Amy v. Jehovah's Witnesses — Court Documents (2012)

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Not a Watch Tower publication

Papers of a civil suit in the United States brought by people who were abused as children by members of Jehovah's Witness congregations: complaints, motions, depositions and rulings, often with the Society's internal letters to elders attached as exhibits.

Court Records: Child Abuse Cases: Court records and official inquiries about how allegations of child sexual abuse were handled in congregations of Jehovah's Witnesses: the exhibits and hearing transcripts of Case Study 29 of Australia's Royal Commission into Institutional Responses to Child Sexual Abuse (2015), the 2013 hearing before a committee of the Parliament of Victoria, the papers of civil suits in the United States (including Conti and Lopez) and a judgment of the High Court in London (2015). A handbook for lawyers prepared by former members (2016) summarises these cases from the plaintiffs' side. The court papers are public documents. For a student of the organisation they are among the few sources that show, under oath and with internal letters and instructions attached as evidence, how the written policies for elders — the "two-witness" rule, judicial committees, reporting to authorities, confidentiality — were applied in real cases, and how the Society responded in court and later revised its policies. Petitions and complaints state the plaintiffs' allegations, not findings of a court. They contain distressing accounts of abuse; victims are often named by pseudonyms or initials, as in the originals. The Society's own statements on the subject are in its publications in this archive.

About the Related Works section

BARBARA ANDERSON

Court Documents

Amy vs Jehovah's Witnesses

Secrets of Pedophilia in an American Religion

Jehovah’s Witnesses in Crisis

BARBARA ANDERSON

Court Documents

Amy

Jehovah’s Witnesses CONTENTS

CASE # 91,08-C-1 DISTRICT COURT OF THE STATE OF TEXAS FOR THE COUNTY OF POTTER Filed: June 3, 2003

WATCHTOWER BIBLE AND TRACT SOCIETY OF NEW YORK, INC. et al., DUMAS CONGREGATION OF JEHOVAH'S WITNESSES, AMARILLO- SOUTHWEST CONGREGATION OF JEHOVAH'S WITNESSES and LARRY KELLY. Defendants.

PLAINTIFF'S ORIGINAL PETITION Filed 6/3/03

OBJECTIONS AND RESPONSES OF THE DUMAS CONGREGATION OF JEHOVAH'S WITNESSES TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION, Filed 10/20/03

PLAINTIFF'S REPLY TO THE RESPONSE OF DUMAS CONGREGATION OF JEHOVAH'S WITNESSES AND AMARILLO-SOUTHWEST CONGREGATION OF JEHOVAH'S WITNESSES TO PLAINTIFF'S OMNIBUS MOTION TO COMPEL AND DEFENDANTS' MOTION FOR PROTECTIVE ORDER, Filed 1/20/04 Attachment: Op. Tex. Attty. Gen. No. JM-342 (1985)

SUPPLEMENT TO PLAINTIFF'S REPLY TO THE RESPONSE OF DUMAS CONGREGATION OF JEHOVAH'S WITNESSES AND AMARILLO- SOUTHWEST CONGREGATION OF JEHOVAH'S WITNESSES TO PLAINTIFF'S OMNIBUS MOTION TO COMPEL AND DEFENDANTS' MOTION FOR PROTECTIVE ORDER, Filed 1/29/04 Exhibit H: May 9, 2002 letter from J.R. Brown

DEFENDANTS' WATCHTOWER BIBLE AND TRACT SOCIETY OF NEW YORK, INC., CHRISTIAN CONGREGATION OF JEHOVAH'S WITNESSES, DUMAS CONGREGATION OF JEHOVAH'S WITNESSES, and AMARILLO-SOUTHWEST CONGREGATION OF JEHOVAH'S WITNESSES' MOTION FOR SUMMARY JUDGMENT, Filed 1/30/04 86 Summary Judgment Evidence: Affidavit of Larry Kelley 92 Affidavit of Chuck Regal 95 Affidavit of Christopher Jensen 100 Plaintiff's Original Petition 102 CONTENTS

Documents: Identified as Kell 171-Kell 175; Kell 181-Kell 189 118

Excerpts: Deposition of Amy. B. 132

DEFENDANTS' WATCHTOWER BIBLE AND TRACT SOCIETY OF NEW YORK, INC., CHRISTIAN CONGREGATION OF JEHOVAH'S WITNESSES. DUMAS CONGREGATION OF JEHOVAH'S WITNESSES, and AMARILLO- SOUTHWEST CONGREGATION OF JEHOVAH'S WITNESSES' BRIEF IN SUPPORT OF THEIR MOTION FOR SUMMARY JUDGMENT, Filed 1/30/04 160

PLAINTIFF'S RESPONSE TO DEFENDANTS' WATCHTOWER BIBLE AND TRACT SOCIETY OF NEW YORK, INC., CHRISTIAN CONGREGATION OF JEHOVAH'S WITNESSES, DUMAS CONGREGATION OF JEHOVAH'S WITNESSES, AND AMARILLO-SOUTHWEST CONGREGATION OF JEHOVAH'S WITNESSES' MOTION FOR SUMMARY JUDGMENT. Filed 3/10/04 181

Oral and Videotaped Deposition of Larry Kelley, 12/5/03 216

Deposition of JAMES WALTER WHITNEY, 3/9/04 248

DEFENDANTS' WATCHTOWER BIBLE AND TRACT SOCIETY OF NEW YORK, INC., CHRISTIAN CONGREGATION OF JEHOVAH'S WITNESSES. DUMAS CONGREGATION OF JEHOVAH'S WITNESSES, and AMARILLO- SOUTHWEST CONGREGATION OF JEHOVAH'S WITNESSES' OBJECTIONS TO PLAINTIFF'S SUMMARY JUDGMENT EVIDENCE, Filed 3/17/04 270

DEFENDANTS' WATCHTOWER BIBLE AND TRACT SOCIETY OF NEW YORK, INC., CHRISTIAN CONGREGATION OF JEHOVAH'S WITNESSES. DUMAS CONGREGATION OF JEHOVAH'S WITNESSES, and AMARILLO- SOUTHWEST CONGREGATION OF JEHOVAH'S WITNESSES' REPLY IN SUPPORT OF THEIR MOTION FOR SUMMARY JUDGMENT, Filed 3/17/04 296 Exhibit A: AFFIDAVIT OF MERTON CAMPBELL 318

Exhibit B:

AFFIDAVIT OF CHARLES REGAL 322

PLAINTIFF'S OBJECTIONS TO DEFENDANTS' UNTIMELY SUMMARY JUDGMENT EVIDENCE, Filed 3/24/04 325

Letter of Opinion to Attorneys Hampton, Jones, Love and Spriggs from Judge Patrick A. Pirtle, 3/29/04 334

