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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