Thanks for posting the documents. It seems that the WTS really pissed the judge off by willfully refusing to comply with discovery orders. However, it is extremely rare for default judgments to stand, as there is a strong preference for cases to be decided on the merits whenever possible. In fact, it doesn't appear that Zalkin was able to cite a single case in his brief where a CA court allowed sanctions in the form of a default judgment on the entire underlying case to permanently stand when challenged.
But I would think that if the WTS is successful in having the default vacated, they will be required to comply with the discovery orders as a condition of vacating the judgment. Unless, of course, they are able to succeed in appealing both the default judgment and the discovery rulings simultaneously. It will be interesting to see what they do if put to the choice of having to turn over all those documents and produce Loesch for a deposition or get the default judgment tossed.
An interesting snippet from the deposition of Mario Moreno (WTS attorney)
Q: Have you ever attended these [Governing Body] meetings?
A: I have
Q: And in what capacity?
A: As a lawyer
Q: And have you attended those meetings for purposes of providing legal counsel?
A: Yes
Truly in the model of first century Christianity... just as the 12 apostles were always lawyered up when they met.