3ABN & Danny Shelton
v.
Gailon Joy & Robert Pickle

Plaintiff 3ABN's Requests for Production of Documents
and Things to Defendant Robert Pickle (First Set)

Document Requests Nos. 7 & 8

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Request No. 7:     All documents provided to, created by, or otherwise relied upon by any expert you have retained or intend to retain, consulted or intended to consult, or expect to call at the trial of this matter related to the subject matter of the instant dispute or to any impression or opinion held by the expert.

Response by Defendant Pickle:     We assume you actually meant "Request No. 8," not "Request No. 7."

Since the court-appointed deadline for expert testimony is so far away, we don't to our knowledge have any thing on this one yet, but feel free to check with Gailon Joy or Attorney Laird Heal.

Request No. 8:     All documents, including recordings, statements, affidavits, notes or other documents setting forth, summarizing or memorializing any interview, examination, interrogation, discussion, or other communication with any person or entity concerning the subject matter of the instant dispute or the current litigation.

Response by Defendant Pickle:     We assume you really meant "Request No. 9," not "Request No. 8."

See auto-discovery materials.

The documents we will highlight in this response refer to the topics of conversation of our September 1, 2006, phone conversation with John Lomacang, and our February 21 and March 28, 2007, phone conversations with Dr. Walt Thompson. You can find these emails in the email collection as well as after this response in the Save3ABN.com collection in the auto-discovery materials.

After the Sept. 1, 2006 Phone Conversation with John Lomacang

-------- Original Message -------- From:  Bob To:  [Nick Miller] Subject:  allegations re: Tommy Shelton Date:  Sun, 17 Sep 2006 09:02:18 -0500 Nick, Gailon asked me to send this to you. I spoke with John Lomacang two weeks ago last Friday I think it was. He was inclined to believe that all the scandalous rumors were due to the Norwegian doctor and Linda trying to get back at Danny. I told him I couldn't buy that since the attached documents come from a 2003 incident, which is before Linda's incident arose. It was the first he had heard of these allegations against Tommy. If you need any further assistance, let me know. The attached correspondence say how to get photocopies of the original letter. Perhaps you could obtain a fax today, if he can be reached outside of church services. I'll also include below transcriptions I made of portions of the August 10, 2006, 3ABN Live, in which global TV was used to bolster Danny's case, similar to what appears to be happening during the MAP Seminar. (I'll just add that John said he didn't mean what it sounds like was being said below.) Bob Pickle (000) 000-0000 ___________________________   -------- Original Message -------- From:  Bob To:  Subject:  Re: 3ABN Date:  Fri, 25 Aug 2006 08:42:22 -0500 Hi _______. I burned the 2-hour Windows Media File onto a CD and can mail it to you today. Here are the quotes from John, along with where in the WMV file they occur. I think under other circumstances it would have been a great sermon, with maybe a little tweaking. "The Israelites had to acknowledge that God had chosen Moses to lead them. I want to stop and say that, we may not always agree with who God chooses, but when God chooses someone, disagreeing with that one can bring on us adversity, discouragement, and the loss of our vision." (starting at 00:41:45) "Moses was the instrument that God used, as Danny Shelton is the instrument that God uses here at 3ABN. Moses was not the deliverer. Danny's not the deliverer. He's simply the chosen servant of God." (starting at 00:47:25) (John Lomacang on 3ABN Today Live, 1st hour, replayed at 3pm CDT, Sunday, August 13, 2006) What really troubled me was the following quotes from Shelley. "As a faithful witness for God, he spoke out against a couple who had entered into a sinful relationship. Now the woman entangled in this situation became offended. She was embittered, and she felt scorned. And you know, there's something about her, that she was unconcerned about her relationship in the eyes of the Lord. Her worry revolved more around the possibility of losing her prominent position. So what did she do? She devised a plan to eliminate this one who had exposed her, and she enlisted the help of her young daughter. Now prompted by her mother, this daughter became entangled in the web of deceit, and she set out to set her mother's position and save it by destroying this man of God. What we see here is that the scheme was to go forward and go straight for the throat and have his head served up on a platter. Does this story sound familiar to you? To whom am I referring? John the Baptist, of course. ..." (starting at 01:27:05; after an intro that starts at 01:25:45, an intro that describes John the Baptist in a way that sounds like Danny) "Now how could such a holy, Spirit-filled man, who was hand-picked by God, and called to such an important ministry, fall victim to such vile persecution? Why would God allow it?" (starting at 01:33:25) (Shelley Quinn on 3ABN Today Live, 2nd hour, replayed at 4pm CDT, Sunday, August 13, 2006) In what way was Salome "entangled in the web of deceit"? Or is Shelley referring to Linda and her daughter, the latter who has issued a signed, confidential statement alleging sexual assault on the part of Danny, one of several allegations supported by Barbara Kerr's recently "published" open letter? After repeatedly saying on this program that you aren't going to come to your own defense, why on global television accuse Linda's daughter of lying? Bob [Attachment: Ezra CoG Letter.pdf]

