­

Federal magistrate judge orders Russ Whitney to answer John T. Reed questions under oath 1 There comes a time in all lawsuits when the parties have to answer each other' questions under oath. That time has come in Russ Whitney' four suits against John T. Reed after three years of litigation. 50 questions to Whitney and his corporation In federal court, each party is permitted to ask the other 25 interrogatories (written questions that must be answered under oath). In Whitney' litigation against John T. Reed, there are two plaintiffs"”Russ Whitney and Whitney Information Network, Inc. Reed seved 25 interrogatories on each plaintiff. Whitney tried to avoid answering Whitney filed a motion for a protective order. That motion would, if granted, prevent Whitney from having to answer any of Reed' questions. Reed filed an opposition to that order explaining why Whitney and his corporation should be required to answer all of the interrogatories. Court' decision On May 23, 2005, the federal magistrate judge decided the issue. He ordered Whitney and Whitney Information Network, Inc. to answer Reed' interrogatories, including 15 that they explicitly complained about. If you know the answers to any of these interrogatories or know where Reed can find the answers, please tell him. Reed is not sure Whitney will answer these questions even though there is now a court order. He may drop the suit to avoid answering. He may give Reed non-answers or evasive answers that necessitate another round of motions and court orders. He may file some other legal papers to try to avoid answering. Time will tell. Here are the 25 interrogatories Reed served on Russ Whitney. The ones in bold are the ones Whitney specifically objected to. He objected to answering all of them but specifically cited those in bold. 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-DNF (LAG) v. JOHN T. REED, an individual, Defendant. _____________________________________/ DEFENDANTS' FIRST SET OF INTERROGATORIES TO PLAINTIFF RUSS WHITNEY 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., requests that Plaintiff, RUSS WHITNEY, 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 RUSS WHITNEY 1. Please state whether you have ever killed anyone. If so, please state whom you killed and when, where, why, and how you killed them. 2. Please state if you are or have ever been divorced or are now in the process of becoming divorced, the date of your divorce(s) and the name(s) of your spouse or spouses from whom you were divorced or are getting divorced. 3. Have you ever been convicted of a crime was punishable by death or imprisonment in excess of one (1) year, or that involved dishonesty or a false statement regardless of the punishment? If so, state as to each conviction, the specific crime, and the date and place of conviction. 4. List the names and addresses of all persons who are believed or known by you, your agents or attorneys to have any knowledge concerning any of the issues raised by the pleadings in this case and specify the subject matter about which the witness has knowledge. 5. Please state whether you have used, without a prescription, during the time your name has been at Defendant's Web site, any drug or other substance listed in schedule I, II, or III of the Controlled Substances Act (CSA), Title II of the Comprehensive Drug Abuse Prevention and Control Act of 1970 [21 USCS Section 812], [commonly-known drugs are in red] namely, SCHEDULE I (a) Unless specifically excepted or unless listed in another schedule, any of the following opiates, including their isomers, esters, ethers, salts, and salts of isomers, esters, and ethers, whenever the existence of such isomers, esters, ethers, and salts is possible within the specific chemical designation: (1) Acetylmethadol. (2) Allylprodine. (3) Alphacetylmathadol. (4) Alphameprodine. (5) Alphamethadol. (6) Benzethidine. (7) Betacetylmethadol. (8) Betameprodine. 9) Betamethadol. (10) Betaprodine. (11) Clonitazene. (12) Dextromoramide. (13) Dextrorphan. (14) Diampromide. 15) Diethylthiambutene. (16) Dimenoxadol. (17) Dimepheptanol. (18) Dimethylthiambutene. 19) Dioxaphetyl butyrate. (20) Dipipanone. (21) Ethylmethylthiambutene. (22) Etonitazene. (23) Etoxeridine. (24) Furethidine. 25) Hydroxypethidine. 26) Ketobemidone. 27) Levomoramide. (28) Levophenacylmorphan. (29) Morpheridine. (30) Noracymethadol. (31) Norlevorphanol. (32) Normethadone. 33) Norpipanone. (34) Phenadoxone. (35) Phenampromide. (36)

