Informal Discovery Simple Strategies for Cost-Effective Litigation
Allan lee jerome pierce memo
1. To: Lawrence Lee and Jerome Pierce
It is my understanding that you have approached two of my clients involved in a legal action that is
pending. A legal action that is involving various parties that are associated with the local Kingdom Hall
of Jehovah's Witnesses and the Watchtower itself.
I would ask that you refrain from approaching my clients, Walter A. St. Clair and Jonathan D. Cobb. If
however, you cannot refrain, I will obtain a court order in the names of Jerome Pierce, Lawrence Lee
Alan Lee and whoever seeks to make unauthorized contact, either by fax, email, phone, through a third
party, postal letter or any other means meant to circumvent legal and due process. I will also add the
name of Don Adams since, I feel he clearly is orchestrating and or condoning this situation from the
shadows so to speak.
Due to the fact that this is a pending legal action, that being CV12-01372-PSG in the San Jose Northern
California District Federal Court, I would ask that any contact that you may feel needs to be made, be
made through your attorney of record. At this time, I am not clear on who is your attorney if it is Mr.
Rouse or still Mr. Smith, but you need to have them make contact with me prior to any contact being
made with my clients. My number is 650-776-3825.
On Sunday, April 15th, 2012 on or about the hour of 1pm, you approached Mr. Walter St. Clair while he
was in a local establishment, Cafe Zoe's and when he asked how you were aware of his being at Cafe
Zoe's at that time you stated, “we know your routine”. This statement implies that you or parties
associated with you may be stalking Mr. St. Clair and may seek to do him harm. As a courtesy to you
we will not have charges filed for making threats as my client did feel threatened by this contact. We
will however, make a declaration of this action to be filed for the courts. I suggest you make contact
with your attorney and inform him your names will most likely be included in filed court documents.
I wish to also address the issues raised in this encounter at Cafe Zoe's. It is also my understanding that
you have leveled charges against my clients for apostasy and fraud. I find this puzzling in light of the
clear evidence of fraud on the defendants part. Circuit Overseer Paul Kohler has spent the better part of
his career lying to individuals in various congregations stating that he was retired Army personnel and
while in other congregations stated he was a Navy SeeBee and or Navy SEAL when in fact he has
never served in the military at all. Ernest Brede and Donald Showers filed a false police report possibly
with the hope of having Mr. Jason Cobb charged with embezzlement for a bank account at Chase Bank
that Brede and Showers claimed to have no knowledge of only to find out later they in fact opened this
account themselves.
There is also the matter of Donald Showers making a threat to Mr. Jason Cobb and his family via
email, that under the guidelines of Homeland Security statutes is a chargeable offense. There is also the
matter of Mr. Paul Kohler instructing potential witnesses that if called they are to plead the 5th
Amendment and not cooperate with any court proceedings. There is the admission on the witness stand
by Ernest Brede that the rightful officers were never voted out and they were never voted into office
thus making their takeover of Menlo Park illegal as it's a clear violation of Failure to Follow Corporate
Procedure which in a memo by your Watchtower Society it clearly states that corporate procedures and
local laws are to be followed at all times with regard to corporations.
Then there is the matter of Attorney Anthony Smith and his continued intent to have the Plaintiffs
documents and filings suppressed in an effort to sabotage the original filed case. His various outright
2. lies which are too numerous to mention but are on record in the previous filed action, seem to fly in the
face of your teachings. Not to mention the fact that Mr. Smith implied to parties within Chase Bank and
Wells Fargo Bank that they were not to supply certain documents even as so ordered by the court.
It seems clear the Watchtower itself has engaged in efforts to circumvent the legal process in an effort
to try to conceal certain facts, that leads me personally to believe that maybe the Watchtower itself is
complicit in these various illegal activities. Yet, with all of this evidence on record you are only
concerned with my clients. Let's take it a bit further.
There is also the matter of the Watchtower refusing to comply with subpoenas in an effort to suppress
evidence, which under the circumstances is puzzling since no legal action has been levied against the
Watchtower in any way. Ironically, the Watchtower seems to preach that those under the guidance of
the Watchtower are supposed to be in subjection to the superior authorities. However, that only seems
to apply as long as the superior authorities do not have subpoenas for the Watchtower itself.
There seems to be concise evidence of what appears to be money laundering and a scheme to avoid
paying taxes by the Watchtower Society. Something that I am currently in discussions with agents of
the IRS about now.
So I, as well as the public in general, would like clarification of what fraud you are accusing my clients
of in light of these facts. Also I would like an explanation as to why you don't seem to be in a rush to
have Ernest Brede, Donald Showers, Paul Koehler and the rest of the defendants in some meeting or
tribunal. With all the evidence against them it is brutally clear that they should be facing
excommunication.
As per your mention of the charge of apostasy, I don't see how that is possible since my clients have
never been in contact with any excommunicated person, nor have they frequented any of these websites
as they have been accused of doing. I do understand that I have been accused of frequenting such sites
but since I am not one of Jehovah' Witnesses and not in any way part of your faith and belief system
and not baptized in your beliefs, I am free to utilize any resource available to me and I did so, at all
times without my clients knowledge. However, if you are seeking to implicate them in my researching
the Watchtower, you are not seeing the ramifications of what this would mean. Let me be clear.