Letter of Opinion to Attorneys Hampton, Jones, Love and Spriggs from Judge Patrick A. Pirtle, 4/21/04 338 CONTENTS

PLAINTIFF'S THIRD AMENDED PETITION, Filed 4/21/04

FENDANTS’ WATCHTOWER BIBLE AND TRACT SOCIETY OF NEW YORK, INC., CHRISTIAN CONGREGATION OF JEHOVAH’S WITNESSES, DUMAS CONGREGATION OF JEHOVAH’S WITNESSES, and AMARILLO-SOUTHWEST CONGREGATION OF JEHOVAH’S WITNESSES’ FIRST AMENDED ANSWER & SPECIAL EXCEPTION TO PLAINTIFF’S THIRD AMENDED PETITION, Filed 5/11/04 348

SUPPLEMENTAL EVIDENTIARY SUPPORT FOR PLAINTIFF’S MOTION FOR CLARIFICATION AND MOTION FOR LEAVE TO CONDUCT ADDITIONAL DISCOVERY, Filed 11/24/04 355

Exhibits:

(A) ORGANIZED TO ACCOMPLISH OUR MINISTRY (4 pages) 370

(B) Cover: BRANCH OFFICE PROCEDURE DWELLING IN UNITY; Inside cover page, BRANCH ORGANIZATION 12/15/77, TABLE OF CONTENTS page with five additional pages (subheading “Governing Body and Branch Committees”) Revised 1/91 374

(C) Copy 12/15/71 Watchtower magazine article, “Theocratic Organization With Which To Move Forward Now,” includes page 7 from a 2001 Kingdom Ministry 382

(D) Watch Tower Bible and Tract Society of Pennsylvania Former and Current Directors’ List 398

(E) SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF NAPA, Case No.: 26-22191 DEFENDANT’S RESPONSE TO PLAINTIFF’S FIRST SET OF SPECIAL INTERROGATORIES 402

(F) Book (5 pages), “YOUR WORD IS A LAMP TO MY FOOT 407

(G) AFFIDAVIT OF DON ADAMS, Filed 2/10/86 412

(H) March 15, 1990 Watchtower magazine (3 pages) 422

(I) Letter from WATCH TOWER OF PENNSYLVANIA, 9/20/77; 425

(J) NOTICE OF TAKING DEPOSITION DUCES TECUM 427

DER OF DISMISSAL, Filed 2/15/07 431 VS.

WATCHTOWER BIBLE AND TRACT SOCIETY OF NEW YORK, INC.,

WATCHTOWER ENTERPRISES, L.L.C.,

WATCHTOWER FOUNDATION, INC.,

WATCHTOWER ASSOCIATES, LTD.,

KINGDOM SUPPORT SERVICES, INC.,

CHRISTIAN CONGREGATION OF

JEHOVAH'S WITNESSES, RELIGIOUS

ORDER OF JEHOVAH'S WITNESSES,

DUMAS CONGREGATION OF

JEHOVAH'S WITNESSES,

AMARILLO-SOUTHWEST

CONGREGATION OF JEHOVAH'S

WITNESSES and LARRY KELLY

Defendants.

IN THE DISTRICT COURT OF

POTTER COUNTY, TEXAS

2510t JUDICIAL DISTRICT

Jury Trial Requested

PLAINTIFF'S ORIGINAL PETITION

I. PARTIES

Plaintiff AMY B. is a resident of Texas.

Defendant WATCHTOWER BIBLE AND TRACT SOCIETY OF NEW YORK, INC., a corporation organized and existing under the laws of the State of New York, with offices at 25 Columbia Heights, Brooklyn, New York 11201-2483, has

COMES NOW AMY B., Plaintiff in the above-numbered and entitled cause, and files this, her Original Petition, and as grounds therefore would show unto this Honorable Court and Jury as follows: conducted business within the State of Texas through its agents and alter egos and may be served with process through its registered agent Mr. Tad Curtis, 702 Orland Blvd, Austin, Texas 78745-2144.

Defendant WATCHTOWER BIBLE AND TRACT SOCIETY OF PENNSYLVANIA, INC., a corporation organized and existing under the laws of the State of Pennsylvania, has conducted business within the State of Texas through its agents and alter egos. Said Defendant has not designated or maintained a registered agent for service of process in Texas. Pursuant to Tex. Bus. Corp. Act § 8.10(B), this Defendant may be served with process by serving the Texas Secretary of State who should mail a copy of the process by registered or certified mail to the Defendant's offices located at 1630 Spring Run Road Extension, Coraopolis, Pennsylvania 15108.

Defendant WATCHTOWER ENTERPRISES, INC., a limited liability company organized and existing under the laws of the State of New York, has conducted business within the State of Texas through its agents and alter egos. Said Defendant has not designated or maintained a registered agent for service of process in Texas. Pursuant to Tex. R. Civ. S. art. 1528n, art. 2.08(B), this Defendant may be served with process by serving the Texas Secretary of State who should mail a copy of the process by registered or certified mail to the Defendant's offices located at 25 Columbia Heights, Brooklyn, New York 11201.

Defendant WATCHTOWER FOUNDATION, INC., a corporation organized and existing under the laws of the State of New York, has conducted business within the State of Texas through its agents and alter egos.

Said Defendant has not designated or maintained a registered agent for service of process in Texas. Pursuant to Tex. Bus. Corp. Act § 8.10(B), this Defendant may be served with process by serving the Texas Secretary of State who should mail a copy of the process by registered or certified mail to the Defendant's offices located at 25 Columbia Heights, Brooklyn, New York 11201.

Defendant WATCHTOWER ASSOCIATES, LTD., a corporation organized and existing under the laws of the State of New York, has conducted business within the State of Texas through its agents and alter egos. Said Defendant has not designated or maintained a registered agent for service of process in Texas. Service of process on this Defendant is not requested at this time.

Defendant KINGDOM SUPPORT SERVICES, INC., a corporation organized and existing under the laws of the State of New York, has conducted business within the State of Texas through its agents and alter egos. Said Defendant has not designated or maintained a registered agent for service of process in Texas. Pursuant to Tex. Bus. Corp. Act § 8.10(B), this Defendant may be served with process by serving the Texas Secretary of State who should mail a copy of the process by registered or certified mail to the Defendant's offices located at 98 Montague Street, Brooklyn, New York 11201.

Defendant CHRISTIAN CONGREGATION OF JEHOVAH'S WITNESSES, a corporation organized and existing under the laws of the State of New York, has conducted business within the State of Texas through its agents and alter egos.

