REQUEST FOR ADMISSION NO. 13
state Ros provided investigators states Ross investigator copy above transactions. Ross confirmed Ros that he then sent three $300000 wires on June 25 27 and 29 2001 from his Turismo wire por Nation Computadora account to an account at Nations Bank now Bank of America in Dallas Dalla in the name of Lear Jet Inc. In Answer you state Claimant believe the three wire Claimants your transfer came from funds provided transfers fund from legitimate earning earnings of Mr. Abed.
Paragraph 82 of the most recent of the
$1000000
BNP
complaint
wire transfer
reflecting
the
TX
Admit
that
claimant claimants have
in the wire
no evidence
upon which
to base
thi this belief that the fund funds
other
contained
transfer transfers
representation representations
allegedly
came from earning of earnings provided by Ross.
Abed
than oral
Admit
Deny _______
If you responded to Request for Admissions Admission with anything other than an unqualified admission answer the following Interrogatory
13
13
10
State
every
fact
you
rely
upon you
in
thi making this
response. denial
11
Identify
every
document
rely
upon
in
thi making this
and as to each such
document
12
custodian
the
identify the document by title author and date state the current or last of the documents describe document the subject matter addressed in the document
known
and state
substance
of the information contained
in the
document
as
it
relate relates to this response. thi
13
14
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres witnes number subject matter on which the witness is expected to testify and substance of the
give the expected testimony.
15
16
REQUEST FOR ADMISSION NO. 14
17
Paragraph
18
including paragraph to the Lear Jet funds fund
92 of the complaint refers to refer stipulation executed by Ross specifically which admit that allegations admits fund les traced allegation of funds of not less that $900000 of not less than les
traced to the
Ros
$892000 You
traced
to the
Austa
funds helicopter and fund of
19
les not less than 260-262
$250000
308
Cessna
aircraft also
as alleged that
in paragraph paragraphs
265
and 309 are correct.
deny
Ros Ross
upon
received
20
21
$5000000
provision.
in cash
from
Abed
and give notice
of reliance
80 82-83 90 les no less than Mexican Criminal Code
A. 22
23
Admit that claimants have no evidence upon which to contradict the admission of claimant Ross Ros that not less than $900000 of Romeros funds can be traced to the Lear Jet les Romero fund Romero funds of not less than $892000 can be traced to the Agusta helicopter and fund les Romero funds of not less than $250000 can be traced to the Cessna aircraft as fund les
alleged in paragraphs paragraph
80 82-83 90 260-262 Deny _______
for
265
308
and 309.
24
Admit
25
26
If you responded to Request unqualified admission answer the
Admission Admissions
14A
with anything other than an
following Interrogatory
l4A
27 28
State
every
fact you
rely
upon
in
thi making this
response.
Case 2:04-cv-00363-JWS
Document 132-8 15 Filed 11/11/2005
Page 1 of 18
document
custodian
the
identify
in making this denial and as to each thi Identify every document you rely upon the document state the current or last known title author and date by the subject in the
such
of the document describe documents
matter addressed
in the
document
and state
substance
of the information contained
document
as
it
relate relates to this response. thi
thi witnes Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telqphone busines addres addres witnes number subject matter on which the witness is expected to testify and substance of the
give the
expected
B.
testimony.
Admit
that
Abed
provided
les not less than
$5000000
in cash
to Ross
Ros
for the
purchase
of
aircraft.
Admit
Deny _______
If you responded to Request for Admissions Admission the following Interrogatory unqualified admission answer
14B
with anything other than an
14B
10
State
thi every fact you rely upon in making this response. such
11
document
12
identify
thi Identify every document you rely upon in making this denial and as to each the document by title author and date state the current or last known
the subject in the
custodian
the
of the document describe documents
matter addressed in the
document
and state
substance
of the information contained
document
as
it
relate relates to this response. thi
13
14
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres give witnes number subject matter on which the witness is expected to testify and substance of the
the
15
expected
C.
testimony.
16
Admit
that
allegations allegation
Ross of Ros contained
in the
stipulation
do not accuse
Abed
of any
cnme
17
in Mexico.
