REQUEST FOR ADMISSIONS ADMISSION REOUEST FOR ADMISSION NO. Ros you employed Jaime Ross Castillo as the agent or representative location Mexico and other locations on behalf of Abed behalf of business entities controlled entitie Abed. busines by Admit Deny _______ ________
Admit
that to acQuire aircraft for use in
of
Abed
or on
with anything Admission you responded to Request for Admissions answer the following Interrogatory unqualified admission
If State fact
other
than an
every
you
rely
upon
in
thi making this
response.
document you rely upon in making this denial and as to each such thi document by title author and date state the current or last known custodian of the document describe documents the subject matter addressed in the document and state the substance of the information contained in the document as it relates to this response. relate thi
Identify
every
document
identify
the
10
11
witnes thi Identify every witness who can provide testimony in support of this response witness addres busines addres give the witnesss personal address and telephone number business address and telephone witnes number subject matter on which the witness is expected to testify and substance of the
expected testimony.
and
12
13
REQUEST FOR ADMISSION NO.2
Admit
outlined that
14
Abed employed
15
Mexico
in Request in his
For Admission No.
or the
Abed Abeds name
Jaime Ros Castillo as your agent or representative Ross as because Abed could not acquire aircraft in
name
of any business closely busines
associated
with
Abed
16
due to the bankruptcy
and failure of
TAESA
Admit
17
Deny _______
for Admission Admissions
18
If you responded to Request unqualified admission answer the
with anything other
than an
following Interrogatory
19
State
every
fact
you
rely
upon you
in
thi making this
response.
20
Identify
every
document
rely
upon
in
thi making this
denial
and
as to each
such
document
21
custodian
the
identify the document by title author and date state the current or last of the documents describe the subject matter addressed in the document document
known
and state
substance
of the information contained
in the
document
as
it
relate relates to this response. thi
22
23
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telphone addres busines addres give witnes number subject matter on which the witness is expected to testify and substance ot the
the
24
25
expected
testimony.
REQUEST FOR ADMISSION NO.3
Admit that defendant number was purchased in part with finds provided find Ross Ros Castillo which were obtained from Alejandro Romero Garcia. Admit by Jaime
26 27
Deny _______
28
Case 2:04-cv-00363-JWS
Document 137-3
Filed 11/21/2005
Page 1 of 15
with anything Admission you responded to Request for Admissions admission answer the following Interrogatory unqualified
If State
other
than an
thi every fact you rely upon in making this response. thi upon in making this denial and as to each such and date state the current or last known the subject matter addressed in the document and state information contained in the document relate thi as it relates to this response. every document
Identify
you
rely
document
custodian
the
identify
of the
document by documents document describe
the
title author
substance
of the
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telphone busines addres addres witnes number subject matter on which the witness is expected to testify and substance of the
give the expected
testimony.
REQUEST FOR ADMISSION NO.4
10
Admit that defendant number fund was purchased in part with funds provided Ross Ros Castillo which were obtained from Alejandro Romero Garcia. Admit
by Jaime
11
Deny _______
anything other than an
12 If you responded to Request for Admissions Admission with unqualified admission answer the following Interrogatory
13
14
State
every
fact
you
rely
upon you
in
thi making this response.
15
Identify
every document
rely
upon
in
thi making this
denial
and as to each such
document
16
custodian
the
document by identify of the document describe documents
the
title author and date state the current or last known the subject matter addressed in the document and state in the
substance
of the information contained
document
as
it
relate relates to this response. thi
17
18
witnes thi Identify every witness who can provide testimony in support of this response and busines addres witness addres give the witnesss personal address and telephone number business address and telephone witnes number subject matter on which the witness is expected to testify and substance of the
expected testimony.
19
20
21
REQUEST FOR ADMISSION NO.5
Admit that defendant number fund was purchased in part with funds provided Ross Ros Castillo which were obtained from Alejandro Romero Garcia. Admit by Jaime
22
Deny _______
other than
23
24
25
Admission with anything you responded to Request for Admissions answer the following Interrogatory unqualified admission
If State
an
every
fact
you
rely
upon
in
thi making this
response.
26
27
28
document you rely upon in making this denial and as to each such thi document by title author and date state the current or last known custodian of the document describe documents the subject matter addressed in the document and state in the document relate thi the substance of the information contained as it relates to this response.
Identify
every
document
identify
the
Case 2:04-cv-00363-JWS
Document 137-3
Filed 11/21/2005
Page 2 of 15
Identify
give the
witness witnesss
subject
number
expected
of this response thi witnes every witness who can provide testimony in support busines addres business address and telephone address addres and telephone number personal matter on which the witnes is expected to testify and substance of the witness
and
testimony.
