LAWSUIT GETS BIGGER!
WATCHTOWER PRESIDENT DON A. ADAMS MAY
HAVE TO TESTIFY
| Photo attributed to P. Vasiliadis |
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| http://en.wikipedia.org/wiki/File:DonAdams_200907.png for terms |
Among other people this
mentions Watchtower Society heavies Don Adams, his brother Joel Adams and others at Watchtower’s world headquarters
in New York. The Governing Body is mentioned but other than its President Don Adams, no other names for
Governing Body members are cited yet. Following are extracts of the “Response To Interrogatories” document
going from pages 25 to the end. In the document are calls for Watchtower’s President Don Adams to
come give testimony in this case that alleges that defendants committed Wire And Mail Fraud, Religious Affinity Fraud, money-laundering,
systematic major tax evasion, falsifying of evidence, witness tampering, “Mafia Style tactics,” harassment, personal
threats electronically through email that “under Homeland Security Laws fall under electronic terroristic threats,”
invasion of privacy via illegal cell phone surveillance to get confidential phone conversations, etc. Please
remember and bear in mind that all defendants are to be presumed innocent until and unless they may possibly be convicted
in a court of law.
The document involves not
only the takeover of the Menlo Park in California but it alleges Watchtower is doing such against independent high-dollar
congregations across the U.S. for example in Washington D.C., New York, Kentucky and Texas. Even
the F.B.I. is mentioned. To be more precise, the following is after Case No.: 3:10-CV-03907-MEJ “In
the United States District Court For The Northern District Of California” with the Honorable Maria-Elena James presiding;
and the Response To Interrogatories part of it goes from page 18 to page 54.
The document’s online address is http://ex-jw.com/wp-content/uploads/2011/05/50-main.pdf To make it easier to read the extracted material is presented
here with paragraphs and some (not all) correcting of some of the original’s misspelled words. Now,
here is the extracted material:
Page 25: Whenever problems
arose in the affecting of their illegal takeover various phone conferences were held with Defendant Allen Shuster who gave
logistical support to his fellow Defendants on what measures they should undertake to ensure that the takeover would happen.
The chain of command was as follows; Defendant Allen Shuster would give information and make plans and provide this
assistance to Defendant Paul Koehler who would then provide information to his cousin Defendant Ernest Brede and then Defendant
Brede would disseminate the information to the rest of his fellow Defendants. Upon receiving the original
complaint filed in August of 2010, and seeing the charge of Wire Fraud, much of the communications that occurred after that
were direct. Defendant Shuster on two known occasions boarded a flight and flew trans continentally from
New York, Patterson office to California to speak directly to the Defendants here.
It is believed this was done in an effort to try to prevent any further liability for Wire Fraud. It is also surmised that any technical planning and execution of their furtherance of
their original planned takeover was done at the behest of Joel C. Adams who heads the various departments that were managed
by Defendant Allen Shuster. It should be noted that Joel C. Adams is the brother of Don Adams, the current
Watchtower president. Drawing upon his extensive legal knowledge and along with his knowledge of the inner
workings of the Watchtower organization from a corporate standpoint, it could easily be alleged that this planned takeover
was the brainchild of Joel C. Adams with his brother, Don Adams lending assistance in the form of planning and advising due
to his legal knowledge and his knowledge of the inner workings of the organization as a whole. So tentatively,
it can be surmised that Don Adams oversaw this takeover and sanctioned it, through Joel C. Adams, his brother who headed the
department that Defendant Allen Shuster managed, and than Defendant Shuster carried out the plan utilizing Defendant Koehler
as a pointman directing Defendant Brede. Defendant Brede would than disseminate the plans or counter plans
to the rest of the Defendants.
For this reason, the Plaintiff's feel it will be very necessary to secure testimony from Joel C. Adams
to ascertain possible involvement in this ongoing situation. It will also be necessary to call as witness
Don Adams, the Watchtower president as he is the most knowledgeable about procedures within the organization.
Due in part, to his being the standing president of the Watchtower organization he is in the best position to be able
to convey and explain the correct procedures with regard to corporate issues and since there is a direct separation between
the corporate and religious sides to the organization, there should not be a conflict of interest in with regard to his testimony
about corporate procedures within the organization. Please refer to Exhibit G for a hierarchal breakdown
and how the upper echelon of the Watchtower Corporation purport to the field operatives. With regard to secular motives
which would thus invoke Serbian as a basis for this complaint, a motive can be clearly established by Defendant Brede himself.
On or about the date of June 7th 20011, Defendant Brede had been engaging in conversation with Bill Douglass, a potential
witness for the Plaintiff's. During this conversation Mr. Bill Douglas stated that he wanted to know
the exact reasons for the removal of the entire elder body of Menlo Park which occurred on July 1st, 2010. According
to Mr. Douglas the reason stated by Defendant Brede for their removal was for retaliatory purposes. Defendant
Brede stated that they, meaning the entire elder body was removed because of their having to remove Peter Gallego for disciplinary
measures.
Defendant Brede also went
on to state to Mr. Bill Douglas, that they only wished to remove Jason Cobb and Jonathan D. Cobb, but to prevent
it from appearing as a racial issue, since both Jonathan D. Cobb and Jason Cobb are black, they in fact made the choice
to remove them all. It should be noted that Plaintiff Walter St. Clair and George Stock are in fact caucasian.
It was implied to Mr. Bill Douglas that the removal and takeover of the Congregation was for retaliatory and revenge
motives, along with the furtherance of their scheme.
As background information, Peter Gallego had been an elder
based in the Menlo Park Congregation for many years prior to his death. During his tenure as an elder Mr.
Gallego had been involved in behavior that was unbecoming of an elder in good standing, so it was decided that Mr. Gallego
had to be removed. This was due in part to his seemingly excessive and weekly drinking, along with some
issues with regard to his sons behavior that was deemed inappropirate by religious standards. Mr. Gallego
was regularly in contact with members back at the Patterson office of the Watchtower and had been engaging in collecting and
documenting the movements and activities of the then elders. Mr. Gallego had been acting more or less as
a pointman, directed by parties at the Patterson office, with a clear motive to try to document in a negative way the activities
of Jason Cobb and Jonathan D. Cobb with seemingly the hope of finding a way to get them removed from their positions.
Prior to Mr. Gallegos death he did divulge the names of the parties he was in contact with and the purpose of said
contact. Those parties may be called as hostile witnesses to testify to the intent and that there were
various parties who conspired to find fault with Jason Cobb and Jonathan D. Cobb for the sole purpose of their removal.
With Defendant Brede establishing
the true motive for this takeover it is clear that this is NOT a 1st Amendment issue but only that the Defendants are hoping
to shield themselves behind the facade of this situation being an ecclesiastical issue that is not open to the scrutiny of
the courts. In actuality, the Defendants have established their true intent with the conversation with
Mr. Bill Douglas, who has also stated he will testify as to the content of this conversation as well as others if called upon
by the court.
With regard to Mr.
Bill Douglas who resides at 735 Ramona Ave, in Palo Alto, California, he has stated that he had been threatened with (page
28) excommunication by Defendant Paul Koehler himself if he appeared to be aiding Jason Cobb or the Plaintiff's in any
way. He was expressly told to not "talk" to Jason, who is in good standing within the Congregation.
He was also told to ask no further questions in regard to this matter.
It is clear that the Defendants along with Mr. Anthony Smith are engaging in continued
witness tampering in an effort to try to intimidate possible witnesses into not cooperating with any directives of the court.
Mr. Bill Douglas is considering options to secure protections from the court prior to any dates where his testimony
may be needed. The Defendants seem bent on trying to utilize religious right as a type of blanket immunity
even regarding criminal activities.
