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REQUEST NO. 1

Admit that you knew by Plaintiffs’ July 19, 2012 email to you to which you replied, that Plaintiffs were ready and willing to be interviewed by you.

REQUEST NO. 2

Admit that you violated the Society of Professional Journalists Code of Ethics which instructs journalists “to diligently seek subjects to respond to criticism or allegations of wrongdoing" by your refusal and failure to interview Mia Kim or Tommy Vig before publishing your Book.

REQUEST NO. 3

Admit that your failure to interview Mia Kim or Tommy Vig before publishing your Book constituted reckless disregard for the truth by you.

REQUEST NO. 4

Admit that your failure to interview Mia Kim or Tommy Vig before publishing your Book constituted actual malice against the Vigs by you.

REQUEST NO. 5

Admit that you should have asked for the permission of Mia Kim to use her photos which you used, including in and on the cover of your Book.

REQUEST NO. 6

Admit that when you referred to Mia by the name “Mia (Lee) Kim” in your Book, you knew that that was not Mia’s name.

REQUEST NO. 7

Admit that you wrote on Amazon.com, using the fake name “Brandi L.”, the greatly libelous comment toward Plaintiffs attached as Exhibit “A” to Plaintiffs’ 4^th Supplement to Motion for Summary Judgment.

REQUEST NO. 8

Admit that when you wrote in your Book on page 285 that Sue paid Mia $52,500 in 1993, you knew it was not true.

REQUEST NO. 9

Admit that you failed to request proof (such as the cancelled check you wrote about in your Book) that Sue paid Mia $52,500 in 1993.

REQUEST NO. 10

Admit that you failed to request to see the 1993 demand letter from Mia you referenced in your Book on page 285.

REQUEST NO. 11

Admit that you lied when you wrote in your letter to Tommy Vig dated 11.25.17 that: “A settlement document was provided to me for the settlement between Mia and the Sue Kim Corporation, which I sourced in the book.”, since you knew that you did not source the same in your Book.

REQUEST NO. 12

Admit that when you wrote in your letter to Tommy Vig dated 11.25.17 that “A settlement document was provided to me for the settlement between Mia and the Sue Kim Corporation”, you were referring to a settlement document dated 1987.

REQUEST NO. 13

Admit that when you wrote in your letter to Tommy Vig dated 11.25.17 that “A settlement document was provided to me for the settlement between Mia and the Sue Kim Corporation”, you did not reveal that the date on the settlement document was 1987 even though 1987 was in fact the date on that settlement document.

REQUEST NO. 14

Admit that when you wrote in your letter to Tommy Vig dated 11.25.17 that: “A settlement document was provided to me for the settlement between Mia and the Sue Kim Corporation”, you did not reveal that the date on the settlement document you were referencing was 1987 because doing so would reveal that you lied in your Book on page 285 about the non-existent settlement taking place in 1993, or 6 years later.

REQUEST NO. 15

Admit that when you wrote in your letter to Tommy Vig dated 11.25.17 that: “A settlement document was provided to me for the settlement between Mia and the Sue Kim Corporation”, you knew that the date on that settlement document and the claimed payment of $52.500 was 1987, and yet you referenced that very $52,500 settlement in your Book on page 285 as having occurred in 1993, or 6 years later, constituting knowledge of falsity.

REQUEST NO. 16

Admit that when you wrote the story in your Book on page 285 about the 1993 settlement between Sue and Mia, based on the information you had, you knew for certain that your story could not be true.

REQUEST NO. 17

Admit that you had received many communications from the Vigs, - which you admitted receiving in two 2017 letters - the Plaintiffs alleging, and providing evidence that you had printed many specific lies in your Book against them, and even though you were told about the adoptive admission rule, you never once denied or disputed any of the Vigs’ allegations or evidence, because you knew that what the Vigs told you were true.

REQUEST NO. 18

Admit that by not investigating the truth of your allegations against the Vigs which you wrote on page 285 in your Book, you acted with actual malice towards the Vigs.