REQUEST FOR ADMISSION NO.6
Admit that defendant number fund was purchased in part with funds provided by Jaime Ross Ros Castillo which were obtained from bank accounts of Enrique Giraud Mijares account Mijare other Loma Palma Giraud and others at Scotiabank Inverlat Lomas Palmas Branch by wire transfers transfer traveler cheques and cash conducted travelers cheque by Account Executive Myriam Serdio. Admit
Deny _______
anything other than an
If you responded to Request for Admissions Admission with unqualified admission answer the following Interrogatory
10
State
every
fact you
rely
upon
in
thi making this
response.
11
document
12
thi Identify every document you rely upon in making this denial and as to each the document author and date state the current or last known identify by title of the
such
custodian
the
document documents
describe
the
subject in the
matter addressed
in the
document
and state
substance
of the information contained
document
as
it
relate relates to this response. thi
13
14
witnes thi Identify every witness who can provide testimony in support of this response and witness addres busines addres give the witnesss personal address and telephone number business address and telephone witnes number subject matter on which the witness is expected to testify and substance of the
expected testimony.
15
16
REQUEST FOR ADMISSION NO.7
Admit that defendant number fund was purchased in part with funds provided by Jaime Ross Ros Castillo which were obtained from bank accounts of Enrique Giraud Mijares account Mijare other Loma Palma Giraud and others at Scotiabank Inverlat Lomas Palmas Branch by wire transfers transfer traveler cheques and cash conducted travelers cheque by Account Executive Myriam Serdio. Admit ________
17
18
19
Deny _______
other
20
21
Admission with anything you responded to Request for Admissions answer the following Interrogatory unqualified admission
If State
than an
22
every fact you rely upon
in
thi making this
response.
23
document
24 custodian
the 25
thi Identify every document you rely upon in making this denial and as to each such identify the document by title author and date state the current or last known of the documents describe the subject document matter addressed in the document and state of the information contained
in the
substance
document
as
it
relate relates to this response. thi
26
27
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres witnes number subject matter on which the witness is expected to testify and substance ofthe
give the expected testimony.
28
10
Case 2:04-cv-00363-JWS
Document 137-3
Filed 11/21/2005
Page 3 of 15
REQUEST FOR ADMISSION NO.8
Admit that defendant number fund was purchased in part with funds provided by Jaime Ross Ros Castillo which were obtained from bank accounts of Enrique Giraud Mijares account Mijare other Loma Palma Giraud and others at Scotiabank Inverlat Lomas Palmas Branch by wire transfers transfer traveler cheques and cash conducted travelers cheque by Account Executive Myriam Serdio.
Admit
Deny _______
than
If you responded to Request for Admissions Admission with anything other unqualified admission answer the following Interrogatory
an
State
every fact you
rely
upon
in
thi making this
response.
document
custodian
10 the
thi Identify every document you rely upon in making this denial and as to each the document author and date state the current or last known identify by title of the document describe documents
the subject in the
such
matter addressed
in the
document
and state
substance
of the information contained
document
as
it
relate relates to this response. thi
Il
12
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres witnes number subject matter on which the witness is expected to testify and substance of the
give the expected
testimony.
13
14
REQUEST FOR ADMISSION NO.9
Admit
the the purchase of defendant number XA-TSR was structured to conceal of the funds used to acquire the aircraft and to conceal the ownership fund source that
15
16
interest of Jaime
Ross-Castillo and Alberto
Abed-Schekaiban.
17
Admit
18
Deny _______
than an
19
If you with anything other for Admissions Admission responded to Request unqualified admission answer the following Interrogatory
20
21
State
every
fact you
rely
upon
in
thi making this
response.
document
22 custodian
the 23
identify
thi Identify every document you rely upon in making this denial and as to each the document by title author and date state the current or last known
the subject in the
such
of the document describe documents
substance
of the information contained
mattr addressed in the document and document as it relates to this response. relate thi
state
24
25
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres witnes number subject matter on which the witness is expected to testify and substance of the
give the expected
testimony.
26 27
REQUEST FOR ADMISSION NO. 10
Admit
the that the purchase of defendant number XA-TUF was structured to conceal fund source of the funds used to acquire the aircraft and to conceal the ownership
28
interest of Jaime
Ross-Castillo and Alberto
Abed-Schekaiban.
Case 2:04-cv-00363-JWS
Document 137-3
11
Filed 11/21/2005
Page 4 of 15
Admit
If
Deny _______
to Request for
you responded
Admission Admissions
10
with
unqualified admission
State
answer
the
following
in
Interrogatory
10
anything other than an
every
fact you
rely
upon you
thi making this
response.