Defendant RELIGIOUS ORDER OF JEHOVAH'S WITNESSES, a corporation organized and existing under the laws of the State of New York, has conducted business within the State of Texas through its agents and alter egos. Said Defendant has not designated or maintained a registered agent for service of process in Texas. Pursuant to Tex. Bus. Corp. Act § 8.10(B), this Defendant may be served with process by serving the Texas Secretary of State who should mail a copy of the process by registered or certified mail to the Defendant's offices located at 25 Columbia Heights, Brooklyn, New York 11201-2483.

Defendant DUMAS CONGREGATION OF JEHOVAH'S WITNESSES may be served with process at its offices at 114 Santa Barbara Avenue, Dumas, Texas 79029.

Defendant AMARILLO - SOUTHWEST CONGREGATION OF JEHOVAH'S WITNESSES may be served with process at its offices at 5141 Canyon Drive, Amarillo, Texas 79110.

Defendant LARRY KELLEY currently resides and may be served with process at 3113 SW 11th Street, Potter County, Amarillo, Texas.

The Defendant entities are collectively referred to herein as the "WATCHTOWER DEFENDANTS" because each is the alter ego of each other and operate as a single business enterprise.

II. JURISDICTION AND VENUE

Plaintiff has been damaged in an amount exceeding the minimum jurisdictional levels of this court.

Venue is proper in Potter County, Texas because a substantial part of the events complained of herein took place in Potter County, Texas and Defendant LARRY KELLEY currently resides in Potter County.

III. SUMMARY OF FACTS

A. WATCHTOWER DEFENDANTS' ORGANIZATION AND CHAIN OF COMMAND

The WATCHTOWER DEFENDANTS' organization has a hierarchical structure in which the GOVERNING BODY sits at the top of a strict chain of command that extends over each individual and Defendant entity in the organization. These individuals and entities act as agents, servants and alter egos of each other. Authority for any actions by the organization, it leader and/or its members must derive from the GOVERNING BODY, which has absolute authority over every person and all matters in the organization and its worldwide operations. The GOVERNING BODY is a small group of men who operate out of various entities within the hierarchical structure.

All of the Defendants are the agents and servants of each other and are vicariously liable for each other's acts. The WATCHTOWER DEFENDANTS are so organized and controlled and their affairs are so conducted that they are alter egos of each other and operate as a single business enterprise.

B. VICARIOUS LIABILITY OF THE WATCHTOWER DEFENDANTS

Through its hierarchical structure, the WATCHTOWER DEFENDANTS assume complete responsibility for the development, protection and discipline of its membership, especially the children of members. All male members, whether Elders, Ministerial Servants, Pioneers and/or Publishers, are appointed and empowered by the GOVERNING BODY to carry out this responsibility.

To further their goals, the WATCHTOWER DEFENDANTS authorize male members to develop relationships of trust with women, children and families and to assume the role of counselor and advocate for any problems that might arise, including claims of child abuse. All male leaders have the responsibility through the Elders and those higher up in the chain of command, all the way up to the GOVERNING BODY, to decide if abuse has occurred and how it should be handled.

At all material times, the WATCHTOWER DEFENDANTS have prohibited the victim and/or accuser from warning others or speaking about the matter to anyone under penalty of discipline. Victim/accusers are not permitted to report suspected abuse to outside authorities or to other Publishers within the organization, despite secular laws and duties regarding the reporting of sexual abuse. Violation of this policy can lead to severe sanctions.

C. LARRY KELLEY

At sometime prior to 1988, the Watchtower Defendants appointed LARRY KELLEY to the position of Elder of Defendant DUMAS CONGREGATION of Jehovah's Witnesses in Dumas, Texas. As an Elder, LARRY KELLEY was given the specific assignment of instructing and supervising children in the Congregation. LARRY KELLEY had a children's show and used his puppetry skills to instruct and attract Jehovah's Witness children in furtherance of his responsibilities as an Elder for the Watchtower Defendants. Families in the Congregation were encouraged by the Watchtower Defendants to send their children to LARRY KELLEY's home for instruction and supervision. LARRY KELLEY then used his position as an Elder with supervisory responsibility over children to sexually abuse them.

While LARRY KELLEY was an appointed Elder in the Defendant DUMAS CONGREGATION, the WATCHTOWER DEFENDANTS learned that Defendant LARRY KELLEY was using his position of authority to sexually abuse children in the Congregation. Despite this admission, the WATCHTOWER DEFENDANTS did not report the abuse to authorities or warn other members of the organization of Defendant LARRY KELLEY'S propensities to use his position of authority to abuse children. Instead, they continued to place him in positions of supervisory authority and control over children.

In approximately 1988, the WATCHTOWER DEFENDANTS transferred Defendant LARRY KELLEY from Defendant DUMAS CONGREGATION to Defendant AMARILLO - SOUTHWEST CONGREGATION and appointed him to the position of Ministerial Servant. In appointing Defendant LARRY KEELY to the leadership position of Ministerial Servant, the WATCHTOWER DEFENDANTS affirmatively placed this known child molester in a position of trust and confidence with fiduciary responsibility for children in the congregation.

Despite notice of Defendant LARRY KELLEY'S propensities to use his position with the WATCHTOWER DEFENDANTS to gain access to and abuse young children, the WATCHTOWER DEFENDANTS presented him to their membership as a Ministerial Servant in good standing where he was placed in leadership roles with supervisory authority and control over children in the organization. Once again members of the Congregation were instructed and encouraged to entrust their children to Defendant LARRY KELLEY'S care both at the Kingdom Hall and off premises. Forseeably, this sexual predator used his leadership position with the WATCHTOWER DEFENDANTS to abuse other children. One of these children was Plaintiff, AMY B. AMY B. was born on June 5, 1980 and was eight years old when the abuse began.

In 1992, LARRY KELLEY was convicted of indecency with a child/sexual contact.

Beginning prior to 1988 and continuing through at least 1992, Defendant LARRY KELLEY used his appointed leadership positions of trust and authority in the WATCHTOWER DEFENDANTS' organization to sexually abuse Plaintiff AMY B.

For at least five years, the WATCHTOWER DEFENDANTS knew or should have known that Defendant LARRY KELLEY was sexually molesting and physically abusing young girls within the WATCHTOWER DEFENDANTS' organization. Nevertheless, the WATCHTOWER DEFENDANTS continued to appoint him to leadership positions with supervisory authority and control over children, entrusting him with the welfare of numerous young girls in the WATCHTOWER DEFENDANTS' local congregations, whom he sexually molested. The WATCHTOWER DEFENDANTS failed to notify anyone that Defendant LARRY KELLEY was molesting or had sexually molested young girls. They further failed to take appropriate steps to protect these young victims from his abuse. Instead, they knowingly concealed this information from Plaintiff and others. By their conduct, the WATCHTOWER DEFENDANTS aided, abetted and ratified the abuse.

