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[Cindy]

Here is a question for you Mr. Pickle is the piece of fruit in my hand a pear?

Make sense?

Nope.

Why?

Because there is no context. Just like this ridiculous post of yours which is absent any context whatsoever. Have the guts to put up the whole thing and let the world have a chance to decide if you are manipulating these words. But you won't because it would prove you are manipulating things and misleading people. Why don't you treat your readership with some decency and not assume they don't think for themselves.

... the single defamatory statement remotely related to Danny Shelton’s personal finances would make relevant only the title, purchase documents and payment information for a Toyota Sequoia automobile [Complaint ¶ 50(g)].

Does this statement make sense to anyone?

Post edited by Snoopy to remove offensive quote from the prior post.

Why do you insist on posting personal insults, put downs  and ridicule Eduard? So many of your posts are like this. I found the post about asking for a requiem for Danny totally unecessary and mean, and mocking anymans education or intellect is certainly not necessary?

Do you have some hurt or anger causing this and can I help in some way? It's distressing to me and I worry about you, but at the same time I have a hard time accepting anything you write as to me it is all so ugly and  just outright rude. Can't you just address the topics of discussion?

maybe you don't see this yourself? Maybe I am wrong, as the moderators don't seem to have a problem with with what you say or how you talk about fellow members..

I apologize for my comment about the moderators. In retrospect was also uncalled for, and I am ashamed. I should have just bit my tongue and been more patient, as I realize you are all learning, and doing the best you can.  I appreciate the eyes which see, and you doing what is for the most part a unthankful job.

blessings..

[Eduard]

Here is a question for you Mr. Pickle is the piece of fruit in my hand a pear?

Make sense?

Nope.

Why?

Because there is no context. Just like this ridiculous post of yours which is absent any context whatsoever. Have the guts to put up the whole thing and let the world have a chance to decide if you are manipulating these words. But you won't because it would prove you are manipulating things and misleading people. Why don't you treat your readership with some decency and not assume they don't think for themselves.

... the single defamatory statement remotely related to Danny Shelton’s personal finances would make relevant only the title, purchase documents and payment information for a Toyota Sequoia automobile [Complaint ¶ 50(g)].

Does this statement make sense to anyone?

Post edited by Snoopy to remove offensive quote from the prior post.

Why do you insist on posting personal insults, put downs  and ridicule Eduard? So many of your posts are like this. I found the post about asking for a requiem for Danny totally unecessary and mean, and mocking anymans education or intellect is certainly not necessary?

Do you have some hurt or anger causing this and can I help in some way? It's distressing to me and I worry about you, but at the same time I have a hard time accepting anything you write as to me it is all so ugly and  just outright rude. Can't you just address the topics of discussion?

maybe you don't see this yourself? Maybe I am wrong, as the moderators don't seem to have a problem with with what you say or how you talk about fellow members..

Ian,


Shakespeare said somewhere that truth turns words into daggers. The statements I have made so far in this forum are nothing but true and precise evaluations of the messages posted by you, Donna, Junebug, anyman, and others who defend Danny Shelton. My messages may not sound politically correct when formulated as I did so far, but they are not at all different IN ESSENCE from the insults your group piles on Pickle and Joy every day. Constant efforts from your group to twist the truth, and to deceive those who read the posts in this forum are EVEN MORE OFFESIVE than the posts I make because behind the false politeness with which you write your messages hides their true spirit, the UGLINESS OF DECEPTION.


God is TRUE, and His message is TRUTHFUL. Satan is THE FATHER OF LIES, and his goal is to spread DECEPTION. The messages of your group do not contain truth, but deception. Those who love the truth hate deception and are outraged by it.


Eduard

[Eduard]

Thanks Donna for letting us know about the new site. It looks very interesting. I already signed up. If anyone wants to see PACER documents in their entirety you can go here but you have to be a member of this site in order to see the files where the PACEr documents are located. Lots of information here!

http://groups.yahoo.com/group/3abnDefended/messages

Junebug, Donna, and Ian:

Here are two messages posted on the website Donna mentioned:

___________

I see that Mr. Robert Pickle has made some youtube video's trying to
bring dishonor to God's Name and to discredit 3ABN.