Officer Jeff Keegan has stated that during the course of his initial investigation with regard to Case No. MPPD 11-973 that
Mr. Anthony Smith has implied that due to the fact that this situation in ecclesiastical in nature, his Defendants seemingly
do not have to cooperate with the investigation. Again, though it should be clearly noted that religious
policies do not in any way supersede the law of the land. With three police reports filed and investigations
now in the early stages for various potential offenses ranging from identity theft to fraud by the Defendants, it is obvious
to the layman that no religious policies excuse one from responsibility to the law. The Defendants are
simply trying to override the law using religious procedures as an excuse. There is a stated procedure
for dealing with corporate issues. The question based upon the preponderance
of the law now is, were the Defendants aware of this procedure or not? One cannot claim ignorance of the
law which is by its very nature a basic principle of the law, since the law is readily accessible to all. The
simple principle is that the Defendants do not have the power to remove officers from a corporation. They
may have the power to remove the Plaintiff's from there spiritual responsibilities within the Congregation but they do
NOT have the power to remove officers or just to simply vote themselves in, and this is what is at the core of this legal
proceeding. See attached exhibit F, which is a cop of an email from Defendant Brede to Jason Cobb which
obviously shows that Defendant Brede does not understand corporation procedures.
Page 29: One cannot vote oneself into a specified position within a corporation then arbitrarily use subterfuge
to maintain control of that corporation and then absorb the assets of the original corporation when there are standing officers
of that corporation in place. By virtue of the documents that were filed fraudulently with the Secretary
of State office it is clear this was the intent of the Defendants. The corporate bank accounts were taken
over without the Plaintiff's signing off and the fraudulent State filed documents were used to gain access to these accounts.
The bank accounts themselves contain the names of Defendants Brede,
Donald Showers and Glenn Watson. The property deed was then absorbed and the names contained on the deed
are Defendants Ernest Brede, Donald Showers and Larry Laverdure. The secret bank account at Chase Bank
contains the names of Defendants Ernest Brede, Donald Showers and Luis Contreras, so it is obvious they were all appear complicit
in this alleged criminal activity. They sought to take over by force alone, utilizing fraudulent documents
and fraudulent filings. Any document that contained their names was used in the effecting of this alleged
criminal behavior. When discovered they sought to then try to have Jason Cobb charged with the crime of
embezzlement in a way to retroactively cover over their wrongdoing and lay blame on him. Even going so
far as to file a fraudulent police report in the hopes of possibly getting Jason Cobb arrested so as to gain leverage with
the Plaintiff's. Why else would Defendants
Ernest Brede and Donald Showers file a police report claiming embezzlement for an account that they themselves opened and
were aware of? It was only when Jason Cobb became aware of this accounts existence did it become an issue.
The only question that remains is whether or not this was an idea of their creation or whether or not they were instructed
to take this course of action by parties at the Patterson office of the Watchtower headquarters, through their liaison here,
Defendant Paul Koehler. The Defendants are all willing participants in this fraud and hope to hide behind
religious polity to cover over their complicity in these alleged criminal acts.
(page 30) Exhibits B, C and D are letters by the entire previous
body of elders who although were removed from the religious positions did not sign over or waive their corporate positions.
These documents were at the request of the Menlo Park Police Department for that ongoing investigation and it's
clear that the Defendants circumvented any legal process and opted to simply take by force and fraudulent means, the assets,
accounts and property attached to the Menlo Park Corporation. Their motives obviously being secular in
fashion. Within the scope of the Palo Alto Police Department's investigation they are concentrating
on what appears to be low level money laundering on the part of the Defendants. Which is why the Defendants
need access to the accounts as part of their scheme.
The scheme has a two-fold purpose; one being the complete control by the Watchtower headquarters of all physical Kingdom Hall buildings. Notice please Exhibit D, the Restated Articles
of the Defendants corporation which state that in the event there is any default the real property of 811 Bay Road will transfer
ownership to the Watchtower headquarters. Which is akin to a modern day land grab. The
seemingly new policy in effect by the Watchtower is to gain absolute control of all the actual Congregation properties for
all Kingdom Halls that are independently owned. To do this and make it palatable for the parishioners is
create the need to expand the physical size of the building itself. Step one is to force merge two congregations into one building. With
more parishioners in attendance it becomes obvious that the physical building may not be able to accommodate the influx of
new members, so a remodeling project is then planned.
Step two is to then loan
the necessary funds to that congregation to complete the remodeling work. The property deed is then leveraged
in lieu of loan payment. This means that the Watchtower Corporation has their name placed on the deed as
temporary owner until the loan is paid off. The loans are usually exorbitant amounts, way more than what
is normally needed for any remodeling project but this is done to make sure the congregation stays in debt for a longer period
of time.
Thirdly,
when the loan is finally paid off by the congregation who received the remodeling work, the Watchtower Corporation never remove
their names from the property deed (page 31) even though they agreed to at the very beginning of the transaction.
In effect the Watchtower Corporation then becomes the owner of the physical building,
thus putting that particular congregation under the direct control of the Watchtower Corporation in Patterson.
On closer inspection though, it has become obvious that these remodeling projects are used as a means to launder and
embezzle money. The remodeling projects are always overpriced, this being akin to the U.S. Army charging
$500 dollars for a toilet. The remodeling projects are priced with cost overruns which allow unscrupulous
parties to be able to profit and launder and or embezzle funds from within the remodeling project itself.
The embezzlement scheme is predicated on their being a need for a remodeling project and if you force merge two congregations,
it instantly creates the need to remodel as the parishioners have increased. The old building that was
occupied by the merging congregation is sold at a profit, thus giving the appearance of the remodeling project being necessary
to accommodate the new congregation.
The Regional Building Committee or RBC who arranges the building projects then becomes a clearinghouse for
the money, but with a discretionary clause, see Exhibit H which is a letter by the RBC on the subject of building renovations
and remodeling. In paragraph four it states that due to the rising costs of building materials remodeling
should not be the first thought. Maintaining the buildings with good ventilation, care for restrooms and
such is first priority. Page 2 of the same exhibit states that even if the congregation has the funds to
complete a remodeling project, that does not necessarily mean a full remodeling project should be undertaken.
This means in layman terms we are only interested in allowing a congregation to remodel if the property will garner
more money in a proposed sale and that renovations and remodeling projects are primarily reserved for merged congregations
due to the fact that the empty building left after the congregation assimilates into a new location is one that would have
a high dollar value attached to it.
It should be also noted that Joel C. Adams
heads the department that oversees the RBC, so it is likely that if any party within the Watchtower organization can testify
as to why these mergers are forced he Page 32: could. On the surface it all seems reasonable
but the whole scheme operates on one basic principle--most parishioners, who are Christians, would never think that a fellow
Christian would lie. This is the operating principle that has allowed the Defendants to seemingly act with
impunity. It is also why they would
try to blame an innocent party, Jason Cobb, and make claim that he was embezzling money and placing it into an account that
in fact the Defendants themselves opened on July 9th, 2010 with the help of confederates within the bank and using Jason Cobb's
identity and credentials. They sought to create a crime that they had no real intention of trying to charge
Jason Cobb with but that they had planned to use as leverage an excuse to excommunicate Jason Cobb, Jonathan D. Cobb Sr. and
possibly Walter Arlen St. Clair along with George Stock.
