267-0 Motion to Quash

Document filed February 5th, 2014

Case Number: 37-2012-00099849

Document Title: 

NOTICE OF MOTION AND MOTION TO SET ASIDE OR OTHERWISE QUASH ORDER GRANTING PLAINTIFF’S MOTION TO COMPEL THE DEPOSITION OF GERRIT LOSCH AND THE UNDERLYING “NOTICE OF TAKING THE DEPOSITION OF GERRIT LOSCH, WITH PRODUCTION OF DOCUMENTS REQUIRED — VIDEORECORDED FOR USE AT TRIAL”; DECLARATION OF GERRIT LOSCH; DECLARATION OF DANNY BLAND; DECLARATION OF ASHLEY A. ESCUDERO; AND [PROPOSED] ORDER

This document contains the 2014 motion by Gerrit Losch opposing the Court’s order granting Plaintiff Jose Lopez a motion to compel the testimony of Jehovah’s Witness Governing Body member Gerrit Losch.

Attorneys for Jose Lopez asked the court for permission to depose Gerrit Losch since he was considered by the Plaintiff as a PMQ (Person Most Qualified) to give testimony on behalf of the Jehovah’s Witnesses. He was the longest-serving member of the Governing Body.

This document also contains the Declaration of Danny Bland, a long-time member of the Jehovah’s Witness Headquarters staff who occupies a prominent position in the Treasurer’s Office.

Additional supporting documents: 

Declaration of Ashley A. Escudero, associate with Morris Polich & Purdy, LLP, attorneys representing Gerrit Losch and other Jehovah’s Witness entities.

December 25th, 2013 Declaration of Allen Shuster

February 15th, 2012 Excerpts from deposition of Allen Shuster from Jane Doe v Watchtower, a civil case filed in Alameda California

November 2013 Declaration of Danny Bland supporting Watchtower’s Brief RE: Gerrit Losch

December 20th, 2013 Discovery Referee Recommendations