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
Case 2:04-cv-00363-JWS
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Page 1 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 2 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
Case 2:04-cv-00363-JWS
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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
Case 2:04-cv-00363-JWS
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Page 4 of 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 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. 29
A.
Admit
from
that
of the total purchase
price
defendant
number
BNP Swiss Swis
one
approximately
of approximately $6 million paid to BA for $2800000 of the payment which originated
controlled
account accounts which were
Ross by Ros and
not
Abed.
Admit
Deny _______
If you responded to Request for Admissions Admission the following Interrogatory unqualified admission answer
29A
with
29A
anything other
than an
State 10
thi every fact you rely upon in making this response. every
11
12
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 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
13
14
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
15
16
B.
Admit
that
of the total purchase
price
of approximately
$6 million paid to
BA
for
defendant
17
Abed Abeds
Admit
If you
thi number one approximately $2800000 of this payment did not come income from TAESA held in accounts in the name of Calezar Ltd. account
from
18
Deny ______
responded
for
19
to Request answer the unqualified admission
Admission Admissions
29B
with anything other than an
following Interrogatory
in
29B
20
State 21 Identify
every fact you rely upon every document
thi making this response.
you
the
rely
upon
in
thi making this
denial
and as to each
such
22
23
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 and
24 give the
25
number
expected
witnes thi every witness who can provide testimony in support of this response busines addres witnesss witness personal addres and telephone number business address and telephone address witness matter on which the witnes is expected to testify and substance of the subject
Identify testimony.
26
C. 27
Admit that $892000 of the total purchase price of the Agusta is traced to finds find removed from the Romero accounts and not from any accounts controlled by Abed. account account Admit
28
Deny _______
37
Case 2:04-cv-00363-JWS
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Admission 29C with anything you responded to Request for Admissions answer the following Interrogatory admission unqualified
If
other
than an
29C
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
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.
REOUEST FOR ADMISSION NO. 30
Admit
10 the
Abed never supplied personal financial statement in support of of any of the aircraft including the defendant Lear Jet specifically purchase of including the submission personal statement to Wilmington Trust Company.
that
Alberto
11
Admit
________
Deny _______
for Admission Admissions
12
If you responded to Request unqualified admission answer the
30
with anything other
following Interrogatory
in
30
than an
13 State 14 Identify 15
every
fact
you
rely
upon you
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
16
17
relate relates to this response. thi Attach copy of the personal financial statement supplied by Abed to Wilmington Trust thi Company and every other company involved in this action.
as
it
substance
of the information contained
in the
document
18 give 19
Identify the witness witnesss subject
number
expected
witnes thi every witness who can provide testimony in support of this response and address addres and telephone number business address and telephone busines addres personal witness matter on which the witnes is expected to testify and substance of the
testimony.
20
21
REQUEST FOR ADMISSION NO. 31
A.
22
Admit
that
Abed own owns
control or controls
financial
majority interest in Holding statement
in his
Aeronautica
Turistica 23
identified
in the as part
Wilmington Trust Admit
If
of the transactions transaction
presented to BCI and regarding the Lear Jet 31A.
name
24
25
Deny _______
with anything other than an
Admission 31 you responded to Request for Admissions answer the following Interrogatory unqualified admission
State
1A
26 every
fact
you
rely
upon
in
thi making this
response.
27
Identify
every
28
document
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
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38
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Page 6 of 14
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
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.
Admit
that
Holding
Aeronautica
Turistica
is
owned
and controlled
by Franmil
Holdings.
Admit
Deny _______
with
If you responded to Request for Admission 31 Admissions the following Interrogatory unqualified admission answer
31B
anything other than an
State
thi every fact you rely upon in making this response. every
10
11
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
12
13
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
C. testimony.
14
15
Admit Admit
If
that
Abed own owns
control or controls
majority interest of Franmil
Holdings.