After several long moths when this account was discovered by Jason with the help of a banking agent from Wells
Fargo Bank, it became clear that the Defendants in an effort to try to neutralize any criminal charges incurred from the unauthorized
use of Jason Cobb's identity and credentials, the Defendants, Ernest Brede and Donald Showers sought to file a police
report claiming that they in fact were the ones who "discovered" this account, when in actuality they were the ones
according to Chase Bank that opened the account. The Defendants have demonstrated that they are willing
to lie, falsify documents, file false reports, fabricate evidence and deal in subterfuge, intimidations and anything else
necessary in an effort to resolve this situation and not have to answer for their criminal acts.
To this end they have enlisted the help of several parties from within the confines
of the religious organization to assist them in a systematic form of harassment, all designed to prevent their exposure.
The Defendants have utilized people with specific skills such as Mr. Bruce Radetich, who is an ex-police officer and
now a security specialist who, it is believed has been employed in an effort to use illegal means to surreptitiously monitor
phone calls in hopes of gaining information as to the possible direction the Plaintiff's are heading with regard to legal
matters. Certain personal cell phones of the Plaintiff's as well as other parties closely associated
with the Plaintiff's appear as if they (Page 33) been monitored by parties outside.
One particular cell phone used by Jason Cobb was inspected
by a cell phone specialist, named Milano at Cell Phone Repair, located at 859 W. El Camino Real, Mountain View, CA 94040 where
it was determined that the phone in question had been set up to allow a remote party to be able to intercept calls and monitor
them. Milano the cell phone technician who worked on the cell phone in question has had nearly ten years
of experience with various makes and models of phones and this party has agreed to testify about the state of the phone and
the potential ramifications of what he discovered while working on Jason Cobb's cell phone. The technician's
expert testimony can easily show intent and how far the Defendants, acting in consort with various confederates, are willing
to go in an effort to try to conceal the true nature of this situation, not to mention clearly defining Wire Fraud issues. As the Defendants seem intent
on portraying this situation and being an issue of polity it lends credence to the charge of Religious Affinity Fraud.
Why do you ask parishioners of the congregation to donate money for a remodeling project that will be paid
for by a loan secured from the Watchtower Corporation? Again this demonstrates that the Defendants
are part of a vast network of carefully placed individuals who are there to use their positions to influence any type of outcome
they wish. A good example of this is
Wells Fargo Bank, N.A. This bank has received several numerous subpoenas with regard to the possible accounts
being used for laundering and still they have yet to comply with any subpoena in full. The Plaintiff's
have subpoenaed requesting the signature cards for th account #87894705, an account that contain the name of Mr. Glenn M.
Watson who is listed as a party that any and all account information has been sought but the banks response was, that the
signature cards have been lost and they no longer possess them.
Clearly subterfuge in that
the signature cards are an integral part of any account but more especially for a business account attached to a corporation.
It is either a case of gross negligence or concealment as it is so believed that it was Mr. Glenn M. Watson who removed
the authorized names of Jason Cobb and Jonathan D. Cobb Sr. from these accounts PRIOR to the (page 34) date of July 1st, 2010
at the time the Defendants came and claimed they were authorized to be the new officers of the corporation.
It is incomprehensible that a
bank would loose the signature cards for a corporation, as it demonstrates the extreme mishandling and irresponsibility of
the bank in question and if this is not the case then it is clearly subterfuge on the part of certain bank employees in trying
to help the Defendants conceal their wrongdoing and possible involvement with this scheme. Wells Fargo
Bank has demonstrated a premeditated desire to aid the Defendants in covering up the fact that Jason Cobb, may have had his
name removed from the accounts in question even BEFORE the Defendants arrived to the Menlo Park Congregation in an effort
to lay the ground work for this takeover.
This is not in any way supposition as there are facts to support this
claim based upon information already obtained through other subpoenas from Wells Fargo Ban, N.A. Refer
to Exhibit I which is an actual bank statement with regard to one of the accounts in question and on page 2 it shows an annual
gross sale of $150,000 dollars. Firstly, Jehovah's Witnesses do not "sell" anything and there
is the question of where did these funds originate from? According to account historical information, this
amount, $150,000 dollars came into this bank account in late 2008, yet Jason Cobb who was rightful custodian of this account
during this time had no knowledge of this money. The
only way this could have occurred is if Mr. Glenn M. Watson had Jason Cobb's name removed from the account so that he
would not be able to access any information or receive any statements that would have alerted him to this money much in the
same way that his identity was used by the Defendants to establish a secret account at Chase Bank that
was flush with $60,000 dollars. It could exist, if no one would know or have knowledge of its existence
on the part of the rightful officers of the corporation. Further documentation
could easily ferret out, how exactly they removed Jason Cobb's name to prevent detection, and Wells Fargo Bank is aware
of this as it presents a high degree of liability by the bank. Using carefully placed confederates within
the bank, the (page 35) Defendants obviously had planned all along to effect the removal of the then elders
and Plaintiff's. Wells Fargo Bank's only interest is in concealing the fact of their liability
in this situation as it is being made public would seriously undermine the publics trust in the bank overall. Refer
to Exhibit G for the diagram that outlines the inner workings of their network from within the Watchtower Corporation.
The network itself is a series of individuals who are in place and by extension have underlings working under them,
the Defendants are such an example of this. Many times they have used unwitting parties to effect their
ends. In these cases they have used religious statutes in an effort to try to convince parties that cooperating
with either law enforcement or the Plaintiff's would be contrary to the laws of God and what is laid out in the bible,
sadly most parties forget that a Christian's first and foremost duty is to the truth, whatever that may be.
However, the Defendants have steadfastly made claim to various individuals that providing any information to the Plaintiff's
would be going against the Watchtower itself and by extension God. Nothing
could be further from the truth, it's simply a case of the Defendants trying silence individuals and block any possible
testimony of parties privy to pertinent information that could expose what the Defendants have done in trying to obfuscate
the lawful process with regard to the corporation itself. Again, clear evidence of this is the private
meeting that the Defendants had with Mr. Bill Douglas where they informed him that providing any information to the Plaintiff's,
would result in his excommunication from the organization. According to Mr, Bill Douglas, even AOR Anthony
V. Smith had seemingly implied the same thing in a telephonic conversation with him. The
Defendants are obviously using fear tactics in trying to sway potential witnesses. If fear does not work
then direct intimidation is the next step in a systematic plan to try to render the case a moot point if parties are too afraid
to come forward and tell the truth about what they in fact know, have seen, or been part to in various interactions with the
Defendants at the congregational hall of meeting. All Defendants have participated in one form or another
in witness intimidation and using religion as a basis to ensure that potential witnesses will not (page 36)
cooperate any court case or with the various police agencies that are now investigating and many have come forward
complaining that they are tired of being bullied and harassed by the Defendants. The
takeover of the Menlo Park Congregation Corporation was done with a series of fraudulent acts all committed by the Defendants
acting as willing participants in a wider scheme. That scheme is predicated on the forced merger of several
congregations. With the new tax laws that have gone into effect accountability of religious organizations
has now increased. When we speak of accountabilities we are speaking in a monetary sense. With
the new 990 tax laws religious organizations now must make an accounting of funds for potential taxation purposes and in doing
so the Watchtower Corporation has used mergers as a way to more or less beat possible taxation. The
scheme works like this, the Watchtower Corporation has $150,000 dollars of money they do not wish to report to be taxed on,
so they earmark this money to be used as a donation to a particular congregation. That congregation is
then told to merge with another congregation, which naturally will cause an instant increase in membership as in actuality
two congregations are being merged into one. With the advent of their being more members the claim is then
made that due to the higher volume of members it is necessary to then build a larger congregation building.
