Free Motion to Quash - District Court of Arizona - Arizona

If you

responded

to Request the

for

Admission Admissions

22A

with

unqualified admission answer
State

following

Interrogatory

22A

anything other

than an

thi every fact you rely upon in making this response. every

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

document

the

witnes thi Identify every witness who can provide testimony in support of this response and witness busines addres 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.

B.

be performed
10

Ros by Ross for the purchase of the Lear Jet could not due to an inability to pay the balance due on the contract by purchasers purchaser leading to the need to obtain financing of the balance due.
Admit
that the contract as executed

11

Admit

Deny _______

12

If you responded to Request for Admission Admissions unqualified admission answer the following Interrogatory

22B

with

22B

anything other than an

State 14

every

fact

you

rely

upon

in

thi making this

response.

15

16

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

17

18

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.

19

20
21

C.

the interest of Abed in the defendant Lear Jet could not be identified by an of the registration document available to the public associated documents with both inspection Wilmington Trust Company as Owner Trustee and Calezar Ltd. as the alleged source

Admit

that

22
23

the

of the purchase funds because no beneficial fund records public record of either entity.

ownership

interest of

Abed

appeared

in

Admit
If

Deny _______
other

24

Admission 22C with anything you responded to Request for Admissions the following Interrogatory unqualified admission answer

22C

than an

25 State

every

fact

you

rely

upon you
the

in

thi making this

response.

26
Identify

every document

rely

upon

in

thi making this
state the

denial current

and

as to each

such

27
28

document
custodian
the

document by identify of the document describe documents
the

title author and subject in the

date

or last

known
and state

matter addressed

in the

document

substance

of the information contained

document

as

it

relate relates to this thi response.

23

Case 2:04-cv-00363-JWS

Document 136-4

Filed 11/21/2005

Page 1 of 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 telphone number subject matter on which the witnes is expected to testify and substance of the witness
expected D.
testimony. the cooperation of Abed regarding the defendant defendant Lear Jet was seized when the interest of

Admit

that

Lear Jet

commenced
already

only

after the

Abed had

been

discovered.

Admit

Deny _______
for

If you responded to Request unqualified admission answer the

Admission Admissions

22D

with anything other

than an

following Interrogatory

22D

State

every

fact you

rely

upon

in

thi making this response. such

document
10

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

custodian
the

of 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

11

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 telphone 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. 23
15

Paragraph
16

number

183 of the complaint

state states

17

Abed also contracted with BA to purchase or lease/purchase four Lear Jets and one BD-100 Corporate jet in the names of Uptongrove Jet name three Lears and Casafin Ltd Lear 40 and BD-100 respectively. Lear
and
other

Ros Ross

Ltd.

18

Your answer denied
19 the

that

name names

of Uptongrove
that

Ros Ross contracted Lear Lears and Casafin
additional in the

with

BA

to purchase

additional

aircraft in

Lear and

BD-lOO.

20
21

Admit

Ros Ross
by

executed

contract contracts

manufactured

BA

names name of Uptongrove

for the purchase of the aircraft Ltd. and Casafin Ltd.

Admit
22

Deny _______
for

23

If you responded to Request unqualified admission answer the

Admission Admissions

23

with anything other

following Interrogatory

23

than an

24
25

State

every

fact

you

rely

upon

in

thi making this

response.

26
27

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 relates to this response. thi as
Identify

every

document

identify

the

it

28

give 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 telephone addres busines addres

24

Case 2:04-cv-00363-JWS

Document 136-4

Filed 11/21/2005

Page 2 of 14

number
expected

subject

matter on which the witness witnes

is

expected

to testify

and substance

of the

testimony.

REQUEST FOR ADMISSION NO. 24
Paragraph

number

184 of the complaint

state states
to be

Ros Ross

and

Abed
Lear.

caused

numerou progres payment numerous progress payments
but the only completed

made

into

all

of the
the

proposed Defendant

aircraft transactions transaction

transaction

involved

be

proposed denied on the basis that you did not basi A.

