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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' 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' 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 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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