Identify
every document
rely
upon
in
thi making this
denial
and as to each
such
document
custodian
the
document by identify of the document describe documents
the
substance
title author and date state the current or last known the subject matter addressed in the document and state relate thi of the information contained in the document as it relates to this response.
witnes thi Identify every witness who can provide testimony in support of this response witness addres busines addres give the witnesss personal address and telephone number business address and telephone witnes number subject matter on which the witness is expected to testify and substance of the
expected
10 testimony.
and
REQUEST FOR ADMISSION NO. 11
Paragraph
11
number
fund funds
12
except
for the
and
through Ross denial indicates indicate lack
Ros
of the stolen 70 of the complaint states state The sole beneficiary returned transfers to the original Romero account transfer was Jaime Ross Ros two Alberto Abed and his straw or shell companies. In your answer your of knowledge
are
regarding the of the
funds source of the fund provided
by Ross.
13
Admit
14 benefit 15
that you
now
on
notice
funds source of the fund provided
refuse to disgorge the in the form of control
Ross by Jaime Ros
and continue
to
Castillo
and continue
to hold the
fund funds
fund funds
from the possession defendant aircraft.
funds of the fund
over the three
16
Admit
Deny _______
17
If you responded to Request with anything other for Admissions Admission unqualified admission answer the following Interrogatory
11
11
than an
18 State 19
every
fact
you
rely
upon
in
thi making this response.
20
21
thi you rely upon in making this denial and as to each such document by title author and date state the current or last known identify custodian of the document describe the subject matter addressed in the document and state documents the substance of the information contained in the document relate thi as it relates to this response.
Identify
every document
document
the
22
23
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres witnes number subject matter on which the witness is expected to testify and substance of the
give the expected testimony.
24
REQUEST FOR ADMISSION NO. 12
25
Paragraph 26 27
80 of the complaint
state states
The 6/13/01
wire of
$1000000 from
in
the
Romero BNP account to Ros Ross account at Casa de Cambio of Turismo por Computadora was then sent by Ross name Ros Lear Jet account in Dallas Texas as partial payment for the Dalla Texa
for that paragraph neither admit or denies the admits denie be divided into separate sections. allegations.
Mexico City in the in three $300000 increment increments to Defendant Lear. Your answer
Majapara Therefore allegation your allegations
will
28
12
Case 2:04-cv-00363-JWS
Document 137-3
Filed 11/21/2005
Page 5 of 15
A.
Admit
that
Abed
did
2001
Admit
as alleged
in paragraph
not provide Ros with $950000 in cash on or about June Ross 80 of your Answer.
20
Deny _______
for Admission Admissions
If you responded to Request unqualified admission answer the
12A
with
following Interrogatory
12A
anything other than an
State every fact you rely upon in making this response thi specifically including State why cash would be used in the performance of an proof of the source of the cash. international financial transaction of this magnitude. thi
Identify
every document
you
rely
upon
in
thi making this
denial
and as to each
such
document
custodian
the
document by identify of the document describe documents
the
title author and date state the current or last the subject matter addressed in the document in the
known
and state
substance
of the information contained
document
as
it
relate relates to this response. thi
10
thi witnes Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres give witnes number subject matter on which the witness is expected to testify and substance of the
the
11
expected
B. If
testimony. persist in your claim that
12
you
Abed
did provide
Ros Ross
with
$950000
in cash
on or
13
in paragraph 80 of your Answer Admit that the as alleged the financial transaction in cash was to conceal the fi.inds from fi.ind purpose of conducting the government of Mexico and the banks to which Abed was obligated regarding the
about June
20 2001
14
imminent Admit
If
financial
collapse
of
bank TAESA.
15
Deny _______
other
16
Admission 12B with anything you responded to Request for Admissions answer the following Interrogatory unqualified admission
than an
l2B
17 State 18 Identify 19
every
fact
you
rely
upon you
in
thi making this
in
response.
every
document
rely
upon
thi making this
denial
and as to each
such
document
custodian
the
identify the document by title author and date state the current or last of the documents describe document the subject matter addressed in the document
known
and state
20
substance
of the information contained
in the
document
as
it
relate relates to this response. thi and
21
22
witnes thi Identify every witness who can provide testimony in support of this response witness addres busines addres give the witnesss personal address and telephone number business address and telephone witnes number subject matter on which the witness is expected to testify and substance of the
expected
testimony.
