195-0 Plaintiffs Motion for In Camera Review

January 18th, 2023

Plaintiffs, by and through their undersigned counsel, and pursuant to Rules 34 and 37 of the Federal Rules of Civil Procedure, hereby respectfully move the Court for an order compelling in camera review of documents withheld by Defendant Watchtower Bible and Tract Society of New York, Inc. (“WTNY”) under the attorney-client privilege. A brief in support of this Motion is being filed contemporaneously herewith.

Pursuant to L.R. 26.3 (c), Plaintiffs’ counsel certifies that the parties conferred regarding the disputed issues, i.e. the exact nature of the privilege being asserted and how it applied to the withheld documents. Such conferral included multiple written communications and at least one phone call, where WTNY stated that it would not submit the withheld document to the Court for in camera review.

Pursuant to L.R. 26.3(c)(2)(C), a copy of all relevant discovery requests and WTNY’s responses are attached as an exhibit to the brief in support being filed
contemporaneously herewith