16
Deny ______
17
Admissions 1C with you responded to Request for Admission the following Interrogatory unqualified admission answer
State fact
31C
anything other than an
18
every
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 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
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 subject matter on which the witness is expected to testify and substance of the
expected testimony.
24
25
REQUEST FOR ADMISSION NO. 32
At paragraph
of the answer
the
26 291 27
28 that
all
fund funds
used
cash
from Mr.
Abed Abeds
to purchase legitimate
Claimant appears thi appear this assertion Claimants state their belief Defendant aircraft came from the Calezar Ltd. account
or
assets.
Case 2:04-cv-00363-JWS
Document 132-9
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Page 7 of 14
A.
Admit
belief
that that
Claimant Claimants have no evidence with which
all
Ltd.
account
to support the statement of such ftind ftinds used to purchase the Defendant aircraft came from the Calezar assets. or cash from Mr. Abeds legitimate
Abed
Admit
Deny _______
If you responded to Request for Admission Admissions unqualified admission answer the following Interrogatory
32A
with anything other than an
32A
State
every
fact
thi you rely upon in making this response. you
the rely
Identify
every document
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 matter addressed in the document
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
expected
11
testimony.
12
B.
Admit
to
that
financial
account
in the
name
make
contract
13
controlled
payment payments by Abed nor did
for the
it
aircraft received
of Calezar Ltd. at BNP in Switzerland flind no flinds from any entity
used
receive
cash from Mr.
Abed Abeds
legitimate
assets.
14
Admit
If
Deny _______
other
15
Admission 32B with anything you responded to Request for Admissions the following Interrogatory unqualified admission answer
than an
32B
16 State 17 Identify 18
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 known the subject matter addressed in the document and state in the
19
substance
of the information contained
document
as
it
relate relates to this response. thi
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 telephone addres busines addres witnes number subject matter on which the witness is expected to testify and substance of the
give the
expected 22
testimony.
23
C.
Admit
that
claimant claimants cannot demonstrate Casa de Cambio
legitimate
million dollar source for the millions of dollars
in aircraft progres payment in the progress payments
form of cash
24
Mexico
Cambio.
specifically
Intercontinental
House through Exchange Houses in and Consultoria Casa de
25
Admit
26
Deny _______
27 28
If you responded to Request for Admission Admissions unqualified admission answer the following Interrogatory
32C with
32BC
response.
anything other
than
an
State
every
fact you
rely
upon
in
thi making this
Case 2:04-cv-00363-JWS
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Page 8 of 14
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
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 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.
REQUEST FOR ADMISSION NO. 33
At paragraphs 299 and 300 of paragraph
the
claimant answer claimants
from
assert that Ross
Abed 5950000 in cash from legitimate funds fund that Abed required Ross to sign Ros receipt.
A.
Abed Abeds
earning earnings
at
Ros received from TAESA and denied
that 10
Claimant Claimants have no evidence or financial records which support or establish record in cash from TAESA were ever presented to Ross as Ros $950000 payment for the LearJet3lA.
that
Admit
11
Admit
Deny _______
12
If Admissions you responded to Request for Admission unqualified admission answer the following Interrogatory
33A
with anything other than an
33A
13 State 14
every fact you rely upon
in
thi making this
response.
15
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
such
of the
document documents
describe
the
subject in the
matter addressed
in the
document
and state
16
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 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
19
testimony.
20
21
B.
generated from TAESA was required to be used first to pay and secondly to repay the loans to financial institution which loan institutions expense expenses defaulted were subsequently on as the result of non payment by TAESA.
Admit
that revenue
operating
22
23
Admit
Deny _______
If you responded to Request for Admission Admissions the following Interrogatory unqualified admission answer
33B
with
33B
anything other
than an
24
State 25
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
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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.
C.
Admit
the
that the
generated
by
TAESA
of these
alleged
financial
transaction
was required
to be conducted
in cash from revenue involving $950000 in cash to prevent the discovery of insecure
diversion
fund funds
from the financially
company.