REQUEST NO. 19

Admit that your untrue allegations against the Vigs, which you wrote on page 285 in your Book, were written by you with knowledge of their falsity.

REQUEST NO. 20

Admit that you did not interview 70 people for your book.

REQUEST NO. 21

Admit that you cannot name more than 20 people you interviewed for your Book.

REQUEST NO. 22

Admit that you did not specifically deny any of the almost 60 allegations of your lying made against you in the document entitled “LIST OF ADMITTED LIES BY DEFENDANT GERDES” (which document Plaintiffs filed with the Court and properly served on you) because all of the allegations therein are true.

REQUEST NO. 23

Admit that in your 1/25/18 Answer to Plaintiffs’ Verified Complaint you did not specifically deny any of the allegations made against you by the Plaintiffs in their Verified Complaint because all of the allegations made therein were true.

REQUEST NO. 24

Admit that you did not specifically deny at any time any of the allegations made by Plaintiffs in Plaintiffs’ Verified Complaint because all of the allegations made therein are true.

REQUEST NO. 25

Admit that you failed to oppose Plaintiffs’ Summary Judgment Motion because you agree that such Motion should be granted in the interest of justice.

REQUEST NO. 26

Admit that you will not oppose Plaintiffs’ Summary Judgment Motion because you agree that such Motion should be granted in the interest of justice.

REQUEST NO. 27

Admit that you have been mailing back to Plaintiffs their properly served court documents in the original envelopes, unopened, because you realized that Plaintiffs are correct in wanting to have your Book withdrawn from sales due to the fact that it is not a biography of Sue Kim or The Kim Sisters, but a Book of Lies about both Sue and The Kim Sisters.

REQUEST NO. 28

Admit that you never really believed the story Sue Kim told you about herself and The Kim Sisters.

REQUEST NO. 29

Admit that since it was you who wrote and published your Book, there is no other party except you who is responsible for the contents of your Book.

REQUEST NO. 30

Admit that you got money from the Bonifazios to write your Book.

REQUEST NO. 31

Admit that Sue and/or her husband requested that you do not to interview Mia Kim or Tommy Vig.

REQUEST NO. 32

Admit that you have never had any sworn statement by any witness regarding Mia Kim having done anything wrong.

REQUEST NO. 33

Admit that if the Vigs are hurt, or killed by Mafioso Bonifazio, or his “large men” (as you referred to his “collectors” (hitmen) in your Book), sales of your Book would increase greatly: there is no such thing as bad publicity.

REQUEST NO. 34

Admit that if the Vigs were killed by Mafioso Bonifazio or his hitmen, you would make more money from the sales of your Book.

REQUEST NO. 35

Admit that you were never able to prove any of the derogatory stories you wrote against Plaintiffs in your Book, or on Amazon.com using the fake name “Brandi L”, to be true.

REQUEST NO. 36

Admit that you have not interviewed a single eyewitness regarding any of the derogatory stories you wrote in your Book against Mia Kim or Tommy Vig and their familes.

REQUEST NO. 37

Admit that your story in your Book regarding Sue’s wedding was not true, as proven by the wedding pictures.

REQUEST NO. 38

Admit that you never asked for and never received from any source any proof that it was Sue Kim, and not Tommy Vig, who negotiated the 1973 Hilton Contract for The Kim Sisters referenced in your Book.

REQUEST NO. 39

Admit that you never received any documentation that could support that the stories you wrote about Sue and John in your Book were true.

REQUEST NO. 40

Admit that you invented all the derogatory stories you wrote against Mia Kim in your Book because you needed a foil for Sue Kim in your Book.

REQUEST NO. 41

Admit that you invented a non-exisent, completely fictional version of Mia Kim, because you needed an antagonist to Sue in your Book.

REQUEST NO. 42

Admit that you invented many false stories in your Book, to make it more interesting than reality and you did not care about besmirching Plaintiffs in the process.