Claimant Claimants made into all of

answer
the

denied that Ros and Ross

Abed

caused

aircraft transactions.

know
of

to

what completed

numerous progres payment numerou progress payments The balance of the paragraph was
transaction
referred.

to

Admit

that

contract contracts
10

with

Ros Ross at BA

the

direction

for the

delivery

Abed made progres payments pursuant progress payment of aircraft descnbed in the complaint.

to

Admit
If

Deny ______
other

11

Admission 24A with anything you responded to Request for Admissions the following Interrogatory unqualified admission answer

24A

than an

12 State 13 Identify 14

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

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

15

substance

of the information contained

document

as

it

relate relates to this response. thi

16

17

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.
at

and

18 B. 19

Admit that
transaction the direction

the

time of the

seizure

of the defendant

aircraft

the

or completed

contract

of

Abed

was

for the purchase of an aircraft executed with the defendant Lear Jet. that associated

only completed Ross by Ros

at

20

Admit
21 If

Deny _______
other

22

for Admissions Admission 24B with anything you responded to Request answer the following Interrogatory unqualified admission

than an

24B

23

State

every

fact

you

rely

upon
you
the

in

thi making this response.

24

Identify

every document

rely

upon

in

thi making this
state the

denial current

and as to each
or last

such

document
25

identify

custodian
the

of the

document by documents document describe
the

title author and subject in the

date

known
and state

matter addressed

in the

document

substance

of the information contained

document

as

it

relate relates to this response. thi and

26

27

give

the

number
28

witnes who can provide testimony in support of this response thi every witness addres busines addres witnesss witness personal address and telephone number business address and telephone witness matter on which the witnes is expected to testify and substance ofthe subject
Identify testimony.

expected

Case 2:04-cv-00363-JWS

Document 136-4

25

Filed 11/21/2005

Page 3 of 14

REQUEST FOR ADMISSION NO. 25
number statement Paragraph numbers 186 to 199 of the complaint relate to statements Intemational Contract Administrator Daniel Louis in Tucson Contracts Arizona. Loui Claimant answer Claimants answers
knowledge. A.
to these

made by

BA

paragraph paragraphs

generally

are

denial denials based

on lack

of

Admit Louis Loui

dealt with

Ros Ross

and

Abed

Lear Jet but on purchase andlor lease and one BD-100 corporate jet.

not only on the purchase of the Defendant for four other Lear models model contract purchase contracts

Admit

Deny _______

If you responded for Admission Admissions to Request the following Interrogatory unqualified admission answer

25A

with

25A

anything other

than an

State 10

thi every fact you rely upon in making this response. such

11

document
custodian
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

matter addressed

in the

document

and state

12

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

expected
15 B. 16

testimony.
that

Admit

Alberto

Abed

contract contracts

for the

purchase

represented that he was of the aircraft.

partner

with Ros regarding the Ross

17

Admit

Deny _______

18

If you responded to Request for Admission Admissions the following Interrogatory unqualified admission answer

25B

with

25B

anything other than an

19 State

thi every fact you rely upon in making this response. such

20
21

document
custodian
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

matter addressed

in the

document

and state

22

substance

of the information contained

document

as

it

relate relates to this response. thi

23

24
25

witnes who can provide testimony in support of this response and thi Identify every witness 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 testifiy and substance of the
give the expected testimony.

26

C.

Admit

that

Alberto Ltd.

Abed

Uptongrove
27

as indicated

of represented Jaime Ross was CEO and/or President on numerous contract numerou related official documents.

Ros

Admit
28

Deny _______

26

Case 2:04-cv-00363-JWS

Document 136-4

Filed 11/21/2005

Page 4 of 14

If

you responded

unqualified admission
State

to Request answer the

for

Admission Admissions

25C

with anything other than an

following

Interrogatory

25C

every

fact you

rely

upon

in

thi making this

response.

