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Updated 1/10/2013
2011 Form 990

Updated 6/22/2011
3ABN sued
over Tommy!

Added 3/14/2010
Can 3ABN Survive?

Added 11/16/2010
Judge Rejects
Plea Deal

Updated 4/2/2010
Tommy Shelton

Must Read:
Mom in Pain #1

Mene, Mene,
Tekel, Parsin

The Actual Lawsuit
IRS Criminal Investigation

3ABN & Danny Shelton
Gailon Joy & Robert Pickle

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

Instructions and Definitions

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Three Angels Broadcasting Network, Inc.,
an Illinois non-profit corporation, and
Danny Lee Shelton, individually,


Gailon Arthur Joy and Robert Pickle,



Case No.: 07-40098-RCL


Defendant Robert Pickle, and his counsel of record, Laird Heal, Esq., 3 Clinton Road, P.O. Box 365, Sterling, MA 01564.


PLEASE TAKE NOTICE that You are hereby requested and required to produce the following documents and things for inspection and copying within thirty (30) days of the date of service herein pursuant to Federal Rule of Civil Procedure 34. Except for electronically stored documents and things, which are to be produced in their native form, on their original archival mechanism (computer, server, etc.), at the location they are normally and routinely maintained, the documents and things should be produced for inspection and copying at the offices of Fierst, Pucci & Kane, LLP, 64 Gothic Street, Northampton, Massachusetts, 01060.

Response by Defendant Pickle:     Unless agreed upon or ordered by the Court, all electronically stored documents and things will be produced on CD or DVD in either a) native format or b) a readily accessible and usable format, without on-site inspection. Doing otherwise would not be in harmony with the Sedona Principles.

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Unless otherwise stated, the time period for these requests is January 1, 2004 through the present, and thereafter on a continuing basis until the disposition of the trial of this matter.

Any references to a person or corporation herein includes agents, employees, officers, directors, attorneys, or anyone acting on behalf of that person or corporation.

If any request for document herein is deemed to call for the production of privileged or work product materials and such privilege or work product claim is asserted, you are to identify in writing each document so withheld and for each such document you are to provide the following information:

  1. the reason for withholding the document;

  2. a statement of the basis for the claim of privilege, work product, or other grounds of nondisclosure;

  3. A brief description of the document, including:

  a. the date of the document;

  b. the number of pages, attachments and appendices to the document;

  c. the names of the document's author(s) or preparer(s) and the identification of such person by employment and title;

  d. the name of each person who was sent, shown, or carbon copied the document or who has had access to or custody of the document, together with an identification of each such person;

  e. the present custodian of the document; and

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  f. the subject matter of the document, and in the case of any document relating or referring to a meeting or conversation, identification of such meeting or conversation.

If any document requested herein was at one time in existence but has been lost, discarded or destroyed, identify such document as completely as possible, providing as much of the following information as possible:

  1. the type of document;

  2. the document's date;

  3. the date or approximate date the document was lost, discarded or destroyed;

  4. the circumstances under which and the manner in which the document was lost, discarded or destroyed;

  5. the reason or reasons for disposing of the document (if discarded or destroyed);

  6. the identity of all persons authorized or having knowledge of the circumstances surrounding disposal of the document;

  7. the identity of the person(s) who lost, discarded, or destroyed the document; and

  8. the identity of all persons having knowledge of the contents of the document.

Your attention is directed to Federal Rule of Civil Procedure 34(b), which requires that any party who produces documents for inspection shall "produce them as they are kept in the usual course of business or shall organize and label them to correspond with the categories of the request." In this connection, and for purposes of illustration, it is requested that all documents requested be produced in the file folders and cartons in which they have been maintained and stored, clipped, stapled or otherwise arranged in the same form and manner as they were found. If you choose to produce the documents requested corresponding with the categories in the

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request, it is requested that you identify the file folders, drawers or cartons in which the documents were originally maintained.

Any response to these requests shall set forth the request in full before each response. Separate responses shall be provided with respect to each request. If, after a good faith search, you conclude that there have never been documents responsive to a particular request, you should so state.

You are required to supplement your responses to these Requests for Production of Documents in accordance with the provisions of the Federal Rules of Civil Procedure.

You are hereby put on notice that objection will be made at the time of trial to any attempt to introduce evidence which is directly sought by these requests and to which no response or disclosure has been made.