Admit
18
Deny _______
19
If you responded to Request for Admissions Admission the following Interrogatory unqualified admission answer
l4C with
l4C
anything other than an
20
21
State
every
fact
you
rely
upon
in
thi making this
response.
22
23
document you rely upon in making this denial and as to each such thi document by title author and date state the current or last known custodian of the document describe documents the subject matter addressed in the document and state the substance of the information contained in the document as it relates to this response. relate thi
Identify
every
document
identify
the
24
25
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres give witnes number subject matter on which the witness is expected to testify and substance ofthe
the
expected D.
testimony.
that provisions provision in
26 27
Admit
United
admissibility
of the stipulation
Mexican Federal Penal Code Ross thi provided by Ros in this
are not determinative
civil
of the
in the
forfeiture
action
States.
28
Admit
Deny _______
16
Case 2:04-cv-00363-JWS
Document 132-8
Filed 11/11/2005
Page 2 of 18
If you
responded
to Request the
for
Admission Admissions
14D
with anything other than an
unqualified admission answer
State fact
following
Interrogatory
14D
every
you
rely
upon
in
thi making this
response.
Identify
every document
document
custodian
the
identify
of the
document by documents document describe
the
thi you rely upon in making this denial and as to each title author and date state the current or last known
the subject in the
such
matter addressed
in the
document
and state
substance
of the information contained
document
as
it
relate relates to this response. thi
thi witnes Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telqphone addres busines addres witnes number subject matter on which the witness is expected to testify and substance of the give the expected
testimony.
REQUEST FOR ADMISSION NO. 15
10
Paragraph Paragraphs
93 to 107 of the
Ros Ross Romero
11
and Inverlat
bank
transaction and involvement with complaint relate to transactions and financial transactions transaction related to his account and do not
mention
Abed
Admit
or his fellow claimants.
12
that claimant do not contest claimants
that these
event events
and including 107 happened
13
and that claimants have claimant complaint
specifically
allegation allegations
containecf specific
in the
in the paragraphs alleged paragraph 93 no reason to dispute the that claimants do not contest claimant
to
Romero
14
lost
sum which was Deny _______
repaid by Inverlat.
Admit
15 If
16
Admission you responded to Request for Admissions 15 with anything the following Interrogatory answer unqualified admission
other
15
than an
17
State
every
fact
you
rely
upon you
the
in
thi making this
response.
18
Identify
every document
rely
upon
in
thi making this
denial
and as to each
such
document
19
identify
custodian
the
of the
document by documents document describe
the
title author and subject in the
date state the current or last known matter addressed in the document and state
substance
of the information contained
document
as
it
thi relate relates to this response.
20
21
witnes thi Identify every witness who can provide testimony in support of this response and witness addres busines addres give the witnesss personal address and telephone number business address and telerhone witnes number subject matter on which the witness is expected to testify and substance of the
expected testimony.
22
23 24
REQUEST FOR ADMISSION NO. 16
mentioned as owning an interest in Vuelamex in paragraph number 119 an allegation by Abed. The paragraphs of the complaint numbered 108 to 122 other paragraph with Ross Serdio victims generally victim than 119 relate to transactions transaction and involvement Ros described as the family of Em-ique Giraud Mijares Giraud and Inverlat Mijare bank and financial transaction transactions related to accounts of the victims and do not mention Abed or his fellow account victim
is
Abed
denied
25 26
claimants.
27 28
17
Case 2:04-cv-00363-JWS
Document 132-8
Filed 11/11/2005
Page 3 of 18
in the paragraph 108 to that claimants do not contest claimant that these events alleged event paragraphs the 118 and from 120 to 122 happened and that you have no reason to dispute in the complaint that you do not contest the victims victim allegation contained allegations specifically
Admit
lost
specific
sum which was
repaid by Inverlat.
Admit
If
Deny _______
other
Admission you responded to Request for Admissions 16 with anything the following Interrogatory unqualified admission answer
than an
16
State
every fact you
rely
upon
in
thi making this
response.
document you rely upon in making this denial and as to each such thi document by title author and date state the current or last known identify custodian of the document describe documents the subject matter addressed in the document and state the substance of the information contained in the document relate thi as it relates to this response.