REQUEST NO. 43

Admit that you did not ask for and did not receive any evidence or proof from any source of any of the libelous stories you wrote in your Book concerning Mia and Tommy.

REQUEST NO. 44

Admit that your idea that Plaintiffs sued the wrong person in you in this lawsuit is based on absolutely no facts, since it was you alone who wrote and published and continue to sell worldwide the defamatory Book mistitled “biography.”

REQUEST NO. 45

Admit that it was obvious to you that Sue and John hated the Vigs and were prejudiced against them and wanted to hurt them and that your failure to hear Mia’s and Tommy’s side of the story before publishing your Book constituted actual malice by you against the Vigs.

REQUEST NO. 46

Admit that is was obvious to you while writing your Book that Sue was very jealous of and prejudiced against Mia because Mia was still performing on stage, while Sue was only a real estate agent.

REQUEST NO. 47

Admit that you just wanted to make money from your Book, and that you did not care about the truth of the story of Sue or The Kim Sisters.

REQUEST NO. 48

Admit that your using the false name of “Brandi L.” on Amazon.com to besmirch Plaintiffs Mia and Tommy was not the first time you committed such fraud and deceit.

REQUEST NO. 49

Admit that the characterization of your Book being “A BOOK OF LIES” is correct.

REQUEST NO. 50

Admit that you were aware while writing your Book that after Sue ousted Mia from The Kim Sisters act, Sue had to pay Mia weekly pursuant to a negotiated 1973 contract.

REQUEST NO. 51

Admit that you were aware while writing your Book that Sue broke the 1973 contract according to which Sue was obligated by signed conract to pay Mia weekly after Sue had ousted Mia from The Kim Sisters act.

REQUEST NO. 52

Admit that you knew while writing your Book that John and Sue stole about four (4) million dollars from Mia by 1976.

REQUEST NO. 53

Admit that you knew that all of your derogatory statements about the Vigs were lies when you wrote them in your Book, and on Amazon.com using the fake name “Brandi L.”

REQUEST NO. 54

Admit that you knew that your lies about the Plaintiffs would lower them in the estimation of the community and that your lies would deter third persons from associating with the Plaintiffs and that Plaintiffs would no longer be invited to perform in Korea.

REQUEST NO. 55

Admit that you always knew from 2008-2016 that you would receive complaints from the Plaintiffs about all your lies in your Book.

REQUEST NO. 56

Admit that you rejected all of Plaintiffs’ good faith offers which they made to you to cooperate with you on your Book.

REQUEST NO. 57

Admit that you lied in your letter to Tommy dated 11.25.17 about following the US Journalism Code of Ethics in your researching, verifying and sourcing the items referenced in your Book, since you knew that according to their principles of ethical journalism, under the circumstances you had a duty to interview the Vigs too.

REQUEST NO. 58

Admit that you knowingly and negligently made your defamatory statements regarding Paintiffs in your Book even though you knew them to be false.

REQUEST NO. 59

Admit that you should never have agreed not to interview Mia and Tommy for your Book, no matter how much money the Bonifazios paid you.

REQUEST NO. 60

Admit that you do not have a single sworn statement by any witness to support any of the more than 50 libelous lies you wrote about Plaintiffs in your Book.

REQUEST NO. 61

Admit that you lied about sourcing material from publications regarding wrong-doings by Mia and/or Tommy, and that you never sourced or came across any such material because no such material exists.

REQUEST NO. 62

Admit that you wrote your libelous Book as a hit piece against the Vigs to enrich yourself at the expense of the Vigs’ well being.

REQUEST NO. 63

Admit that by writing and publishing your libelous Book, you are guilty of the crime of Libel as defined by Idaho Statute 18-4801 and ought to be punished to the full extent of the law pursuant to Idaho Statute 18-4802 including being fined $5000 and imprisoned in county jail for six (6) months.