After the Feb. 21, 2007 Phone Conversation with Walt Thompson

Brief Thought on Legal Liability

-------- Original Message -------- From:  [Bob] To:  Walt Thompson Subject:  Brief thought on legal liability Date:  Wed, 21 Feb 2007 23:09:10 -0600 Walt, I just thought of this: All the cases where the Catholic Church is having to shell out millions of dollars in claims, out of all those cases, there weren't any convictions prior to hiring. So the fact that Tommy has never had a conviction doesn't protect 3ABN from legal liability. What has made it bad for the Catholic Church is that their leadership knew about the allegations and didn't handle them in a way that the courts, juries, and the aggrieved felt was adequate. Hence my concern for 3ABN. Thanks again for talking with me. Bob

"I Can Appreciate Your Concerns, But [Not] Your Way of Handling [Them]"

-------- Original Message -------- From:  Walt Thompson To:  [Bob] Subject:  Re: Brief thought on legal liability Date:  Fri, 23 Feb 2007 07:37:54 -0600 Bob, I can appreciate your concerns, but I will never appreciate your way of handling those concerns. Walt Walter Thompson MD

"How Would You Suggest That They Be Dealt With?"

-------- Original Message -------- From:  Bob To:  Walt Thompson Subject:  Re: Brief thought on legal liability Date:  Fri, 23 Feb 2007 09:19:56 -0600 Walt, If you truly appreciate my concerns, how would you suggest that they be dealt with? If you truly have the good of 3ABN at heart, then these concerns can't be ignored. I learned long ago that while I may not appreciate how someone says something, if they say something valid, I should listen and take heed. In the Bible we have the story of Josiah, and Ellen White comments on that story. He had been promised that he would die in peace, but he died from a battle wound instead. Why? Because he did not heed the message of God speaking through Pharaoh that told him not to come up to battle against him. He went anyway and was mortally wounded. So how do you propose that my concerns that you say you appreciate will be dealt with, concerns brought to your attention in a general way more than six months ago, and in a very specific way nearly three months ago? Concerns of such a serious nature, which most folks can appreciate, should not take months and months to deal with. Just the delay alone gives the appearance of a desire to cover things up like the Catholic Church has done. And certainly you don't want to give such an appearance, do you? Bob

"I Have No Further Comment"

-------- Original Message -------- From:  Walt Thompson To:  Bob Subject:  Re: Brief thought on legal liability Date:  Fri, 23 Feb 2007 10:31:16 -0600 I have no further comment, Bob. Walt Walter Thompson MD

The Very Existence of 3ABN Is at Stake

-------- Original Message -------- From:  Bob To:  Walt Thompson Subject:  Re: Brief thought on legal liability Date:  Fri, 23 Feb 2007 12:03:50 -0600 Walt, How can you just sit there and do nothing when the very existence of 3ABN is at stake? Why did you take the position of board chairman if you can't take a stand for truth and righteousness when duty calls? I plead with you, brother, take a stand. Don't just not do anything. Bob

"I Have Taken a Stand for Truth"

-------- Original Message -------- From:  Walt Thompson To:  Bob Subject:  Re: Brief thought on legal liability Date:  Fri, 23 Feb 2007 14:51:16 -0600 Bob, I have taken a stand for truth and have no plans to alter it. Walt Walter Thompson MD

"Praise the Lord! ... You Hold the Key"

-------- Original Message -------- From:  Bob To:  Walt Thompson Subject:  Re: Brief thought on legal liability Date:  Mon, 26 Feb 2007 12:15:35 -0600 Hi Walt. Praise the Lord! I am so glad to hear that. Regarding the issues we have talked about recently: Your form letter's false claim that Danny had paid off the remaining debt on Linda's car. Danny's false claim on that recent damage control broadcast you were also on, that ASI was willing to hear any complaints and accusations. Your false understanding that if Tommy had no convictions, 3ABN would incur no liability if a future incident occurred. As you have decided to take a stand for truth, not just in word but in deed as well, what do you personally plan on doing regarding the above three false claims or misunderstandings? You hold the key to the end of this crisis. Bob

After the Mar. 28, 2007 Phone Conversation with Walt Thompson

-------- Original Message -------- From:  Bob To:  Walt Thompson Subject:  Who do we ask for the privilege of speaking to the board? Date:  Sun, 01 Apr 2007 16:36:33 -0500 Walt, I was thinking, given the gravity of the situation and all, I'm not sure it is wise for me to just take your word for it that it is too late to speak to the board about our concerns, especially since some folks question whether you would have ever allowed that anyway. What would be the protocol of going over the chairman's head and requesting the privilege of speaking to the board about some of the ethical, financial, and moral concerns that we have? Bob

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