Defendant LARRY KELLEY used the authority of his leadership position as an agent of the WATCHTOWER DEFENDANTS' organization to sexually abuse Plaintiff AMY B. The WATCHTOWER DEFENDANTS directly and vicariously caused foreseeable harm to Plaintiff AMY B. by, among other things:

a. aiding, abetting and ratifying the abuse of children by Elders, Ministerial Servants, Pioneers and other leaders in their congregation;

b. blaming, humiliating, sanctioning and/or disciplining victims/accusers of sexual abuse instead of the perpetrators; c.

negligently failing to report such sexual abuse, including the abuse by Defendant LARRY KELLEY, to law enforcement and governmental child welfare agencies and requiring that Publishers not make such reports.

d. negligently failing to warn Plaintiff, her family, and others of the risk of Defendant LARRY KELLEY'S abuse after they knew or should have known of Defendant LARRY KELLEY'S propensities to use his position of leadership to engage in acts of sexual abuse;

e. negligently failing to train its Elders, Ministerial Servants, Pioneers appointed overseers and other associated leaders in their local churches to prevent, identify, investigate, respond to or report child abuse;

f. negligently failing to adopt adequate policies and procedures for the protection of children and other publishers and/or to implement and comply with such procedures that did exist;

g. failing to properly investigate matters brought to the WATCHTOWER DEFENDANTS' attention involving child sexual abuse and/or suspicions of child sexual abuse;

h. negligently allowing Defendant LARRY KELLEY to move between congregations as an appointed agent and leader in good standing after the WATCHTOWER DEFENDANTS knew or should have known of his propensities to use his position of leadership to engage in acts of sexual abuse of children;

i. negligently failing to provide child abuse victims and their families with any assistance in coping with the trauma of abuse and preventing Plaintiff and her family from reporting the abuse to outside authorities and obtaining outside help to deal with the trauma of abuse.

j. concealing from Plaintiff and her family that the WATCHTOWER DEFENDANTS had information that Defendant LARRY KELLEY was abusing young children;

k. negligently failing to undertake a sexual offender evaluation, provide sexual offender treatment and/or obtain psychiatric evaluation and treatment of Defendant LARRY KELLEY after they knew or should have known of his propensities to use his position of leadership to engage in acts of sexual abuse; 1.

negligently failing to properly supervise Defendant LARRY KELLEY as a leader in the organization or to monitor his activities after they knew or should have known of his propensities to use his agency position of leadership to engage in acts of sexual abuse.

IV. CAUSES OF ACTION

COUNT I SEXUAL BATTERY AND RESPONDEAT SUPERIOR

For a number of years, beginning in about 1988 or before, as an agent and alter ego of the WATCHTOWER DEFENDANTS, Defendant LARRY KELLEY repeatedly committed sexual battery upon the person of the Plaintiff, AMY B. in the State of Texas. Each of the WATCHTOWER DEFENDANTS was in the chain of command and acted pursuant to the authority granted to them as agents and the alter ego of the GOVERNING BODY and each other, utilizing such leadership and authority to carry out and/or aid, abet and ratify the sexual abuse of Plaintiff. The WATCHTOWER DEFENDANTS are therefore liable for the sexual battery of Plaintiff under the legal theory of respondeat superior.

COUNT II COMMON-LAW NEGLIGENCE

At all material times, WATCHTOWER DEFENDANTS assumed a duty to protect Plaintiff from sexual predators within the WATCHTOWER DEFENDANTS' organization. The WATCHTOWER DEFENDANTS further knew or should have known that Plaintiff was at risk of foreseeable harm by Defendant LARRY KELLEY, but failed to act to protect her from said harm. The WATCHTOWER DEFENDANTS breached their duty to the great harm of Plaintiff.

As a direct result of the negligent conduct of the WATCHTOWER DEFENDANTS, Plaintiff has suffered the injuries and damages described herein.

COUNT III NEGLIGENT HIRING, RETENTION AND SUPERVISION

At all material times, the WATCHTOWER DEFENDANTS knew or should have known of Defendant LARRY KELLEY'S propensities to use his position as a leader in the Watchtower organization to engage in acts of sexual abuse. The WATCHTOWER DEFENDANTS failed to adequately investigate, discipline, evaluate, treat, supervise and otherwise monitor the conduct of Defendant LARRY KELLEY who was their agent and under their control. They therefore negligently hired, retained and supervised Defendant LARRY KELLEY in the organization at a time when they knew or should have known of his propensities to use his position of leadership to engage in acts of sexual abuse against Plaintiff and other young children. The WATCHTOWER DEFENDANTS also negligently hired, retained and supervised the Elders of the local congregations with respect to the investigation, reporting and care of victims of child abuse within their organization. As a result, Plaintiff has suffered grave harm.

COUNT IV GROSS NEGLIGENCE

The behavior of the WATCHTOWER DEFENDANTS set forth above demonstrated a conscious indifference to the safety and welfare of Plaintiff entitling Plaintiff to punitive damages, including attorneys' fees.

As a direct result of the grossly negligent conduct of the WATCHTOWER DEFENDANTS, Plaintiff has suffered the injuries and damages described herein.

COUNT V BREACH OF FIDUCIARY DUTY

The WATCHTOWER DEFENDANTS placed themselves in a position of trust and confidence with Plaintiff. The relationship between Plaintiff and the WATCHTOWER DEFENDANTS' organization was fiduciary in nature and imposed on the WATCHTOWER DEFENDANTS a duty to act in Plaintiff's best interest.

Because of this special relationship between the Plaintiff and the WATCHTOWER DEFENDANTS, Plaintiff and her family placed their trust and confidence in the WATCHTOWER DEFENDANTS that they would not harm Plaintiff or fail to warn Plaintiff of potential harm. Further, Plaintiff and their families placed their trust and confidence in the WATCHTOWER DEFENDANTS that they would protect Plaintiff from harm.

The above acts and/or omissions by the WATCHTOWER DEFENDANTS, either independently or in conjunction with each other constitutes a breach of the fiduciary duty owed to Plaintiff by WATCHTOWER DEFENDANTS.

As a direct result of the conduct of the WATCHTOWER DEFENDANTS, Plaintiff has suffered the injuries and damages described herein.