Identify

every document

document
custodian
the

document by identify of the document describe documents
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

witnes thi Identify every witness who can provide testimony in support of this response witness busines addres 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 ot the
expected D. testimony.
that Alberto

and

Admit

Abed

received

contract contracts

related

to the

acquisition

of aircraft which

represented Jaime
10

Ros Ross

was

CEO andlor

President of Uptongrove

Ltd.

Admit

Deny _______
for

11

If you responded to Request unqualified admission answer the

Admission Admissions

25D

with anything other than an

following Interrogatory

25D

12 State 13

every

fact you

rely

upon

in

thi making this

response.

14

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

15

substance

document

as

it

relate relates to this response. thi

16

17

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 witnes number subject matter on which the witness is expected to testify and substance of the give the expected testimony.

18

19

E.

Admit

that Alberto

Abed was

aware

that Ltd.

Jaime

Ros Ross

represented to

BA

that he

was

CEO
20

andlor President

of Uptongrove

Admit
21

Deny _______

22
23

If you responded to Request for Admissions Admission unqualified admission answer the following Interrogatory

25E with

25E

anything other than an

State

every

fact

you

rely

upon

in

thi making this

response.

24

document
25

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

custodian
the

matter addressed

in the

document

and state

substance

of the information contained

document

as

it

relate relates to this response. thi

26

27 28

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.

27

Case 2:04-cv-00363-JWS

Document 136-4

Filed 11/21/2005

Page 5 of 14

F.

Admit

that Jaime

Ros Ross
in the

was an agent

for Alberto Ltd.

Abed

aircraft for

Abed

name

oflJptongrove

regarding the acquisition and Casafin Ltd.

of

Admit

________

Deny _______

If you responded for Admission Admissions with to Request the following Interrogatory unqualified admission answer

25F

25F

anything other

than an

State

every

fact

you

rely

upon

in

thi making this

response.

thi document you rely upon in making this denial and as to each such 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

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 telqphone addres busines addres witnes number subject matter on which the witness is expected to testify and substance of the
give the
10

expected G.

testimony.

11

Admit
for the the

that

Jaime Ros signed almost Ross Agusta.

all

of the

contracts contract

as the

six aircraft contract but also contracts

on the contract

for the

buyer not just Defendant Cessna

at

BA

and for

12

Defendant

13

Admit
If

Deny _______

14

Admission you responded to Request for Admissions the following Interrogatory unqualified admission answer
State

25G

with

25G

anything other

than an

15

every

fact you

rely

upon

in

thi making this

response.

16

17

18

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 thi as it relates to this response relate
Identify

every

document

the

19

20
21

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 telqphone addres busines addres give witnes number subject matter on which the witness is expected to testify and substance of the
the

expected

testimony.

22

H.

Admit
contract

that

for the

Jaime Ros was specifically authorized to act for Abed with respect Ross Defendant Cessna and for the Defendant Agusta.

to the

23

Admit
24
25 If

Deny _______
other

Admission 25H with anything you responded to Request for Admissions the following Interrogatory answer unqualified admission

than an

25H

26

State

thi every fact you rely upon in making this response. every

27

Identify

document
28

identify

the

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

Case 2:04-cv-00363-JWS

Document 136-4

28

Filed 11/21/2005

Page 6 of 14

custodian
the

of the document describe documents

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

witness thi Identify every witnes 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
testimony.

and

I.

Admit

that the contract for the financing of defendant Lear Jet included as additional loan security for insurance which would pay the balance of the debt due to provision BCI in the event the purchaser failed to continue to make the required payments.

Admit

Deny _______
for Admission Admissions

If you responded to Request unqualified admission answer the

251

with anything other than an

following Interrogatory

251
response.

State 10

every

fact

you

rely

upon

in

thi making this

11

12

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

13

14

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 telphone addres busines addres witnes number subject matter on which the witness is expected to testify and substance of the give the expected
testimony.