Phenomorphan. (37) Phenoperidine. (38) Piritramide. (39) Proheptazine. (40) Properidine. (41) Racemoramide. (42) Trimeperidine. (b) Unless specifically excepted or unless listed in another schedule, any of the following opium derivatives, their salts, isomers, and salts of isomers whenever the existence of such salts, isomers, and salts of isomers is possible within the specific chemical designation: (1) Acetorphine. (2) Acetyldihydrocodeine. (3) Benzylmorphine. (4) Codeine methylbromide. 5) Codeine-N-Oxide. (6) Cyprenorphine. (7) Desomorphine. 8) Dihydromorphine. (9) Etorphine. (10) Heroin. (11) Hydromorphinol. (12) Methyldesorphine. (13) Methylhydromorphine. (14) Morphine methylbromide. (15) Morphine methylsulfonate. (16) Morphine-N-Oxide. (17) Myrophine. (18) Nicocodeine. (19) Nicomorphine. (20) Normorphine. (21) Pholcodine. (22) Thebacon. (c) Unless specifically excepted or unless listed in another schedule, any material, compound, mixture, or preparation, which contains any quantity of the following hallucinogenic substances, or which contains any of their salts, isomers, and salts of isomers whenever the existence of such salts, isomers, and salts of isomers is possible within the specific chemical designation: (1) 3, 4-methylenedioxy amphetamine. (2) 5-methoxy-3, 4-methylenedioxy amphetamine (3) 3, 4, 5-trimethoxy amphetamine. 4) Bufotenine. (5) Diethyltryptamine. (6) Dimethyltryptamine. (7) 4-methyl-2, 5-dimethoxyamphetamine. 8) Ibogaine. (9) Lysergic acid diethylamide. (10) Marijuana. (11) Mescaline. (12) Peyote. (13) N-ethyl-3-piperidyl benzilate. (14) N-methyl-3-piperidyl benzilate. (15) Psilocybin. (16) Psilocyn. (17) Tetrahydrocannabinols. SCHEDULE II. (a) Unless specifically excepted or unless listed in another schedule, any of the following substances whether produced directly or indirectly by extraction from substances of vegetable origin, or independently by means of chemical synthesis, or by a combination of extraction and chemical synthesis: (1) Opium and opiate, and any salt, compound, derivative, or preparation of opium or opiate. (2) Any salt, compound, derivative, or preparation thereof which is chemically equivalent or identical with any of the substances referred to in clause (1), except that these substances shall not include the isoquinoline alkaloids of opium. (3) Opium poppy and poppy straw. (4) coca leaves, except coca leaves and extracts of coca leaves from which cocaine, ecgonine, and derivatives of ecgonine or their salts have been removed; cocaine, its salts, optical and geometric isomers, and salts of isomers; ecgonine, its derivatives, their salts, isomers, and salts of isomers; or any compound, mixture, or preparation which contains any quantity of any of the substances referred to in this paragraph. (b) Unless specifically excepted or unless listed in another schedule, any of the following opiates, including their isomers, esters, ethers, salts, and salts of isomers, esters and ethers, whenever the existence of such isomers, esters, ethers, and salts is possible within the specific chemical designation: 1) Alphaprodine. (2) Anileridine. (3) Bezitramide. (4) Dihydrocodeine. (5) Diphenoxylate. (6) Fentanyl. (7) Isomethadone. 8) Levomethorphan. (9) Levorphanol. (10) Metazocine. (11) Methadone. 12) Methadone-Intermediate, 4-cyano-2-dimethylamino-4, 4-diphenyl butane. (13) Moramide-Intermediate, 2-methyl-3-morpholino-1, 1-diphenylpropane-carboxylic acid. (14) Pethidine. (15) Pethidine-Intermediate-A, 4-cyano-1-methyl-4-phenylpiperidine. (16) Pethidine-Intermediate-B, ethyl-4-phenylpiperidine-4-carboxylate. (17) Pethidine-Intermediate-C, 1-methyl-4-phenylpiperidine-4-carboxylic acid. (18) Phenazocine. (19) Piminodine. (20) Racemethorphan. (21) Racemorphan. (c) Unless specifically excepted or unless listed in another schedule, any injectable liquid which contains any quantity of methamphetamine, including its salts, isomers, and salts of isomers. SCHEDULE III. (a) Unless specifically excepted or unless listed in another schedule, any material, compound, mixture, or preparation which contains any quantity of the following substances having a stimulant effect on the central nervous system: (1) Amphetamine, its salts, optical isomers, and salts of its optical isomers. (2) Phenmetrazine and its salts. (3) Any substance (except an injectable liquid) which contains any quantity of methamphetamine, including its salts, isomers, and salts of isomers. (4) Methylphenidate. (b) Unless specifically excepted or unless listed in another schedule, any material, compound, mixture, or preparation which contains any quantity of the following substances having a depressant effect on the central nervous system: (1) Any substance which contains any quantity of a derivative of barbituric acid, or any salt of a derivative of barbituric acid. (2) Chorhexadol. (3) Glutethimide. (4) Lysergic acid. (5) Lysergic acid amide. (6) Methyprylon. 7) Phencyclidine. 8) Sulfondiethylmethane. (9) Sulfonethylmethane. 