Money that would normally have
to be reported for tax purposes then in earmarked for a new project. It is usually an amount that is higher than what
is needed to do the construction project. Meaning, if to do a basic remodeling project would cost $75,000 dollars, the
Watchtower Corporation then provides $100,000 as a donation to the building project. The congregation is then responsible
for the "donation" that is also considered a loan. The congregation then pays the funds back, supposedly the
cost of the loan when in actuality the Watchtower Corporation is receiving the same money back that was initially made as
a donation. It is therefore non taxable as it appears as if its a loan payment for the remodeling work.
This also answers the question as to why the congregation also has a (page 37)
building fund knowing full well it is going to get the loan from the Watchtower Corporation. The Watchtower Corporation
has its name placed on the deed as collateral for the loan and once the remodeling work is done, they never remove their name
from the deed, whether the loan is paid back or not and thus the Watchtower Corporation effectively takes control of the congregational
building, or Kingdom Hall and they have more or less laundered the funds that they would have been taxed. This is nothing
more than a large scheme that has its basis in tax avoidance. The government cannot tax monies the Watchtower Corporation
no longer has as it is given to congregations for the purpose of building and remodeling. In doing so, the congregation in
question loses control over the actual property but as a consolation that congregation gets a newly remodeled building which
is to placate anyone who may question the inner workings of the scheme.
It's an illusion, you see a
new Kingdom Hall but what you do not realize is to get this new Kingdom Hall you are giving up control of it and also helping
the Watchtower Corporation to effectively launder the funds that would have had to be taxed under the new taxation laws that
apply to religious organizations. It is also about control of the actual congregation Kingdom Hall buildings. The Watchtower
Corporation did not want a repeat of what happened in the Bonham Texas case where it was established that the various Kingdom
Halls, although they may use the name Jehovah's Witnesses are not necessarily owned by the Watchtower Corporation itself.
Thus the Watchtower Corporation sought to find a way
to force all congregation Kingdom Halls under their control but do it in such a way that none of the members themselves would
realize that ever merger is nothing more than a hostile takeover with the newly remodeled Kingdom Hall building being nothing
more than placebo to placate anyone that may question the true intent and motives of the Watchtower Corporation. It
should also be noted that this was obviously a way to launder monies that should have been taxed by the necessary governmental
agencies. With new upcoming tax laws that will go into effect soon, the Watchtower Corporation is actively seeking to
merge as many congregations, possibly as a last ditch effort to effectively operate their (page 38) "money machine"
until such time as they can no longer, due to tax regulations, be able to continue it further. Due to the fact that the
Menlo Park Corporation has never received any loans from the Watchtower Society Corporation, it is in no way beholden to the
Watchtower Corporation, the Defendants main objective was to incur debt to the Watchtower Corporation, in the form of the
remodeling work proposed for the physical building at 811 Bay Road. The Christian Congregation of Jehovah's
Witnesses is a corporation based in Patterson, New York. It is a part of the overall Watchtower Corporation
and as such has no ecclesiastical authority. As a corporation they can't. Yet Exhibit
J clearly shows that it was in fact this part of the corporation that made the decision for the removal of the elders of the
Menlo Park Congregation, namely Jason Cobb, Walter A. St. Clair, George Stock and Jonathan D. Cobb Sr.
This decision could have only come from the ruling
class of the Governing Body based in Brooklyn, New York. Mr. Anthony Smith AOR for the Defendants has tirelessly
claimed that this is an ecclesiastical issue and that it has been resolved at the very highest ecclesiastical levels but yet
he failed state who that is. He would have to claim that it is Don Adams, who is the president of the Watchtower
Corporation or that it was the Governing Body of the Jehovah's Witnesses. It is established that this
is not a decision by the Governing Body as no documentation bears their names or signatures, nor is there any documentations
and communiques from Mr. Don Adams, so this begs the question as to who makes the decisions.
If the decision was made by the Governing Body,
it can only be for an ecclesiastical issue, namely the Plaintiff's positions as elders within the congregation but this
in no way also includes their positions as officers of the congregation corporation. Although Defendant
Brede stated in an email to Jason Cobb that their removal from ecclesiastical positions automatically includes removal from
corporate duties, when in fact a corporation is baed upon laws of the land and not biblical laws, so therefore Defendant Brede's
claim is false, please see referenced email as Exhibit F.
With all of the various intricacies to policies within the Watchtower Corporation
and the fact that this part of the Watchtower is (page 39) corporate based and not particularly about religious doctrine it
is obviously necessary to have Mr. Don Adams testify as an expert witness about the current policies within the organization.
The current goals of the parties involved in this network is not to control the flow of information and to try and
conceal their complicity by any means necessary.
An example of this is the Wells Fargo Bank, N.A. subpoena processing
department. The assigned individual who is supposed to be handling the subpoena is Miss Terry Holland,
who is supposed to facilitate the dissemination of information needed as per what is described on the subpoena.
Several phone calls have been placed to her and yet she refuses to respond. Contact has been made
via U.S. Postal mail with a complete description of the items requested and yet they have not been forthcoming and their lack
of cooperation clearly shows an intent to try to cover over either the banks complicity in this matter or to aid the Defendants
in furthering their scheme due to the banks lack of cooperation. When Jason Cobb
began pressing the bank to request records about the account, he was summarily told to close out those accounts, which would
have allowed the bank to be able to seal the records that would have indicated the participation of Mr. Glenn Watson in effectively
removing the authorized names of Jason Cobb and so forth to make way for the Defendants to take over. Defendants
Brede and Donald Showers then sought to file papers with the Secretary of State listing themselves as officers of the Corporation
in an effort to wrest control of the accounts and effectively prevent Jason Cobb from making further inquiry as to the nature
of the account in question. This would allow the bank to not have to reveal who handled (page 41) the account,
who removed the authorized names, namely Jason Cobb and it would also protect the identity of the parties that the Defendants
had worked with to facilitate this takeover. Which would lend credence as to why now even under subpoena Wells Fargo
Bank is not cooperating with the subpoena. Although, if asked it is understood that Miss Terry Holland would state she
was on vacation which would allow the bank time to prevent the Plaintiff's from getting access to these documents to keep
them from being included in the interrogatories that would clearly show fraudulent activity with regard to the account in
question. This network the Defendants
appear to be a part of is vast in that they have used members of their religion in various ways to further their ends.
