229-0 Plaintiffs Response Brief
May 5th, 2023
Full docket text for document 229:
RESPONSE to Motion re  MOTION to Compel Responses by Camillia Mapley filed by Camillia Mapley. (Attachments: # (1) Exhibit A Excerpts from 2022-11-29 Depo. of Camillia Mapley, # (2) Exhibit B 2023-05-02 Proposed Stipulation) (Shaffer, Ryan)
Plaintiff Camillia Mapley responds in opposition to Defendant Watch Tower Bible and Tract Society of Pennsylvania’s (“WTPA”) Motion to Compel Responses by Camillia Mapley (“Motion”). (Doc. 223).
SUMMARY OF OPPOSITION
When the Defendants propound legitimate discovery requests that the Plaintiffs are capable of answering, the Plaintiffs answer them. However, the discovery requests at issue in WTPA’s Motion are all objectionable, including contention interrogatories that should either never require an answer, or only be answered after discovery is complete. Nevertheless, Plaintiff provided WTPA responsive, compliant answers.
WTPA’s central complaint is that it wanted Ms. Mapley to personally answer its contention interrogatories, which seek identification of all relevant facts to various legal claims and positions. As Plaintiff’s counsel stated repeatedly, Ms. Mapley hired her lawyers to identify relevant facts and apply them to the law. She does not have knowledge of all relevant facts discovered by her lawyers, and even if she did, she is not trained or capable of determining which of those facts are relevant to the various legal issues in this case. As a result, her personal opinion
about what facts are relevant to the legal claims drafted by her lawyers will surely be incomplete and unhelpful to advancing any legitimate purpose of discovery.
WTPA had the burden of showing that its discovery requests were within the scope of permissible discovery. It cannot do so. Its discovery requests are all objectionable. Despite this, Plaintiff provided responsive answers to the interrogatories. WTPA’s demand that Ms. Mapley answer them personally serves no legitimate purpose in this case: it does not help identify evidence; it does not help identify Plaintiff’s trial position; and it does not help eliminate fact disputes ahead of trial. To the contrary, because she does not know all of the facts and is
not trained to apply them to the law, her answers are guaranteed to be incomplete and inaccurate. The only conceivable reason WTPA is demanding incomplete and inaccurate discovery answers is to use them for some ulterior purpose.
WTPA’s conduct and its frivolous Motion should not be tolerated. Plaintiffs therefore respectfully request the Court deny WTPA’s Motion, consider whether the Motion was not substantially justified such that sanctions to reimburse Plaintiff’s fees and costs are appropriate, and issue a protective order forbidding WTPA from continuing to harass Plaintiffs with the requests at issue in its Motion and, if it persists, exempting Plaintiffs and their counsel from any otherwise existing requirement to engage with WTPA on these issues.