Folks, what Mr. Pickle is saying is not truthful. Before you believe
what he says, check it out. You can check with 3ABN by e-mailing them
at this link:

http://www.3abn.org/contact_email.cfm

You will find the truth from kind Christian loving people who work
there. I'm sorry that Mr. Pickle and Mr. Joy seem to have such a hatred
for God's work. They must hate the Bible and the truth in it.

In fact we are told when people do these kinds of things, it is as if
they were doing it to the Lord Jesus Christ. I wonder if they have
thought of this?

Sammy

________________


Mr. Pickle now has 11 different youtube videos made to try to bring
forth to the public accusations and innuendo. Notice how below these
video's it has a section for comments by the public. Mr. Pickle and Mr.
Joy have disabled this feature so that no one can comment that these
videos are based on nothing but opinion.

This ought to prove right there that they are AFRAID people will speak
up against what they are saying and to let them know they (Mr. Pickle
and Mr. Joy) are not truthful. When men try to bring discredit to
Christian programming such as 3ABN, and they do not allow the truth to
be posted, showing and proving they are wrong in their assumptions,
they will find they are working on the wrong side.

Also the timing of putting these video's out for the public to see was
just as a 3-day holiday began. You can see how calculating these evil
men are.

But praise the Lord--He will overrule what they are trying to do. The
upcoming Ten Commandments week-end will be a total success for the
truths sake. God's Name will be glorified.

Truth will triumph!!


________________


Do you agree with these offensive and degrading messages that attack Joy and Pickle? Do Joy and Pickle really  "hate the Bible and the truth in it"?

Do they have "a hatred for God's work" because they have blown the whistle about the wrongs that have been happening at 3ABN?

Do they really "try to bring discredit to Christian programming such as 3ABN, and they do not allow the truth to be posted"?


Who was the one who wanted all the documents in the lawsuit locked up so that nobody will be able to know what the truth is?


I am glad that Donna mentioned the <http://groups.yahoo.com/group/3abnDefended/messages> website. It will be another opportunity for people to see what kind of defenders Danny Shelton has and how much truth they speak!

Eduard

[anyman]

There are two things that can always be counted on in your response to posts that effectively refute or put to question your postings. First, you claim the reply validates or supports your point - which isn't the case at all. Second, rather than address the issues made in the reply to your post or dealing with issue at question you attempt to divert other readers by brining into your post completely unrelated and irrelevant comments.

Some how you missed it, but in my reply establishing context to your initial cherry picked statement, I made the following observation, which was taken directly from the document filed by 3ABN's attorney. According to Document 67, p. 11, Item 4 cites the Complaint, P's 46(h), 46(i), 50(c), 50(e), 50(i), "The public record in Danny Shelton's divorce proceedings". So you are wrong in regards to your first comment below.

No, I don't see any problems. Everything the mention is found in the Complaint against you. Again, you filed a Motion to Compel and Document 67 is 3ABN's response to that and outlines the unreasonable and overly broad nature of your demands. They effectively show how you have demanded access to documents that have nothing to do with any of the items in the Complaint against you. You seem to have lost focus and don't realize that discovery involves only those things addressed in the Complaint and you can't add to that as you are a defendant - the context was established by the Complaint you must operate within that.

Once again you attempt to subtly confuse the discussion with your last question. It is indeed a fact that the only personal financial documents that are related to the issues established in the Complaint have to do with the Toyota SUV. Again, what you are suggesting is that everything you have leveled false accusations about since the filing of the Complaint has some relevance in this case, and in this you are wrong.

It is also obvious that you are choosing to ignore the issue here; that you have made "abusive," "overly broad" demands not only in this Motion to Compel, but as a matter of operation throughout the discovery process. You have also failed to provide your position on why all of the documents you demand hold relevance to the Complaint - as is required.

How about this, taken directly from Document 67:

"Plaintiff's exercise is merely an attempt to illustrate the excessively broad and unduly burdensome nature of Pickle's request and why Plaintiffs cannot respond until the requests are narrowed to seek relevant information or information that is reasonably calculated to lead to the discovery of admissible evidence."

