Candace Conti v Watchtower Society | June 3, 2013 | Respondent's Brief - prepared by Rick Simons | A136641

by jwleaks 212 Replies latest watchtower child-abuse

• 

  Calebs Airplane

  Recap

  1st Appellate District	</form>
  		Court data last updated: 09/03/2013 03:05 PM Case Summary Docket Briefs Scheduled Actions Disposition Parties and Attorneys Trial Court Docket (Register of Actions)		Jane Doe v. The Watchtower Bible and Tract Society of New York Inc. et al. Division 3 Case Number A136641 Date Description Notes 09/25/2012 Notice of appeal lodged/received. by attorney Robert J. Schnack (Jackson Lewis) for The Watchtower Bible and Tract Society of New York Inc. and attorney James M. McCabe (McCabe Law Firm) for Fremont California Congregation of Jehovah's Witnesses, North Unit (defendants); notice of appeal filed in the superior court on 09/20/2012 09/25/2012 Notified parties of local rules and procedures. 09/25/2012 Filing fee. from One Legal LLC [504 Redwood Boulevard - Suite 223; Novato, CA 94947; (800) 938-8815]; check number D 3267358 issued 09/20/2012 as to The Watchtower Bible and Tract Society of New York Inc. 10/01/2012 Filing fee. $775 check# 3749 from Jackson Lewis LLP for Fremont California Congregation of Jehovah's Witnesses North Unit 10/04/2012 Received document entitled: appellant's notice designating reporter trancripts; notice filed in the superior court on 10/02/2012 10/04/2012 Default re: 8.130(b) rptrs fees not deposited rcvd. dtd. default notice issued by the superior court on 10/03/2012 10/12/2012 Default letter sent; no case information statement filed. as to The Watchtower Bible and Tract Society of New York Inc. 10/12/2012 Default letter sent; no case information statement filed. as to Fremont California Congregation of Jehovah's Witnesses North Unit 10/24/2012 Certificate of interested entities or persons filed by: Jon R. Williams, for The Watchtower Bible and Tract Society of New York Inc. et al. 10/30/2012 Telephone conversation with: Superior court, parties filed a waiver for reporter's fee, and court reporter were notified 10/26. 10/24/2012 Civil case information statement filed. as to The Watchtower Bible and Tract Society of New York Inc. by attorney Joe Williams for appellants (The Watchtower) w/a copy of the order attached. 10/24/2012 Civil case information statement filed. as to Fremont California Congregation of Jehovah's Witnesses North Unit by attorney McCabe w/a copy of the order attached. 11/07/2012 Notice to reporter to prepare transcript. sent to CSR Kathryn Lloyd, Michelle Barbante and Tina Kelly dated 10/26/12. Txs due 11/26/12. 11/28/2012 Notice of record completion received. 11/28/2012 Original entry stricken - sequence no. not removed. r-13 (rule 8.124) Record was filed. Returned to Superior court for pagination. 12/19/2012 Change of contact information filed for: Furtado, Jaspovice & Simons A Law Corporation 6589 Bellhurst Lane Castro Valley, CA 94552 510-582-1080 ph 510-585-8254 fax 01/02/2013 Record on appeal filed. 13 vols. of "corrected paginated RT" 01/04/2013 Stipulation filed to: extend 30 days for AOB, now due 2/6. extend 30 days for RB. 01/04/2013 Stipulation of extension of time filed to: Appellant's opening brief. Due on 02/06/2013 By 30 Day(s) 02/07/2013 Stipulation of extension of time filed to: Appellant's opening brief. Due on 03/08/2013 By 30 Day(s) 03/11/2013 Appellant notified re failure to timely file opening brief. Defendant and Appellant: The Watchtower Bible and Tract Society of New York Inc. Attorney: Robert Jerry Schnack Defendant and Appellant: Fremont California Congregation of Jehovah's Witnesses, North Unit Attorney: James Murray McCabe 03/27/2013 Appellant's opening brief. Defendant and Appellant: Fremont California Congregation of Jehovah's Witnesses, North Unit Attorney: James Murray McCabe 8.25(b)(3) 03/27/2013 Received: Watchtower Bible & Tract Society's AOB. Oversized brief. 03/27/2013 Application filed to: File Watchtower Bible & Tract Society's AOB in excess of word count limit. 03/27/2013 Pro hac vice application Mario F. Moreno for watchtower Bible & Tract Society. 03/27/2013 Appellant's appendix filed. 8 - vols of Joint Appellants' Appendix. 03/27/2013 Record in box. 1 - box of joint appellants' appendix. 03/29/2013 Pro hac vice granted BY THE COURT: Upon due consideration, the verified application of Mario F. Moreno to appear as counsel pro hac vice for appellant Watchtower Bible & Tract Society of New York, Inc. in the above-referenced appeal is granted. 03/29/2013 Order filed. BY THE COURT: Upon due consideration, appellant Watchtower Bible & Tract Society of New York, Inc.'s application to file an opening brief in excess of 14, 000 words is granted. The clerk of the court is ordered to file appellant Watchtower Bible & Tract Society of New York, Inc.'s 15, 352-word brief as of the date of this order. 03/29/2013 Appellant's opening brief. Defendant and Appellant: The Watchtower Bible and Tract Society of New York Inc. Attorney: Robert Jerry Schnack 05/29/2013 Respondent notified re failure to file respondent's brief. Plaintiff and Respondent: Jane Doe Attorney: Kelly I. Kraetsch 06/06/2013 Application filed to: For leave to file oversized RB. 06/06/2013 Received: Oversized RB. 06/06/2013 Respondent's appendix filed. 1 - vol. 06/06/2013 Filing fee. $390 responsive filing fee check# 69236 from Furtado, Jaspovice & Simons. 06/11/2013 Order filed. BY THE COURT: Upon due consideration, respondent's application for leave to file a brief in excess of 14, 000 words is granted. The clerk of the court is directed to file respondent's 16, 076-word brief as of the date of this order. 06/11/2013 Respondent's brief. Plaintiff and Respondent: Jane Doe Attorney: Kelly I. Kraetsch 06/27/2013 Stipulation of extension of time filed to: Appellant's reply brief. Due on 07/31/2013 By 30 Day(s) 06/27/2013 Stipulation of extension of time filed to: Appellant's reply brief. Due on 07/31/2013 By 30 Day(s) 07/30/2013 Stipulation of extension of time filed to: Appellant's reply brief. Due on 08/30/2013 By 30 Day(s) 07/30/2013 Stipulation of extension of time filed to: Appellant's reply brief. Due on 08/30/2013 By 30 Day(s) 1 stipulation for both ARBs 09/03/2013 Appellant's reply brief. Defendant and Appellant: The Watchtower Bible and Tract Society of New York Inc. Attorney: Robert Jerry Schnack 8.25(b)(3) 09/03/2013 Appellant's reply brief. Defendant and Appellant: Fremont California Congregation of Jehovah's Witnesses, North Unit Attorney: James Murray McCabe 8.25(b)(3) 09/03/2013 Case fully briefed. Click here to request automatic e-mail notifications about this case.
• 