10) Sulfonmethane. (c) Nalorphine. (d) Unless specifically excepted or unless listed in another schedule, any material, compound, mixture, or preparation containing limited quantities of any of the following narcotic drugs, or any salts thereof: (1) Not more than 1.8 grams of codeine per 100 milliliters or not more than 90 milligrams per dosage unit, with an equal or greater quantity of an isoquinoline alkaloid of opium. (2) Not more than 1.8 grams of codeine per 100 milliliters or not more than 90 milligrams per dosage unit, with one or more active, nonnarcotic ingredients in recognized therapeutic amounts. (3) Not more than 300 milligrams of dihydrocodeinone per 100 milliliters or not more than 15 milligrams per dosage unit, with a fourfold or greater quantity of an isoquinoline alkaloid of opium. (4) Not more than 300 milligrams of dihydrocodeinone per 100 milliliters or not more than 15 milligrams per dosage unit, with one or more active, nonnarcotic ingredients in recognized therapeutic amounts. (5) Not more than 1.8 grams of dihydrocodeine per 100 milliliters or not more than 90 milligrams per dosage unit, with one or more active, nonnarcotic ingredients in recognized therapeutic amounts. (6) Not more than 300 milligrams of ethylmorphine per 100 milliliters or not more than 15 milligrams per dosage unit, with one or more active, nonnarcotic ingredients in recognized therapeutic amounts. (7) Not more than 500 milligrams of opium per 100 milliliters or per 100 grams, or not more than 25 milligrams per dosage unit, with one or more active, nonnarcotic ingredients in recognized therapeutic amounts. (8) Not more than 50 milligrams of morphine per 100 milliliters or per 100 grams with one or more active, nonnarcotic ingredients in recognized therapeutic amounts. (e) Anabolic steroids. If so, please state which drug or substance you used and when and where you used it. 6. Please state whether you have ever been to Cuba. If so, please state when you went, how you got there, where you left the United States from, where in the United States you returned to, and what prior acquaintances of yours, if any, were on the same aircraft or vessel during the trip? 7. Please state the amounts and all sources of your net income when you turned 23. 8. Please list all the real properties you owned, including street addresses, city and state in the case of buildings and lot and block number and city, county and state in the case of land without buildings, when you were 25. 9. Please list all the businesses of which you were an owner or partner when you were 25 including the name of the business, the nature of the business, your percentage ownership, the address of the business, and where the business in question was registered or incorporated. 10. Please list all your assets and liabilities on the date between 11/18/75 and 11/17/80 when your net worth was at its maximum level. Please describe the nature of each asset. In the case of personal property, please describe the make, year, and model of each item. In the case of real estate, please give the street address, city, and state of buildings and the lot and block number and city, county, and state of land without buildings. In the case of liabilities, please state the balance due, to whom the debt was owed, and what property, if any, was pledged as security for the debt. 11. Please list all your assets and liabilities on the date during your 27th year when your net worth was at its maximum level. Please describe the nature of each asset. In the case of personal property, please describe the make, year, and model of each item. In the case of real estate, please give the street address, city, and state of buildings and the lot and block number and city, county, and state of land without buildings. In the case of liabilities, please state the balance due, to whom the debt was owed, and what property, if any, was pledged as security for the debt. 12. Please list all your assets and liabilities on each of the two dates that began and ended the 18-month period during which you claim you "œturned $1,000 into $4.7 million in 18 months" on page 47 of your book Building Wealth. Please describe the nature of each asset. In the case of personal property, please describe the make, year, and model of each item. In the case of real estate, please give the street address, city, and state of buildings and the lot and block number and city, county, and state of land without buildings. In the case of liabilities, please state the balance due, to whom the debt was owed, and what property, if any, was pledged as security for the debt. 13. Please state how much you paid [hit-and-run victim] and the form of payment? If you transferred any debt instruments to him, please list the balance due at the time, the debtor on each such debt instrument, the street address, city, and state of buildings and the lot and block number and city, county, and state of land without buildings of any real property that secured said debt instrument. 14. Please state the date on which you committed the crime that resulted in your pleading guilty to second degree robbery, the location at which you committed the crime, the names of your accomplice(s), and the identity of the victim, and what weapon, if any was used by you or your accomplices. 15. With regard to your pleading guilty to second degree robbery, please state the crime(s) with which you were initially charged, identify the name and location of the court in which you were charged, the date you were charged, the date of your conviction, and the identity of your defense attorney.

Log in to comment
­