To do this all one would have to do is use their positions from within the organization to influence someone into doing
something "for the sake of the brotherhood" or in the name of the Watchtower Society. If you
simply say this person is associating with "apostates", (people who appear to not simply accept the teachings of
the Watchtower without question), it is used as a code word that has the effect of automatically turning a person away from
wanting to have anything to do with this person, even if it is a blood relative or relation. It's a term used to
instill fear and compliance as no person within the Jehovah's Witness faith would want to be labeled an apostate, it effectively
would be the same as being treated like a leper, ones spiritual life would be over. People, friends and
association one may have had for years would abruptly end and ironically, it takes no real proof to have
someone labeled an apostate within the Jehovah's Witness Organization. One would merely have to verbally
say whatever party is an apostate and the stigma alone would effectively end a person’s spiritual existence and the
Defendants have used this tool as well as other carefully placed individuals who feel they are working towards keeping the
Watchtower above scrutiny but who really are acting as minions for individuals with an agenda. Please refer to Exhibit
L, you will see it is a copy of an email sent by one Mr. Neil Edwards. On the surface it seems like a friendly
email from someone willing to provide discount tickets to a sporting event, but what is interesting about this email is that
it was sent by Mr. Neil (page 42) Edwards, December 12, 2010. The significance of this date is that the
Defendants had already prepared the fraudulent documents to file with the Secretary of State that they knew would allow them
to takeover the control of the Menlo Park Corporation and the only thing that stood in their way was the rightful officers,
namely Jason Cobb who was CEO of the Menlo Park Corporation. In Exhibit F, Defendant
Brede in an email stated that a person removed from his spiritual duties was also automatically removed from their corporate
duties but this is in point of fact false according to the laws governing California corporations. The
reality is Defendant Brede needed to have Jason Cobb out of the way so that it would not be discovered that the Defendants
would be filing fraudulent papers with the Secretary of State. To do this it was important to know the
whereabouts of Jason Cobb, so enlisting the help of Mr. Neil Edwards he agreed to send this email hoping that Jason Cobb would
respond and give his location. The email was nothing more than a ploy to get Jason Cobb to divulge his
whereabouts so that the Defendants could file the fraudulent paperwork and hope that it would go undiscovered
by Jason Cobb. The Defendants filed their
fraudulent paperwork December 16th, 2010 just a few days after Mr. Neil Edwards made contact via email to Jason Cobb about
this sporting event. Again, the Defendants used confederates either knowingly or unknowingly to achieve
their goal. Motive in this case is important and thus far has proven to be secular and not ecclesiastically
based. Please refer to Exhibit I that in summary states the entire elder body was removed because they
were no longer qualified. However, as previously mentioned in a direct conversation with Defendant Brede,
Mr. Bill Douglas was told by the Defendant himself that the elders removal was in retaliation for Mr. Peter Gallego's
removal from his position. It was also further iterated that the removal of the elders was only aimed at
Jason Cobb and Jonathan D. Cobb Sr. but to prevent any potential ideas that their removal was racially motivated, all the
elders of the Menlo Park Congregation were removed. This is what Defendant Brede has stated.
That being the case then
the letter listed as (page 43) Exhibit J, then would have to be a fraud designed to hide the real motives and intent.
The Defendants acting in a conspiratorial way acted on the orders of Defendant Paul Koehler, directed by Defendant
Allen Shuster to find a way to remove the elders because they were aware that with their previous resistance to suggested
mergers, they would effectively stand in their way of being able to complete a merger. The merger would
then allow the excuse of the remodeling work. Defendant Steve Misterfeld, knowing the issues involved were
not about theocratic things, used his position as then acting "District Overseer", which is a position higher than
Defendant Paul Koehler being a "Circuit Overseer" needed Defendant Misterfeld to concur with his decision to remove
the Plaintiff's and the entire elder body. Defendant Misterfeld used
his position of authority in an effort to legitimize the decision to remove the Plaintiff's and then elders giving the
impression that their removal was about theocratic or ecclesiastical issues, when in point of fact, the issues were secular.
Defendant Misterfeld was a knowing accomplice before and after the fact as he sought to help Defendant Koehler in any
way to affect this hostile takeover, getting any parties out of the way that would be against their interest, even if those
interests were unlawful. This was a systematic pattern of operation that parties within the Watchtower
have used in the past with other congregations. They would first seek out
any parties that would object or stand in their way and they go about finding a way to neutralize them and remove them, claiming
they were no longer qualified to be elders or removing them for some other infraction and then next placing parties in control
who were a part of the network that would work to secure the permits to allow the remodeling work, which ultimately would
give the Watchtower Corporation control of the physical Kingdom Hall or building of worship and also allow them to launder
funds that would normally have been taxed. There is a sense of urgency now for the Watchtower Corporation
as new tax laws will come into effect that will call for more detailed reporting of monies. The tactics used by the
Watchtower Corporation are pure discrimination, they only target congregations that are independently owned and autonomous
in (page 44) nature. This is due to the fact that after the Bonham, Texas case one thing was established
as fact, the Watchtower has no direct jurisdiction over the congregations and Kingdom Halls that are autonomous and independently
owned. The only way they can have control is through the debt of the loan. This is because
the congregation that has the remodeling work done must put the Watchtower Corporation down on their property deed and even
when the loan is paid off the Watchtower Corporation never removes their name from the deed. So they effectively
now own the building. It starts with the forced merger,
but foremost the Watchtower seeks to get any persons out of the way who may object or see the mergers and remodeling work
for what it is, an illusion designed to get control and launder money that should be taxed by the government.
Although the Defendants are but a cog in this money machine, they are nonetheless willing participants of this scheme
which is based upon a certain measure of fraud that must occur to get control of the buildings, the fraud, such as filing
false documents, or false police reports, if discovered would be explained away as issues of polity and religious right, with
the use of the 1st Amendment as a blanket type of immunity from closer scrutiny by any potential governmental or law enforcement
agencies as is what appears to be the case here. It starts with the forced merger,
but foremost the Watchtower seeks to get any persons out of the way who may object or see the mergers and remodeling work
for what it is, an illusion designed to get control and launder money that should be taxed by the government.
Although the Defendants are but a cog in this money machine, they are nonetheless willing participants of this scheme
which is based upon a certain measure of fraud that must occur to get control of the buildings, the fraud, such as filing
false documents, or false police reports, if discovered would be explained away as issues of polity and religious right, with
the use of the 1st Amendment as a blanket type of immunity from closer scrutiny by any potential governmental or law enforcement
agencies as is what appears to be the case here. Aside from that no congregations
that are merged and assimilated into new Kingdom Halls have ever been informed that the Watchtower Corporation never removes
their name from the property deeds, even when the loans are paid back and nor are the parishioners ever informed they are
moving into congregations that carry debt that they will have to also assume as being new members of the congregations.
If these details were revealed it is likely that less congregations would agree to mergers and or remodeling projects
as a whole. Although this case seems on the
surface to be an isolated incident, deeper research shows that it is in fact not an isolated incident and that the Watchtower
Corporation is systematically forcing congregations all over the U.S. to merge, selling off one building that was the previous
parishioners place of worship to force them into crowding into a building in a location farther away, and then of course the
promise of (page 45) remodeling. Please refer to Exhibit M and you will see it is clearly a growing trend
within the Watchtower Corporation, with only the choicest properties being taken over. The Northwest Congregation
in Washington, D.C. which was for sale by Century 21 Real Estate Inc. The asking price being $2,000,000
dollars for this property in this affluent area of Washington, D.C. The Kingdom Hall in Garland,
Texas that was force merged in 2005. The parishioners got an all new Kingdom Hall building, but yet the
deed reflects its under control of a Trustee group which is under the control of the Watchtower Corporation. The
Patriot Ledger, one of the leading newspapers for Massachusetts ran this article in 2009 about the Watchtower Corporation
wanting to sell this particular Kingdom Hall building, a building that was considered a landmark and as such would fetch a
much higher price than other properties of the same type. Up till then there had been a congregation in
existence at this location, 255 Furnace St. in Marshfield, Massachusetts for over 30 years. Then this congregation
was also force merged and relocated to Rockland, Massachusetts to 339 Summer St. There were other congregations
in and around the city area, in Hingham, Plymouth and Stoughton but yet the building on Furnace St. was chosen to sell due
to the intrinsic value it held being a landmark, this would garner more profit in a potential sale. Fort
Thomas, Kentucky, the building at 1960 Memorial Parkway is being sold due to the fact that yet another congregation was force
merged into another location, the remaining empty building is an asset to be profited from through sale, and the parishioners
being merged into a building in a different location were also given a remodeling loan to expand their Kingdom Hall.
