AWN California, to any law enforcement agency, including, but not limited to, a police department, associational right to privacy incorporated into the Fourteenth Amendment of the United States Constitution arid its California analog. (See National Ass?n for Advancement of Colored People v. State of Alobama, 357- US. 449 (1953); Planned Parenthood Golden Gate Superior Court, 83 Ca1.App.4th 347 (2000); Special luterrogatorvr No. 7 improperly seeks information that. is related to the religious beliefs, faith, custom, practices and internal governance or discipline of Jehovah?s Witnesses because the First Amendment of the United States Constitution and its California analog bar civil courts from evaluating or interpreting such retigious evidence in order to reach a decision. (See Serbian Eastern Orthodox Diocese v. Millvojevich (1976) 426 US 696.). SPECIAL INTERROGATORY N0. 3: Since January 1, 1997, has YOUR Service Department reported any incident of known OR suspected childhood sexual abuse which occurred, OR is suspected to have occurred, in sheriff?s department, county probation department, 0R government child protection agency, including, but not limited to, child protective services OR county We] fare department? RESPONSE TO SPECIAL INTERROGATORY NO. 8: Objection. Special Interrogatory No. 3 is vague, ambiguous, compound, and unintelligible as to the terms Service Department? and ?known OR suspected childhood sexual abuse?; Special Interrogatory No. 8 seeks information prepared in anticipation of litigation, infonnation that constitutes attorney?s work product or constitutes attomey-CIient' communication, and therefore is privileged and protected from disclosure; Special hrterrogatory No. 8 is vague, ainbiguous and overbroad as to time and scope; l2 unq? DEFENDANT WATCHTOWER BIBLE AND TRACT SOCIETY OF NEW YORK, INC. '3 RESPONSE TO PLAINTIFF OSBALDO SPECIAL INTERROGATORIES, SET ONE .N Ix) 1- I?LAI Special Interrogatory No. 8 seeks information that is irrelevant to the subject matter of this litigation and which is not reasonably calculated to the discovery of admissible evidence; Special Interrogatory No. 8 seeks information speci?cally protected from discovery by. thelclergy-penitent privilege under Evidence Code sections 1033 and 1034; (E) Special Interrogatory No. 8 seeks information that would violate the rights of privacy of persons who are not parties to this litigation including without limitation the associations] right to privacy incorporated into the Fourteenth Amendment of the United States Constitution and its California analog. (See Notional Ass?n for Advancement of Colored :People v. State ofAIobaino (1958) 357 U.S. 449; Planned Parenthood Golden Gate v. Superior Court (2000) 83 Cal.App.4th 347.); Special Interrogatory No. 8 improperly seeks information that is related to the religious beliefs, faith, custom, practices and internal governance or discipline of Jehovah's Witnesses because the First Amendment of the United States Constitution and its California analog bar civil courts from evaluating or interpreting such religious evidence in order to reach a decision. (See Serbian Eastern Orthodox Diocese v. Mili'vojevich (1976) 426 US. 696.); Special Interrogatory No. 8 improperly seeks to establish the existence of a non- existent duty to report by elders residing in the State of New York; Special Interrogatory No. 3 assumes facts not in evidence and incorrectly and improperly assumes and implies that elders in the Service Department of the United States Branch Of?ce of ehovah?s Witnesses in New Yorlc had a duty to report such information to secular authorities. 1 Without waiving and subject to the Preliminary Statement and General Objections and speci?c objections, Responding Defendant responds as follows: A This Responding Defendant objects to the use of the term Service Departmen Responding Defendant does not have a ?Service Department.? However, to the 13 DEFENDANT WATCHTOWER BIBLE AND TRACT SOCIETY OF NEW YORK, RESPONSE TO PLAINTIFF OSBALDO SPECIAL SET ONE 3ft acumen-nutsextent the Service Department of the United States Branch Of?ce of Jehovah?s Witnesses communicated through Responding Defendant, Responding Defendant provides the following Response: No. A I SPECIAL N0. 9: if YOUR response to Special interrogatOry number 8 is yes, DESCRIBE the circumstances surrounding each such report. RESPONSE TO SPECIAL INTERRO GATORY N0. 