67-0 Watch Tower Response Brief

May 11th, 2021

Watch Tower Pennsylvania and Watchtower New York submit their response brief Opposing the Plaintiff’s motion to compel Jurisdictional Discovery Responses and opposing the costs and fees demanded by Plaintiffs.

This is a 38 page document plus 9 Exhibits

Exhibit Index:

Exhibit 1 Draft Joint Jurisdictional Discovery Plan Drafted by Plaintiffs’ Counsel. …………………………………….. 2, 7, 11

Exhibit 2 Letter to Plaintiffs’ Counsel dated January 22, 2021. … 5, 16, 23

Exhibit 3 Letter to Plaintiffs’ Counsel dated February 12, 2021 …………………………………………………… 6, 21, 24

Exhibit 4 Letter to Plaintiffs’ Counsel dated March 22, 2021 …… 6, 21, 24

Exhibit 5 Letter to Plaintiffs’ Counsel dated April 8, 2021. …………………………… 7, 13, 17, 21, 23, 24, 26

Exhibit 6 Pertinent Pages of WTNY’ s Responses to Plaintiffs’ First Set of Jurisdictional Discovery to WTNY ……………… 18

Exhibit 7 Pertinent Pages of WTPA’s Responses to Plaintiffs’ Second Set of Jurisdictional Discovery to WTPA …………… 18

Exhibit 8 Pertinent Pages of WTNY’ s Responses to Plaintiffs’ Second Set of Jurisdictional Discovery to WTNY …………… 18

Exhibit 9 Pertinent Pages of WTP A’s Responses to Plaintiffs’ Third Set of Jurisdictional Discovery to WTPA ………… .18, 25