The value of the property in Kentucky, is listed at nearly half a million dollars as per the listing. The listing in
Eaton, New York shows a retained value of just a little less than a quarter of a million dollars, but since the Watchtower
Corporation did not originally pay for any of these properties any dollar value obtained
is a clear profit. In all cases parishioners
were force merged into other congregation locations and some type of remodeling work was done to the building with the combined
parishioners. It is obvious by the fact that these locations are in various parts (page 46) of the U.S.
this is a systematic effort. New York, Massachusetts, Kentucky, Washington D.C., Texas and now Menlo Park,
California. In all cases the properties were assessed and any party who would give any type of resistance
was removed. Parishioners were force merged and the new congregational location was remodeled in some way
and all deeds, for the new location reflected a Trustee group that is the Watchtower Corporation. All of these congregations that were sold off or in the process
being sold are congregations that are independently owned and carry no debt to the Watchtower Corporation and basically autonomous
of the Watchtower, the same as the Menlo Park Congregation is. All the Defendants have been either directed
to take the course of action that would result in the takeover or the Menlo Park Congregation or did so of their own volition
and to effect their plan as already stated they used various confederates, highly placed individuals within various positions.
They used their confederates either directly or in advisory capacities. Such as Mr. Donald H. Maynor,
who resides at 235 Catalpa Ave., Menlo Park, California. All of these congregations
that were sold off or in the process being sold are congregations that are independently owned and carry no debt to the Watchtower
Corporation and basically autonomous of the Watchtower, the same as the Menlo Park Congregation is. All
the Defendants have been either directed to take the course of action that would result in the takeover or the Menlo Park
Congregation or did so of their own volition and to effect their plan as already stated they used various confederates, highly
placed individuals within various positions. They used their confederates either directly or in advisory
capacities. Such as Mr. Donald H. Maynor, who resides at 235 Catalpa Ave., Menlo Park, California.
Mr. Donald Maynor is one such
individual who, it is believed, had an advisory role in that he is a lawyer and could easily give them advices and or information
in effecting this takeover. Mr. Donald Maynor is the son of Special Agent Maynor formerly of the FBI whose
assignment was to monitor and place under surveillance the Jehovah's Witnesses as an organization, as they were suspected
of being a religious cult within the Federal Bureau of Investigations. Mr. Maynor's special knowledge
of the law and the inner workings of the religious organization, may have allowed him a logistical advantage of being instrumental
in the progression of this takeover as a particular area of his law practice covers real estate issues. This
party consulted regularly with Defendant Paul Koehler in various private settings. The tactics used by the Watchtower
Corporation are pure discrimination, they only target congregations that are independently owned and autonomous in (page 44)
nature. This is due to the fact that after the Bonham, Texas case one thing was established as fact, the Watchtower
has no direct jurisdiction over the congregations and Kingdom Halls that are autonomous and independently owned. The
only way they can have control is through the debt of the loan. This is because the congregation that has the remodeling
work done must put the Watchtower Corporation down on their property deed and even when the loan is paid off the Watchtower
Corporation never removes their name from the deed. So they effectively now own the building.
It starts with the forced merger, but foremost the Watchtower seeks to get any persons
out of the way who may object or see the mergers and remodeling work for what it is, an illusion designed to get control and
launder money that should be taxed by the government. Although the Defendants are but a cog in this money machine, they
are nonetheless willing participants of this scheme which is based upon a certain measure of fraud that must occur to get
control of the buildings, the fraud, such as filing false documents, or false police reports, if discovered would be explained
away as issues of polity and religious right, with the use of the 1st Amendment as a blanket type of immunity from closer
scrutiny by any potential governmental or law enforcement agencies as is what appears to be the case here. This is but one example that shows
the depth and scope of this situation as it pertains to the case overall. Again, we make mention of Leon
Opolski, who sought to help the Defendants prepare documents and papers to be filed fraudulently, with the Secretary of State
that would allow the Defendants to change the deed thus giving them effective control over the physical building.
Please refer to (page 47) Exhibt E, notice, please the property deed has been changed to reflect the names of Defendants
Ernest Brede and Luis Contreras, who file the fraudulent document dated April 18, 2011. In trying to circumvent
actual laws with regard to California Corporations, they acted recklessly and with wanton regard and when their illegal actions
were brought to their attention Defendant Ernest Brede stated in an email to Jason Cobb, that he believed Jason Cobb had been
removed from his position from within the Congregation and that it automatically terminated his position as an officer in
the Corporation. See Exhibit F. In actuality, Defendant
Brede recognized Jason Cobb's authority as being the rightful CEO of the Corporation as referenced in Exhibit N, which
is an email where Brede is stating that he wishes Jason Cobb to voluntarily turn over documentations and account information.
Truly, if they had a basis to take over, they would not need Jason Cobb to voluntarily turn over the items in question.
Jason Cobb refused to turn them over as he being more familiar with Corporation laws in California knew that the correct
procedures had not been adhered to. In short, the Defendants had no basis or real authority for the records
they were requesting, they, however could have obtained them if they had proper authority and realizing that Jason Cobb was
not going to cooperate sought to obtain the necessary access to the accounts using other means. The fact
is they did not have natural access to the information or accounts as they were not authorized. Defendants all used strong
arm tactics to achieve their end. Even going so far as to make threats, refer to Exhibit O, and see enclosed
an email from Defendant Donald Showers that clearly states if the Defendants do not get what they wanted they would, "address
this issue from another direction". Defendant Showers also goes on to say, that if they are not provided
with what they wanted, account access, it would cause "unnecessary stress and frustration for not only yourself, but
everyone involved". Clearly a threat to Jason Cobb and to possibly those associated with him, such
as family members and anyone else that the Defendants could use to apply pressure to Jason Cobb. Notice also Defendant Showers
tries to invoke religious right in an effort to convince Jason Cobb that what he is doing (page 48) is sanctioned by the Watchtower
Corporation, as if to say if you do not comply you are going against the Organization itself, and it is this tactic that all
the Defendants have continually used to browbeat, threaten, coerce and intimidate persons to cooperate with their scheme either
willingly or unwillingly. It is clear that within the Congregation Jason Cobb and his family have seemingly
been singled out for intimidation tactics. While in attendance at the
Congregation Meeting on Sunday, May 15th, 2011 Defendant Lucas verbally articulated that he or his wife, Jennifer L. Cobb
would not be called upon to convey scriptural thoughts which is a necessary part of the learning process as one of Jehovah's
Witnesses. Thus by doing so Defendant Aaron Lucas has shown himself to be a willing participant in this
ongoing situation. Various others from within the Congregation have acted in such a manner as to belittle,
harass, intimidate or shun Mr. Jason Cobb, even though he is in no way a party to this action but the son of Plaintiff Jonathan
D. Cobb Sr. The only question now is,
is this behavior sanctioned by the Watchtower Corporation president, Don Adams and as the president of the Organization would
he not be aware of any legal issues that arise? If so, does he condone such actions by parties who are
not even named in a legal proceeding? Questions that can only be answered during cross examination of what
correct (page 49) procedures are within the Watchtower Organization. All Defendants have engaged willfully
and willingly in Mafia styled tactics, utilizing fraudulent documents, threats, intimidations, subterfuge and acts of concealment
in the carrying out of their alleged criminal endeavor as part of a large enterprise and scheme. A scheme
being played out all over the United States in various locales and areas. Exhibit I, shows a deposit of
over $150,000 in 2008. This deposit shows intent and motive, the motive being to find any way to take over
the Menlo Park Corporation even as far back as 2008 things were set in motion by the Defendants with this end as being the
chief goal and once done, to effect the remodeling work quickly which is why funds were allocated even BEFORE the Defendants
came to the Menlo Park Congregation. The money came from the
Watchtower Corporation and as a "donation" it is funds that would not be taxed. The remodeling
work was to happen as soon as the takeover was complete and then the money for the remodeling work was already in pay and
would therefore be considered a loan which the newly formed congregation would have to pay back, thus laundering the funds
and allowing the Watchtower Corporation to take over another building. The motive and intent was to take
over the Menlo Park Corporation and then to remodel for the sole secular purpose of laundering the money so as to not report
it to the proper governmental authorities and to have an entire congregation in debt so as to maintain control by the Watchtower
Corporation. To this end, the Defendants had clearly dedicated themselves to this purpose.