COUNT VI FRAUD AND FRAUDULENT CONCEALMENT

After receiving reports that Defendant LARRY KELLEY was abusing young girls, the WATCHTOWER DEFENDANTS, with the intent to keep the information from Plaintiff, other victims similarly situated, and the community-at-large, willfully concealed that information.

The WATCHTOWER DEFENDANTS materially misrepresented to Plaintiff and her family that Defendant LARRY KELLEY was a leader in good standing with authority to supervise, control and instruct Plaintiff in spiritual, ethical and moral matters and that he was to be obeyed. The WATCHTOWER DEFENDANTS further materially misrepresented that they would act in Plaintiff's best interest. The WATCHTOWER DEFENDANTS failed to disclose that they knew of Defendant LARRY KELLEY'S propensities to use his leadership position to sexually abuse Plaintiff and others and that they were doing nothing to protect them. Plaintiff did not know the falsity of the WATCHTOWER DEFENDANTS' representations, were entitled to rely upon them, and did in fact rely upon them, to their serious injury and harm.

COUNT VII RATIFICATION

Upon learning that its agent, Defendant LARRY KELLEY had sexually abused young children in the organization, the WATCHTOWER DEFENDANTS failed to take sufficient steps to discipline or hold Defendant LARRY KELLEY accountable for his actions. The WATCHTOWER DEFENDANTS transferred Defendant LARRY KELLEY to the AMARILLO - SOUTHWEST JEHOVAH'S WITNESSES CONGREGATION as a leader in good standing with the organization, providing no warning to its members that they were entrusting them to the care of a sexual predator.

The WATCHTOWER DEFENDANTS thereby ratified Defendant LARRY KELLEY'S conduct in sexually abusing Plaintiff and others. The WATCHTOWER DEFENDANTS are thus liable in damages to Plaintiff.

COUNT VIII ALTER EGO AND SINGLE BUSINESS ENTERPRISE

The WATCHTOWER DEFENDANTS are organized and controlled, and their affairs are so conducted, that they are in fact mere instrumentalities and alter egos for each other and liable for each other's acts. Alternatively, the WATCHTOWER DEFENDANTS were all engaged, at all material times, in a single business enterprise and are liable for each other's acts.

V. DAMAGES

As a result of the WATCHTOWER DEFENDANTS' acts, Plaintiff has incurred and will continue to incur costs for medical expenses, counseling and psychological treatment, have lost earning capacity and have suffered and will continue to suffer extreme, permanent emotional distress and psychological harm with accompanying physical manifestations, embarrassment, loss of self-esteem, disgrace, humiliation, loss of enjoyment of life, and economic and non-economic damages in excess of the jurisdictional limits of this Court.

VI.

JURY DEMAND

Plaintiff requests a trial by jury and has submitted herewith the appropriate jury fee.

VII.

PRAYER

WHEREFORE, Plaintiff demands judgment against Defendants individually, jointly and severally in an amount for economic, non-economic, and punitive damages, including attorneys' fees, plus costs, disbursements, and any and all other relief the court deems just and equitable.

Respectfully submitted,

FIBICH, HAMPTON LEEBRON & GARTH, L.L.P.

Tommy Fibich, Esq.

Hartley Hampton, Esq.

Mike Leebron, Esq.

1401 McKinney, Suite 1800

Five Houston Center

Houston, Texas 77010

(713) 751-0025-Telephone

(713) 751-0030-Telecopy

LOVE & NORRIS

Gregory S. Love

Kimberlee D. Norris

314 Main Street, Suite 300

Fort Worth, Texas 76102-7423

(817) 335-2800-Telephone

(817) 335-2912-Telecopy

ATTORNEYS FOR PLAINTIFF Plaintiff,

IN THE 251 ST DISTRICT COURT

WATCHTOWER BIBLE AND TRACT SOCIETY OF NEW YORK, INC.,

WATCHTOWER ENTERPRISES, L.L.C.,

WATCHTOWER FOUNDATION, INC.,

WATCHTOWER ASSOCIATES, LTD.,

KINGDOM SUPPORT SERVICES, INC.,

CHRISTIAN CONGREGATION OF

JEHOVAH'S WITNESSES, RELIGIOUS

ORDER OF JEHOVAH'S WITNESSES,

DUMAS CONGREGATION OF

JEHOVAH'S WITNESSES,

AMARILLO-SOUTHWEST

CONGREGATION OF JEHOVAH'S

WITNESSES and LARRY KELLEY,

Defendants.

IN AND FOR

POTTER COUNTY, TEXAS

OBJECTIONS AND RESPONSES OF THE DUMAS CONGREGATION OF JEHOVAH'S WITNESSES TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION

TO: Plaintiff, AMY B., by and through her attorney of record, Hartley Hampton, Fibich Hampton, Leebron & Garth, L.L.P., Five Houston Center, 1401 McKinney, Suite 1800, Houston, Texas 77010

COMES NOW, DUMAS CONGREGATION OF JEHOVAH'S WITNESSES, (hereinafter "Dumas Congregation" or "Defendant") one of the Defendants in the above entitled and numbered cause, and hereby submits its Objections and Responses of the Dumas Congregation of Jehovah's Witnesses to Plaintiff's First Request for Production.

Respectful'y submitted,

SPROUSE SHRADER SMITH P.C.

801 S. Fillmore, Suite 600

P. O.Box 15008

Amarillo, Texas 79105-5008

Phone: (806) 468-3335

Fax: (806) 373-3454

Christopher T. Tenns

Marvin W. Jones

State Bar No. 10929100

Christopher L. Jensen

State Bar No. 00796825

Attorneys for Defendant CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the above and foregoing document was sent to the following as signified below on this 20 day of October 2003:

Hartley Hampton, Esq.

Fibich, Hampton, Leebron & Garth, L.L.P.

1401 McKinney, Suite 1800

Five Houston Center

Houston, TX 77010

Certified Mail, Return Receipt Requested

United States Regular Mail

Overnight Mail

By Facsimile Transmission

By Hand Delivery

Gregory S. Love

Kimberlee D. Norris

Love & Norris

314 Main Street, Suite 300

Fort Worth, TX 76102-7423

Certified Mail, Return Receipt Requested

United States Regular Mail

Overnight Mail

By Facsimile Transmission

By Hand Delivery

Larry Kelley3113 SW 11th,#BAmarillo,TX79106

Certified Mail,Return ReceiptRequested

\Box

United States Regular Mail

\Box

Overnight Mail

\Box

By Facsimile Transmission

\Box

By Hand Delivery

\Box

Christopher F. Sensen

Marvin W. Jones

Christopher L. Jensen GENERAL OBJECTIONS

Defendant objects to the Definitions and Instructions contained in Plaintiff's requested discovery because they are overly broad, unduly burdensome and constitute undue annoyance and harassment. Defendant further objects to these Definitions and Instructions for the reason that they impose an undue burden upon Defendant to attempt to decipher the language of each request in accordance with the language of the purported Definitions and for the reason that they tend to impose upon Defendant burdens which are not imposed by law or by the Rules of Civil Procedure governing this action. Therefore, Defendant will wholly reject Plaintiff's attempt to redefine commonly used words and will interpret the requests with common understanding of the language used without any regard or thought to definitions as stated by Plaintiff.