23 C.
24
25
Admit that you have no evidence or records including deposit slips into Casa de record slip Cambio Majapara which establish what Ross may have done with the $950000 Ros in cash you allege was delivered on or about June 20 2001 as alleged in paragraph 80 of Answer. your Admit
26
Deny _______
27
28
If you responded Admissions to Request for Admission unqualified admission answer the following Interrogatory
12C
with anything other than an
12C
13
Case 2:04-cv-00363-JWS
Document 137-3
Filed 11/21/2005
Page 6 of 15
State
every
fact you
rely
upon
you
the
in
thi making this
in
response.
Identify
every document
rely
upon
thi making this
state the
denial current
and as to each
or last
such
document
custodian
the
identify
of the
document by documents document describe
the
title author and date subject in the
known
and state
matter addressed
in the
document
substance
of the information contained
document
as
it
relate relates to this response. thi and
witnes thi Identify every witness who can provide testimony in support of this response witness addres busines addres give the witnesss personal address and telephone number business address and telphone witnes number subject matter on which the witness is expected to testify and substance of the
expected D.
testimony. are based
Admit upon
that the allegation contained allegations oral representations representation allegedly
in paragraph
80 of your Answer
solely
made by
Ross.
Admit
Deny _______
for Admission Admissions
10
If you responded to Request unqualified admission answer the
12D
with
following Interrogatory
12D
anything other
than
an
11
State
every
fact
you
rely
upon you
in
thi making this
in
response.
12
Identify
every document
rely
document
13
custodian
the
the document identify by title author and date state the current or last known of the documents describe document the subject matter addressed in the document and state
upon
thi making this
denial
and as to each
such
substance
of the information contained
in the
document
as
it
relate relates to this response. thi
14
15
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres give witnes number subject matter on which the witness is expected to testify and substance of the
the
16
expected
E.
testimony.
that
17
Admit
contained
18
in paragraph
you have no evidence with which 80 of the Complaint
in the three
to dispute specifically
or contradict related
the
allegation allegations and
to the
source
Romero
of the fund contained funds Majapara
wire transfers transfer
dated June
25 27
29
19
from Casa de Cambio number 1. Admit
If
and which were applied to the purchase
of defendant
20
Deny _______
21
Admissions you responded to Request for Admission unqualified admission answer the following Interrogatory
State fact
12E with
12E
anything other than an
22 every
you
rely
upon
in
thi making this response.
23
24
25
document you rely upon in making this denial and as to each such thi document by title author and date state the current or last known identify custodian of the document describe the subject documents matter addressed in the document and state the substance of the information contained in the document relate thi as it relates to this response.
Identify
every
document
the
26 27
witnes thi Identify every witness who can provide testimony in support of this response addres witness busines addres give the witnesss personal address and telephone number business address and telephone witnes number subject matter on which the witness is expected to testify and substance of the
expected testimony.
and
28
14
Case 2:04-cv-00363-JWS
Document 137-3
Filed 11/21/2005
Page 7 of 15
REQUEST FOR ADMISSION NO. 13
state Ros provided investigators states Ross investigator copy above transactions. Ross confirmed Ros that he then sent three $300000 wires on June 25 27 and 29 2001 from his Turismo wire por Nation Computadora account to an account at Nations Bank now Bank of America in Dallas Dalla in the name of Lear Jet Inc. In Answer you state Claimant believe the three wire Claimants your transfer came from funds provided transfers fund from legitimate earning earnings of Mr. Abed.
Paragraph 82 of the most recent of the
$1000000
BNP
complaint
wire transfer
reflecting
the
TX
Admit
that
claimant claimants have
in the wire
no evidence
upon which
to base
thi this belief that the fund funds
other
contained
transfer transfers
representation representations
allegedly
came from earning of earnings provided by Ross.
Abed
than oral
Admit
Deny _______
If you responded to Request for Admissions Admission with anything other than an unqualified admission answer the following Interrogatory
13
13
10
State
every
fact
you
rely
upon you
in
thi making this
response. denial
11
Identify
every
document
rely
upon
in
thi making this
and as to each such
document
12
custodian
the
identify the document by title author and date state the current or last of the documents describe document the subject matter addressed in the document
known
and state
substance
of the information contained
in the
document
as
it
relate relates to this response. thi
13
14
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres witnes number subject matter on which the witness is expected to testify and substance of the
give the expected testimony.