REQUEST NO. 64

Admit that the sole affirmative defense you listed in item number 6. in your 1.25.18 Answer to Plaintiffs’ Verified Complaint is totally unintelligible, meaningless, and false.

REQUEST NO. 65

Admit that the sole affirmative defense you listed in item number 6. in your 1.25.18 Answer to Plaintiffs’ Verified Complaint is totally false since there is no “necessary and proper party to the owner of the asset (Sue Kim: The Authorized Biography)” aside from you individually who alone wrote, published, and continues to sell your Book worldwide.

REQUEST NO. 66

Admit that BMG Inc. which you falsely listed in your 1.25.18 Answer to Plaintiffs’ Verified Complaint as being a defendant in this case is not a party to, nor does it have any interest whatsoever in this case.

REQUEST NO. 67

Admit that you have 0 newspaper articles saying anything negative against Mia or Tommy.

REQUEST NO. 68

Admit that at the suggestion of your publisher, Amazon.com, and WARP Films, who promised you a movie deal in connection with your Book, you moved the address of the publisher of your Book to Georgia from Idaho in an effort to avoid criminal charges to be brought against you for your defamation against Plaintiffs in your Book.

REQUEST NO. 69

Admit that at the suggestion of your publisher, Amazon.com, and WARP Films, who promised you a movie deal in connection with your Book, you changed the cover of your Book from the Book’s Original Cover to the Book’s Revised Cover because your use of Mia’s photo without Mia’s permission in the Original Cover was illegal.

REQUEST NO. 70

Admit that the majority of your Books sold to date bore the Original Cover.

REQUEST NO. 71

Admit that you never believed any of Sue’s derogatory stories about her sister Ai-Ja, including the tale about Sue walking her dog early in the morning and then looking out her window and suddenly discovering Ai-Ja on the street at 3 am, yet you printed these fables as facts in your Book.

REQUEST NO. 72

Admit that ever since you have known Sue, you knew that Sue was continually lying to you when Sue would communicate with you about Mia and Tommy.

REQUEST NO. 73

Admit that you lied in your Book about Mia and Tommy to make your Book more interesting.

REQUEST NO. 74

Admit that you lied in your Book about Mia and Tommy in exchange for being paid $25,000 by Sue and John, plus for the promise of a movie deal by WARP films.

REQUEST NO. 75

Admit that the Book is not a biography, but a fantasy which has nothing to do with the real life of Mia and Tommy.

REQUEST NO. 76

Admit that the Book is not a biography, but a fantasy which has nothing to do with the real life stories of Tom Ball, Danny Lembark, Ai-Ja Kim, Sue’s parents, Mia’s parents, John Bonifazio, Frank Pastore, and Sue Kim.

REQUEST NO. 77

Admit that you lied in your Book about Sue obtaining the Hilton Hotel contract for the Kim Sisters since you knew while you were writing your Book that it was solely Tommy who had in fact negotiated that deal with David Victorson, proven by the dates, times and names you yourself set forth therein which in fact excluded the possibility of Sue’ involvement.

REQUEST NO. 78

Admit that you committed actual malice by publishing your Book without interviewing key witnesses to the people and events you wrote about in your Book, including Paul Lee, Young Ju Lee, Barbara Myung, Andy Myung, Lisa Lee Chang and Mr. Chang and their daugter Anna, and Kim Sisters Secretary Pat, family members of Frank Pastore, and Patsy, Mary and Seiko Ball, and Mona Matoba and Wayne Newton.

REQUEST NO. 79

Admit that you did not interview any person for your Book who was not under the influence of Sue and/or John.

REQUEST NO. 80

Admit that you did not add a third-party defendant to this lawsuit because you alone are responsible for your libelous Book.

REQUEST NO. 81

Admit that you are aware of the fact that pursuant to I.R.C.P Rule 14, you could bring a third party into this lawsuit as another defendant, who would then become a participant known as a third-party defendant.

