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What documents should John T. Reed demand that Russ Whitney and his companies produce?

One of the reasons guys like Russ Whitney should not sue me or anyone else for libel is that by suing he gives us subpoena power and the power to demand that he produce documents, answer written questions, and give deposition testimony. This article asks readers—especially former associates of Russ Whitney—for advice on what documents I should demand that he and his companies produce.
Rule 34 of the Federal Rules of Civil Procedure says,
(34) Scope. Any party may serve on any other party a request (1) to produce and permit the party making the request…to inspect and copy any designated documents (including writings, drawings, graphs, charts, photographs, phonorecords, and other data compilations from which data can be obtained…)
Basically, I am allowed to demand any documents, audio or video tapes, CDs, etc. that is
“…relevant to the claim or defense of any party…”
The parties would be me, Russ Whitney, and Whitney Information Network, Inc.
You can see my defenses in my Answer to the Complaint.
Basically, my defense would be helped by proving that Whitney:
• has a lousy reputation
• has broken the law
•
The basic issues in Whitney’s complaint against me are:
• whether Whitney has a “good name, reputation, credit, and standing in the business community”
• whether Whitney and/or Whitney Information Network, Inc. make threats
• whether Whitney and/or Whitney Information Network, Inc. uses coercion
• whether Whitney and/or Whitney Information Network, Inc. have engaged in scams
• whether Whitney as broken any laws
• whether my mention of Whitney’s name at my Web site is likely to cause readers of the Web site to be confused into thinking that my Web site is actually his Web site
Copyright 2003 by John T. Reed
Last update 4/10/03
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John T. Reed, a.k.a. John Reed, Jack Reed, 342 Bryan Drive, Alamo, CA 94507, Voice: 925-820-7262, Fax: 925-820-1259, Email: johnreed@johntreed.com

CONSUMER WARNING NOTICE: I recently saw Russ Whitney on a late night TV infomercial and then attended one of his "free" seminars. Unfortunately I believed all of their LIES and FRAUDULENT CLAIMS and I paid thousands of dollars to go to his "training camps". Needless to say I was clearly ripped off, cheated and lied to by Russ Whitney and his employees (band of thieves). My mistake was not searching the Internet to find out more about Russ Whitney and his company's HORRIBLE reputation for fraud, deception and illegal activities. Had I searched online I would have found out about THOUSANDS of customers being cheated, HUNDREDS of investigations by the Attorney General into the fraud of Russ Whitney and his company's, and that Russ Whitney himself is a CONVICTED VIOLENT FELON and spent years in PRISON. I saved the cached pages from the major search engines of the John Reed lawsuit with Russell Whitney and the TRUTH and FACTS that Reed discovered during his investigation of Whitney. I am posting this information on real estate discussion boards so other people do NOT get cheated and ripped off like I did.