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John T. Reed’s supplement motion to quash Russ Whitney’s subpoena

John T. Reed, pro se
342 Bryan Drive
Alamo, CA 94507
925-820-6292 fax 925-820-1259
johnreed@johntreed.com

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

WHITNEY INFORMATION NETWORK, INC., No. CV 04-0142 MISC MHP (Case #C 03-60693-CIV-MARRA/ SELTZER U.S.D.C., S.D. FL)
Plaintiff, SUPPLEMENT TO EMERGENCY MOTION
v. TO QUASH SUBPOENA
GLENN PURDY, an individual
Defendant.
________________________________/
1. On June 14, 2004 John T. Reed, pro se, (REED) moved this Court (Case # CV 04-0131 MISC MHP) to quash the subpoena ordering him to appear for a deposition on June 18, 2004, in San Francisco, CA in the above Florida case. (Exhibit A)
2. Plaintiff (WIN) withdrew that notice of deposition and served a new subpoena (Case # CV 04 0142-MISC MHP) on REED on July 13, 2004. (Exhibit B). This commanded REED to give a deposition on July 16, 2004 from 10:00 AM to 1:00 PM in San Francisco. WIN subsequently re-noticed that deposition to July 23, 2004 in Walnut Creek, CA (Exhibit C)
3. WIN also filed an opposition to REED's motion to quash. That opposition was not served on REED at the time it was filed. REED did not receive a copy of it until July 14, 2004.
4. REED has made additional attempts to ascertain what relevant information the parties to the lawsuit believe REED possesses. WIN attorney Christina Kitterman again stated that they only know that REED is listed in PURDY's initial disclosures. Those initial disclosures were drawn up by PURDY's original attorney. Since then, PURDY has represented himself in the case, then hired a new law firm. PURDY's new attorneys have refused to speak to REED or return his phone calls except to state that they did not initiate the subpoena.
5. As stated in REED's original motion to quash, these subpoenas are apparently part of a harassment campaign against REED for publicly criticizing WIN and its owner Russell A. Whitney and an attempt to get around the Florida court's limit of seven hours per deposition in WIN's suit against REED in the same court (Case 03-60195-CIV-MARRA/SELTZER).
6. Neither REED nor WIN has any idea why PURDY listed REED in his initial disclosures. PURDY's current attorneys show no interest in taking REED's deposition or communicating with REED in any way.
7. The parties have not “…take[n] reasonable steps to avoid imposing undue burden or expense on a person subject to [a] subpoena…” as required by F.R.C.P. 45(c)(1).
8. WHEREFORE, REED respectfully requests that this Court quash the subpoena commanding REED to give a deposition in WIN v. PURDY in Walnut Creek, CA on July 23, 2004 at 10 AM.
Dated: _______________ _____________________________________ John T. Reed, Pro se
342 Bryan Drive
Alamo, CA 94507 925-820-6292, fax 925-820-1259
johnreed@johntreed.com

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

WHITNEY INFORMATION NETWORK, INC., CV 04-0142 MISC MHP [No. C 03-60693-CIV MARRA/SELTZER (S.D. FL)]
Plaintiff, DECLARATION OF
v. SERVICE
GLENN PURDY, an individual
Defendant.
________________________________/
JOHN T. REED, under penalty of perjury hereby declares:

On July 20, 2004, I served the Proposed Deponent's Motion To Quash Subpoena and Declaration by Federal Express on Scott Rothstein, 300 Las Olas Place, Suite 860, 300 S.E. Second Street, Fort Lauderdale, FL 33301 and Steven Eisenberg, Feldman, Gale, P.A., Miami Center-19th Floor, 201 South Biscayne Boulevard, Miami, FL 33131.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on July 20, 2004

John T. Reed, pro se
342 Bryan Drive
Alamo, CA 94507 925-820-6292, fax 925-820-1259
johnreed@johntreed.com

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

WHITNEY INFORMATION NETWORK, INC., CV 04-0142 MISC MHP [No. C 03-60693-CIV MARRA/SELTZER (S.D. FL)]
Plaintiff, ORDER
v.
GLENN PURDY, an individual
Defendant.
________________________________/
ORDER
On the motion of John T. Reed, pro se for an order pursuant to F.R.C.P. 45(c) to quash the subpoena of Whitney Information Network, Inc. commanding John T. Reed to give a deposition in Walnut Creek, CA on July 23, 2004, and good cause having been shown, therefore,
IT IS ORDERED that the motion be granted and John T. Reed not be required to give a deposition in the Whitney Information Network, Inc. v. Glenn Purdy case (No. 03-60693-CIV-MARRA/SELTZER, U.S. District Court for the Southern District of Florida, Fort Lauderdale Division)
______________ _____________________________________
Date United States District Judge

John T. Reed
Copyright 2004 by John T. Reed
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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.