Obviously this establishes that Document 67 is an attempt to establish a foundation for Mr. Pickle's request of the Court to be thrown out and includes a request for oral arguments (p. 13) as a means to provide larger context for the Court. The exercise referred to is Section III on page 9 which establishes why the Court should deny Mr. Pickle's request seeking information that is "not discoverable." 3ABN's attorney is merely making it clear that Mr. Pickle is not operating within the context of the Complaint thus unduly lengthening the process thereby causing monetary expenditures to be greater than they should or would be if he would stick to the context of the Complaint.

So the questions in your court Mr. Pickle, are:

"Why have you failed to provide defense, by establishing relevance, for your demands."

"Why do you refuse to narrow your request to only those documents that are relevant to the Complaint."

Thanks, anyman, for making it clear that I was correct: They did not include in that list anything having to do with the divorce, and issue that was in the complaint.

Also, I do not recall saying anything about royalties earned by 3ABN. Nor about the board prohibiting donations to Cherie Peters.

Notice also that there is nothing on the list that would enable one to prove what financial damage was caused by what statements.

There are a number of other problems about their list, are there not?

Now when you consider what we really have said, how in the world could anyone claim that the only stuff remotely relevant to Danny's personal finances is the title of and payment for the Toyota van?

[Cindy]

I am glad that Donna mentioned the <http://groups.yahoo.com/group/3abnDefended/messages> website. It will be another opportunity for people to see what kind of defenders Danny Shelton has and how much truth they speak!

Eduard

Fine, but "Off topic" imo... again you ignore the issues to concentrate on the individuals you disagree with, find fault with them and post ad hominems...

The subject here is " "single ... statement remotely related to Danny Shelton's personal finances" and the link was given to the PACER documents under discussion so those who wanted to view and examine what is being discussed/debated because they are interested in the topic and the truth could do so...


The following is ontopic, relevant and deserves an answer imo...

There are two things that can always be counted on in your response to posts that effectively refute or put to question your postings. First, you claim the reply validates or supports your point - which isn't the case at all. Second, rather than address the issues made in the reply to your post or dealing with issue at question you attempt to divert other readers by brining into your post completely unrelated and irrelevant comments.

Some how you missed it, but in my reply establishing context to your initial cherry picked statement, I made the following observation, which was taken directly from the document filed by 3ABN's attorney. According to Document 67, p. 11, Item 4 cites the Complaint, P's 46(h), 46(i), 50(c), 50(e), 50(i), "The public record in Danny Shelton's divorce proceedings". So you are wrong in regards to your first comment below.

No, I don't see any problems. Everything the mention is found in the Complaint against you. Again, you filed a Motion to Compel and Document 67 is 3ABN's response to that and outlines the unreasonable and overly broad nature of your demands. They effectively show how you have demanded access to documents that have nothing to do with any of the items in the Complaint against you. You seem to have lost focus and don't realize that discovery involves only those things addressed in the Complaint and you can't add to that as you are a defendant - the context was established by the Complaint you must operate within that.

Once again you attempt to subtly confuse the discussion with your last question. It is indeed a fact that the only personal financial documents that are related to the issues established in the Complaint have to do with the Toyota SUV. Again, what you are suggesting is that everything you have leveled false accusations about since the filing of the Complaint has some relevance in this case, and in this you are wrong.

It is also obvious that you are choosing to ignore the issue here; that you have made "abusive," "overly broad" demands not only in this Motion to Compel, but as a matter of operation throughout the discovery process. You have also failed to provide your position on why all of the documents you demand hold relevance to the Complaint - as is required.

How about this, taken directly from Document 67:

"Plaintiff's exercise is merely an attempt to illustrate the excessively broad and unduly burdensome nature of Pickle's request and why Plaintiffs cannot respond until the requests are narrowed to seek relevant information or information that is reasonably calculated to lead to the discovery of admissible evidence."

Obviously this establishes that Document 67 is an attempt to establish a foundation for Mr. Pickle's request of the Court to be thrown out and includes a request for oral arguments (p. 13) as a means to provide larger context for the Court. The exercise referred to is Section III on page 9 which establishes why the Court should deny Mr. Pickle's request seeking information that is "not discoverable." 3ABN's attorney is merely making it clear that Mr. Pickle is not operating within the context of the Complaint thus unduly lengthening the process thereby causing monetary expenditures to be greater than they should or would be if he would stick to the context of the Complaint.