15
16
REQUEST FOR ADMISSION NO. 14
17
Paragraph
18
including paragraph to the Lear Jet funds fund
92 of the complaint refers to refer stipulation executed by Ross specifically which admit that allegations admits fund les traced allegation of funds of not less that $900000 of not less than les
traced to the
Ros
$892000 You
traced
to the
Austa
funds helicopter and fund of
19
les not less than 260-262
$250000
308
Cessna
aircraft also
as alleged that
in paragraph paragraphs
265
and 309 are correct.
deny
Ros Ross
upon
received
20
21
$5000000
provision.
in cash
from
Abed
and give notice
of reliance
80 82-83 90 les no less than Mexican Criminal Code
A. 22
23
Admit that claimants have no evidence upon which to contradict the admission of claimant Ross Ros that not less than $900000 of Romeros funds can be traced to the Lear Jet les Romero fund Romero funds of not less than $892000 can be traced to the Agusta helicopter and fund les Romero funds of not less than $250000 can be traced to the Cessna aircraft as fund les
alleged in paragraphs paragraph
80 82-83 90 260-262 Deny _______
for
265
308
and 309.
24
Admit
25
26
If you responded to Request unqualified admission answer the
Admission Admissions
14A
with anything other than an
following Interrogatory
l4A
27 28
State
every
fact you
rely
upon
in
thi making this
response.
Case 2:04-cv-00363-JWS
Document 137-3 15 Filed 11/21/2005
Page 8 of 15
document
custodian
the
identify
in making this denial and as to each thi Identify every document you rely upon the document state the current or last known title author and date by the subject in the
such
of the document describe documents
matter addressed
in the
document
and state
substance
of the information contained
document
as
it
relate relates to this response. thi
thi witnes Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telqphone busines addres addres witnes number subject matter on which the witness is expected to testify and substance of the
give the
expected
B.
testimony.
Admit
that
Abed
provided
les not less than
$5000000
in cash
to Ross
Ros
for the
purchase
of
aircraft.
Admit
Deny _______
If you responded to Request for Admissions Admission the following Interrogatory unqualified admission answer
14B
with anything other than an
14B
10
State
thi every fact you rely upon in making this response. such
11
document
12
identify
thi Identify every document you rely upon in making this denial and as to each the document by title author and date state the current or last known
the subject in the
custodian
the
of the document describe documents
matter addressed in the
document
and state
substance
of the information contained
document
as
it
relate relates to this response. thi
13
14
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres give witnes number subject matter on which the witness is expected to testify and substance of the
the
15
expected
C.
testimony.
16
Admit
that
allegations allegation
Ross of Ros contained
in the
stipulation
do not accuse
Abed
of any
cnme
17
in Mexico.
Admit
18
Deny _______
19
If you responded to Request for Admissions Admission the following Interrogatory unqualified admission answer
l4C with
l4C
anything other than an
20
21
State
every
fact
you
rely
upon
in
thi making this
response.
22
23
document you rely upon in making this denial and as to each such thi document by title author and date state the current or last known custodian of the document describe documents the subject matter addressed in the document and state the substance of the information contained in the document as it relates to this response. relate thi
Identify
every
document
identify
the
24
25
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres give witnes number subject matter on which the witness is expected to testify and substance ofthe
the
expected D.
testimony.
that provisions provision in
26 27
Admit
United
admissibility
of the stipulation
Mexican Federal Penal Code Ross thi provided by Ros in this
are not determinative
civil
of the
in the
forfeiture
action
States.
28
Admit
Deny _______
16
Case 2:04-cv-00363-JWS
Document 137-3
Filed 11/21/2005
Page 9 of 15
If you
responded
to Request the
for
Admission Admissions
14D
with anything other than an
unqualified admission answer
State fact
following
Interrogatory
14D
every
you
rely
upon
in
thi making this
response.
Identify
every document
document
custodian
the
identify
of the
document by documents document describe
the
thi you rely upon in making this denial and as to each title author and date state the current or last known
the subject in the
such
matter addressed
in the
document
and state
substance
of the information contained
document
as
it
relate relates to this response. thi
thi witnes Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telqphone addres busines addres witnes number subject matter on which the witness is expected to testify and substance of the give the expected
testimony.
REQUEST FOR ADMISSION NO. 15
10
Paragraph Paragraphs
93 to 107 of the
Ros Ross Romero
11
and Inverlat
bank
transaction and involvement with complaint relate to transactions and financial transactions transaction related to his account and do not
mention
Abed
Admit
or his fellow claimants.
12
that claimant do not contest claimants
that these
event events
and including 107 happened
13
and that claimants have claimant complaint
specifically
allegation allegations
containecf specific
in the
in the paragraphs alleged paragraph 93 no reason to dispute the that claimants do not contest claimant
to
Romero
14
lost
sum which was Deny _______
repaid by Inverlat.
