IN THE COUNTY COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI DADE COUNTY, FLORIDA GENERAL JURISDICTION

DIVISION CASE NO. 11 20527 CA 21

LTA LOGISTICS, INC. A Florida corporation, and LESTER TRIMINO, ANNETTE TRIM I NO, LESTER TRIMINO SR.,
Plaintiffs and Defendant's in the counterclaim,

V.

Enrique Varona,
Defendant and Plaintiff in the counterclaim,

REQUEST OF ADMISSIONS

COMES NOW, The Defendant and Plaintiff in the counterclaim, Enrique Varona, proceeding pro-se, (from hereon, "Varona") a human person and not a corporate fiction or statutory person, hereby requests that this Court enter an order to Compel the Plaintiff's and Defendant's in the counterclaim, LTA LOGISTICS, Inc., LESTER TRIMINO, ANNETTE TRIMINO, and LESTER TRIMINO SR. (From hereon, "Trimino") to admit or deny the following statement of law. If objection is made, please state the reason for the objection. If denying the matter, please set forth in detail the reasons why the answering party cannot truthfully admit or deny the matter pursuant to Florida Rules of Civil Procedures, Rule 1.370 within thirty (30) days after the filing and/or mailing via USA mail of this motion and in support thereof states:

1. Please admit that Varona never executed a Non disclosure and Non Solicitation Agreement before being employed by LTA Logistics, Inc. (aka Trimino). 2. Please admit that Varona has made truthful statements regarding the nature and character of the services offered by LTA Logistics, Inc on the internet. 3. Please admit that Trimino has been violating federal copyright laws by making false representations and take down claims of an alleged nonexistent copyright. 4. Please admit that there are over 50 such federal violations of copyright infringement violation notices made by Trimino to Google/You Tube. 5. Please admit that Trimino filed a malicious Affidavit with the court and has committed perjury. 6. Please admit that there is no right in law that Trimino has to defraud and misrepresent his transportation services to the shipping public. 7. Please admit that there are no alleged customers past, present, or future known to Trimino or anyone else in this cause of action that he (LTA) has lost or have been interfered to as a result of VaronaJellingthe truth in his internet postings. 8. Please admit that Trimino's law suit against Varona is a sham and a fraud against the court and a stealthy encroachment of his First amendment right. 9. Please admjt that the reason for the refusal and failure of Trimino to provide any requested paperwork asked by Varona in his motions to Produce is due to Trimino's fear of criminal self incrimination in front of the court and on the record. 10. Please admit that on June 2009, Varona was not an employee of Trimino. 11. Please admit that as of June 2009, Trimino launched an unsolicited Telephone, Fax, email, U.S. Mail campaign against Varona's and his employer to tarnish the reputation and have Varona fired from his employment with Landstar Transportation Logistics, Inc. 12. Please admit that exhibit "D" in Varona's counter claim is a true copy of the forged signed contract by Trimino sent to Landstar Transportation Logistics, Inc.

13. Please admit that Trimino continued to harass Varona's employer after having been told to cease and desist. 14. Please admit that Trimino went as far as to hire counsel to contact Varona's employer's CEO to further his defamatory and fraudulent campaign against Varona. 15. Please admit that Trimino entered into a conspiracy with his wife Mrs. Annette Trimino and their office manager Mr. Todd Osipiak to claim they had witnessed Varona sign a contract evidenced by exhibit "D". 16. Please admit that this alleged contract signing witnesses was a lie and a fraud in order to give credence to Trimino's allegations of having a contract signed by Varona. 17. Please admit that Mrs. Annette Trimino and Mr. Todd Osipiak conspired and committed a fraud against Varona by claiming to be witnesses of an event such as signing of a contract that never took place in furtherance of a criminal act. 18. Please admit that Exhibits "A" through "F" on Varona's counter claim are legitimate documents as to their claimed origins, contents, and context. 19. Please admit that Trimino has committed Tortous Interference, Civil Conspiracy and Fraud to hurt and inflict extreme economic prejudice against Varona. 20. Please admit that all referenced documents and Exhibits which are the subject of this action are known by Trimino and his counsel.

WHEREAS, Varona expects a response to these admissions within the time frame allowed by
law.

?ricyue\Varon? 1482&S.W. 125 Ct. Miami ,Florida 33186

IN THE CIRCUIT COURT OF THEN ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI DADE COUNTY FLORIDA

LTA LOGISTICS. INC. A Florida Corporation., and LESTER TRIMINO, Plaintiffs,

GENERAL JURISDICTION DIVISION CASE NUMBER: 1 1-20527 CA 21 HONORABLE WILLIAM THOMAS

VS.
ENRIQUE VARAONA, Defendant.
I

"ORIGINAL FILED
HARVEY RUVIN
CLERK

RESPONSE TO REQUEST FOR ADMISSIONS

COMES NOW the Plaintiffs LTA LOGISTICS INC. and LESTER

JO by

and through undersigned counsel and files this response to Request for Admissions. 1. That number one (1) is denied. 2. That number two (2) is denied. 3. That number three (3) is denied. 4. That number four (4) is denied. 5. That number five (5) is denied. 6. That number six (6) is admitted to the extent that Mr. Trimino has no right to in

law to defraud and misrepresent his transportation services to the shipping public but is denied as to any other allegations. 7. That number seven (7) is denied 8. That number eight (8) denied. 9. That number nine (9) is denied. 10. That number ten (10) is admitted.

1 1 . That number eleven (1 1 ) is denied. 12. That number twelve (12) is denied in part and admitted in part. 13. That number thirteen (13) is denied. 14. That number fourteen (14) is admitted in part and denied in part. 15. That number fifteen (15) is denied. 16. That number sixteen (16) is denied 17. That number seven teen (17) is denied. 18. That number eighteen (1 8) is denied 19. That number nineteen (19) is denied. 20. That number (20) is so vague and ambiguous that the Plaintiff can not file a formal response by either admitting or denying the allegation. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true a correct copy of the foregoing response was forwarded to Enrique Varona 14823 S.W. 125* Court Miami Florida 33186 on this day of _ .****V 2012. Respectfully submitted,
By.^hL^K

(V

Scott Egleston, E^uire Florida Bar Nutober 883425 12000 Biscayne Blvd Suite 220 N. Miami, Fl 33181 Tel. (305) 892-8088