250-0 Watchtower Response Brief
July 13th, 2023
DEFENDANT WATCHTOWER BIBLE AND TRACT SOCIETY OF NEW YORK, INC.’S RESPONSE BRIEF IN OPPOSITION TO PLAINTIFFS’ MOTION TO STRIKE AND ORDER DEPOSITIONS TAKEN AS NOTICED
Full docket text for document 250:
RESPONSE to Motion re [248] MOTION to Strike and Order Depositions Taken as Noticed filed by Watchtower Bible and Tract Society of New York, Inc.. (Attachments:
# (2) Exhibit 1 2023-06-21 WTNY Counsel ltr to Ps Counsel
# (3) Exhibit 2 2023-04-26 Ps Counsel ltr to WTNY Counsel
# (4) Exhibit 3 2023-05-01 Ps Counsel ltr to WTNY Counsel
# (5) Exhibit 4 2023-05-15 Ps Counsel ltr to WTNY) (Wilson, Jon)
Excerpt:
CONCLUSION
For the reasons explained herein, and until the filing of Plaintiffs’ Response Brief, WTNY’s understanding based on the communications of Plaintiffs’ counsel was that the depositions of the Proposed Deponents were being sought in the context of 30(b )(6) topics. It was not until Plaintiffs’ Response Brief that Plaintiffs argued the Proposed Deponents had to be produced pursuant to notices of deposition because they are officers or managerial agents of WTNY. WTNY had the right to rebut that argument by reminding Plaintiffs the Proposed Deponents do not have roles as officers, directors, or managing agents so that a Rule 45 subpoena, rather than a mere notice, is required. Therefore, WTNY respectfully requests the Court deny Plaintiffs’ Motion to Strike.
