3ABN & Danny Shelton
v.
Gailon Joy & Robert Pickle
Plaintiff 3ABN's Interrogatories to Defendant Robert Pickle (First Set)
Interrogatory Nos. 10-13
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[page 10]
Interrogatory No. 10:
Describe in detail and with particularity each and every fact
and circumstance that You claim supports Your statement that
"the international television ministry known as Three Angels'
Broadcasting Network (3ABN) has found itself beset by a growing
number of moral, ethical, and financial allegations," which statement
You admitted in Defendants' Answer to Paragraph 46a of Plaintiffs'
Complaint, including in Your description each moral, ethical
or financial allegation by which 3ABN has found itself beset,
the person or entity who has made the allegation, the date, time,
and location where the allegation was made, the means by which
the allegation was made (e.g., print publication, radio broadcast,
internet posting, written correspondence, etc.), and the means
by which the allegation was communicated to 3ABN.
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Response by Defendant Pickle:
See auto-discovery materials and Save3ABN.com.
Your quotation comes from the homepage of Save3ABN.com,
which you did not include as an exhibit to your complaint. That home page gives a brief synopsis of
Save3ABN.com's coverage of some of the more serious moral
and ethical allegations that have beset 3ABN and Danny Shelton.
See also BlackSDA.com and
ClubAdventist.com, the former which contains discussions going back to
at least 2004, two years before the Defendants became involved. Regarding the material at
ClubAdventist.com, much of it has been at least deleted from view.
Whether Stan Jensen would turn over that material to you (if he hasn't deleted it) we do not know.
We could ask him if you'd like us to.
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Interrogatory No. 11:
For each and every instance You claim to have "published an allegation
that is a restatement of a protected source or sources," as You
repeatedly set forth in Defendants' Answer to Plaintiffs' Complaint,
identify and describe the allegation, the identity of the person
or entity who originally made or stated the allegation, the date
and means by which the allegation was Communicated to You, and
the legal and factual basis for Your claim that the source of
the allegation is entitled to "protection" from disclosure.
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Response by Defendant Pickle: Regarding whatever source or sources
are protected, it would be unethical for us to divulge those sources if they are protected.
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Interrogatory No. 12:
Describe in detail and with particularity each and every fact
or circumstance that You claim supports each Statement of Fact
or other statement identified in Your Answer to Interrogatory No. 3, above.
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Response by Defendant Pickle: See
auto-discovery materials and Save3ABN.com.
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Interrogatory No. 13:
If You claim that Plaintiff 3ABN or Plaintiff Danny Shelton have
made any admissions against interest in connection with this
dispute, state where and when such admission was made, what was
said, by whom it was said, and to whom it was said.
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Response by Defendant Pickle:
You have not explained what you mean by "against interest in connection with this dispute,"
so we will do our best to answer.
From a Christian and Adventist perspective, not admitting
a fault or error could be against one's interest in this dispute, since 1 John 1:9 requires confession
as a condition for forgiveness. In that sense, whatever admissions have been made
are not against 3ABN or Danny Shelton's interest.
From a worldly perspective, admitting to a fault or error could be misconstrued
into being against one's interest in this dispute. In that sense, the various admissions documented
on Save3ABN.com could be falsely described by someone
unacquainted with the principles of Christian mediation and arbitration as being against interest
in this dispute.
For various admissions by various 3ABN-related parties and Danny Shelton,
whether for or against interest, see auto-discovery materials and
Save3ABN.com.
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