In making the charge of apostasy, this would be an admission that you or those of your faith have been
making slanderous accusations, remarks or comments about an individual who is not even a part of
your faith. As such it would leave your organization open to legal action for defamation, slander and
libel. To make the charge you would have to admit that you or parties within your religion and
organization have made slanderous remarks against a private person or individual not of your faith. I
have taken the liberty to speak to the other individual who was also slandered by some of your
parishioners and he has conveyed to me his interest in pursuing legal action towards any parties who
have engaged in defamation of character talk along with the Watchtower itself. This would include Don
Adams, since he bares the responsibility of what his underlings do and seems to be condoning this
behavior by so called christians. I am fully aware of the fact that the Watchtower themselves monitor
many of these apostate websites, so it seems to me that accusing my clients of being party to websites
they themselves have never frequented is a bit hypocritical on your part. Everyone is aware the
Watchtower has an entire department devoted to monitoring web activity so the Watchtower is
constantly abreast of what other organizations and or individuals are saying about them. So based upon
your logic, that would mean that the Watchtower itself may be engaging in apostate activities by
frequenting these apostate websites. Would you not agree?
3. Irregardless, this will not stop any pending legal action and would only serve to make your
organization appear a tad bit desperate, if not vindictive, to be slandering parties who are not even part
of your faith and using this as excuse and reason to excommunicate members who only sought to
expose wrongdoing that they discovered. As such, it is obvious that either the Watchtower is grossly
misinformed of the facts and chooses to ignore the facts for their own selfish reasons or the alternative
is that the level of corruption discovered by myself and the Plaintiffs is not relegated to a handful of
individuals within the fold but possibly of the entire upper echelon of the Watchtower organization
itself.
If you wish to excommunicate my clients then by all means do so, it will only serve to be an empty face
saving gesture because the reality is the public at large are aware of the fact that there are certain
individuals within your brethren who are engaging in what strongly appears to be criminal activity.
Excommunicating them will only appear to be a hollow vindictive effort to cover up the involvement of
those listed as defendants. If you are seeking to excommunicate them then please expect to be added as
accessories after the fact. I will begin to prepare the summons for any individuals insisting on levying
these charges against my clients. It is clear that you wish to punish my clients not for any alleged
wrongdoing since it took you nearly two years to come up with fabricated charges that seem believable
but more because of the fact they had the courage to expose certain questionable practices by parties
within your organization. Any hearing you would officiate would be a sham, a total farce, lacking total
credibility.
Please remember that my clients tried on several occasions to contact the Watchtower headquarters but
their pleas, calls and letters fell on deaf ears. Seeing what they thought to be wrongdoing they sought to
excise the cancer that seems to be ever prevalent within your organization. For this they have been
treated like outcasts and pariahs and the only reason I can conclude for this is that, there are individuals
in high positions within the Watchtower branch headquarters who are involved in these schemes to
defraud and avoid taxation or who benefit from them. This is a theory that will be explored in the
pending legal actions.
Sadly, the Watchtower seems more concerned with covering up the wrongdoing rather then addressing
it and as long as that is the case please expect my clients and myself to do all in our power to expose
this alleged criminal behavior. There should never exist a system of double standards for what is taught
to any followers of religion and what is done by those doing the teaching which is patently the case in
this situation.
Further, by excommunicating them you will also force my clients to pursue this matter until the proper
authorities deem it necessary to bring charges against those involved in the alleged criminal activity.
Under the circumstances it will be the only way my clients will be able to exonerate themselves from
the false accusations of apostasy and fraud. I feel once parties involved have been arrested, it will go a
long way to establishing the innocence and credibility of my clients as well as also serve as explanation
to the parishioners about the true nature of their excommunication, should you still wish to pursue that
avenue.
For these reasons my clients will not be participating in any hearing until the pending court action is
resolved. If you wish to proceed in absentia, we will subpoena any documents or notes to use as
evidence of the Watchtower's continued effort to cover and conceal the true nature of the situation. We
will use it to establish motive by the Watchtower in seeking to conceal alleged criminal activity in the
pending RICO statute case.
4. As a final thought, the attorney representing the defendants in the state action during his opening
arguments in Redwood City, California stated that the “Watchtower organization was a hierarchy much
like the Catholic church”. Ironically, in all the research I have done about the Watchtower, your
organization claims to not be a hierarchy. This means that basically those involved in this situation
obviously are willing to say anything to prevent facing the consequences of their alleged criminal
enterprise. This also means that my clients will be railroaded in any hearing you control. It's certain
none of you are interested in the truth but in only making it appear as if my clients will get a fair
hearing, but since its not open to the public and recording is not allowed, those in control of the hearing
can make any claim with no one being able to contradict them. Since it has been established that thus
far a christian is allowed to lie or mislead, it is obvious that none of you can be counted on to be honest
or hold a fair hearing.
Sadly, Mr. Rouse destroyed much of your credibility as being the true religion the minute he compared
you to the Catholic church that day in the courtroom in Redwood City. If you are supposed to be the
true religion then why would you compare yourself to a false religion? With that one statement by Mr.
Rouse you lost a great deal of public credibility and all that was really established is that you will say
or do anything necessary to twist words with a clear motive of trying to absolve yourself of the charges
made by the Plaintiffs. Even if it means delivering them up to be excommunicated on fabricated
charges but yet you call your religion “the truth”. How ironic.....
J. Steele