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Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 28 of 45 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) As a threshold matter, a court must determine whether the statements set forth in a request for admissions satisfy the formal requirements of Rule 36: “(e)ach request for admissions must be direct, simple and ‘limited to singular relevant facts,” United States v. Consolidated Edison Co., 1988 WL 138275 (E.D.N.Y. [Dec. 15, 1988] ) (quoting S.E.C. v. Micro—Moisture Controls, 21 F.R.D. 164, 166 (S.D.N.Y.1957)), so that “it can be admitted or denied without explanation.” [8 C. Wright & A. Miller,] Federal Practice and Procedure, § 2258 [(1970)]. A request “should not state ‘half a fact’ or ‘half-truths' which require the answering party to qualify responses.” Havenfield Corp. v. H & R Block, Inc., 67 F.R.D. 93, 96-97 (W.D.Mo.1973); Dubin, 125 F.R.D. at 375-76. See also Thalheim v. Eberheim, 124 F.R.D. 34, 35 (D.Conn.1988) (court must consider phraseology of requests as carefully as that of answers or objections). Consequently, Ms. Giuffre objects to answering this request for admission as it is based on “half-truths,” which make it impossible to answer without a qualified response. 13. Admit that You never observed Al Gore on the island of Little St. James. Response to Request For Admission No. 13: Denied in part. Her memory from 15 or more years ago is that it was on the island where she met Mr. Gore, although she has testified that she could have been incorrect on that location. While traveling with Epstein and Maxwell, she met so many people and was taken to so many places as a minor that perfect recall of exact locations is difficult, but based on her best recollection, denied. 14. Admit that You never had sexual contact with Alan Dershowitz. Response to Request For Admission No. 14: Denied. 15. Admit that You never had sexual contact with Andrew, Duke of York. 27