218-0 Watchtower Reply Brief

March 27th, 2023

Excerpt:

“COMES NOW, Defendant Watchtower Bible and Tract Society of New York, Inc. (hereinafter “WTNY”), by and through its attorneys of record, and respectfully submits its Reply Brief in Support of its Motion for Leave to File a Surreply Pursuant to Local Rule 7.1 ( d)(l )(D). For the reasons explained in its initial Brief in Support and for the reasons explained herein, WTNY is entitled to respond to the new arguments raised and different relief sought by Plaintiffs in their Reply (Doc. 208) in support of their Motion to Compel In Camera Review of Documents Withheld on the Basis of Attorney-Client Privilege (Doc. 196). Therefore, WTNY respectfully requests leave to file a surreply to Doc. 208.”…

Exhibits:

A Hardin Congregation Privilege Log and Response to Plaintiffs’ Subpoena Duces Tecum

B Affidavit of Marty Merrifield Re: West Laurel Congregation’s Response to Subpoena Duces Tecum

C Watchtower Draft Surreply Brief Opposing Motion to Compel

Note: Exhibit C is the Draft Surreply that includes the following statement:

“WTNY believes the court in the Illinois case erred in its conclusion that the elders had a duty to report, just as the district court in Nunez v. Watchtower Bible & Tract Soc’y, 455 P.3d 829 (Mont. 2020), erred in its conclusion that elders had a duty to report-an error corrected by the Montana Supreme Court. The elders in the Illinois case chose not to appeal, however, because the punishment was so minimal-a $250 fine. (See Doc. 208-2).”