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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 35 of 50 fictitious scenario and asks Ms. Giuffre to admit or deny it. This fictitious scenario is not something that Ms. Giuffre has ever alleged. As stated in the objection, Defendant has interposed and comingled facts which comprise the foundation of this request for admission. Specifically, Ms. Giuffre has never alleged that “she had a conversation with Bill Clinton regarding him flying with Ghislaine Maxwell in a helicopter.” Instead, Ms. Giuffre has been quoted by a reporter as saying, “I flew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill [Clinton] in a huge black helicopter that Jeffrey had bought her.” Sara Nathan, Bill Clinton Pictured with Jeffrey Epstein’s Social Fixer, Daily Mail, (12 January 2015). 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). At the end of the day, in making a determination under Rule 35(a)(5), “the Court is reminded that the ‘purpose of the rule is to reduce the costs of litigation by eliminating the necessity of proving facts that are not in substantial dispute, to narrow the scope of disputed issues, and to facilitate the presentation of cases to the trier of fact.”” Spin Master Ltd. v. Bureau Veritas Consumer Products Service, Inc., 2016 WL 690819, at *18 (W.D.N.Y., 2016) 29