As an initial matter, Defendant objects to the directions regarding the method, manner and location of production to the extent that such directions would place upon Defendant burdens not imposed by the Texas Rules of Civil Procedure. Further, Defendant states that Defendant is not required to produce copies of the documents at the offices of FIBICH, HAMPTON, LEEBRON & GARTH. Instead, Defendant will produce documents for Plaintiff's review at the offices of SPROUSE SHRADER SMITH P.C. Pursuant to Rule 196.6, TEX. R. CIV. P., if Plaintiff wants to receive copies of the documents produced for review at SPROUSE SHRADER SMITH P.C., the Plaintiff can make arrangements to pay for the costs of reproduction.

Without waiver of the generality of the foregoing, Defendant specifically objects to the initial paragraph under the heading "Definitions" because Plaintiff impermissibly imposes a burden upon Defendant to interpret definitions in different ways depending upon the "context" which makes these requests vague and ambiguous.

Defendant objects to paragraph 1 of the Definitions because Plaintiff imposes the burden to identify the full name of the Plaintiff as well as Plaintiff's agents, representatives, officers, directors, employees, partners, corporate agents, subsidiaries, affiliates, family, parent or any other person acting in concert with the Plaintiff but have not provided any such information to the Defendant. Therefore, it is impossible for the Defendant to apply a definition of "Plaintiffs" when the Plaintiff has failed to provide the information. In addition, the definition of "Plaintiffs" is vague because Plaintiff is an individual and therefore references to officers, directors, employees, corporate agents, subsidiaries, and affiliates are nonsensical. Finally, the purported definition of "Plaintiffs" imposes an undue burden upon Defendant to attempt to decipher the definition in conjunction with the requests.

Defendant further objects to paragraph 2 of Plaintiff's Definitions because the paragraph purports to define "The Watchtower Organization" as a unified whole when each entity is separate and apart from the other entities. As such, the purported definition is improper.

Defendant further objects to paragraph 3 of the Definitions for the reason that such paragraph purports to define the word "document" in a manner that is overly broad. Defendant further objects to such definition for the reason that the definition includes items which are not commonly understood to be documents. In addition, the breadth of the definition would require disclosure of information which is neither relevant nor reasonably calculated to lead to discovery of admissible evidence.

Defendant further objects to paragraph 6 for the reason that such paragraph purports to define the word "person" as including a variety of entities or associations which construed in conjunction with the requests in question causes them to be overly broad and calls for information regarding persons, associations or entities, the affairs of which have no relevance to any issue involved in this case.

Therefore, the requests would require disclosure of information which is neither relevant nor reasonably calculated to lead to discovery of admissible evidence.

Defendant further objects to paragraph 9 for the reason that such paragraph purports to define the term "communication" in an overly-broad manner and in a manner that would impose an unreasonable burden upon Defendant. In addition, the definition in conjunction with the requests could require the creation of documents that are not in existence.

Defendant further objects to paragraph 11 for the reason that such paragraph purports to define the words "identify" and "describe" as including a broad array of information that does not necessarily include the "identity" of an individual, partnership or document and as such the purported Definitions attempt to escape the limitations placed upon Plaintiff under the Texas Rules of Civil Procedure. In addition, the definition of "identity" when construed in conjunction with the requests causes the requested discovery to be overly broad and calls for information which has no relevance to any issue involved in this case. Therefore, the requested discovery would require disclosure of information which is neither relevant nor reasonably calculated to lead to discovery of admissible evidence.

Subject to these objections and without waiver of the foregoing, Defendant will apply the ordinary definition of the words used and will respond to the requests as required by the Texas Rules of Civil Procedure.

REQUESTS FOR PRODUCTION

REQUEST FOR PRODUCTION NO.1:

Please produce all documents that concern, reference, or in any way relate to Larry Keith Kelley's sexual abuse, or alleged sexual abuse, of Amy Betzen.

RESPONSE:

Dumas Congregation objects to this request as it seeks information protected by Texas Rules of Evidence, Rule 505 (communications to members of the clergy). Dumas Congregation further asserts that this request calls for information protected from discovery by the lawyer-client and work product privileges, as protected by the Texas Rules of Civil Procedure and the Texas Rules of Evidence, Rule 503.

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: Dumas Congregation has none.

REQUEST FOR PRODUCTION NO.2:

Please produce all documents that concern, reference, or in any way relate to Larry Keith Kelley's sexual abuse, or alleged sexual abuse, of Tamara Jordan.

RESPONSE:

Dumas Congregation objects to this request as it seeks information protected by Texas Rules of Evidence, Rule 505 (communications to members of the clergy). Dumas Congregation further asserts that this request calls for information protected from discovery by the lawyer-client and work product privileges, as protected by Texas Rules of Evidence, Rule 503. Dumas Congregation also objects to this request as an unnecessary and impermissible invasion of privacy of individuals who are not parties to this lawsuit.

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: Dumas Congregation has none.

REQUEST FOR PRODUCTION NO.3:

Please produce all reports of any kind made to a Jehovah's Witness or Watchtower Organization circuit office or branch office regarding charges or allegations of sexual abuse made by anyone against Larry Keith Kelley.

RESPONSE:

Dumas Congregation objects to the use of the term "Jehovah's Witness or Watchtower Organization circuit office or branch office" as vague and ambiguous. Dumas Congregation further objects to this request as overbroad as it is unlimited in time and geographic scope and not limited to issues related to this case.

Dumas Congregation also objects to this request because it seeks documents, which are irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. In addition, Dumas Congregation objects to this request as it fails to describe with reasonable particularity the documents requested.

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: See the Privilege Log in response to this Request.

REQUEST FOR PRODUCTION NO.4:

Please produce any and all reports made to Bethel, the Service Department, the Writing Department, and/or the Governing Body, or any individual member thereof, regarding or in any way relating to charges or allegations of sexual abuse made by anyone against Larry Keith Kelley.