Identify
every
document
the
10
witnes thi Identify every witness who can provide testimony in support of this response and witness addres busines addres give the witnesss personal address and telephone number business address and telphone witnes number subject matter on which the witness is expected to testify and substance of the
expected
testimony.
11
12
REOUESTFORADMISSIONNO.
17
13
14
admission The paragraph of the complaint numbered 123 to 138 relate to admissions made by paragraphs Serdio in an interview on or about March 22 2002 regarding victims victim generally described as the family of Enrique action of Ross and his co-conspirators Ros Giraud Mijares Giraud actions and Mijare co-conspirator
other
than mentioning
fear of
Abed
at
paragraph
136
do not mention
Abed
or his fellow
15
claimants.
16
A.
Admit
that
138 happened
17
complaint
that these events event alleged in the paragraph 123 to contest paragraphs and that you have no reason to dispute the allegations allegation contained in the that claimant do not contest claimants Serdio made these statements. specifically
claimant claimants do not
18
Admit
Deny _______
19
If you responded to Request for Admission Admissions unqualified admission answer the following Interrogatory
17A
with
17A
anything other
than an
20
State 21 Identify
every
fact
you
rely
upon you
in
thi making this response.
every document
rely
upon
in
thi making this
denial
and as to each
such
22
document
custodian
the
document by identify of the document describe documents
the
title author and date state the current or last the subject matter addressed in the document in the
known
and state
23 24
substance
of the information contained
document
as
it
relate relates to this response. thi
25 26 27
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres witnes number subject matter on which the witness is expected to testify and substance of the
give the expected
testimony.
B.
Admit
fear
that
claimant claimants do not have any evidence
as alleged in the
with which to deny that Serdio has
of
Abed
paragraph
136.
28
18
Case 2:04-cv-00363-JWS
Document 132-8
Filed 11/11/2005
Page 4 of 18
Admit
If you
Deny _______
responded
to Request the for Admission Admissions
l7B with
unqualified admission answer
State
following Interrogatory
l7B
anything other than an
every
fact
you
rely
upon you
in
thi making this
in
response.
Identify
every
document
rely
upon
thi making this
denial
and as to each such
document
custodian
the
identify the document by title author and date state the current or last of the documents describe document the subject matter addressed in the document
known
and state
substance
of the information contained
in the
document
as
it
relate relates to this response. thi
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telphone busines addres addres witnes number subject matter on which the witness is expected to testify and substance of the
give the
expected
testimony.
10
REQUEST FOR ADMISSION NO. 18
The paragraph of the complaint numbered 139 to 154 relate to admissions made by admission paragraphs Serdio in an interview on or about April 10 2002 regarding victims generally described as victim the family of Enrique action Ros and Giraud Mijares Giraud actions of Ross and his co-conspirators Mijare co-conspirator
do not mention
11
12
Abed
or his fellow claimants.
13
14
Admit
in the
154 happened
15 statements. 16
claimant claimants do not contest that these events alleged in the paragraphs event paragraph 139 to and that claimants have no reason to dispute claimant the allegations allegation contained that claimants do not contest claimant Serdio made these complaint specifically
that
Admit
17 If
Deny _______
18
Admission you responded to Request for Admissions 18 with anything the following Interrogatory answer unqualified admission
18
other
than an
19
State
every
fact
you
rely
upon
in
thi making this
response.
20
21
document you rely upon in making this denial and as to each such thi document by title author and date state the current or last known custodian of the document describe documents the subject matter addressed in the document and state the substance of the information contained in the document relate as it relates to this response. thi
Identify
every
document
identify
the
22
23
witnes thi Identify every witness who can provide testimony in support of this response and witness addres busines addres give the witnesss personal address and telephone number business address and telephone witnes number subj ect matter on which the witness is expected to testify and substance of the
expected testimony.
24
25
REQUEST FOR ADMISSION NO. 19
The paragraphs of the complaint numbered 155 to 178 the first 177 paragraph 178 relate to admission made by Serdio in an interview on or about April 11 2002 regarding victims admissions victim described Giraud Mijares Giraud actions as the family of Enrique action of Ross and his Ros generally Mijare financial transactions transaction conducted co-conspirator co-conspirators by Serdio and do not regarding specific
mention
26 27
28
Abed
or his fellow
claimants.