As used herein, the following words and phrases shall have the following definitions:

  1. Document shall have the broadest possible meaning permitted under applicable law, and shall include any written, recorded or graphic material of any kind, including the originals and all non-identical copies, including those materials in electronic form, that is or has been in Your possession, control or custody or of which You have knowledge, including, but not limited to: documents, letters, correspondence, e-mail, memoranda, notes, invoices, bulletins, calendars, diaries, contracts, agreements, letters, telegrams, minutes, reports, studies, checks, statements, receipts, vouchers, invoices, summaries, pamphlets, blueprints, specifications, drawings, sketches,

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    interoffice and intraoffice communications, stenographic or handwritten notes of any sort of conversation, telephone calls, meetings or other communications, agendas, computer printouts, graphical records or representations of any kind (including without limitation photographs, charts, graphs, microfiche, microfilm, videotapes, recordings, and motion pictures), electrical data compilation, electronic mail, computer files or documents, computer disks, computer programs, computer software, tapes and all other tangible things upon which any handwriting, typing, printing, drawing, representation, photocopy, magnetic, electrical or optical impulse, data, or other form of communication is stored, recorded, or reproduced, and preliminary drafts and non-identical copies of the above. The term also includes each and every file folder, folio or other material in which the above items are stored, filed, or maintained as well as every copy of such documents where the original is not in Your possession, custody or control, or where such copy is not an identical copy of an original or where such copy contains any commentary or notation whatsoever that does not appear in the original.
  2. Identify when used in reference to an individual person means to (a) state the person's full name, resident address and telephone number (designated as present or last known), (b) state his or her position or business affiliation, and (c) state the person's business address and telephone number (designated as present or last known).
  3. Identify when used in reference to a firm, partnership, corporation, proprietorship, association, or any other organization or entity, means to (a) state its full name, registered address, the address and telephone number (designated as present or last

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    known) of its principal place of business, (b) state the legal form of such organization or entity and the state of incorporation or organization of the entity, and (3) state the identity of the entity's Chief Executive Officer and Registered Agent.
  4. Identify when used in reference to a document means to (a) state the type of document (e.g. letter, memorandum, telegram, contract, invoice, etc.) or some other means of identifying it, (b) state its dates of creation, finalization and dissemination, (c) state its author, the addresses or other information identifying its intended recipient or audience, and its present location and its current custodian. If any identified document was, but is no longer, in Your possession or subject to Your control, state also its means of disposition and date of disposition, and identify the person or persons who last had possession or control of the document.

  5. Identify when used in reference to a conversation, conference or a meeting means to (a) state all persons participating in or attending the conversation, conference or meeting, (b) state the nature and purpose of the conversation, conference or meeting, (c) state the date upon which the conversation, conference or meeting occurred, (d) state the means of communication by which the conversation, conference or meeting occurred (e.g. in-person, by teleconference, by videoconference, etc.), (e) state all documents prepared for or assembled in preparation for the conversation, conference or meeting, (f) state all documents that record, summarize or memorialize the conversation, conference or meeting, (g) state all documents arising out of such conversation, conference or meeting, and (h) identify all action known by You to have been taken as a result of the conversation, conference, or meeting.

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  6. Date means the exact day, month and year, if ascertainable, or the best available approximation thereof, including relationship to other events (designated whether exact or approximate).
  7. Describe means to state with particularity, including but not limited to each date, fact, event, or occurrence, to identify each matter, and to identify each individual who can testify as to such dates, facts, events, occurrences and documents.
  8. Relating to means stating, concerning, pertaining to, setting forth, describing, evaluating, projecting, mentioning, referring to, relating to, or constituting.

  9. Statement of Fact means any statement You have made orally or in writing to any third party about Plaintiff 3ABN or about Plaintiff Danny Shelton during the period January 1, 2004 to the present which you claim is factual and truthful and which forms the basis for your claims that Danny Shelton has committed wrongdoing and should resign his position at 3ABN. Without limiting the scope of this definition, and without intending to be an exhaustive list of such statements, examples would include "the actions of the Plaintiff Danny Lee Shelton ... has conducted himself in such a way as to violate theological integrity, undermine operational capability, to prey upon the financial soundness ofthe entity 3ABN and to inappropriately redirect large sums to his personal benefit with and without properly constituted corporate authority" contained in Defendants' Answers to Plaintiffs' Complaint and "The plaintiffs' personal, professional and corporate conduct is chimcral and duplicitous as they profess adherence to Seventh-Day Adventist conservative theology while Three Angels Broadcasting Network, Inc., allows their self-appointed leader to conduct himself in such a way as lo prove violative of the clear and rigorously enforced

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    standards required of ministry leadership within the Seventh-day Adventist Faith just as they are expected of the churches' membership" and "They collusively have repeatedly violated the code of conduct expected of an institution that professes an absolute faith in, and teaches, the doctrines of the Seventh-day Adventist Church contained in Defendants' Rule 26(f) Conference Report.
  10. You or Your means Defendant Robert Pickle and his agents, representatives, employees, assigns or attorney(s).

  11. 3ABN means Plaintiff Three Angels Broadcasting Network, Inc.

  12. Or is used in the inclusive sense (i.e. "and/or"). Thus, if a request seeks all documents relating to "A or B," you are to produce all documents relating to "A," all documents relating to "B," and all documents relating to "A and B."

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