  Gayle

  Nothing in over 2 months? All parties applied for "oral" arguments. But no follow up? Do we assume that "oral" has not been done yet or? Is this 'stretch' common? I think I read after written *and oral* have been presented, then the Court has 3 months (or 90 days) for decision?
• 

  DATA-DOG

  Watching this space....

  DD
• 

  Gayle

  http://www.lacba.org/Files/Main%20Folder/Areas%20of%20Practice/AppellateCourts/Files/070522_Appellate%20Courts%20Committeeprimer.pdf

  The Court will usually schedule oral argument within a few months after briefing is complete.

  So Court reads or studies the written briefs "within few months," 'before the' "oral arguments." So, timing is on course. Schedule for "oral arguments" could be posted soon now?
• 

  Gayle

  12/12/2013

  Received:

  letter dated 11/18/13 from Joseph Herrera requesting denial of Watchtower appeal

  http://appellatecases.courtinfo.ca.gov/search/case/dockets.cfm?dist=1&doc_id=2025979&doc_no=A136641

  why (what purpose?) was this letter entered in the "docket" and who is this "Joseph Herrera?"
• 

  Phizzy

  Bump
• 

  Splash

  Is he this guy?

  http://www.youtube.com/user/anonacea
• 

  OUTLAW

  Joey Herrera

  QA Coordinator, Manager, Insurance Processing / Interpreter, Spanish-English

  Florence, South Carolina Area

  Insurance

  Join LinkedIn and access Joey Herrera’s full profile. It's free!

