190-0 Plaintiffs Brief

“Plaintiffs bring this Motion because WTNY is using the Organization’s opaque organizational structure to unreasonably limit the scope of its discovery production.”

“Therefore, according to WTNY, critical evidence like the 1978 Hardin Congregation Circuit Overseer Report, could be sitting at the Organization’s New York Headquarters but does not have to be produced and cannot be obtained by subpoena.”

Conclusion of the Brief:

“The Organization is one conglomerate all working towards the same goals, led by the same group of men known as the Governing Body. The myriad connections, coordination, and overlap between WTNY, WTPA, CCJW, the Service Department, the Legal Department, the U.S. Branch Committee, the Branch Office, and many other entities establishes that WTNY has the ability to obtain discoverable documents and information at the New York headquarters. Accordingly, Plaintiffs respectfully request that the Court issue an Order requiring WTNY to search for and produce discoverable documents and information at the Case 1:20-cv-00052-SPW Document 192 Filed 01/13/23 Page 26 of 28 New York headquarters, regardless of the entity that allegedly has physical possession of the documents.”