3ABN & Danny Shelton
v.
Gailon Joy & Robert Pickle
Plaintiff 3ABN's Interrogatories to Defendant Robert Pickle (First Set)
Interrogatory Nos. 5-7
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Interrogatory No. 5:
Describe in detail and with particularity each and every fact
and circumstance that you claim supports your allegations that
3ABN has deceived Seventh-Day Adventist laymen everywhere because
it claims to promote the messages unique to the Seventh-Day Adventist
Denomination, that 3ABN has deceptively promoted itself as a
Seventh-Day Adventist proselytizing outreach ministry, and that
3ABN has deceptively promoted to SDA church rallies that it was
promoting the SDA message and bringing souls into the SDA churches,
as those allegations have been set forth in the Answer of Defendants
to Paragraph 12 of the Plaintiffs' Complaint.
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Response by Defendant Pickle:
See ¶ 10 and
¶ 12 of your
complaint. Then read those paragraphs to the average Seventh-day Adventist leader or layman and
listen to how they respond. (Personally, we are surprised that you would ask such a question.)
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Interrogatory No. 6:
Describe in detail and with particularity each and every fact
and circumstance that You claim supports Your allegation that
not all sums of money entrusted to 3ABN as gifts, donations,
trusts and tithes of earnings have been appropriately accounted
for, as that allegation has been set forth in the Answer of Defendants
to Paragraph 13 of the Plaintiffs' Complaint.
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Response by Defendant Pickle:
You will need to speak with Gailon Joy regarding this one.
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Interrogatory No. 7:
Describe in detail and with particularity each and every fact
and circumstance that You claim supports Your allegation that
the actions and conduct of Plaintiff Danny Lee Shelton have violated
the theological integrity, undermined the operational capability,
and preyed upon the financial soundness of 3ABN, as that allegation
has been set forth in the Answer of Defendants to Paragraph 14
of the Plaintiffs Complaint, including in Your description, the
identity of all documents of any kind in Your possession relevant
to Your allegation, the identity of all persons from whom You
have obtained information relevant to Your allegation and a detailed
description of that information, the exact means by which 3ABN's
theological integrity has been violated, the exact means by which
3ABN's operational capability
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has been violated, and the exact means by which
3ABN's financial soundness has been preyed upon.
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Response by Defendant Pickle: See auto-discovery materials,
to which we will add a few comments.
On August 10, 2006, Danny Shelton had a special broadcast
that was designed to neutralize and deflect criticism and suspicions arising from the sexual assault
allegations of Alyssa Moore against himself. In that broadcast John Lomacang likened Danny Shelton to
Moses, indicated that it was wrong to disagree with Danny Shelton, called Danny Shelton the Lord's anointed,
and indicated that Danny Shelton is beyond human correction. Thus, John Lomacang exalted Danny Shelton to
what could be termed the status of a cult leader, and such a status is totally contrary to Seventh-day Adventist
theology.
Additionally, as has been repeatedly pointed out, in today's litigious climate, to cover
up or ignore child molestation allegations through deceit, negligence, or subterfuge jeopardizes the
financial stability of any organization in the event that future actions result in claims of damages.
And if such claims result in substantial settlements or awards, that organization's operational
capability could in consequence be undermined.
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