  As a LinkedIn member, you'll join 250 million other professionals who are sharing connections, ideas, and opportunities.

  • See who you and Joey Herrera know in common
  • Get introduced to Joey Herrera
  • Contact Joey Herrera directly

  View Joey's full profile

  Joey Herrera's Overview

  Current

  • Spanish / English Interpreter at Language Solutions
  • Quality Coordinator, Hazard Insurance Processing at Assurant

  Past

  • Claims Analyst IV/Lead at BCBSSC - BlueCross BlueShield of SC
  • Production / Customer Service at Megaprints-commercial printing & marketing
  • Security / Tour Manager at WTBTS - Watchtower

  Education

  • Midlands Technical College

  Connections

  228 connections

  Websites

  • Company Website

  Joey Herrera's Summary

  This summary focuses on my language and interpreting skills and experience. For Managerial and Quality Assurance experience, see current and previous positions below.
  
  June 1, 2011 - The South Carolina Department of Health and Environmental Control (DHEC) and the Department of Social Services (DSS) has approved of me providing Spanish/English oral interpreting, sight translation and small text translations.
  
  On August 31, 2010, The South Carolina Court Administration of the Supreme Court certifies that I have successfully completed the Phase II Written Examination for Court Interpreters.
  
  On July 18, 2010, Midlands Technical College (Columbia, SC) certifies that I have successfully completed the SC Court Interpreter Certification Program Phase I Orientation.
  
  The American Council on the Teaching of Foreign Languages (ACTFL) has awarded me the highest rating as a speaker in the Spanish Language, based on the ACTFL Proficiency Guidelines. Speakers at the "Superior" level are able to communicate in the language with accuracy and fluency in order to participate fully and effectively in conversations on a variety of topics in formal and informal settings from both concrete and abstract perspectives.

  Joey Herrera's Experience

  Spanish / English Interpreter

  Language Solutions

  May 2010 – Present (3 years 8 months)

  Comprehensive interpreting and translation solutions for your Spanish / English language needs in central and coastal South Carolina and North Carolina. We also offer tutoring services in your quest to learn to speak Spanish effectively.
  --On-Site Interpreting --Prison Conferences
  --Court Appearances --Medical Evaluations/Appointments
  --Document Translation --Tutoring

  Quality Coordinator, Hazard Insurance Processing

  Assurant

  Public Company; 10,001+ employees; AIZ; Insurance industry

  June 2008 – Present (5 years 7 months) Florence, SC

  --Quality Coordinator, Hazard Insurance Customer Care
  Previous Role: Hazard Insurance Unit Manager
  --Responsible for managing a processing unit of the Hazard Insurance Processing Center.
  --Coordinate workflow for domestic and global teams, identify and implement process improvements.
  --I've worked closely with the Operations Manager in developing and implementing short and long-term goals for the constantly changing business unit.
  --Daily involvement in planning, organizing and coordinating day-to-day activities of some 20 associates.
  --Monitor and evaluate direct reports' performance, attendance and compliance to all company's requirements.
  --Regularly communicate approved policies, procedures and service level standards to associates.
  --Responsible for performing root cause analysis and gathering back-up documentation for weekly audits as directed by our clients and other Quality focused internal departments.
  --Collaborate with counterparts at other Assurant and vendor sites to ensure completion of weekly goals and constant improvement of the service we provide to our clients.

  Claims Analyst IV/Lead

  BCBSSC - BlueCross BlueShield of SC

  October 2005 – June 2008 (2 years 9 months)

  Production / Customer Service

  Megaprints-commercial printing & marketing

  July 2004 – September 2005 (1 year 3 months)

  Security / Tour Manager

  WTBTS - Watchtower

  April 1993 – April 2004 (11 years 1 month)

  ...............................................................................

  Question:

  Why is a "WBT$ Tour Manager" involved in such a crucial case?!...................

  ........................................ ...OUTLAW
• 

  Londo111

  Very curious.
• 

  DATA-DOG

  He looks like a real douche. Just sayin'... Maybe he's being trained as a double for Mark Sanderson??