216-0 Subpoena Duces Tecum
September 30th 2021
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 Kona English Congregation,
also known as Kona Hawaiʻi Pidgin Congregation of Jehovah’s Witnesses) (hereinafter referred to as “Kona
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 Kona 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 between Kona Congregation (including, but not limited to, Jeff Neubauer, Alex
Armenta, Raymond Burk, Neil Reed, Jason Lamb and Nolan Correa) and Makaha Congregation (including,
but not limited to, its members/elders, Philip Main, John Gray, David Shima, and Joseph Laa, Sr.), 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 Kona 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.
8. Any and all documents received from and/or send to Kaloko Congregation of Jehovah’s Witnesses, including,
but not limited to, its members/elders, Glenn Yoshizawa, Chris Cho (a.k.a. Christopher Bing Lam Cho), and
Barry Strom, 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.
9. Any and all communications between Kona Congregation (including, but not limited to, Jeff Neubauer, Alex
Armenta, Raymond Burk, Neil Reed, Jason Lamb and Nolan Correa) and Kaloko Congregation of Jehovah’s
Witnesses (including, but not limited to, its members/elders, Glenn Yoshizawa, Chris Cho (a.k.a. Christopher
Bing Lam Cho), and Barry Strom) 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.
10. Any and all communications and documents stored and/or retrieved from Kona Congregation’s email
address, [JWCA Redacted], 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.