19
Case 2:04-cv-00363-JWS
Document 132-8
Filed 11/11/2005
Page 5 of 18
Admit
that
claimant claimants do not
and that you
contest
that these
event events
Serdio
did
alleged the
in the
paragraph paragraphs 155
contained
to
178 happened
have
no reason
to dispute
allegation allegations
these in the table
in the
complaint
the
specifically that you do not contest financial transaction transactions alleged specifically in the
first
made
statement statements
and that
as set out occur.
of financial
transaction transactions
paragraph
number
178
Admit
If
Deny _______
other
Admission you responded to Request for Admissions 19 with anything the following Interrogatory answer unqualified admission
19
than an
State
every
fact
you
rely
upon you
in
thi making this response.
Identify
every document
rely
upon
in
thi making this
denial
and as to each
such
document
custodian
the
identify the document by title author and date state the current or last of the documents describe document the subject matter addressed in the document
known
and state
substance
of the information contained
in the
document
as
it
relate relates to this response. thi
10
11
witnes thi Identify every witness who can provide testimony in support of this response and witness addres busines addres give the witnesss personal address and telephone number business address and telephone witnes number subject matter on which the witness is expected to testify and substance of the
expected testimony.
12
REQUEST FOR ADMISSION NO. 20
13 14
Aerospace
Abed
15
numbered paragraph 177 of the complaint alleges that Bombardier allege the Defendant Lear Jet and sold it to Jaime Ross and Alberto Ros Inc. manufactured sale office in Tucson Arizona. through the Lear Jet regional aircraft sales and maintenance you
filed denied the
The second
The Answer
Calezar
Lear
1A was
sold to
Ros Ross
and claimed
that
Abed
through
Ltd
purchased
Lear with
Abed
family money.
16
17
A.
Admit Admit
If
that
Ros Ross
executed
the purchase
contract
for defendant
Lear
Jet.
18
Deny ______
other
19
Admission 20A with anything you responded to Request for Admissions the following Interrogatory unqualified admission answer
than an
20A
20
State 21
every
fact
you
rely
upon
in
thi making this
response.
22
23
document you rely upon in making this denial and as to each such thi document by title author and date state the current or last known identify custodian of the document describe documents the subj ect matter addressed in the document and state the substance of the information contained in the document relate thi as it relates to this response.
Identify
every
document
the
24
Identify
witness give the witnesss
25
number
expected
subject
witnes thi every witness who can provide testimony in support of this response and addres busines addres personal address and telephone number business address and telephone witness matter on which the witnes is expected to testify and substance of the
testimony.
26
B.
27 28
Admit that not all of the purchase price other than the amount financed by BCI was find fund from paid from finds contained in the Calezar Ltd. account from funds provided
Abed
and his family.
20
Case 2:04-cv-00363-JWS
Document 132-8
Filed 11/11/2005
Page 6 of 18
Admit
________
Deny _______
If you responded to Request for Admissions Admission unqualified admission answer the following Interrogatory
20B
with
20B
anything other
than an
State
thi every fact you rely upon in making this response. every document you
the rely
Identify
upon
in
thi making this denial
and as to each
such
document
custodian
the
identify
of the
document by documents document describe
the
title author and subject in the
date state the current or last known matter addressed in the document and state
substance
of the information contained
document
as
it
relate relates to this response. thi
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres give witnes number subject matter on which the witness is expected to testify and substance of the
the
expected
testimony.
10
C.
Admit
that
11
Ross by Ros which were unrelated included receipt of funds from Abed and fund
controlled
portion
of the purchase
price
of the Lear Jet came
to the
from accounts account
Calezar
Ltd.
account
which
did
not
his family.
12
Admit
If
Deny _______
13
Admission you responded to Request for Admissions the following Interrogatory unqualified admission answer
State
20C
with anything other
than
an
20C
14
every fact you rely upon in making every document you
the rely
thi this response. thi making this
state the denial current in the
15 Identify 16
upon
in
and as to each
or last
such
document
custodian
the
document by identify of the document describe documents
the
title author and subject
in
date matter addressed
known
and state
document
17
substance
of the information contained
the
document
as
it
relate relates to this response. thi
18
Identify
witness give the witnesss
19
number
expected
subject
witnes thi every witness who can provide testimony in support of this response and addres busines addres personal address and telephone number business address and telephone witness matter on which the witnes is expected to testify and substance of the
testimony.
