wilson
Exhibit 10 2022-09-12 Shaffer email to Wilson
Exhibit 11 2022-09-15 Wilson LT Shaffer
Exhibit 12 2022-09-23 Shaffer LT Wilson
Exhibit 13 2022-09-26 Wilson LT Shaffer w 2nd Supp PL
Exhibit 14 2022-09-27 Shaffer email to Wilson
Exhibit 15 2022-09-28 Sweeney email to Shaffer-copy to Wilson
Exhibit 16 2022-09-28 Shaffer email to Sweeney-copy to Wilson
Exhibit 17 2022-09-29 Shaffer LT Wilson and Sweeney
Exhibit 18 2022-10-05 Jensen email to Shaffer and Sweeney
Exhibit 19 2022-10-05 Shaffer email to Wilson and Sweeney) (Wilson, Jon)
Jon A. Wilson, attorney from the Brown Law Firm of Montana, hereby submits his foundation for verification of the supplemental attached documents supporting Watchtower Bible and Tract Society of New York’s Brief Opposting the Plaintiff’s Motion to Compel Depositions from Watchtower Officials.
1. I am an attorney admitted to practice in the State of Montana. I am a shareholder with Brown Law Firm, P.C.
2. I am co-counsel for Defendant/Cross-Claimant Watchtower Bible and Tract Society of New York, Inc. (hereinafter “WTNY”), in the above-entitled matter, have personal knowledge of the facts set forth herein, and am otherwise competent to testify.
3. The purpose of this Affidavit is to provide the foundation for and verification of the accuracy of the documents attached hereto in support of WTNY’s Response Brief in Opposition to Plaintiffs’ Motion to Compel Depositions.
4. Attached as Exhibit 1 is a true and correct copy of WTNY’ s initial privilege log served on March 25, 2022.
5. Attached as Exhibit 2 is a true and correct copy of a letter from Plaintiffs’ counsel to WTNY’s counsel dated April 13, 2022.
6. Attached as Exhibit 3 is a true and correct copy of a letter from WTNY’s counsel to Plaintiffs’ counsel dated May 2, 2022, as well as a true and correct copy of the enclosed WTNY’ s first supplemental privilege log.
7. Attached as Exhibit 4 is a true and correct copy of an e-mail from Plaintiffs’ counsel to WTNY’s counsel, counsel for Defendant Watch Tower Bible and Tract Society of Pennsylvania (hereinafter “WTPA”), and Cross-Claim Defendant Bruce Mapley Sr. (hereinafter “Mr. Mapley”) dated June 29, 2022, as well as a true and correct copy of the draft Notice attached thereto.
8. Attached as Exhibit 5 is a true and correct copy of an e-mail from WTNY’s counsel to Plaintiffs’ counsel with copies to WTPA’s counsel and Mr. Mapley dated July 14, 2022.
9. Attached as Exhibit 6 is a true and correct copy of a letter from WTNY’s counsel to Plaintiffs’ counsel dated August 15, 2022, which followed a telephone call between Plaintiffs’ counsel and WTNY’s counsel on August 2, 2022.
10. Attached as Exhibit 7 is a true and correct copy of a letter from Plaintiffs’ counsel to WTNY’s counsel dated August 18, 2022.
11. Attached as Exhibit 8 is a true and correct copy of a letter from Plaintiffs’ counsel to WTNY’s counsel dated August 30, 2022, as well as a true and correct copy of the enclosed Notice.
12. Attached as Exhibit 9 is a true and correct copy of a letter from Plaintiffs’ counsel to WTNY’ s counsel dated September 9, 2022.
13. Attached as Exhibit 10 is a true and correct copy of an e-mail from Plaintiffs’ counsel to WTNY’ s counsel and WTP A’s counsel dated September 12,
2022.
14. Attached as Exhibit 11 is a true and correct copy of a letter from WTNY’ s counsel to Plaintiffs’ counsel with copy to WTP A’s counsel dated September 15, 2022. The issues raised therein were discussed during a telephone call between Plaintiffs’ counsel and WTNY’ s counsel on September 19, 2022.
15. Attached as Exhibit 12 is a true and correct copy of a letter from Plaintiffs’ counsel to WTNY’s counsel dated September 23, 2022.
16. Attached as Exhibit 13 is a true and correct copy of a letter from WTNY’ s counsel to Plaintiffs’ counsel dated September 26, 2022, as well as a true and correct copy of the enclosed WTNY’s second supplemental privilege log.
17. Attached as Exhibit 14 is a true and correct copy of an e-mail from Plaintiffs’ counsel to WTNY’s counsel and WTPA’s counsel dated September 27, 2022.
18. Attached as Exhibit 15 is a true and correct copy of an e-mail from WTPA’s counsel to Plaintiffs’ counsel with copy to WTNY’s counsel dated September 28, 2022.
19. Attached as Exhibit 16 is a true and correct copy of an e-mail from Plaintiffs’ counsel to WTPA’s counsel with copy to WTNY’s counsel dated September 28, 2022.
20. Attached as Exhibit 17 is a true and correct copy of a letter from Plaintiffs’ counsel to WTNY’ s counsel and WTP A’s counsel dated September 29, 2022. While the letter is dated September 29, 2022, WTNY’s counsel did not receive it until October 4, 2022, through the U.S. Mail.
21. Attached as Exhibit 18 is a true and correct copy of an e-mail from WTNY’ s counsel to Plaintiffs’ counsel with copy to WTP A’s counsel dated October 5, 2022.
22. Attached as Exhibit 19 is a true and correct copy of an e-mail from Plaintiffs’ counsel to WTNY’s counsel with copy to WTPA’s counsel dated October 5, 2022.
