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Whitney Information Network, Inc. files fourth lawsuit against John T. Reed On July 30, 2004, WIN filed a fourth lawsuit against John T. Reed. The suit is Whitney Information Network, Inc. vs. Robert Yates and John T. Reed Case # 04-CA-003045 and is in the 20th Judicial Circuit Court in Lee County, Florida. The court is actually located in Fort Myers, same as the location of the federal suits against me. The assigned judge is William C. McIver. I would appreciate it if someone would tell me who Robert Yates is. In May, 2004, I got a series of emails signed Rob Yates or Robert Yates. He said he had been Whitney' paralegal, no longer worked there, and wanted to write a book about the Whitney-Reed litigation. I said I thought this was a Whitney trick and refused to grant his request for an interview. Here are the emails he sent me and my answers to them. Whitney Information Network, Inc. says in their suit that I tortiously interfered with their business relationship with Robert Yates and that I violated the Florida Uniform Trade Secrets Act by getting some unspecified Whitney trade secret from Yates. That' bull, as you can see from reading the emails between Yates and me. For all I know,

Yates is Russ Whitney. If not, I suspect that Yates is working in cahoots with Whitney and only pretending to be my co-defendant. Why? In 2002, Whitney tried to file a similar state court suit. He sued me in state court in Fort Lauderdale (17th Judicial Circuit Court)"”the city of his attorney. The prior litigation was in federal court in Fort Myers. I immediately removed the state court to federal court in Fort Lauderdale. You can read the notice of removal here. By now suing me with another defendant who is a Florida resident"”Yates"”Whitney prevents me from removing the case to federal court. Why? It' just a procedural rule. When I am the only defendant, there is what the federal courts call "diversity" because the plaintiff and defendant live in different states. When the parties live in different states, and the amount in dispute is $75,000 or more, the case can be moved to federal court by the defendant. But if one defendant (like Yates) lives in the same state as the plaintiff (Whitney), there is no diversity and you cannot remove the case to federal court. Could Whitney have sued me about Yates in federal court? Yes. He did not need to link me with Yates or even sue Yates at all. Why would Whitney want cases involving the same parties in two different courts in the same city? I cannot say for sure, but most likely because he thinks it will jerk me around more than just adding another cause of action to his federal complaint. If you have any information that might help me in this new lawsuit, please let me know. Copyright 2004 by John T. Reed John T. Reed, a.k.a. John Reed, Jack Reed, 342 Bryan Drive, Alamo, CA 94507, Voice: 925-820-7262, Fax: 925-820-1259, www.johntreed.com

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