<<<<As a result, the Court denied both requests by the WTS, and the WTS must post a cash bond (or bond from an insurance company) for the full amount of the judgement. This round surely did NOT go the way of the WTS.>>>>
This is not accurate. The Court has not heard the motion yet, and, accordingly, has not rendered any decision.
Nevertheless, Conti's argument is sound. The relevant statutes do not support the WTBTS's position on this motion. Their only hope is to find a case that they can cite as authority to alllow the property substitution they seek.
I don't have the time to spend hours researching this, but I did take a quick look and found no case authority to support a WTBTS rebuttal of the Conti opposition. The WTBTS lawyers have lots of resources at their disposal. If the authority exists, they will find it. I doubt it does. From a strategic standpoint, if such authority existed, it would have been wise to cite it in the moving papers, rather than in the reply papers. It's wise to anticipate the opposition argument, and preempt it by addressing it in the moving papers, thereby taking the wind out of the oponent's sails. That didn't hapen here, and I doubt the WTBTS will be able to salvage the motion with their reply.