To avoid a massive transfer
of real estate assets worth, at present, approximately $1 Billion, from
Watchtower to another corporate entity of Jehovah’s Witnesses, which
would leave Plaintiff with no enforcement right for the Judgment,
Plaintiff requests that any stay be subject to the condition that
defendant Watchtower Bible and Tract Society of New York, Inc. not
transfer, convey, or change title to any of its real property prior to the filing of a bond or undertaking required as a condition of appeal.
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