15

REQUEST FOR ADMISSION NO. 26
16

17

Representative

number statements Paragraph numbers 200 to 219 of the complaint relate to statement Alberto Castaneda in Tucson Anzona.

made by

BA

Sale Sales

18

A.
19

on several occasion occasions regarding directions direction spoke with Castaneda Ros sale contract given to Ross to make progress payments on several of the sales contracts progres payment including the Lear 31A.
that

Admit

Abed

Abed

have

20

Admit
21 If

Deny _______
other

22

for Admissions Admission 26A with anything you responded to Request answer the following Interrogatory unqualified admission

than an

26A

23

State

every

fact

you

rely

upon

in

thi making this

response.

24

document
25

custodian
the

thi Identify every document you rely upon in making this denial and as to each such the document by title author and date state the current or last known identify 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 and

26
Identify

27

witnesss give the witness

number
28

subject

witnes thi every witness who can provide testimony in support of this response address busines addres personal addres and telephone number business address and telephone witness matter on which the witnes is expected to testify and substance of the

expected

testimony.

29

Case 2:04-cv-00363-JWS

Document 136-4

Filed 11/21/2005

Page 7 of 14

B.

Admit

that

Abed

did

associated

with these

not provide funds to Ross to make these progress payments fund Ros progres payment sale contract for aircraft including the Lear 31A. sales contracts

Admit
If

Deny _______
other

Admission 26B with anything you responded to Request for Admissions admission answer the following Interrogatory unqualified

than an

26B

State

thi every fact you rely upon in making this response. such

document
custodian
the

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

of the document describe documents of the

matter addressed

in the

document

and state

substance

information contained

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 telephone addres busines addres witnes number subject matter on which the witness is expected to testify and substance of the
give the
10

expected
C.

testimony.

11

Admit that pursuant Arizona. in Tucson Admit

to the

contract

executed

Ross by Ros

the

Lear Jet

1A was

delivered

12

Deny _______

13 If you responded for Admission Admissions to Request unqualified admission answer the following Interrogatory

26C with

anything other

than an

14

26C

15

State

every

fact

you

rely

upon

in

thi making this response. such

16

document
17

thi Identify every document you rely upon in making this denial and as to each the document identify by title author and date state the current or last known of the document describe documents of the
the subject in the

custodian
the

matter addressed

in the

document

and state

substance

information contained

document

as

it

relate relates to this response. thi

18

19

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 D.
testimony.

20

21

Admit that Abed was very
Institucional including the

22

close to the leadership of the PRI Partido Revolucional and performed chatter aircraft services service for high level PRI members member former Mexican president Carlos Salinas de Gortari. Carlo Salina

23

Admit
If

Deny _______
other

24
25

Admission 26D with anything you responded to Request for Admissions the following Interrogatory unqualified admission answer

than an

26D

State

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 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

Case 2:04-cv-00363-JWS

Document 136-4

30

Filed 11/21/2005

Page 8 of 14

Identify

witness give the witnesss

number
expected

subject

thi witnes every witness who can provide testimony in support of this response busines addres addres personal address and telephone number business address and telphone witness matter on which the witnes is expected to testify and substance of the

and

testimony.

E.

Admit that PRI Partido Admit

at

the

time of the seizure

of defendant

Lear Jet the then President
the
aircraft.

of the

Revolucional

Institucional

was on board

Deny _______

If Admissions you responded to Request for Admission unqualified admission answer the following Interrogatory

26E with

26E

anything other

than an

State

every

fact

you

rely

upon

in

thi making this

response.

document
10

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

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

11

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 telphone addres busines addres witnes number subject matter on which the witness is expected to testify and substance of the
give the expected
F.

13

testimony.
that the

14

Admit

flight

was

chartered

to assist the

Revolucional
15

Institucional in Florida.

regarding medical

then President of the PRI Partido treatment for his wife which she was

undergoing

16

Admit

Deny _______

17

If you responded to Request for Admissions 26F with anything other than an Admission the following Interrogatory unqualified admission answer

26F

18 State 19

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 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 relates to this as thi response.
Identify

every

document

the

it

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 give witnes number subject matter on which the witness is expected to testify and substance of the
the

expected
24

testimony.

25

G.

Admit Admit
If

that the

flight

was

publicly

described

as

demonstration flight
Institucional

for

which

the

then President of the PRI Partido
26

Revolucional

did not pay.

