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`IN THE CIRCUIT COURT OF THE
`11TH JUDICIAL CIRCUIT IN AND FOR
`MIAMI DADE, FLORIDA
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`CASE NO.: 2024-006105-CA-01
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`Plaintiff,
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`BRIAN CRIST,
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`vs.
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`BARRY CHASE, individually, and
`LAW OFFICE OF BARRY OLIVER
`CHASE, P.A., a Florida profit corporation,
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`Defendants.
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`____________________________________/
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`DEFENDANTS’ SECOND REQUEST FOR ADMISSIONS TO PLAINTIFF
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`Defendants, Barry Chase and Law Office of Barry Oliver Chase P.A., pursuant to Florida Rule of
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`Civil Procedure 1.370, hereby request Plaintiff, Brian Crist, to admit or deny the truth of the
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`following matters, within thirty (30) days from receipt hereof.
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`Requests to Admit
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`
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`1. Admit that the copyright mortgage granted to Plaintiff Brian Crist by Not Without Hope
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`LLC (‘NWH’) in the Security Agreement and Copyright Mortgage dated as of March 27
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`2023 has priority over any copyright mortgage granted by NWH to XTS Two, LLC
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`formerly known as XTP One, LLC.
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`CERTIFICATE OF SERVICE
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`I HEREBY CERTIFY that on this February 28, 2025, a true and correct copy of the
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`foregoing was filed with the Clerk of Miami-Dade by using the Florida Courts e-Filing Portal and
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`was served by the Portal via an automatic e-mail message to counsel of record registered with the
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`e-Filing Portal system.
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`
`/s/ Isaac J. Mitrani
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