They have implored illegal
tactics, and have sought to wrap it all under the umbrella of religious right which easily falls under Religious Fraud.
When one attempts secular things but have labeled them as spiritual things in the effort to gain exemption from the
laws of the land it is clearly Religious Affinity Fraud. Especially in light of Defendant Brede's false
claim from the pulpit that there was only $3500 dollars in the building fund, when in actuality he was fully aware of the
Chase account that was flush with $60,000 dollars that he opened fraudulently using Jason Cobb's credentials, a matter
(page 50) that is now being investigated by the Palo Alto Police. All Defendants have sought
to exact control over the parishioners by continually using verbal expressions such as, "This is what the Society (The
Watchtower) wants." (Statement by Defendant Ernest Brede) As well as, "if
you go against what we are doing, then you are going against the Society" (Statement by Defendant Paul Koehler to parishioners
within the Menlo Park Congregation). Defendant Aaron Lucas has gone on record saying, "We can do this
because we got the letter giving us the authority to take over from the Society (The Watchtower Corporation)".
A letter that one claims
to give authority, even from the highest levels of a religious organization, does not give one the authority to circumvent
the legal process with regard to corporations in California. Or as Defendant Brede said, "Jason Cobb
stole the money we found in the Chase account". When in actuality it was Defendants Brede, Showers
and Contreras who in point of fact, opened the account but yet told several parishioners falsehoods about the issue.
Because a party makes a claim does not necessarily validate that claim as being true. With the
exhibits placed it is clear the Defendants meant to defraud the congregation about the true nature of the accounts, money,
property and merger. It is also clear that this is some systematic plan with a twofold purpose; one being
tax avoidance, if not the outright refusal to disclose the monies involved and ultimately it is about control of all properties
and a direct effort to bring under control all independently owned Kingdom Hall buildings. Due to the intricate nature
of the scheme it shows clear premeditation in that all Defendants as well as confederates knowingly acted in consort with
the clear objective to take over the Menlo Park Congregation and Corporation using whatever means necessary, with no regard
to legal ramifications or actions, in short, to the Defendants, the end justified the means, even if those means were fraudulent.
In the effecting of this scheme various techniques were used, such as the mailing of fraudulent documents through U.S.
Postal mail for the purpose of securing control of the real property. This was done with the initial documents
filed with the Secretary of State were sent via Postal mail, which constitutes Mail and Wire Fraud. The (page 51) statements
made by the various Defendants that were witnessed and heard by parties within the membership of the Menlo Park Congregation
show their intent to conceal. Their using various contacts and confederates in a conspiratorial fashion
show the Defendants motives were conscious decisions that were premeditated and clear criminal intent. Their continued mob
like mentality and negative treatment of those who have sought to expose this situation and bring to light the alleged illegal
activity such as Jason Cobb. The threats and intimidation tactics of Defendant Showers and Lucas show a
continued motive to try to prevent exposure. Finally, the three cases that are in the early stages of investigation
by three separate police agencies all show that there is clear intent, motive and criminal activity by the Defendants, that
make this case purely secular and not in any way ecclesiastical in nature. The copious exhibits show
the Defendants had no regard for law or legal procedures and sought to only gain and achieve their objectives; revenge for
Mr. Peter Gallego's removal of position within the congregation by the Plaintiffs, the removal of Jason Cobb and Jonathan
D. Cobb in such a way as to not raise racial suspicions, the questionable sum of $150,000 dollars that was on deposit possibly
as far as 2008 which goes to motive and intent being to take over Menlo Park and begin some sort of remodeling work to effect
debt and control to the Watchtower Corporation, continued harassment by members of the Menlo Park Congregation towards Jason
Cobb as a way to pressure Plaintiff Jonathan D. Cobb Sr, to quash this action, continual filing of false documents in an effort
to gain control of the corporation unlawfully, a case of identity theft that was effected to open an account that the Defendants
claimed they "discovered" when in fact it was the Defendants who opened this secret account, personal threats made
by Defendant Showers electronically through email which under Homeland Security Laws fall under electronic terroristic threats,
a very serious crime. Defendant Aaron Lucas helping to effect the takeover by being in total support of
his fellow Defendants, Defendants Brede and Luis Contreras filing false documentation giving them authority on paper to change
the property deed for property valued at over $2 million dollars (page 52) which is the basic theft of property,
a network of confederates who sought to track and trace all parties involved so as to commit illegal surveillance on parties
associated with the Plaintiff's. A continued campaign to discredit and slander the Plaintiff's
and parties associated with the Plaintiff's in an effort to isolate them sso as to apply pressure in an effort to force
them to withdraw this action, continued effort to try to find fault with the Plaintiff's to excommunicate them and thus
blacklist them when in fact the Plaintiff's have acted as whistlebowers to report irregularities and wrongdoing to the
powers that be within the Watchtower Society, the Defendants being party to a conspiracy to, with discrimination, malice and
premeditation, effectively wipe out all independently owned Kingdom Halls using fraudulent tactics with regard to the shareholders,
and trying to extort more money from the shareholders in the form of donations for a remodeling project that will be funded
by a loan from the Watchtower Corporation, thus making the shareholders pay twice. A
continued effort to try to conceal the details of this scheme by all Defendants, while trying to derail the cause of actions.
As the circumstances bear out, the Defendants have no regard for the law and the only question that remains is since
these actions are all continuing in furtherance of the scheme, all Defendants are accessories before and after the fact to
the above described activities that appear criminal in nature. Finally, the Plaintiff's had nothing
but glowing reports as far back as 2006. Refer to Exhibit Q and you will see that an inspection report
was made on the Menlo Park Congregation under the management of the Plaintiff's Walter A. St. Clair, Jonathan D. Cobb
Sr and the individuals of George Stock and Jason Cobb.
This appears to be a standard
tactic used in the applying of pressure whenever the Watchtower is embroiled in some type of legal action. Research
has shown a definite pattern of action. First being to accuse the person of being an apostate, or someone
who has questionable beliefs within the Organization that are not totally in line with the standard rhetoric.
Second, is to find a way to remove that person for being an apostate, an excommunication, if you will, which is more
an effort to silence a party who will not conform to the official line. Thirdly, if a party can survive
the aforementioned tactics, next is direct pressure or harassment which takes the form of non-association, where the parishioners
have been instructed that the particular party is not someone to associate with. This renders the offending
party alone and isolated. No friends, no support, and a total cutting off of this person. This
appears to be a standard tactic used in the applying of pressure whenever the Watchtower is embroiled in some type of legal
action. Research has shown a definite pattern of action. First being to accuse the person
of being an apostate, or someone who has questionable beliefs within the Organization that are not totally in line with the
standard rhetoric. Second, is to find a way to remove that person for being an apostate, an excommunication,
if you will, which is more an effort to silence a party who will not conform to the official line. Thirdly,
if a party can survive the aforementioned tactics, next is direct pressure or harassment which takes the form of non-association,
where the parishioners have been instructed that the particular party is not someone to associate with. This
renders the offending party alone and isolated. No friends, no support, and a total cutting off of this
person. The only question now is, is this behavior sanctioned by the Watchtower
Corporation president, Don Adams and as the president of the Organization would he not be aware of any legal issues that arise?