RESPONSE:

Dumas Congregation objects to the use of the terms "Bethel, the Service Department, the Writing Department, and/or the Governing Body, or any individual member thereof" as vague, ambiguous, and overbroad. Dumas Congregation further objects to this request as overbroad as it is unlimited in time and geographic scope and not limited to work related to this case. Dumas Congregation also objects to this request because it seeks documents which are irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. In addition, Dumas Congregation objects to this request as it fails to describe with reasonable particularity the documents requested.

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: See Privilege Log in response to this Request.

REQUEST FOR PRODUCTION NO. 5:

Please produce a true and correct copy of the 1991 Our Kingdom Ministry.

RESPONSE:

Dumas Congregation objects to this request as it is vague, ambiguous and overbroad. Dumas Congregation also objects to this request as it fails to describe with reasonable particularity the documents requested. Dumas Congregation further objects to this request because it seeks religious documents concerning the doctrine, teachings and internal workings of the church, which have nothing to do with child abuse and are therefore irrelevant and not reasonably calculated to lead to the discovery of admissible evidence, and which are protected from disclosure by the First Amendment to the United States Constitution. See Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976).

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: See the portion of the October 1991, issue of Our Kingdom Ministry that does reference child abuse, identified as DUMC0001.

REQUEST FOR PRODUCTION NO. 6:

Please produce a true and correct copy of the August 1, letter to all Bodies of Elders.

RESPONSE:

Dumas Congregation further objects to this request because it seeks religious documents concerning the doctrine, teachings and internal workings of the church, which are irrelevant and not reasonably calculated to lead to the discovery of admissible evidence, and which are protected from disclosure by the First Amendment to the United States Constitution. See Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976). Dumas Congregation also objects to this request as it seeks information protected by the Texas Rules of Evidence, Rule 505 (communications to members of the clergy).

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: See documents identified as DUMC0002-DUMC0003.

REQUEST FOR PRODUCTION NO. 7:

Please produce true and correct copies of all Congregation's Publisher Record cards and membership files for Larry Keith Kelley.

RESPONSE:

Dumas Congregation objects to this request as it is vague, ambiguous, overbroad, and unlimited in time. Dumas Congregation further objects to this request as it seeks information protected by Texas Rules of Evidence, Rule 505 (communications to members of the clergy).

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: See documents identified as DUMC0004-DUMC0007.

REQUEST FOR PRODUCTION NO. 8:

Please produce true and correct copies of all Congregation's Publisher Record cards and membership files for Amy Betzen.

RESPONSE:

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: Dumas Congregation has none.

Please produce true and correct copies of all Congregation's Publisher Record cards and membership files for Tamara Jordan.

REQUEST FOR PRODUCTION NO. 9:

RESPONSE:

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: Dumas Congregation has none.

REQUEST FOR PRODUCTION NO.10:

Please produce true and correct copies of any letters of introduction written for Larry Keith Kelley when he transferred from one Jehovah's Witness or Watchtower Organization congregation to another.

RESPONSE:

Dumas Congregation objects to term "Watchtower Organization" as overbroad, vague, and ambiguous. Dumas Congregation further objects to this request as it is vague, ambiguous, overbroad, and unlimited in time. Dumas Congregation also objects to this request as it seeks information protected by Texas Rules of Evidence, Rule 505 (communications to members of the clergy).

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: Dumas Congregation has none.

REQUEST FOR PRODUCTION NO.11:

Please produce a true and correct copy of the Kingdom Ministry School Supplementary Course for Congregation Elders that includes "Use Discernment in Handling Serious Matters."

RESPONSE:

Dumas Congregation objects to this request because it seeks religious documents concerning the doctrine, teachings and internal workings of the church, which have nothing to do with child abuse and are therefore irrelevant and not reasonably calculated to lead to the discovery of admissible evidence, and which are protected from disclosure by the First Amendment to the United States Constitution. See Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976). Dumas Congregation further objects to this request as it seeks information protected by Texas Rules of Evidence, Rule 505 (communications to members of the clergy).

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: Dumas Congregation has no such document.

REQUEST FOR PRODUCTION NO.12:

Please produce a true and correct copy of every edition of the Kingdom Ministry School textbook published between 1970 and the present date.

RESPONSE:

Dumas Congregation objects to this request because the burden and expense of the proposed discovery outweighs its likely benefit and seeks documents which are not reasonably calculated to lead to the discovery of admissible evidence. Dumas Congregation further objects to this request because it seeks religious documents concerning the doctrine, teachings and internal workings of the church, which have nothing to do with child abuse and are therefore irrelevant and not reasonably calculated to lead to the discovery of admissible evidence, and which are protected from disclosure by the First Amendment to the United States Constitution See Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976). Dumas Congregation further objects to this request as it seeks information protected by Texas Rules of Evidence, Rule 505 (communications to members of the clergy).

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: See the redacted document identified as DUMC0008- DUMC0014, which includes all references to child abuse.

REQUEST FOR PRODUCTION NO.13:

Please produce a true and correct copy of the letter to all Bodies of Elders dated July 20,1998.

RESPONSE:

As an initial matter, Dumas Congregation objects because the requested documents are neither relevant not reasonably calculated to lead to the discovery of admissible

OBJECTIONS AND RESPONSES OF THE DUMAS CONGREGATION OF JEHOVAH'S WITNESSES PAGE 11 TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION evidence because the item requested was not produced until many years following the events made the basis of Plaintiff's suit.

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: See the Privilege Log in response to this Request.

REQUEST FOR PRODUCTION NO.14:

Please produce a true and correct copy of the May 9,2002 letter written by J.R. Brown, Director of the Watchtower Society Office of Public Information, to Betsan Powys, "Panorama" Program, British Broadcasting Corporation.

RESPONSE:

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: Dumas Congregation does not have this document.

REQUEST FOR PRODUCTION NO.15:

Please produce true and correct copies of all written communications addressed or sent to "All Bodies of Elders" between 1970 and the present regarding or in any way relating to child abuse or sexual abuse.

RESPONSE:

Dumas Congregation objects to this request as it is overly broad and seeks documents which are not reasonably calculated to lead to the discovery of admissible evidence. Dumas Congregation also objects to this request as it fails to describe with reasonable particularity the documents requested. Dumas Congregation further objects to this request because it seeks religious documents concerning the doctrine, teachings and internal workings of the church, which have nothing to do with child abuse and are therefore irrelevant and not reasonably calculated to lead to the discovery of admissible evidence, and which are protected from disclosure by the First Amendment to the United States Constitution. See Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976). Dumas

OBJECTIONS AND RESPONSES OF THE DUMAS CONGREGATION OF JEHOVAH'S WITNESSES PAGE 12 TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION Congregation further objects to this request as it seeks information protected by Texas Rules of Evidence, Rule 505 (communications to members of the clergy).

