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Federal magistrate judge orders Russ Whitney to answer John T. Reed questions under oath 2 16. Has there ever been a firearm in your home or vehicle owned by you? If so, please state the dates the firearm was or the firearms were in your home, the type of firearm, the ammunition required for the firearm and the serial number, make, and model of each such firearm. 17. Please state if any female has complained that you behaved inappropriately toward her in the last ten years in the United States or any other country. If so, please identify the complainer, the nature of her complaint, the location, and the date of the complaint. 18. Please identify the person referred to as "Satan" in the book Overcoming the Hurdles & Pitfalls of Real Estate Investing written by you 19. Have you or any of your agents or attorneys ever posted any statement about Defendant at a Web site not owned by you or any of your agents, or companies? If so, where and when was it posted, what name or handle was given as the author of the statement and what did it say? 20. Have you or any of your agents or attorneys ever posted any statement about Russ Whitney or one or more of his products or services at a Web site not owned by you or any of your agents, or companies? If so, where and when was it posted, what name or handle was given as the author of the statement and what did it say? 21. Please identify all of the children you have fathered including their dates of birth, mother's name, who had custody of the child prior to it turning 18 or graduating from college, and what child support you paid for any child for whom you were not the custodial parent. 22. Please identify the person who called Defendant's telephone answering machine on January 10, 2003 around 10:27 AM Eastern Standard Time threatening to "turn the heat up on" Defendant. Please include the name, address, an telephone number of the person in question, his or her relationship to you, and whether the call was made at your direction. 23. A person who said his or her name was Lani Timbers has posted derogatory information about Defendant on the World Wide Web and has sent Defendant a friendly email seeking

information from him. Please identify the person or persons who posted those remarks and sent that email including name, address, telephone number, your relationship to that person or those persons, and whether these actions were done at your direction. 24. What schools did you attend prior to entering prison? Please include the name, city, and state where the school was located and the dates you attended each. 25. Please state where you lived between when you ran away from your stepmother and when you entered prison. Please include the property owners, street addresses, cities, states, names of your roommates, and the dates when you lived at each place. And here are the interrogatories served on Whitney Information Network, Inc.: UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA FORT MYERS DIVISION WHITNEY INFORMATION NETWORK, INC. and RUSS WHITNEY, an individual, Plaintiffs, Case No. 2:04-cv-00395-33DNF (LAG) v. JOHN T. REED, an individual, Defendant. _____________________________________/ DEFENDANTS' FIRST SET OF INTERROGATORIES TO PLAINTIFF WHITNEY INFORMATION NETWORK, INC. Defendant JOHN T. REED pursuant to Fed. R. Civ. P. Rule 33 and Local Rule 3.03, U.S. Dist. Ct. Rules M.D. Fla., request that Plaintiff, WHITNEY INFORMATION NETWORK, INC., answer each of the following interrogatories separately and fully, in writing, under oath, within thirty (30) days after service of this request. INTERROGATORIES TO PLAINTIFF WHITNEY INFORMATION NETWORK, INC. (WIN) 1. Please state whether any person named Whitney has ever used a credit card to pay WIN bills and been reimbursed by WIN and permitted to receive awards of points or miles or any other credit that the person in question could redeem for personal benefit. If so, please identify the person(s) in question, state the amount of such transactions and benefits awarded to the individual, and the dates when these transactions occurred. 2. Please state if Russ Whitney or his agents or companies other than WIN profit from sales of real estate to persons attending seminars promoted by WIN. If so, please state how WIN has been compensated by Russ Whitney or his agents or companies for the role it played in those real estate sales. 3. Please state the drug testing policies of WIN during the last ten years. This question includes but is not limited to, who is tested and who, if anyone, is exempt from such testing, for what substances are they tested, when are they tested, and do the persons being tested know in advance when they will be tested? 4. Please state all payments in any form or transfers of anything of value, including but not limited to compensation, debt relief, reimbursement, made by WIN to Russell A. Whitney, his relatives, agents, or companies other than WIN in the last five years, including the amount and date, the payee or recipient, and what it was for. 5. Please state when WIN or any of its affiliates began to sell products and/or services in Canada and the first date on which WIN or any of its affiliates paid sales or service tax to the Canadian Revenue authorities, the amount of such payment and the time period it covered. 6. Has WIN or any of its affiliates or agents or employees ever employed, retained, hired, suggested, encouraged, required, or otherwise directed any persons, including not-yet-affiliated prospective independent contractors or prospective employees to attend its seminars and while doing so, given testimonials at such seminars, eavesdropped on other students, offered to join with another student to share the cost of the seminar, or otherwise attempted to influence a prospective student to sign up for a service without disclosing their affiliation or hoped-for affiliation with WIN or any of its affiliates, subsidiaries or agents or employees? If so, please describe the job description at such seminar and the compensation, if any, of such person for attending that seminar and performing those tasks. 7. Please state the number of people who have paid the lowest available per-person price for the initial three-day real estate seminars of WIN or any of its affiliates and the number who paid higher prices as a result of not signing up fast enough in the last five years. Please break this down into the number who paid each different price. 