Admit
15 If
16
Admission you responded to Request for Admissions 15 with anything the following Interrogatory answer unqualified admission
other
15
than an
17
State
every
fact
you
rely
upon you
the
in
thi making this
response.
18
Identify
every document
rely
upon
in
thi making this
denial
and as to each
such
document
19
identify
custodian
the
of the
document by documents document describe
the
title author and subject in the
date state the current or last known matter addressed in the document and state
substance
of the information contained
document
as
it
thi relate relates to this response.
20
21
witnes thi Identify every witness who can provide testimony in support of this response and witness addres busines addres give the witnesss personal address and telephone number business address and telerhone witnes number subject matter on which the witness is expected to testify and substance of the
expected testimony.
22
23 24
REQUEST FOR ADMISSION NO. 16
mentioned as owning an interest in Vuelamex in paragraph number 119 an allegation by Abed. The paragraphs of the complaint numbered 108 to 122 other paragraph with Ross Serdio victims generally victim than 119 relate to transactions transaction and involvement Ros described as the family of Em-ique Giraud Mijares Giraud and Inverlat Mijare bank and financial transaction transactions related to accounts of the victims and do not mention Abed or his fellow account victim
is
Abed
denied
25 26
claimants.
27 28
17
Case 2:04-cv-00363-JWS
Document 137-3
Filed 11/21/2005
Page 10 of 15
in the paragraph 108 to that claimants do not contest claimant that these events alleged event paragraphs the 118 and from 120 to 122 happened and that you have no reason to dispute in the complaint that you do not contest the victims victim allegation contained allegations specifically
Admit
lost
specific
sum which was
repaid by Inverlat.
Admit
If
Deny _______
other
Admission you responded to Request for Admissions 16 with anything the following Interrogatory unqualified admission answer
than an
16
State
every fact you
rely
upon
in
thi making this
response.
document you rely upon in making this denial and as to each such thi document by title author and date state the current or last known identify custodian of the document describe documents the subject matter addressed in the document and state the substance of the information contained in the document relate thi as it relates to this response.
Identify
every
document
the
10
witnes thi Identify every witness who can provide testimony in support of this response and witness addres busines addres give the witnesss personal address and telephone number business address and telphone witnes number subject matter on which the witness is expected to testify and substance of the
expected
testimony.
11
12
REOUESTFORADMISSIONNO.
17
13
14
admission The paragraph of the complaint numbered 123 to 138 relate to admissions made by paragraphs Serdio in an interview on or about March 22 2002 regarding victims victim generally described as the family of Enrique action of Ross and his co-conspirators Ros Giraud Mijares Giraud actions and Mijare co-conspirator
other
than mentioning
fear of
Abed
at
paragraph
136
do not mention
Abed
or his fellow
15
claimants.
16
A.
Admit
that
138 happened
17
complaint
that these events event alleged in the paragraph 123 to contest paragraphs and that you have no reason to dispute the allegations allegation contained in the that claimant do not contest claimants Serdio made these statements. specifically
claimant claimants do not
18
Admit
Deny _______
19
If you responded to Request for Admission Admissions unqualified admission answer the following Interrogatory
17A
with
17A
anything other
than an
20
State 21 Identify
every
fact
you
rely
upon you
in
thi making this response.
every document
rely
upon
in
thi making this
denial
and as to each
such
22
document
custodian
the
document by identify of the document describe documents
the
title author and date state the current or last the subject matter addressed in the document in the
known
and state
23 24
substance
of the information contained
document
as
it
relate relates to this response. thi
25 26 27
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres witnes number subject matter on which the witness is expected to testify and substance of the
give the expected
testimony.
B.
Admit
fear
that
claimant claimants do not have any evidence
as alleged in the
with which to deny that Serdio has
of
Abed
paragraph
136.
28
18
Case 2:04-cv-00363-JWS
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Page 11 of 15
Admit
If you
Deny _______
responded
to Request the for Admission Admissions
l7B with
unqualified admission answer
State
following Interrogatory
l7B
anything other than an
every
fact
you
rely
upon you
in
thi making this
in
response.
Identify
every
document
rely
upon
thi making this
denial
and as to each such
document
custodian
the
identify the document by title author and date state the current or last of the documents describe document the subject matter addressed in the document
known
and state
substance
of the information contained
in the
document
as
it
relate relates to this response. thi
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telphone busines addres addres witnes number subject matter on which the witness is expected to testify and substance of the
give the
expected
testimony.