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: See documents previously identified which includes letters to Bodies of Elders that reference child abuse through the present and documents DUMC0018-DUMC0031. See also response to Request Nos. 6 and 13. See also the Privilege Log in response to this Request.

REQUEST FOR PRODUCTION NO.16:

Please produce any and all documents concerning, regarding or in any way relating to any disciplinary hearing conducted regarding allegations of child abuse or sexual abuse against Larry Keith Kelley, including, but not limited to:

a. all S-77 forms;

b. any notes taken by judicial counsel members; and

c. the case summary.

RESPONSE:

Dumas Congregation objects to this request as overbroad as it is unlimited in time and geographic scope and not limited to work related to this case. Dumas Congregation further objects to this request because it seeks documents, which are irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.

Dumas Congregation additionally objects to this request as it seeks information protected by Texas Rules of Evidence, Rule 505 (communications to members of the clergy). Finally, Dumas Congregation asserts that this request calls for information protected from discovery by the attorney-client and work product privileges, privileges as protected by Texas Rules of Civil Procedure and Texas Rules of Evidence, Rule 503.

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: Dumas Congregation has no documents that comply with subparts "a" and "c" of this Request. See Privilege Log in response to subpart "b" of this Request.

REQUEST FOR PRODUCTION NO.17:

Please produce all documents reflecting or in any way relating to instructions by the Jehovah Witnesses', the Watchtower Organization's, Bethel's, the Governing Body's, the Writing Department's, the Service Department's, or any member or agent thereof's instructions to judicial committee members for conducting a disciplinary hearing regarding allegations of child abuse or sexual abuse.

Dumas Congregation objects to the use of the term "Jehovah Witnesses', the Watchtower Organization's, Bethel's, the Governing Body's, the Writing Department's, the Service Department's, or any member or agent thereof's" as overbroad, vague, and ambiguous. Dumas Congregation further objects to this request as it is vague, ambiguous and overbroad, and seeks documents which are not reasonably calculated to lead to the discovery of admissible evidence. Dumas Congregation also objects to this request as it fails to describe with reasonable particularity the documents requested. Dumas Congregation additionally objects to this request because it seeks religious documents concerning the doctrine, teachings and internal workings of the church, which have nothing to do with child abuse and are therefore irrelevant and not reasonably calculated to lead to the discovery of admissible evidence, and which are protected from disclosure by the First Amendment to the United States Constitution. See Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976). Finally, Dumas Congregation objects to this request as it seeks information protected by Texas Rules of Evidence, Rule 505 (communications to members of the clergy).

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: See Response to Request Nos. 6 and 13 above.

REQUEST FOR PRODUCTION NO.18:

Please produce a true and correct copy of the September, 1977 Our Kingdom Service.

RESPONSE:

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: None of these documents have any reference to child abuse. If Plaintiff can specify any such reference, Defendant will provide a copy.

REQUEST FOR PRODUCTION NO.19:

Please produce any and all video or audio recordings of any nature supplied to this Defendant in which any person discusses being sexually abused by Larry Keith Kelley.

RESPONSE:

Dumas Congregation also objects to this request as an unnecessary and impermissible invasion of privacy of individuals who are not parties to this lawsuit.

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: Dumas Congregation has none.

REQUEST FOR PRODUCTION NO.20:

Please produce a true and correct copy of "Pay Attention to Yourselves and to All the Flock", as well as all supplements including changes and additions required to be made verbally.

RESPONSE:

Dumas Congregation objects to this request as it is seeks documents which are not reasonably calculated to lead to the discovery of admissible evidence. Dumas Congregation also objects to this request because it seeks religious documents concerning the doctrine, teachings and internal workings of the church, which have nothing to do with child abuse and are therefore irrelevant and not reasonably calculated to lead to the discovery of admissible evidence, and which are protected from disclosure by the First Amendment to the United States Constitution. See Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976). Dumas Congregation additionally objects to this request as it seeks information protected by Texas Rules of Evidence, Rule 505 (communications to members of the clergy).

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: See Response to Request Nos. 6 and 13 above.

REQUEST FOR PRODUCTION NO.21:

Please produce a true and correct copy of "The Addendum presented at the Kingdom Ministry School," as described on page 3 of the March 23,1992 letter from the Watchtower Bible and Tract Society of New York, Inc. addressed "To All Bodies of Elders."

RESPONSE:

Dumas Congregation objects to this request as it is vague, ambiguous and overbroad. Dumas Congregation further objects to this request as it fails to describe with reasonable particularity the documents requested. Dumas Congregation also objects to this request because it seeks religious documents concerning the doctrine, teachings and internal workings of the church, which have nothing to do with child abuse and are therefore irrelevant and not reasonably calculated to lead to the discovery of admissible evidence, and which are protected from disclosure by the First Amendment to the United States Constitution. See Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976). Dumas Congregation additionally objects to this request as it seeks information protected by Texas Rules of Evidence, Rule 505 (communications to members of the clergy).

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: Dumas Congregation has no such document.

REQUEST FOR PRODUCTION NO.22:

Please produce true and correct copies of all written communications addressed or sent to "All Bodies of Elders" between 1970 and the present pertaining in any way to "Theocratic War", "Theocratic Warfare" or the "Theocratic War Strategy."

RESPONSE:

Dumas Congregation objects to this request as vague and ambiguous as to the use of the terms "theocratic war," "theocratic warfare" or "theocratic war strategy" and further objects to this request as harassing and requesting information that is irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. Dumas Congregation further objects because this request appears to seek information concerning church doctrine and teachings which is protected by the ecclesiastical abstention doctrine and the First Amendment to the United States Constitution. See Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976). Dumas Congregation also objects to this request as it seeks information protected from disclosure by Texas Rules of Evidence, Rule 505.

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: Unable to respond to this request as worded.

REQUEST FOR PRODUCTION NO.23:

Please produce a true and correct copy of the May 1, 1957 issue of The Watchtower.

RESPONSE:

Subject to, and without waiving the above objections, Dumas Congregation responds as follows: This document has no reference to child abuse. If Plaintiff can specify any such reference, we will provide a copy of the relevant portion.

REQUEST FOR PRODUCTION NO.24:

A true and correct copy of the May 15, 1957 issue of The Watchtower.

RESPONSE:

See Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976).

REQUEST FOR PRODUCTION NO.25:

A true and correct copy of the May 15, 1988 issue of The Watchtower.

RESPONSE:

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Amy v. Jehovah's Witnesses — Court Documents (2012)