REQUEST NO. 82

Admit that you read the 1973 agreement of The Kim Sisters and knew that per that signed contract Sue had to pay Mia for forcing Mia out of The Kim Sisters, and that you knowingly lied about this fact in your Book.

REQUEST NO. 83

Admit that you knew at all times when Sue Kim told you derogatory stories about Mia and Tommy that Sue was always lying.

 

REQUEST NO. 84

Admit that you have used the name "Brandi L" in your customer profile on Amazon.com.

 

REQUEST NO. 85

Admit that you did not file a third-party complaint against any nonparty to this lawsuit because you yourself alone are individually and solely liable for all claims made by Plaintiffs against you.

REQUEST NO. 86

Admit that your stating in your 12.10.17 letter to Tommy that you have always been aware of the Vigs’ “WELL-DOCUMENTED MULTI-DECADE LEGAL ISSUES WITH THE KIM-BONIFAZIO FAMILY“ proves that you were fully aware when you wrote your Book of the Bonifazios’ prejudice against, and unfairness towards Mia and Tommy.

REQUEST NO. 87

Admit that you were fully aware when you wrote your Book that the “well documented legal issues” you referenced in your 12.10.17 letter to Tommy made the Bonifazios a totally unreliable source of information regarding the Vigs: you had no doubt whatsoever that the Bonifazios were lying to you about Tommy and Mia, and that the Bonifazios’ derogatory stories about Plaintiffs were not true.

REQUEST NO. 88

Admit that you were certain when the Bonifazios hired you to write your Book that the Bonifazios hated the Vigs, and that the Bonifazios intended for your Book to damage the Vigs by disseminating derogatory lies about Mia and Tommy.

REQUEST NO. 89

Admit that you got so confused with your own contradictory lies you were writing in your Book that several of your invented stories made no sense at all when the dates, names, times, facts and events were compared to reality.

REQUEST NO. 90

Admit that in view of all that you knew about the forged agreements by Sue Kim and the names of the persons in the life of Sue Kim, you purposely misstated names, dates, circumstances and events including relating to Rocky Sennes, David Victorson, Lee Nan Young, Young Ha Kim, Jean Kim, Tom Ball, Daniel Lembark, Bob Alcivar, George Hernandez, Lenny Esposito and Ai Ja Kim to make Sue Kim look good and others around her look bad.

REQUEST NO. 91

Admit that you knew right from the start in 2008 when you were hired by the Bonifazios to write your Book that it was not going to be a fair biography, but that you would fill the Book with lies to make Sue Kim look good and make others around her look bad, since that was the purpose of the Book.

REQUEST NO. 92

Admit that it was never your intention to write a truthful book about The Kim Sisters and Sue Kim, and reality played no part in your stories in the Book.

REQUEST NO. 93

Admit that you never denied any of Plaintiffs’ contentions regarding the more than 50 libelous lies you wrote in your Book, including as set forth in the document entitled “LIST OF ADMITTED LIES BY DEFENDANT GERDES” (which document Plaintiffs filed with the Court and properly served on you), because you had known that they were all lies at the time you had written them.

REQUEST NO. 94

Admit that you have never identified any instance where Tommy or Mia said anything bad about Sue or John in connection with the “long standing, well-documented legal issues between the Vigs and the Bonifazios” as referenced in your 12.10.17 letter to Tommy.

REQUEST NO. 95

Admit that you knew when you wrote your Book that Sue and John bad-mouthed Mia and Tommy in connection with the “well-documented, long standing legal issues” between the Vigs and the Bonifazios referenced in your 12.10.17 letter to Tommy, and that Mia and Tommy never bad-mouthed Sue and John in connection therewith.

REQUEST NO. 96

Admit that you committed actual malice by refusing to interview Mia or Tommy before publishing your Book, since among many other indications of fraudulent comments by Sue and John, you had known of the “well-documented, long standing legal issues between the Vigs and the Bonifazios” referenced in your 12.10.17 letter to Tommy.