If so, does he condone such actions by parties who are not even named in a legal proceeding? Questions
that can only be answered during cross examination of what correct (page 49) procedures are within the Watchtower Organization.
All Defendants have engaged willfully and willingly in Mafia styled tactics, utilizing fraudulent documents, threats,
intimidations, subterfuge and acts of concealment in the carrying out of their alleged criminal endeavor as part of a large
enterprise and scheme. A scheme being played out all over the United States in various locales and areas.
Exhibit I, shows a deposit of over $150,000 in 2008. This deposit shows intent and motive, the motive
being to find any way to take over the Menlo Park Corporation even as far back as 2008 things were set in motion by the Defendants
with this end as being the chief goal and once done, to effect the remodeling work quickly which is why funds were allocated
even BEFORE the Defendants came to the Menlo Park Congregation. The
money came from the Watchtower Corporation and as a "donation" it is funds that would not be taxed.
The remodeling work was to happen as soon as the takeover was complete and then the money for the remodeling work was
already in pay and would therefore be considered a loan which the newly formed congregation would have to pay back, thus laundering
the funds and allowing the Watchtower Corporation to take over another building. The motive and intent
was to take over the Menlo Park Corporation and then to remodel for the sole secular purpose of laundering the money so as
to not report it to the proper governmental authorities and to have an entire congregation in debt so as to maintain control
by the Watchtower Corporation. To this end, the Defendants had clearly dedicated themselves to this purpose.
They have implored illegal tactics, and have sought to wrap it all under the umbrella
of religious right which easily falls under Religious Fraud. When one attempts secular things but have
labeled them as spiritual things in the effort to gain exemption from the laws of the land it is clearly Religious Affinity
Fraud. Especially in light of Defendant Brede's false claim from the pulpit that there was only $3500 dollars in the building
fund, when in actuality he was fully aware of the Chase account that was flush with $60,000 dollars that he opened fraudulently
using Jason Cobb's credentials, a matter (page 50) that is now being investigated by the Palo Alto Police.
All Defendants have sought to exact control over the parishioners by continually
using verbal expressions such as, "This is what the Society (The Watchtower) wants." (Statement
by Defendant Ernest Brede) As well as, "if you go against what we are doing, then you are going against
the Society" (Statement by Defendant Paul Koehler to parishioners within the Menlo Park Congregation). Defendant
Aaron Lucas has gone on record saying, "We can do this because we got the letter giving us the authority to take over
from the Society (The Watchtower Corporation)". A letter that one claims to give
authority, even from the highest levels of a religious organization, does not give one the authority to circumvent the legal
process with regard to corporations in California. Or as Defendant Brede said, "Jason Cobb stole the
money we found in the Chase account". When in actuality it was Defendants Brede, Showers and Contreras
who in point of fact, opened the account but yet told several parishioners falsehoods about the issue. Because
a party makes a claim does not necessarily validate that claim as being true. With
the exhibits placed it is clear the Defendants meant to defraud the congregation about the true nature of the accounts, money,
property and merger. It is also clear that this is some systematic plan with a twofold purpose; one being
tax avoidance, if not the outright refusal to disclose the monies involved and ultimately it is about control of all properties
and a direct effort to bring under control all independently owned Kingdom Hall buildings. Due
to the intricate nature of the scheme it shows clear premeditation in that all Defendants as well as confederates knowingly
acted in consort with the clear objective to take over the Menlo Park Congregation and Corporation using whatever means necessary,
with no regard to legal ramifications or actions, in short, to the Defendants, the end justified the means, even if those
means were fraudulent. In the effecting of this scheme various techniques were used, such as the mailing
of fraudulent documents through U.S. Postal mail for the purpose of securing control of the real property. This
was done with the initial documents filed with the Secretary of State were sent via Postal mail, which constitutes Mail and
Wire Fraud. The (page 51) statements made by the various Defendants
that were witnessed and heard by parties within the membership of the Menlo Park Congregation show their intent to conceal.
Their using various contacts and confederates in a conspiratorial fashion show the Defendants motives were conscious
decisions that were premeditated and clear criminal intent. Their continued mob like mentality and negative treatment of those
who have sought to expose this situation and bring to light the alleged illegal activity such as Jason Cobb. The
threats and intimidation tactics of Defendant Showers and Lucas show a continued motive to try to prevent exposure.
Finally, the three cases that are in the early stages of investigation by three separate police agencies all show that
there is clear intent, motive and criminal activity by the Defendants, that make this case purely secular and not in any way
ecclesiastical in nature. The copious exhibits show the Defendants had no regard
for law or legal procedures and sought to only gain and achieve their objectives; revenge for Mr. Peter Gallego's removal
of position within the congregation by the Plaintiffs, the removal of Jason Cobb and Jonathan D. Cobb in such a way as to
not raise racial suspicions, the questionable sum of $150,000 dollars that was on deposit possibly as far as 2008 which goes
to motive and intent being to take over Menlo Park and begin some sort of remodeling work to effect debt and control to the
Watchtower Corporation, continued harassment by members of the Menlo Park Congregation towards Jason Cobb as a way to pressure
Plaintiff Jonathan D. Cobb Sr, to quash this action, continual filing of false documents in an effort to gain control of the
corporation unlawfully, a case of identity theft that was effected to open an account that the Defendants claimed they "discovered"
when in fact it was the Defendants who opened this secret account, personal threats made by Defendant Showers electronically
through email which under Homeland Security Laws fall under electronic terroristic threats, a very serious crime.
Defendant Aaron Lucas helping to effect the takeover by being in total support of his fellow Defendants, Defendants
Brede and Luis Contreras filing false documentation giving them authority on paper to change the property deed for property
valued at over $2 million dollars (page 52) which is the basic theft of property, a network of confederates
who sought to track and trace all parties involved so as to commit illegal surveillance on parties associated with the Plaintiff's.
A continued campaign to discredit and slander the Plaintiff's and parties associated with the Plaintiff's in
an effort to isolate them sso as to apply pressure in an effort to force them to withdraw this action, continued effort to
try to find fault with the Plaintiff's to excommunicate them and thus blacklist them when in fact the Plaintiff's
have acted as whistlebowers to report irregularities and wrongdoing to the powers that be within the Watchtower Society, the
Defendants being party to a conspiracy to, with discrimination, malice and premeditation, effectively wipe out all independently
owned Kingdom Halls using fraudulent tactics with regard to the shareholders, and trying to extort more money from the shareholders
in the form of donations for a remodeling project that will be funded by a loan from the Watchtower Corporation, thus making
the shareholders pay twice. A continued effort to try to conceal the details of this
scheme by all Defendants, while trying to derail the cause of actions. As the circumstances bear out, the
Defendants have no regard for the law and the only question that remains is since these actions are all continuing in furtherance
of the scheme, all Defendants are accessories before and after the fact to the above described activities that appear criminal
in nature. Finally, the Plaintiff's had nothing but glowing reports as far back as 2006.
Refer to Exhibit Q and you will see that an inspection report was made on the Menlo Park Congregation under the management
of the Plaintiff's Walter A. St. Clair, Jonathan D. Cobb Sr and the individuals of George Stock and Jason Cobb.
Paragraph
3 of that supplemental report states that the elders were to be commended for their excellent upkeep of the premises.
The attachment also is a financial report that show that the Menlo Park Congregation carried no debt to the Watchtower
Society and in fact had placed money in escrow with the Watchtower as a sort of loan. Meaning, the Watchtower
could use the funds if needed but the Menlo Park Congregation would have it as a backup source of money in the event of emergencies.
All was seemingly well, (page 53) even prior to their arrival to the Menlo Park Congregation the Defendants had worked
at length to lay the groundwork for their takeover.
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