9: Objection. Special lnterrogatory No. 9 seeks information prepared in anticipation of litigation, infomatiort that constitutes attorney?s work product or constitutes attorney-client communication, and therefore is privileged and protected from diselosum; Special Interrogatory No. 9 is vague, ambiguous and overbroad as to time and scope; Special Interrogatory No. 9 seeks information that is irrelevant to the subject matter of this litigation and which is not reasonably calculated to the discovery of admissible evidence; . i Special Interrogatory No. 9 seeks information speci?cally protected from discovery by the cierg?z-penitent privilege under Evidence Code sections 1033 and 1034; Special Interrogatory No. 9 seeks information that would violate the rights of . privacy of persons who are not parties to this litigation including without limitation the associational right to privacy incorporated into the Fourteenth Amendment of the United States Constitution and its California analog. (See Nattonoi Ass?n for Advancement of Colored People v. State ofAfabamo (1958) 357 US. 449; Planned Parenthood Golden Gate v. Superior 091010000) 33 Ca1.App.4th 341); i (E) Special Interrc'igatorir No. 9 improperly seeks information that is related to the religious beliefs, faith, custom, practices and internal governance or discipline of Jehovah?s 14 DEFENDANT WATCHTOWER BIBLE AND TRACT SOCIETY OF NEW YORK, INCRS RESPONSE TO PLAINTIFF OSBALDO SPECIAL SET ONE 3 5 . .. somaamm-bmmw Witnesses because the First Amendment of the United States Constitution and its California analog bar civil courts from evaluating or interpreting such religious evidence in order to reach a decision. (See Serbian Eastern Orthodox Diocese v. Mih?vojevich (1976) 426 US. 696.); Special. Interrogatory No. 9 improperly seeks to establish the existence of a non-- existent duty to report by elders residing in the State ofNew York; Special Interrogatory No. 9 assumes facts not in evidence and incorrectly and impmperly assumes and implies that elders in the Service Department of the United States Branch Of?ce of Jehovah?s Witnesses in New York had a duty to report such information to secular authorities. Without waiving and subject to the Preliminary Statement and General Objections and speci?c objections, ReSponding Defendant responds as follows: Not applicable. . INTERROGATORY no. 10: Since January I, 199?, has YOUR Legal Department reported any incident of known OR suspected childhood sexual abuse which occurred, OR is suSpected to have occurred, in California, to any law enforcement agency, including, but not limited to, a police department, sheriff?s department, county probation department, OR government child protection agency . including, but not limited to, child protection services OR county welfare department? RESPONSE TO SPECIAL INTERROGAT ORY N0. 10: Objection. Special Interrogatory No. 10 is vague, ambiguous, compound, and unintelligible as to the term ?knownOR suspected childhood sexual abuse?; A Special Interrogatory No. 10 seeks information prepared in anticipation of litigation, information that constitutes attorney?s work product or constitutes attorney-client communication, and therefore is privileged and protected from disclosure; 15 DEFENDANT WATCHTOWER BIBLE AND TRACT SOCIETY OF NEW YORK, INC. ?8 RESPONSETO OSBALDO SPECIAL INTERROGATORIES, SET ONE 15 SPECIAL INTERROGATORY NO. 11: - - Special lnterrogatory No. 10 is vague, ambiguous and overbroad as to time and scope; Special lntenogatory No. 10 sacks information that is irrelevant to the subject matter of this. litigation and which is not reasonably calculated to the discovery of admissible evidence; Special. Interrogatory No. 10 seeks information that would violate the rights of privacy of persons who are not parties to this litigation including without limitation the associational right to privacy incorporated into the Fourteenth Amendment of the United States Constitution and its California analog. (See Notional Ass?n for Advancement of Colored People v. StatalofAlobamo (1958) 357 US. 449; Planned Parenthdod Golden Gate v. Superior Court (ZOOM-83 CaJ.App.4th 347.); Special Interrogatory No. 10 improperly seeks to establish the exisience of a non- existent duty to report; I Special Interrogatory No._ l0 assumes facts not in evidence and incorrectly and improperly assumes and implies that Responding Defendant?s Legal Departinent in New York had a duty to report such information to secular authorities. Without waiving and subject to the Preliminary Statement and General Objections and speci?c objections, Responding Defendant responds as follows: No. If YOUR response to special interrogatory number 10 is yes, DESCRIBE the circumstances surrounding each such report. RESPONSE TO SPECIAL INTERROGATORY N0. 11: Special lnterrogatory No. 11 seeks information prepared in anticipation of litigation, information that constitutes attorney?s work product or constitutes attorney-client communication, and therefore is privileged and protected from disclosure; - 16 DEFENDANT WATCHTO WER BIBLE AND TRACT SOCIETY OF NEW YORK, RESPONSE TO PLAINTIFF OSBALDO SPECIAL INTERROGATORIES, SET ONE 5 ?uh?h?m ., "and