10. lta logistics vs enrique varona (varona request of admissions and lta response)

7/29/2019 10. LTA LOGISTICs vs Enrique Varona (Varona Request of Admissions and LTA Response)

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IN THE COUNTY COURT OF THE ELEVENTH JUDICIAL CIRCUITIN AND FOR MIAMI DADE COUNTY, FLORIDA

GENERAL JURISDICTION DIVISIONCASE NO. 11 20527 CA 21

LTA LOGISTICS, INC.A Florida corporation , andLESTER TRIMINO,ANNETTE TRIMI NO ,LESTER TRIMINO SR.,Plaintiffs and Defendant's in the coun terclaim,

V.Enrique Varona,Defendant an d Plaintiff in the counterclaim,

REQUEST OF ADMISSIONS

COMES NOW,The Defendant and Plaintiff in the counterclaim, Enrique Varona, proceedingpro-se, (from hereon, "Varona") a human person and not a corporate fiction or statutoryperson, hereby requests that this Court enter an order to Compel th e Plaintiff's andDefendant's in the counterclaim, LTA LOGISTICS, Inc., LESTER TRIMINO, ANNETTE TRIMINO,an d LESTER TRIMINO SR . (From hereon, "Trimino") to admit or deny the following stateme ntof law. If objection is made, p lease state the reason for the objection. If denying the matter,please set forth in detail th e reasons why the ans we ring party cannot truthfully admit ordeny th e matter pursuant to Florida Rules of Civil Procedures, Rule 1.370 with in thirty (30)days after th e filing and/or mailing via USA mail of this motion and in support thereofstates:


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1. Please admit that Varona never executed a Non disclosure and Non SolicitationAgreem ent before being employed by LTA Logistics, Inc. (aka Trimino).

2. Please admit that Varona has made truthful statements regarding the nature andcharacter of the services offered by LTA Logistics, Inc on the internet.

3. Please admit that Trimino has been violating fede ral copyright laws by making falserepresentations and take down claims of an alleged nonexistent copyright.

4. Please admit that there are over 50 such federal violations of copyright infringementviolation notices made by Trimino to Google/You Tube.

5. Please admit that Trimino filed a malicious Affidavit with the court and hascommitted perjury.

6. Please admit that there is no right in law that Trimino has to defraud andmisrepresent his transportation services to the shipping public.

7. Please admit that there are no alleged customers past, present, or future known toTrimino or anyone else in this cause of action that he (LTA ) has lost or hav e beeninterfered to as a result of VaronaJellingthe truth in his internet postings.

8. Please admit that Trimino's law suit against Varon a is a sham and a fraud againstthe court and a stealthy encroachment of his First amendme nt right.

9. Please admjt that the reason for the refusal and failure of Trimino to provide anyrequested paperwork aske d by Varona in his motions to Produce is due to Trimino'sfear 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 thereputation and have Varona fired from his employment with Landstar T ransportationLogistics, Inc.

12 . Please admit that exhibit "D" in Varona's counter claim is a true copy of the forgedsigned contrac t by Trimino sent to Landstar Transportation Logistics, Inc.


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13 . Please admit that Trimino continued to harass Varona's employer after having beentold to ceas e and desist.

14 . Please admit that Trimino went as far as to hire counsel to contact V arona'semployer's CEO to further his defamatory and fraudulent campaign against Varona.

15 . Please admit that Trimino entered into a conspiracy with his wife Mrs. AnnetteTrimino and their office manager Mr. Todd Osipiak to claim they had witnessedVarona sign a contract ev idence d by exh ibit "D".

16 . Please admit that this alleged contract signing witnesses was a lie and a fraud inorder 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 andcommitted a fraud against Varona by claiming to be witnesses of an event such assigning of a contract that neve r took place in furtherance of a criminal act.

18 . Please admit that Exhibits "A " through "F" on Varona's counter claim are legitimatedocuments as to their claime d origins, contents, and context.

19 . Please admit that Trimino has committed Tortous Interference, Civil Conspiracy andFraud to hurt and inflict extreme economic prejudice against Varona.

20. Please admit that all referenced documents and Exhibits wh ich are the subject ofthis action are know n by Trimino and his counsel.

WHEREAS, Varona expects a response to these admissions within the time frame allowed byl a w .

? r i c y u e \ V a r o n ?1482&S.W. 125 Ct.Miami ,Florida 33186


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IN THE CIRCUIT COURT OF THEN ELEVEN TH JUDICIAL CIRCUIT IN AN D FORMIAMI DADE COUN TY FLORIDA

LT A LOGISTICS. INC.A Florida Corporation., andLESTER TRIMINO,Plaintif fs,

VS.ENRIQUE VARAONA,

Defendant .

GENERAL JURISDICTION DIVISIONCASE NUMBER: 1 1-20527 CA 21HONORABLE WILLIAM THOMAS"ORIGINALF I L E D

IRESPONSE TO REQUEST FOR ADMISSIONS

COMES NOW the Plaintiffs LTA LOGISTICS IN C. and LESTERHARVEY RUV IN

C L E R KJO by

and through undersigned counsel and files this response to Request for Adm issions.1. That number one (1 ) is denied.2. That number two (2) is denied.3. That numb er 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 inlaw to defraud and misrepresent his transportation services to the shipping public but isdenied as to any other allegations.7. That numb er seven (7) is denied8. That numb er eight (8) denied.9. That numb er nine (9) is denied.10. That number ten (10) is admitted.


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11 .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 denied17. That number seven teen (17) is denied.18. That number eighteen (18) is denied19. 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 responsewas forwarded to Enrique Varona 14823 S.W. 125*Court Miami Florida 33186 on this

day of _ .****V 2012.(V Respectfully submitted,By. hLK

Scott Egleston, E^uireFlorida Bar Nutober 88342512000 Biscayne BlvdSuite 220N . Miami, Fl 33181Tel. (305)892-8088

10. lta logistics vs enrique varona (varona request of admissions and lta response)

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