20
21
REQUESTFORADMISSIONNO.
Paragraph
21
state states
22
number
179 of the complaint
23
Contract negotiations Lear between BA in Tucson to purchase the Defendant negotiation and Ross and Alberto Abed commenced in approximately April 2001. Ros Arizona
24
The answer claimants claimant
25
filed denied
Ros Ross
was purchaser
under
limited
power of attorney
under
Irish law.
However
and claimed Ross acted only Ros claimant claimants admit Ros was Ross
guarantor of the financing. 26 A. 27 28
Admit
Lear
that
Ros Ross
Jet if he
would not have personally guaranteed the financing of the defendant for the purchase of the defendant Lear Jet. were not party to contract
Admit
Deny _______
21
Case 2:04-cv-00363-JWS
Document 132-8
Filed 11/11/2005
Page 7 of 18
If you responded to Request for Admissions Admission answer the following Interrogatory unqualified admission
2lA
with anything other than an
2lA
State
thi every fact you rely upon in making this response.
document
custodian
the
thi Identify every document you rely upon in making this denial and as to each such identify the document by title author and date state the current or last known of the documents describe document the subject matter addressed in the document and state of the information contained
in the
substance
document
as
it
relate relates to this response. thi
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres witnes number subject matter on which the witness is expected to testifj and substance of the
give the expected
B. testimony.
Admit
contract
that
Ros Ross
representative representatives
10
was the primary contact person or contract negotiator with the of Lear Jet for the purchase of the defendant Lear Jet executing
regarding
the sale contract.
all
document documents
Admit
11
Deny _______
for Admission Admissions to Request answer the following Interrogatory
If 12
you responded
21B
with
unqualified admission
State
2lB
anything other
than an
13
every fact you
rely
upon you
in
thi making this response.
14
Identify
every document
rely
upon
in
thi making this
denial
and as to each
such
document
15
custodian
the
document by identify of the document describe documents
the
title author and date state the current or last known the subject matter addressed in the document and state in the
substance
of the information contained
document
as
it
thi relate relates to this response.
16
17
witnes thi Identify every witness who can provide testimony in support of this response and witness witnesss personal address and telephone number business address and telephone addres busines addres witnes number subject matter on which the witness is expected to testify and substance of the
give the expected
testimony.
18
19
REOUEST FOR ADMISSION NO. 22
20 Paragraph
21
number
182 of the complaint
state states
The
22
N224LJ
23 24
25
United States registration State was registered just prior to export with Delaware corporation called Wilmington Trust Company as Owner Trustee effectively concealing the ownership interest of Ros and Abed Ross and their nominee foreign corporations.
aircraft to
The answer claimants claimant
rezistered to
filed denied
the
of
Abed
Wilmington Trust and claims that Abed has been cooperating and providing claim
years.
denied
that this registration thi
Lear Jet was exported admitted the jet was was used to conceal ownership
record records to the
govemment
for several
26 A. 27
Admit
that
the to
contract
executed
Ross by Ros
for the
exportation
Mexico
of the Lear Jet after
purchase cash sale.
of the Lear Jet called
for the
28
Admit
Deny _______
22
Case 2:04-cv-00363-JWS
Document 132-8
Filed 11/11/2005
Page 8 of 18
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 132-8
Filed 11/11/2005
Page 9 of 18
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 132-8
Filed 11/11/2005
Page 10 of 18
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 132-8
25
Filed 11/11/2005
Page 11 of 18
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 132-8
Filed 11/11/2005
Page 12 of 18
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 132-8
Filed 11/11/2005
Page 13 of 18
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 132-8
28
Filed 11/11/2005
Page 14 of 18
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 132-8
Filed 11/11/2005
Page 15 of 18
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 132-8
30
Filed 11/11/2005
Page 16 of 18
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 132-8
Filed 11/11/2005
Page 17 of 18
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
Document 132-8
32
Filed 11/11/2005
Page 18 of 18