Admit
Deny _______
If you responded for Admissions Admission to Request unqualified admission answer the following Interrogatory
33C with
33C
anything other than
an
State
every
fact
you
rely
upon
in
thi making this
response.
10
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
such
matter addressed
in the
document
and state
11
substance
of the information contained
document
as
it
relate relates to this response. thi
12
13
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.
14
15
REQUEST FOR ADMISSION NO. 34
At paragraph
conducted on their behalf
that
16
305 of the answer claimants deny the details of financial claimant detail the basis of lack of knowledge and information. basi on
transaction transactions
17
Admit
18
claimant claimants have Answer
no evidence
responds.
or financial
record records which contradicts contradict
of the most recent
or to
disproves disprove the
information set out
in paragraph
305
Complaint
which claimants claimant
19
Admit
20
Deny _______
21
If you responded for Admissions Admission with anything other to Request the following Interrogatory unqualified admission answer
34
34
than an
22
State
every
fact
you
rely
upon
in
thi making this
response.
23
document
24
25
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
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.
28
Case 2:04-cv-00363-JWS
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42
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Page 10 of 14
REQUEST FOR ADMISSION NO. 35
aircraft as
At paragraph 311 of the answer claimants deny the Defendant Cessna and Agusta claimant fund Ros were paid for in part with stolen Romero funds from the Ross Credit Suisse account shown below. Admit
that
claimants have claimant
no evidence
or financial
record records which contradicts contradict
of the most recent
or to
information set out in paragraph which claimant Answer responds. claimants disproves disprove the
311
Complaint
Admit
Deny _______
for
If you responded to Request unqualified admission answer the
Admission Admissions
35
with
following Interrogatory
in
35
anything other
than an
State
every fact you rely upon every document
thi making this
in
response. denial
Identify 10
you
rely
upon
thi making this
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
11
substance
of the
information contained
in the
document
as
it
relate relates to this response. thi
12
13
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.
14
15
REQUEST FOR ADMISSION NO. 36
claimant claimants deny the details of financial transactions detail transaction of knowledge and information. The complaint Cessna was paid for in part by two large wires that originated wire at allege alleges that the Defendant Consultoria Casa de Cambio in the name of Flota Mexicana de Aviacion.
312 of the answer conducted
16
At paragraph
basi on their behalf on the basis of lack
17
18
Admit
19
that
claimant claimants have no evidence
or financial
record which contradicts records contradict
or to
disproves disprove the
which
20
information set out in paragraph claimants claimant Answer responds.
312 of the most recent
Complaint
Admit
21 If
Deny _______
responded
to Request the for Admission Admissions
you
36
with
22
unqualified
admission answer
State
following Interrogatory
36
anything other than an
23
every
fact
you
rely
upon
in
thi making this
response.
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 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
identify
the
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.
28
43
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Page 11 of 14
REQUEST FOR ADMISSION NO. 37
denied that TAESA was operating capital of TAESA disappeared Ros strawman or front of Mexico denied that Abed used Ross as supported by the Republic find man to conceal his ownership interest of the aircraft and/or control over the finds admitted .. that TAESA pertained to and was operated by Abed and in 1995 TAESA fell into accident denied
that the
At paragraph
314 of
the
claimant answer claimants
alleged
that
TAESA
failed because
of an
grave financial A.
crisi crisis from
which
it
could
never recover. because
the
Admit
capital
that
TAESA
to continue
filed bankruptcy to function.
company
lacked
sufficient
operating
Admit
Deny _______
If you responded to Request for Admission Admissions unqualified admission answer the following Interrogatory
37A
with anything other
than an
37A
State 10
every
fact
you
rely
upon
in
thi making this
response.
11
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 the
such
of the document describe documents
matter addressed in the document
and state
12
substance
of the information contained
document
as
it
thi relate relates to this response. and
13
Identify give
witnesss the witness
subject
14
number
expected
witnes thi every witness who can provide testimony in support of this response address addres and telephone number business address and telphone busines addres personal matter on which the witnes is expected to testify and substance of the witness
testimony.