________

Deny _______
other

27
28

Admission 26G with anything you responded to Request for Admissions the following Interrogatory unqualified admission answer

260

than an

31

Case 2:04-cv-00363-JWS

Document 136-4

Filed 11/21/2005

Page 9 of 14

State

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

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

witness thi Identify every witnes 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.

H.

Admit that
the

the

action actions

complaint

own

for operation passenger airline in

in ofjet aircraft as outlined by Abed regarding the acquisition in Mexico could not be revealed because Abed could not Mexico prior to February 16 2005.

10

Admit
If

Deny _______
other

11

Admission you responded to Request for Admissions 26H with anything the following Interrogatory answer unqualified admission

than an

26H

12 State 13 Identify 14

every fact you every

rely

upon you

in

thi making this

response.

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

15

substance

of the information contained

in the

document

as

it

relate relates to this thi 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
18
I.

testimony.

Admit that
allow the
respect

that

Abed

executed

19

continued

to the

bankruptcy

operation action

loan to personal guarantees regarding the loans provided guarantee of and that those obligations continue with obligation

TAESA

of

TAESA.

20
21

Admit

Deny ______
than an

22

If you responded for Admissions 261 with anything other Admission to Request unqualified admission answer the following Interrogatory

261

23 State

every

fact

you

rely

upon

in

thi making this

response.

24

25

document
custodian
the

thi Identify every document you rely upon in making this denial and as to each the document identify by title author and date state the current or last known of the document describe documents of the
the subject in the

such

matter addressed

in the

document

and state

26 27

substance

information contained

document

as

it

relate relates to this response. thi

give the
28

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

Case 2:04-cv-00363-JWS

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32

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Page 10 of 14

number
expected

subject

matter on which the witness witnes

is

expected

to testify

and substance

of the

testimony.
to the bankruptcy

Admit that pursuant
conceal

action actions

of

TAESA

Abed

is

not allowed and

to

remove

or fail to account control.

for revenue

generated

by

TAESA

over which

Abed continues continue
Admit
If

to maintain

Deny _______
other

for Admissions 26J with anything Admission you responded to Request 26J unqualified admission answer the following Interrogatory

than an

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

11

thi witnes 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
testimony.

and

12

13

REQUEST FOR ADMISSION NO. 27
A.

14

Admit

that

SIASA

is

company

in

Mexico

owned and

controlled

by Abed.

15

Admit
16

Deny _______

17

If you responded to Request for Admission Admissions unqualified admission answer the following Interrogatory

27A

with anything other

than an

27A

18

State

every

fact

you

rely

upon

in

thi making this

response.

19

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 as it relates to this response. relate thi
Identify

every

document

identify

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
B. testimony.

24
25

Admit

that

controlled

company by Abed.

the

which own and controls owns control

SIASA

is

company

owned

and

26

Admit

Deny _______

27
28

If you responded to Request for Admission Admissions unqualified admission answer the following Interrogatory

27B

with anything other

than an

27B

33

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Page 11 of 14

State

every

fact

you

rely

upon

in

thi making this

response.

Identify

every document

document
custodian

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

the 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 witnes number subject matter on which the witness is expected to testify and substance of the
give the expected testimony.

REOUEST FOR ADMISSION NO. 28
A.

Admit

that

Abed

used

Holding Holdings
purchase
10

Ltd. the

as corporate aircraft.

Uptongrove Ltd. Casafin Ltd. Calezar Ltd. and Hartslope nominees nominee to acquire aircraft and move money required

to

Admit
11

Deny _______
other

12

Admission you responded to Request for Admissions 28A with anything unqualified admission answer the following Interrogatory
If

than an

28A

13

State

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 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

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

18

expected

testimony.

19

B. 20

Admit

that

Abed

directed

Ros Ross

and others to use Uptongrove other
Ltd. the as corporate aircraft.

Ltd.