So the questions in your court Mr. Pickle, are:

"Why have you failed to provide defense, by establishing relevance, for your demands."

"Why do you refuse to narrow your request to only those documents that are relevant to the Complaint."

[Gailon Arthur Joy]

Have you forgotten that we have not yet stated affirmative defenses, countercalim or third parties? And so just how would you know what is relevant?

But, for the sake of clarification, here is that rule 26 and then 34 and is easilly defensible:

" Rule 26:
(4) Form of Disclosures.

Unless the court orders otherwise, all disclosures under Rule 26(a) must be in writing, signed, and served.

(b) Discovery Scope and Limits.
(1) Scope in General.

Unless otherwise limited by court order, the scope of discovery is as follows: Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense — including the existence, description, nature, custody, condition, and location of any documents or other tangible things and the identity and location of persons who know of any discoverable matter. For good cause, the court may order discovery of any matter relevant to the subject matter involved in the action. Relevant information need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence. All discovery is subject to the limitations imposed by Rule 26(b)(2)(C).

Rule 34. Producing Documents, Electronically Stored Information, and Tangible Things, or Entering onto Land, for Inspection and Other Purposes

(a) In General.
A party may serve on any other party a request within the scope of Rule 26(b):

(1) to produce and permit the requesting party or its representative to inspect, copy, test, or sample the following items in the responding party's possession, custody, or control:
(A) any designated documents or electronically stored information — including writings, drawings, graphs, charts, photographs, sound recordings, images, and other data or data compilations — stored in any medium from which information can be obtained either directly or, if necessary, after translation by the responding party into a reasonably usable form; or

(B) any designated tangible things; or

(2) to permit entry onto designated land or other property possessed or controlled by the responding party, so that the requesting party may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it."

So, as they say, get use to it and when you have filed suit, well we will deal with your abberant view of the law, in the interim we will deal with Danny's abberant view of the law...he files suite, does not have to prove his case, and wins...
sorry but it did not work in the State of Illinois case and it won't work here. And we can state that with confidence as the documents role in, not from 3ABN but from third parties...now 3ABN, it is your turn!!! Produce or we will push to compel.

You know, Anyman, you just don't seem to comprehend that we EXPECT TO WIN!!! The weight of the evidence continues to grow in our favor. Unless they come up with something a bit more solid than Danny Says, the trial will be just another big loss for 3ABN while they appeal to avoid the inevitable judgment. But the judgment will come and all the appeals in the world are unlikely to reverse the truth. And we are not the only issue that remains unresolved!!!

So, enjoy the discovery and we will prepare our defense, etc. Like it or lump it.


Gailon Arthur Joy

[anyman]

Rule 26 is going to be your undoing.

Have you forgotten that we have not yet stated affirmative defenses, countercalim or third parties? And so just how would you know what is relevant?

But, for the sake of clarification, here is that rule 26 and then 34 and is easilly defensible:

" Rule 26:
(4) Form of Disclosures.

Unless the court orders otherwise, all disclosures under Rule 26(a) must be in writing, signed, and served.

(b) Discovery Scope and Limits.
(1) Scope in General.

Unless otherwise limited by court order, the scope of discovery is as follows: Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense — including the existence, description, nature, custody, condition, and location of any documents or other tangible things and the identity and location of persons who know of any discoverable matter. For good cause, the court may order discovery of any matter relevant to the subject matter involved in the action. Relevant information need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence. All discovery is subject to the limitations imposed by Rule 26(b)(2)(C).

Rule 34. Producing Documents, Electronically Stored Information, and Tangible Things, or Entering onto Land, for Inspection and Other Purposes

(a) In General.
A party may serve on any other party a request within the scope of Rule 26(b):

(1) to produce and permit the requesting party or its representative to inspect, copy, test, or sample the following items in the responding party's possession, custody, or control:
(A) any designated documents or electronically stored information — including writings, drawings, graphs, charts, photographs, sound recordings, images, and other data or data compilations — stored in any medium from which information can be obtained either directly or, if necessary, after translation by the responding party into a reasonably usable form; or

(B) any designated tangible things; or

(2) to permit entry onto designated land or other property possessed or controlled by the responding party, so that the requesting party may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it."