REQUEST NO. 97

Admit that you lied about your interviewing people other than Sue and John who witnessed anything set forth in the libelous lies you wrote against the Vigs in your Book, including as set forth in the document entitled “LIST OF ADMITTED LIES BY DEFENDANT GERDES” (which document Plaintiffs filed with the Court and properly served on you), because no such witnesses exist apart from Sue and John.

REQUEST NO. 98

Admit that you lied about your reading in publications about bad deeds of the Vigs relating to any of the libelous lies you wrote against the Vigs in your Book, including as set forth in the document entitled “LIST OF ADMITTED LIES BY DEFENDANT GERDES” (which document Plaintiffs filed with the Court and properly served on you), as no such articles exist.

REQUEST NO. 99

Admit that when in 2008 you contracted with Sue and John to write your Book, you promised Sue and John that you would write whatever Sue and John would tell you to write in your Book and that you would not check on the veracity of any of their stories in exchange for your being paid $25,000.

REQUEST NO. 100

Admit that when in 2008 you contracted with Sue and John to write your Book, you promised Sue and John that you would never interview Paul Lee, Young Ju Lee, Barbara Myung, Andy Myung, Lisa Chang, husband Mr. Chang, daughter Anna, Kim Sisters’ Secretary Pat, family members of Frank Pastore, Patsy, Mary and Seiko Ball, Mona Matoba or Wayne Newton, in exchange for your being paid $25,000.

REQUEST NO. 101

Admit that when in 2008 you contracted with Sue and John to write your Book, you promised Sue and John that you would write whatever Sue and John would tell you to write in your volume,  and that you would not ask for proof or evidence relating to any of their stories in exchange for your being paid $25,000.

REQUEST NO. 102

Admit that the numerous pieces of evidence Plaintiffs have presented to this Court clearly prove that you knew you were lying about Plaintiffs throughout your Book at the time you wrote your Book.

REQUEST NO. 103

Admit that your invented derogatory stories about Tommy and Mia in your Book were many times self-contradicting and impossible, and sometimes made no sense at all and that their sole purpose was the libeling of the Plaintiffs.

REQUEST NO. 104

Admit that you invented derogatory stories about Tommy and Mia in your Book even when you knew full well that they could not be true, such as your tale about Mia writing a demand letter to Sue in 1993.

REQUEST NO. 105

Admit that you knew at the time you wrote your Book that Mia receiving $52,500 from Sue in 1993 could not be true, and that you knowingly lied about this in your Book solely for the express purpose of libeling Mia.

REQUEST NO. 106

Admit that in the first sentence on Page 1 of your Book you indicated that Sue’s mother, Lee Nan Young committed suicide in North Korean captivity (1950), but 146 pages later you wrote in your Book that Lee Nan Young died in 1964, which is a lie upon a lie, since Lee Nan Young actually died in 1965, and you lied about this in your Book solely to absolve Sue from the responsibility for causing her mother’s suicide in 1965.

REQUEST NO. 107

Admit that the numerous pieces of evidence Plaintiffs have presented to this Court clearly prove that by your writing your Book, you committed actual malice, libel, and fraud against the Plaintiffs.

REQUEST NO. 108

Admit that your use of Mia’s photo without Mia’s permission in your Book’s Revised (current) Cover is illegal.

REQUEST NO. 109

Admit that sales of the Book dropped because you eliminated the originally used photo and name of The Kim Sisters in the current Revised Cover.

REQUEST NO. 110

Admit that you never believed any of Sue’s derogatory stories about Mia and/or Tommy, yet you presented these stories as facts in your Book.

REQUEST NO. 111

Admit that you never believed any of Sue’s stories about her sister Ai-Ja that you wrote in your Book, yet you presented these stories as facts in your Book.

REQUEST NO. 112

Admit that you lied in your Book about Mia and Tommy for your financial gain.