Casafin Ltd.
aircraft

Calezar Ltd.

and Hartslope Holdings Holding
to purchase

nominee nominees

to acquire

and move money required
21

Admit
22 If

Deny _______
other than

23

Admission you responded to Request for Admissions 28B with anything admission answer the following Interrogatory unqualified

an

28B

24
25

State

every

fact

you

rely

upon

in

thi making this

response.

document
26 27 custodian
the

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

matter addressed

in the

document

and state

substance

of the information contained

document

as

it

relate relates to this response. thi

28

give 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 telephone addres busines addres

Case 2:04-cv-00363-JWS

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34

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Page 12 of 14

number
expected

subject

witnes matter on which the witness

is

expected

to testify

and substance

of the

testimony.

C.

Admit
at

that Calezar Ltd.

is

busines business
portion

through which aircraft listed above.

BNP

large

or corporate of the funds fund

name

used

to

open

Swis Swiss many

account

passed

to acquire

of the

Admit
If

Deny _______
other

Admission you responded to Request for Admissions 28C with anything unqualified admission answer the following Interrogatory

than an

28C

State

every

fact

you

rely

upon you
the

in

thi making this

response.

Identify

every document

rely

upon

in

thi making this

denial

and as to each

such

document
10

identify

custodian
the

of the

document by documents document describe
the

title authQr and subject in the

date state the current or last matter addressed in the document

known
and state

substance

of the information contained

document

as

it

relate relates to this response. thi

11

12

witness thi Identify every witnes 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.

13

14

D.
15

Admit

that

one principal
to act as

activity corporate

stated

for Calezar Ltd.

in its

corporate
it

form forms

is

the

company

was

nominee and be dormant
the

and

remained

dormant

until approximately 16

April

2001 when

aircraft acquisitions acquisition

commenced.

17

Admit

Deny ______
for Admission Admissions

18

If you responded to Request unqualified admission answer the

28D

with

following Interrogatory

28D

anything other than an

19 State

every

fact

you

rely

upon you

in

thi making this response.

20
Identify 21

every document

rely

upon

in

thi making this

denial

and as to each

such

document
custodian
the

the document identify by title author and date state the current or last the subject of the documents describe document matter addressed in the document

known
and state

22

substance

of the information contained

in the

document

as

it

relate relates to this response. thi

23

24

witnes thi Identify every witness who can provide testimony in support of this response and addres witness witnesss personal address and telephone number business address and telephone busines addres witnes number subject matter on which the witness is expected to testify and substance of the
give the expected
testimony.

25

26

E.

Admit

that

one principal
to act as April

activity

stated

for Casafin Ltd.

in its

company
27 28

was

corporate nominee and be dormant

forms is the form corporate and it remained dormant

until approximately

2001 when

the

aircraft acquisitions acquisition

commenced.

35

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Page 13 of 14

Admit
If you

Deny _______
responded
to Request the for

Admission Admissions

28E

with

unqualified admission answer
State fact

following
in

Interrogatory

28E

anything other

than an

every

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

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 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 telephone witnes number subject matter on which the witness is expected to testify and substance of the
expected
testimony.

10

F.

11

for Uptongrove Ltd. in its corporate forms is form nominee and be dormant and it remained company was to act as corporate dormant until approximately April 2001 when the aircraft acquisitions acquisition commenced.

Admit
the

that

one principal

activity

stated

12

Admit
13

Deny _______

14

If you for Admissions 28F with Admission responded to Request the following Interrogatory unqualified admission answer

28F

anything other

than an

15

State

every

fact

you

rely

upon

in

thi making this

response.

16

17

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 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

identify

the

18

19

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 0.
testimony.

20

21

Admit

that

one Principal

Activity

stated

for Hartslope Holding Holdings
is

Ltd.

forms form is The 22
23

in its corporate

company

act acts

as

corporate nominee and

dormant.

Admit

Deny _______

24
25

If you for Admissions Admission responded to Request the following Interrogatory unqualified admission answer

280

with anything other

280

than an

State 26

thi every fact you rely upon in making this response. every

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 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 as it relates to this response. relate thi
Identify

document

the

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Page 14 of 14