So, as they say, get use to it and when you have filed suit, well we will deal with your abberant view of the law, in the interim we will deal with Danny's abberant view of the law...he files suite, does not have to prove his case, and wins...
sorry but it did not work in the State of Illinois case and it won't work here. And we can state that with confidence as the documents role in, not from 3ABN but from third parties...now 3ABN, it is your turn!!! Produce or we will push to compel.

You know, Anyman, you just don't seem to comprehend that we EXPECT TO WIN!!! The weight of the evidence continues to grow in our favor. Unless they come up with something a bit more solid than Danny Says, the trial will be just another big loss for 3ABN while they appeal to avoid the inevitable judgment. But the judgment will come and all the appeals in the world are unlikely to reverse the truth. And we are not the only issue that remains unresolved!!!

So, enjoy the discovery and we will prepare our defense, etc. Like it or lump it.


Gailon Arthur Joy

[Gailon Arthur Joy]

Wishful thinking, ANYMAN?

Why don't you jump right into this case and put your money where your mouth is. So far, this case has been anything but OUR undoing. If you think that relevant documentation can be kept out of the discovery process, well, dream on. Financial documentation is central to the question of damages...keep up hoping ANYMAN...and remember ALL THE RULES!

They are 3ABN's undoing. File suit and then try and hide the evidence...now isn't that classic... and all this to get the truth out. WHAT HYPOCRACY!!!

Gailon Arthur Joy

[anyman]

Rule 26 (b)(2)(C) On motion or on its own, the court must limit the frequency or extent of discovery otherwise allowed by these rules or by local rule if it determines that:

(i) the discovery sought is unreasonably cumulative or duplicative, or can be obtained from some other source that is more convenient, less burdensome, or less expensive;

(iii) the burden or expense of the proposed discovery outweighs its likely benefit, considering the needs of the case, the amount in controversy, the parties' resources, the importance of the issues at stake in the action, and the importance of the discovery in resolving the issues.

If one reads the latest filings by Mr. Pickle and the attrorney for 3ABN, it is obvious that the remands are "unreasonably cumulative or duplicative" and the court has grounds to deny the requests and limit them to only the materials that are relevant to the Complaint.

Additionally, seems like Ian and others you have threatened my very well be able to avail themselves of

Rule 26 (c)(1) A party or any person from whom discovery is sought may move for a protective order in the court where the action is pending - or as an alternative on matters relating to a deposition, in the court for the district where the deposition will be taken. The motion must include a certification that the movant has in good faith conferrred or attempted to confer with other affected parties in an effort to resolve the dispute without court action. The court may, for good cause, issue an order to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense, including one or more of the following:

(A) forbidding the disclosure or discovery;

(B) specifying terms, including time and place, for the disclosure of the discovery;

(C) prescribe a discovery method other than the one selected by the party seeking discovery;

(D) forbidding inquiry into certain matters, or limiting the scope of disclosure or discovery to certain matters;

(E) designating the persons who may be present while the discovery is conducted;

(F) requiring that a deposition be sealed and opened only on court order;

(G) requiring that a trade secret or other confidential research, development, or commercial information not be revealed or be revealed only in a specified way;

(H) requiring parties to simultaneously file specified documents or information in sealed envelopes, to be opened as the court directs.

You see, the courts have the authority to end your sides harassing behavior and keep you and your sidekick in line with the Complaint and the issues that are contained in it. You can threaten and thump your chest - but you are not above the law (as you seem to believe). You can try and spin a web and attempt to get the Court to enter, but they won't. You are beholden to the law and not above it, including claims against you and Mr. Pickle of harassment and unethical behavior.

You flaunt Rule 26 as though it gives you free reign over society to do as you wish, but it will probably bring you and your charging horses back down to earth via the limits it can inflict.

Wishful thinking, ANYMAN?

Why don't you jump right into this case and put your money where your mouth is. So far, this case has been anything but OUR undoing. If you think that relevant documentation can be kept out of the discovery process, well, dream on. Financial documentation is central to the question of damages...keep up hoping ANYMAN...and remember ALL THE RULES!

