On August 18, 2021 a
GENERAL CORRESPONDENCE submitted by KORGUL, MARGARET, T of MARKORLAW LLC on behalf of FAIRLAWN CONGREGATION OF JEHOVAHS WITNESSES against CORINNE PANDELO
was filed
involving a dispute between
Corinne Pandelo,
and
-100 John And Jane Does 1,
Fairlawn Congregation Of Jehov,
Hackensack Congregation Of Jeh,
The Governing Body Of Jehovahs,
Watchtower Bible Andtract Soc,
for Personal Injury
in the District Court of Bergen County.
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BER-L-005508-21 12/21/2023 1:33:44 PM Pg 1 of 1 Trans ID: LCV20233690622
Margaret T. Korgul, Esq.
One Bridge Plaza North
Suite 275 Fort Lee, NJ 07024
M (973) 986-0372
mkorgul@markorlaw.com | www.markorlaw.com
December 21, 2023
VIA FIRST CLASS MAIL AND E-COURTS
Hon. Gregg A. Padovano, J.S.C.
Bergen County Superior Court
10 Main Street
Hackensack, NJ 07601
Re: Pandelo v. The Governing Body of Jehovah’s Witnesses, et al., Docket No.: BER-L-005508-21
Dear Judge Padovano:
I represent Defendant Fairlawn Congregation of Jehovah’s Witnesses (the “Congregation” or “Defendant”) in
the above matter. Pursuant to the December 11, 2023 Order I enclose Congregation’s documents partially
withheld on the basis of clergy-penitent privilege for in camera review along with the privilege log.
As discussed in my opposition to Plaintiff’s Motion to Compel, Defendant completely withheld one (1) one
(1) page handwritten document; undated; authored by Tino Pandelo which was submitted to the Elders of
the Congregation and included a plea for reinstatement. This communication was made in confidence to
clerics in their professional character or role as spiritual advisers. State v. J.G., 201 N.J. 369 (2010). The letter
was specifically directed to the Elders of the Congregation and was indicative of a reasonable expectation of
confidentiality. The letter was not revealed to anyone outside the Body of Elders and was supposed to be
kept in confidence.
The second document called Record of Disfellowshipping or Disassociation was produced with a redaction
reflecting confession made by Clement Pandelo in confidence to clerics in their professional role as spiritual
advisors. I also enclose a redacted document as produced to Plaintiff for Court’s reference.
Respectfully submitted,
Margaret T. Korgul
Margaret T. Korgul, Esq.
cc: All Counsel of Record via ecourts
(without enclosures)
Document Filed Date
December 21, 2023
Case Filing Date
August 18, 2021
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BER-L-005508-21 12/21/2023 1:33:44 PM Pg 1 of 1 Trans ID: LCV20233690622 Margaret T. Korgul, Esq. One Bridge Plaza North Suite 275 Fort Lee, NJ 07024 M (973) 986-0372 mkorgul@markorlaw.com | www.markorlaw.com December 21, 2023 VIA FIRST CLASS MAIL AND E-COURTS Hon. Gregg A. Padovano, J.S.C. Bergen County Superior Court 10 Main Street Hackensack, NJ 07601 Re: Pandelo v. The Governing Body of Jehovah’s Witnesses, et al., Docket No.: BER-L-005508-21 Dear Judge Padovano: I represent Defendant Fairlawn Congregation of Jehovah’s Witnesses (the “Congregation” or “Defendant”) in the above matter. Pursuant to the December 11, 2023 Order I enclose Congregation’s documents partially withheld on the basis of clergy-penitent privilege for in camera review along with the privilege log. As discussed in my opposition to Plaintiff’s Motion to Compel, Defendant completely withheld one (1) one (1) page handwritten document; undated; authored by Tino Pandelo which was submitted to the Elders of the Congregation and included a plea for reinstatement. This communication was made in confidence to clerics in their professional character or role as spiritual advisers. State v. J.G., 201 N.J. 369 (2010). The letter was specifically directed to the Elders of the Congregation and was indicative of a reasonable expectation of confidentiality. The letter was not revealed to anyone outside the Body of Elders and was supposed to be kept in confidence. The second document called Record of Disfellowshipping or Disassociation was produced with a redaction reflecting confession made by Clement Pandelo in confidence to clerics in their professional role as spiritual advisors. I also enclose a redacted document as produced to Plaintiff for Court’s reference. Respectfully submitted, Margaret T. Korgul Margaret T. Korgul, Esq. cc: All Counsel of Record via ecourts (without enclosures)