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

Plaintiff 3ABN's Interrogatories to Defendant Robert Pickle (First Set)

Interrogatory No. 4

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Interrogatory No. 4:     Describe in detail and with particularity the history, purpose, aims, and administration of the website located at www.Save3ABN.com, including, but not limited to, the date the site was registered, activated and launched, the company or companies who serve as the electronic host(s) for the site, the identity of all persons who have authored or contributed text, documents, photographs, or other material published on the site, the identity of all persons who have paid for the hosting and operation of the site or who have contributed money toward the hosting and operation of the site, the dates and times of all additions and deletions made to the site with the full text of each addition or deletion, the schedule of routine maintenance to the site with a description of the maintenance activities performed pursuant to that schedule, the efforts made by You or by others acting on Your behalf to promote, market, advertise, publicize, or raise awareness of the site, and the identity, including e-mail and/or U.S. Mail address, of any person who has contacted the site.

Response by Defendant Pickle:     For when Save3ABN.com was registered, see ¶ 25 on page 7 of your complaint, which refers to Exhibit F, an exhibit which gives the date we think you are looking for. For the purpose and aims of Save3ABN.com, see the home page of Save3ABN.com, which was not made an exhibit to the complaint (thus avoiding the inclusion of references to the child molestation allegations against Tommy Shelton). For the administration of Save3ABN.com, see ¶ 25 and Exhibit F of your complaint. The company that hosts the site is Bluehost, whom, if you are looking for a web host, we would highly recommend. They offer a lot of features for the price, and their tech support is pretty good, in our opinion.

Regarding those who have authored or contributed material for Save3ABN.com, see Save3ABN.com where authorship of much of the material is fairly straightforward. For the identity of authors using pseudonyms such as Bystander and Lee, Danny Shelton may know. Regarding who has paid for the hosting and operation of Save3ABN.com, it is our understanding that Gailon Joy has received invoices for that. Regarding who has contributed money toward those sort of costs, unless you can show good cause, for us to divulge that sort of information would be as inappropriate as your divulging, without our showing good cause, everyone that has ever contributed anything to Danny Shelton and/or 3ABN.

Regarding additions, we haven't kept track of when we added this page or that paragraph. Regarding deletions, we haven't kept track of every little grammatical or spelling alteration. Technically speaking, the Leonard Westphal material outlining some of the allegations against him and how the whistle blowers were fired was never deleted from its web page, but only deleted from view. The same is true regarding Stephen Lewis' name on the web page dealing with the horse donations.

To assist you in your sleuth work in trying to determine exactly when this page was added or that page was altered, we have created a special page that lists system file timestamps (creation, modified, and access) for files on the web site. You can access this continually-updated page at Save3ABN.com, or view an archived version in the Save3ABN.com collection in the auto-discovery materials.

Regarding routine maintenance, other than a cron job that runs a search engine spider, that information is unknown. Regarding publicity, we have used word of mouth, emails, and internet postings. Regarding who has contacted Save3ABN.com, that information is confidential, unless you can show good cause. Divulging that information would be as out of line as if you divulged to us everyone that has ever written 3ABN.org.

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