They are 3ABN's undoing. File suit and then try and hide the evidence...now isn't that classic... and all this to get the truth out. WHAT HYPOCRACY!!!

Gailon Arthur Joy

[Bob Pickle]

Well, anyman, why doesn't 3ABN/Danny amend their complaint if they want to narrow discovery?

[anyman]

No need as the Court, more than likely, will require you to stick to the context of the Complaint. Again, you think you can manipulate the court and falsely assume you can operate outside the laws of the land the Federal Rules of Civil Procedure. Time to follow the letter of law Mr. Pickle.

Well, anyman, why doesn't 3ABN/Danny amend their complaint if they want to narrow discovery?

[Bob Pickle]

Anyman, you didn't answer my question: why doesn't 3ABN/Danny amend their complaint if they want to narrow discovery?

Look at the complaint. It clearly talks about whether Danny had biblical grounds for divorce or not. But the plaintiffs don't want us to touch that one, it appears.

They also make the allegation that 3ABN is a principled, dedicated ministry, and has been so for more than 20 years, but they don't want us to touch that allegation either.

So why don't they simply remove all such allegations form their complaint?

Another allegation is that donations have declined, and have declined because of us. But they don't want us to touch that one either.

So answer my question: why doesn't 3ABN/Danny amend their complaint if they want to narrow discovery?

[Daryl Fawcett]

If they remove those allegations, what will be left?

[Bob Pickle]

My, that sure is a bright question, Daryl.

But then again, you don't have to be that bright to figure that one out!

[anyman]

Anyman, you didn't answer my question: why doesn't 3ABN/Danny amend their complaint if they want to narrow discovery?

Mr. Pickle, I am not going to waste the time of those who read here with questions that hold no relevance to the issues being discussed. If you want to ask a question that is applicable, holds relevance, then I may indulge you - but this one, not wasting anyone's time on it.

Look at the complaint. It clearly talks about whether Danny had biblical grounds for divorce or not. But the plaintiffs don't want us to touch that one, it appears.

You are wrong, I pointed this out, you can choose to ignore it or accept it . . . but it has been asked and answered, go back and check.

They also make the allegation that 3ABN is a principled, dedicated ministry, and has been so for more than 20 years, but they don't want us to touch that allegation either.

Your >opinion< in regards to this issue is immaterial. The mission of 3ABN, the work of 3ABN, the dedication of those who work there from top to bottom will convince a jury that you are lowing smoke up the wrong chimney. If 3ABN wanted to parade one witness after another who would testify to the dedication, the principle, and the Christian spirit they could keep the jury in rapt attention for months . . . but then you don't care about the souls lead to the foot of the cross, you just want to be "right," you want to "win," you aren't interested in the saving of souls - or so the fruit on your tree would indicate.

So why don't they simply remove all such allegations form their complaint?

The Complaint is pretty through and successfully outlines the issues that are being litigated. You have to choose . . . let me add some emphasis . . . YOU . . . have to decide if you are going to remain within the context of the Complaint or waste the courts time and your nonexistent finances trying to make this into more than the Court has acknowledge the case is about. You have your own personal agenda and the Court doesn't care - it just doesn't care what your personal issues are, your personal agenda is, it is going to force you to remain within the appropriate context so you don't waste their time or money.

Another allegation is that donations have declined, and have declined because of us. But they don't want us to touch that one either.

Again, you are trying to add to what has been defined. You want more, you want to spend months and weeks trying to make your case. You want access to all the documents in your list - relevant or not - If you bothered to remain within the context of the Complaint you might actually ave completed your discovery and be in oral arguments already . . . but you just want to go on and on and on and on and on and on and on and on . . . only to in the end be left naked in front of those you have deluded.

So answer my question: why doesn't 3ABN/Danny amend their complaint if they want to narrow discovery?

Here it is, in case you missed it in the beginning of my response . . . I am not going to waste readers time on your questions when they are not relevant or within the context of the Complaint. You can complain, even whine about it, but there is no use or benefit in discussing this. You need to pull back and focus your discovery on those documents and depositions that actually have something to do with the Complaint.

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