366-0 Plaintiffs Brief in Support of Motion for Sanctions
April 19th 2024
Full docket text for document 366:
Brief/Memorandum in Support re [365] MOTION for Sanctions RE: WTNY’S PATTERN OF DECEPTION AND DISCOVERY ABUSE filed by Tracy Caekaert, Camillia Mapley.
Attachments:
# (1) Exhibit A PLs.’ Req. for Prod. No. 72 to WTNY
# (2) Exhibit B List of Withheld Affidavits & Declarations
# (3) Exhibit C – Doc. 88 February 28th 2007 Declaration of Gary Breaux
# (4) Exhibit D – September 29th 2006 Dec of Mario Moreno in Supp. of Opp. to Mt. to Compel Depos re Watchtower Legal Dept
# (5) Exhibit E – February 2nd 2004 – 2nd Affidavit of Richard E.Abrahamson
# (6) Exhibit F – Doc. 229 July 22nd 2021 – Order Enforcing 5-26-2021 Order and Assessing Sanctions
# (7) Exhibit G – Watchtower New York Answer to PLs.’ Interrogatories 26 & 27
# (8) Exhibit H – CONFIDENTIAL July 28th 2003 Letter to Forsyth & Hardin BOE re C.O. Pacheco Visit
# (9) Exhibit I – July 5th 2023 – Watchtower New York 4th Supplementary Privilege Log
# (10) Exhibit J – September 24th 2018 – Vol I AM Trial Session Nunez v Watchtower
# (11) Exhibit K – Watchtower New York Answer to Plaintiffs Interrogatories No. 17 & 18
# (12) Exhibit L – January 10th 2024 – Deposition Transcript Hardin 30(b)(6)