15
16
B.
Admit
bills.
that
the
grave
financial to the
crisi crisis from fact
it
which
it
could
never recover revenue
faced by
to pay
its
TAESA
17
in 1995
related
failed to generate
sufficient
18
Admit
Deny _______
for Admission Admissions
19
If you responded to Request unqualified admission answer the
37B
with anything other
than an
following Interrogatory
37B
20
State 21 Identify
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
22
23
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 and
24
25
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 telephone witnes number subject matter on which the witness is expected to testify and substance of the expected testimony.
26
27 28
C.
Admit that the funds removed from TAESA by Abed as outlined in the complaint and fund answer in thi action and used to acquire the identified aircraft did not assist the this crisi grave financial crisis from which TAESA could never recover.
44
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Page 12 of 14
Admit
If
Deny _______
other
Admission 37C with anything you responded to Request for Admissions answer the following Interrogatory unqualified admission
than an
37C
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
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.
10
D.
Admit
that
the
Government of Mexico provided
institution institutions 11
to assist
TARSA
in obtaining
loan guarantees to financial guarantee financing to continue to operate.
Admit
12
Deny _______
for Admission Admissions
13
If you responded to Request unqualified admission answer the
37D
with
following Interrogatory
in
37D
anything other than an
14
State
every
fact
you
rely
upon
thi making this response. such
15
document
16
in making this denial and as to each thi Identify every document you rely upon the document author and date state the current or last known identify by title
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
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 ofthe
give the expected
E.
19
testimony.
for the benefit
20
21
Admit that by providing loan guarantees guarantee Mexico provided support to TAESA. Admit
of
TAESA
the
government of
Deny _______
other
22
23
Admission 37E with anything you responded to Request for Admissions the following Interrogatory unqualified admission answer
If
37E
than an
24 25
State
every
fact
you
rely
upon you
the
in
thi making this
response. denial current in the
Identify
every document
rely
upon
in
thi making this
state the
and as to each
or last
such
document
26 27 custodian
the
document by identify of the document describe documents
the
title author and subject in the
date
known
and state
matter addressed
document
substance
of the information contained
document
as
it
relate relates to this thi response.
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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Page 13 of 14
number
expected
subject
matter on which the witness witnes
is
expected
to testify
and substance
of the
testimony.
F.
Admit that the funds removed from TAESA by Abed as outlined in the complaint and fund fund answer in thi action and used to acquire the identified aircraft were funds which were this loan required to be paid to repay the loans from the financial institutions. Admit
If
Deny _______
other
Admission you responded to Request for Admissions 37F with anything the following Interrogatory 37F unqualified admission answer
State
than an
every
fact
you
rely
upon you
the
in
thi making this
in
response.
Identify
every document
rely
upon
thi making this
denial
and as to each
such
document
custodian
10 the
document by identify of the document describe documents
the
title author 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
thi witnes 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 witness number subject matter on which the witnes is expected to testify and substance of the expected
testimony.
13
14
G.
Admit
outlined
that
neither
Bankruptcy
15 aircraft. 16
TAESA nor Abed has reported to the Republic of Mexico and the Court the details about the fund removed from TAESA by Abed as detail funds
complaint and answer
in this action thi
in the
and used
to acquire the
identified
Admit
17
Deny _______
for
18
If you responded to Request unqualified admission answer the
Admission Admissions
37G
with anything other
than
an
following Interrogatory
37G
19
State
every
fact you
rely
upon
you
the
in
thi making this response.
20
Identify
every document
rely
upon
in
thi making this
state the
denial current
and as to each
or last
such
document
21
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
22
23
witnes thi Identi 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 H. testimony.
that if the
24
25
Admit
fund funds removed
26 27
aircraft that the
of Mexico and the Bankruptcy Republic from TAESA by Abed were used to fund creditor creditors
in the bankruptcy action
Court became
the
aware
that
could
purchase of additional make claim to the assets.
Admit
Deny _______
28
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