10
REQUEST FOR ADMISSION NO. 18
The paragraph of the complaint numbered 139 to 154 relate to admissions made by admission paragraphs Serdio in an interview on or about April 10 2002 regarding victims generally described as victim the family of Enrique action Ros and Giraud Mijares Giraud actions of Ross and his co-conspirators Mijare co-conspirator
do not mention
11
12
Abed
or his fellow claimants.
13
14
Admit
in the
154 happened
15 statements. 16
claimant claimants do not contest that these events alleged in the paragraphs event paragraph 139 to and that claimants have no reason to dispute claimant the allegations allegation contained that claimants do not contest claimant Serdio made these complaint specifically
that
Admit
17 If
Deny _______
18
Admission you responded to Request for Admissions 18 with anything the following Interrogatory answer unqualified admission
18
other
than an
19
State
every
fact
you
rely
upon
in
thi making this
response.
20
21
document you rely upon in making this denial and as to each such thi document by title author and date state the current or last known custodian of the document describe documents the subject matter addressed in the document and state the substance of the information contained in the document relate as it relates to this response. thi
Identify
every
document
identify
the
22
23
witnes thi Identify every witness who can provide testimony in support of this response and witness addres busines addres give the witnesss personal address and telephone number business address and telephone witnes number subj ect matter on which the witness is expected to testify and substance of the
expected testimony.
24
25
REQUEST FOR ADMISSION NO. 19
The paragraphs of the complaint numbered 155 to 178 the first 177 paragraph 178 relate to admission made by Serdio in an interview on or about April 11 2002 regarding victims admissions victim described Giraud Mijares Giraud actions as the family of Enrique action of Ross and his Ros generally Mijare financial transactions transaction conducted co-conspirator co-conspirators by Serdio and do not regarding specific
mention
26 27
28
Abed
or his fellow
claimants.
19
Case 2:04-cv-00363-JWS
Document 137-3
Filed 11/21/2005
Page 12 of 15
Admit
that
claimant claimants do not
and that you
contest
that these
event events
Serdio
did
alleged the
in the
paragraph paragraphs 155
contained
to
178 happened
have
no reason
to dispute
allegation allegations
these in the table
in the
complaint
the
specifically that you do not contest financial transaction transactions alleged specifically in the
first
made
statement statements
and that
as set out occur.
of financial
transaction transactions
paragraph
number
178
Admit
If
Deny _______
other
Admission you responded to Request for Admissions 19 with anything the following Interrogatory answer unqualified admission
19
than an
State
every
fact
you
rely
upon you
in
thi making this response.
Identify
every document
rely
upon
in
thi making this
denial
and as to each
such
document
custodian
the
identify the document by title author and date state the current or last of the documents describe document the subject matter addressed in the document
known
and state
substance
of the information contained
in the
document
as
it
relate relates to this response. thi
10
11
witnes thi Identify every witness who can provide testimony in support of this response and witness addres busines addres give the witnesss personal address and telephone number business address and telephone witnes number subject matter on which the witness is expected to testify and substance of the
expected testimony.
12
REQUEST FOR ADMISSION NO. 20
13 14
Aerospace
Abed
15
numbered paragraph 177 of the complaint alleges that Bombardier allege the Defendant Lear Jet and sold it to Jaime Ross and Alberto Ros Inc. manufactured sale office in Tucson Arizona. through the Lear Jet regional aircraft sales and maintenance you
filed denied the
The second
The Answer
Calezar
Lear
1A was
sold to
Ros Ross
and claimed
that
Abed
through
Ltd
purchased
Lear with
Abed
family money.
16
17
A.
Admit Admit
If
that
Ros Ross
executed
the purchase
contract
for defendant
Lear
Jet.
18
Deny ______
other
19
Admission 20A with anything you responded to Request for Admissions the following Interrogatory unqualified admission answer
than an
20A
20
State 21
every
fact
you
rely
upon
in
thi making this
response.
22
23
document you rely upon in making this denial and as to each such thi document by title author and date state the current or last known identify custodian of the document describe documents the subj ect matter addressed in the document and state the substance of the information contained in the document relate thi as it relates to this response.
Identify
every
document
the
24
Identify
witness give the witnesss
25
number
expected
subject
witnes thi every witness who can provide testimony in support of this response and addres busines addres personal address and telephone number business address and telephone witness matter on which the witnes is expected to testify and substance of the
testimony.
26
B.
27 28
Admit that not all of the purchase price other than the amount financed by BCI was find fund from paid from finds contained in the Calezar Ltd. account from funds provided
Abed
and his family.