8. Please state whether any associate of WIN or any of its affiliates or agents or employees has ever posted statements on Web sites not owned or controlled by WIN or WHITNEY or sent emails about Russ Whitney or his agents, or companies or WIN or any of its subsidiaries, affiliates or agents or employees without disclosing the poster's or sender's affiliation with WHITNEY or WIN or any of its subsidiaries, affiliates, or agents or employees. If so, what did they post where and when or what did they send to whom and when? 9. Please state whether any associate of WIN or any of its affiliates, subsidiaries or agents or employees has ever been directed to post statements or send emails about John T. Reed or any competitor of RUSS WHITNEY or his agents, or companies or WIN or any of its affiliates, subsidiaries, or agents or employees on Web sites not owned or controlled by WIN or WHITNEY without disclosing their affiliation with WHITNEY or WIN or any of its subsidiaries or agents or employees. If so, what did they post where and when or what did they send to whom and when? 10. Were any persons or entities unrelated to any of the parties to this litigation contacted by WIN by or any of its affiliates, subsidiaries, attorneys, agents, or employees with regard to the person's or entity's relationship with Defendant including, but not limited to, any communication containing the phrase "cease and desist" or "govern yourself accordingly" or any sentence, paragraph or phrase the says or implies that the recipient or Defendant may be violating any law? If so, please list the names, addresses and phone numbers of the persons or entities so contacted, the dates when they were contacted, who contacted them, and what was said. 11. Please identify the owners of the customer lists of persons who have purchased products or services from WIN or any of its affiliates, subsidiaries or agents or employees. 12. Please identify the Florida metropolitan areas in which WIN or any of its affiliates, subsidiaries, or agents or employees has not broadcast television infomercials encouraging persons to attend your free real estate investment training and/or Florida metropolitan areas where you have not held such free real estate investment training sessions in the last five years. 13. Please list the local, county, state, or federal government agencies or other government entities or employees or private organizations that have directed WIN or any of its affiliates, subsidiaries or agents or employees to stop doing anything or which have initiated any official action against or inquiries to WIN or any of its affiliates, subsidiaries or agents or employees including, but not limited to, cease-and-desist orders, administrative actions, or civil lawsuits or criminal prosecutions. 14. Please state whether WIN or any of its affiliates, subsidiaries or agents or employees including, but not limited to, Russell A. Whitney, Ronald Simon, or John Kane, has ever taken steps to increase the stock price and/or trading volume of WIN shares, including but not limited to, buying such shares or directing others to buy them, urging WIN's or any of its affiliates, subsidiaries' agents or employees to buy such stock, directing WIN instructors or speakers to urge attendees at training sessions to buy such stock, or urging attendees at such gatherings as the annual Orlando meeting to buy such stock. If so, please state when, where, and how this was done and by whom. 15. Has there ever not been an exterior sign on the WIN headquarters building that identified it as occupied by an organization with the word Whitney in its name? If so, when was there no such sign on the building? 16. Has WIN or any of its affiliates, subsidiaries, agents, or employees ever had a policy, contract, or agreement with regard to communication with Defendant by current or former agents or employees? If so, what was or is that policy, contract clause, or agreement clause? 17. Has WIN or any of its affiliates, subsidiaries, agents, or employees ever invited or permitted persons other than WIN agents, or employees to invest in or provide money for the promotion of seminars by WIN or any of its subsidiaries, agents, or employees? If so, when and where was this done, how many persons invested how much money, and which agent or employee of WIN invited or permitted such investment? 18. Was Brian C. Seltz who was born on 9/28/77, ever associated with WIN or any of its subsidiaries, agents or employees? If so, when, what were his job descriptions, and what were the circumstances of his ending his association with WIN or any of its subsidiaries, agents, or employees? 19. Have any employees of WIN or any of its affiliates or subsidiaries ever performed personal service for Russell A. Whitney or any of his relatives, including, but not limited to, working on buildings that are not owned by WIN, performing legal work on matters other than WIN business? If so, which employees did what when? 20. Page 14 of WIN's 2003 annual report says, "The revenue is recognized (earned) when the student attends the training program or at the expiration of our obligation to provide training, whichever comes first." Please state how many persons who had paid WIN or any of its affiliates or subsidiaries for WIN training have allowed WIN's obligation to provide that training to expire unused in the last five years and how much money those students paid for the training they did not attend. 21. Please identify any entity, including its name, address, and phone number, that has provided fidelity insurance or a bond to WIN or any of its affiliates, subsidiaries, agents or employees. 22. In a 5/13/04 affidavit in support of Plaintiffs' motion for a preliminary injunction, Plaintiff Russ Whitney said, "As recently as last week, an investor group refused to do business with us based upon the information contained on Reed's website." Please identify the members of that group, including their names and addresses and phone numbers, and the nature of the business they were going to do with WIN or any of its affiliates, subsidiaries, agents or employees before they changed their minds. 23. In a 5/13/04 affidavit in support of Plaintiffs' motion for a preliminary injunction, Plaintiff Russ Whitney said that WIN has lost customers, potential customers, employees, potential employees, potential investors and paid refunds as a direct result of Defendant's Web site discussions of Plaintiffs. For the last five years, please identify the persons in question by category, including their names, addresses, and phone numbers, and the amount of refunds paid by WIN or any of its affiliates, subsidiaries, agents or employees to persons you claim demanded refunds as a direct result of Defendant's Web site. 24. Please state whether WIN or any of its employees, agents, independent contractors, prospective independent contractors, subsidiaries or affiliates urges residents of Nevada to purchase the MPAP program or course, whether WIN or any of its subsidiaries or affiliates has been willing to process MPAP transactions involving properties in that state. 25. Please state whether WIN or any of its employees, agents, independent contractors, prospective independent contractors, subsidiaries or affiliates has urged attendees at its training sessions to incorporate in Nevada and if so, when were they so urged, what benefits were the attendees told they would get from incorporating in Nevada, how many attendees decided to do that, and how much money did WIN make as a result during 2003, 2004, and 2005. Copyright 2005 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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George replied the topic: #12318
Russ Whitney should be taken out on a dirt road, along with his family, and shot like the rabid animals they are!!!!
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