REQUEST NO. 113

Admit that you knowingly lied in your Book about Sue obtaining the Hilton Hotel contract for the Kim Sisters, since from other witnesses, including Nancy Engler, and the actual dates, documents and times, including when Dave Victorson died, you knew at the time when you wrote your Book that it was Tommy, and not Sue, who had obtained the Hilton Hotel contract for the Kim Sisters in 1973, and that it simply could not have been Sue.

REQUEST NO. 114

Admit that you paid Amazon.com to publish your Book and misrepresented to them its content and Amazon did not request any evidence from you regarding the libelous statements you made against Plaintiffs.

REQUEST NO. 115

Admit that you committed actual malice by publishing your Book without interviewing Mia or Tommy.

REQUEST NO. 116

Admit that you were fully aware when you wrote your Book of the Bonifazios’ prejudice against and hatred and unfairness towards Mia and Tommy.

REQUEST NO. 117

Admit that when you wrote your Book you had no doubt whatsoever that the Bonifazios were lying to you about Tommy and Mia, and that the Bonifazios’ derogatory stories about Plaintiffs were not true.

REQUEST NO. 118

Admit that Sue and John paid Amazon to publish your Book.

REQUEST NO. 119

Admit that you were certain when the Bonifazios hired you to write your Book that their intention was to damage the Vigs by your disseminating derogatory lies about Mia and Tommy through your Book.

REQUEST NO. 120

Admit that no one other than Sue and John confirmed anything set forth in any of the libelous lies you wrote against the Vigs in your Book, including as set forth in the document entitled “LIST OF ADMITTED LIES BY DEFENDANT GERDES” (which document Plaintiffs filed with the Court and properly served on you).

REQUEST NO. 121

Admit that you lied to Amazon about the contents of your book to induce them to allow you to pay for Amazon publishing the same: telling Amazon that this was a factual biography of Sue Kim of the Kim Sisters, when you knew that it was in fact a Book of Lies about The Kim Sisters and specifically included at least 50 false, derogatory accusations about Kim Sister Mia Kim and her husband Tommy Vig.

REQUEST NO. 122

Admit that you routinely invented derogatory stories about Tommy and Mia in your Book even when you knew that they could not be true.

REQUEST NO. 123

Admit that Sue Kim assured you that Mia and Tommy would never dare to complain

about whatever derogatory lies you invent about them in your Book, because her husband Mafioso Bonifazio had already threatened the Vigs with physical violence if they did that.

REQUEST NO. 124

Admit that you invented and published the story about Mia’s long departed father

happily telling Mia’s prospective stepmother Lee Nan Young that getting rid of young Mia meant “one less child to feed and worry about” and that such fabrication by you, in addition to making you scum (which is not a crime), constituted your committing the crime of actual malice per Idaho law, including because (1) you blackened the memory of a dead person and (2) made Mia look ridiculous to the world.

REQUEST NO. 125

Admit that Amazon never asked you why you refused to interview Mia, the only

other Kim Sister alive, for the Book they published about Sue Kim and The Kim Sisters.

REQUEST NO. 126

Admit that “Brandi L” is a name you made up to use instead of your own name to try to mislead others into believing that someone else other than you posted your libelous comments against the Vigs on Amazon.com as set forth in Plaintiffs’ 4th SUPPLEMENT TO MOTION FOR SUMMARY JUDGMENT.

REQUEST NO. 127

Admit that Brandi L is not a real person, but simply an invented name you fraudulently

used to defame Plaintiffs on Amazon.com.

REQUEST NO. 128

Admit that your Book of fabrications which you fraudulently represent as being a biography you published per contract with the Bonifazios made you a “hired gun”.

REQUEST NO. 129

Admit that Sue Kim did not actually approve each and every one of the lies you wrote in

your Book.

REQUEST NO. 130

Admit that your publisher Amazon never asked you if the contents of your Book were true.

REQUEST NO. 131

Admit that Amazon knew that you were using the name “Brandi L” for your customer profile on Amazon.com, yet Amazon allowed you to publish derogatory material on Amazon.com about Mia and Tommy under such false name.