20
Case 2:04-cv-00363-JWS
Document 137-3
Filed 11/21/2005
Page 13 of 15
Admit
________
Deny _______
If you responded to Request for Admissions Admission unqualified admission answer the following Interrogatory
20B
with
20B
anything other
than an
State
thi every fact you rely upon in making this response. every document you
the rely
Identify
upon
in
thi making this denial
and as to each
such
document
custodian
the
identify
of the
document by documents document describe
the
title author and subject in the
date state the current or last known matter addressed in the document and state
substance
of the information contained
document
as
it
relate relates to this response. thi
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres give witnes number subject matter on which the witness is expected to testify and substance of the
the
expected
testimony.
10
C.
Admit
that
11
Ross by Ros which were unrelated included receipt of funds from Abed and fund
controlled
portion
of the purchase
price
of the Lear Jet came
to the
from accounts account
Calezar
Ltd.
account
which
did
not
his family.
12
Admit
If
Deny _______
13
Admission you responded to Request for Admissions the following Interrogatory unqualified admission answer
State
20C
with anything other
than
an
20C
14
every fact you rely upon in making every document you
the rely
thi this response. thi making this
state the denial current in the
15 Identify 16
upon
in
and as to each
or last
such
document
custodian
the
document by identify of the document describe documents
the
title author and subject
in
date matter addressed
known
and state
document
17
substance
of the information contained
the
document
as
it
relate relates to this response. thi
18
Identify
witness give the witnesss
19
number
expected
subject
witnes thi every witness who can provide testimony in support of this response and addres busines addres personal address and telephone number business address and telephone witness matter on which the witnes is expected to testify and substance of the
testimony.
20
21
REQUESTFORADMISSIONNO.
Paragraph
21
state states
22
number
179 of the complaint
23
Contract negotiations Lear between BA in Tucson to purchase the Defendant negotiation and Ross and Alberto Abed commenced in approximately April 2001. Ros Arizona
24
The answer claimants claimant
25
filed denied
Ros Ross
was purchaser
under
limited
power of attorney
under
Irish law.
However
and claimed Ross acted only Ros claimant claimants admit Ros was Ross
guarantor of the financing. 26 A. 27 28
Admit
Lear
that
Ros Ross
Jet if he
would not have personally guaranteed the financing of the defendant for the purchase of the defendant Lear Jet. were not party to contract
Admit
Deny _______
21
Case 2:04-cv-00363-JWS
Document 137-3
Filed 11/21/2005
Page 14 of 15
If you responded to Request for Admissions Admission answer the following Interrogatory unqualified admission
2lA
with anything other than an
2lA
State
thi every fact you rely upon in making this response.
document
custodian
the
thi Identify every document you rely upon in making this denial and as to each such identify the document by title author and date state the current or last known of the documents describe document the subject matter addressed in the document and state of the information contained
in the
substance
document
as
it
relate relates to this response. thi
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres witnes number subject matter on which the witness is expected to testifj and substance of the
give the expected
B. testimony.
Admit
contract
that
Ros Ross
representative representatives
10
was the primary contact person or contract negotiator with the of Lear Jet for the purchase of the defendant Lear Jet executing
regarding
the sale contract.
all
document documents
Admit
11
Deny _______
for Admission Admissions to Request answer the following Interrogatory
If 12
you responded
21B
with
unqualified admission
State
2lB
anything other
than an
13
every fact you
rely
upon you
in
thi making this response.
14
Identify
every document
rely
upon
in
thi making this
denial
and as to each
such
document
15
custodian
the
document by identify of the document describe documents
the
title author and date state the current or last known the subject matter addressed in the document and state in the
substance
of the information contained
document
as
it
thi relate relates to this response.
16
17
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres witnes number subject matter on which the witness is expected to testify and substance of the
give the expected
testimony.
18
19
REOUEST FOR ADMISSION NO. 22
20 Paragraph
21
number
182 of the complaint
state states
The
22
N224LJ
23 24
25
United States registration State was registered just prior to export with Delaware corporation called Wilmington Trust Company as Owner Trustee effectively concealing the ownership interest of Ros and Abed Ross and their nominee foreign corporations.
aircraft to
The answer claimants claimant
rezistered to
filed denied
the
of
Abed
Wilmington Trust and claims that Abed has been cooperating and providing claim
years.
denied
that this registration thi
Lear Jet was exported admitted the jet was was used to conceal ownership
record records to the
govemment
for several
26 A. 27
Admit
that
the to
contract
executed
Ross by Ros
for the
exportation
Mexico
of the Lear Jet after
purchase cash sale.
of the Lear Jet called
for the
28
Admit
Deny _______
22
Case 2:04-cv-00363-JWS
Document 137-3
Filed 11/21/2005
Page 15 of 15