Rayon Payne and Folksalert - Request For Admissions

Filing # 93696738 E-Filed 08/06/2019 06:10:17 AM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL

CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA
JERMAINE CARLOS DIAZ,
Plaintiff,
V. CASE NO: 2019-CA-8025-O
RAYON SHERWIN PAYNE

d/b/a FOLKSALERT APP.
Defendant.
______________________________/
DEFENDANT, FIRST REQUESTS FOR ADMISSION
Pursuant to Fla.R.Civ.P. Rule 1.370, Defendant RAYON SHERWIN PAYNE d/b/a
FOLKSALERT APP. (hereinafter referred to as "DEFENDANT") serves the following requests
for admission to Plaintiff, JERMAINE CARLOS DIAZ, (hereinafter referred to as
"PLAINTIFF").
PROPOUNDING PARTY: RAYON SHERWIN PAYNE d/b/a FOLKSALERT APP
RESPONDING PARTY: JERMAINE CARLOS DIAZ
SET NUMBER: ONE
The above-named Defendant requests that the above-named Plaintiff, within thirty (30) days
after the service of this Request, make the following admissions for the purpose of this action
only and subject to all pertinent objections to admissibility which may be interposed at the trial:
1
Request Number 1;
Admit that PLAINTIFF is convicted sex trafficker of a minor child who he forced into
prostitution using a gun.
Request Number 2;
Admit that PLAINTIFF is a lifetime register sex offender as a result of sex trafficking a minor
child.
Request Number 3;
Admit that PLAINTIFF himself or had individuals call DEFENDANT’s job.
Request Number 4;
Admit that PLAINTIFF in the Youtube video title “Young Lace - The Bold Sex Offender Pimp”
url: https://youtu.be/e_LBLHMwifU .. he could be heard saying to Angelica Disiena and an
unindentify female “One time for the pimp game….” (emphasis supplied).
Request Number 5;
Admit that PLAINTIFF has posted and accepted an award for “MVP” from world famous pimp
Bishop Don Juan at his “2018 Playerball” the annual event where pimps gathered. See Youtube
video title “Lace The Blueprint receives Award from The Bishop Don Juan” url:
https://youtu.be/8-zHmfDRb4Y.
2
Request Number 6;
Admit that on or around November 7, 2017, PLAINTIFF had a public dispute which played out
on social media with well known Houston rappers Sauce Walker over a sex worker name
Shawnee Burke aka Austin Monroe who PLAINTIFF admit left him. See Youtube video “Sauce
Walka Clowns Young Lace After Getting His Snow Bunny Back With Profit” url:
https://youtu.be/qIiqcHPq7W0.
Request Number 7;
Admit that there’s a video on Youtube posted November 9, 2017, and title “Young Lace
EXPOSES Sauce Walka His hair like Lil Uzi & Dex Chain like the Migos on Instagram Live”
url: https://youtu.be/E-26ACIxlxs .. where PLAINTIFF speaks openly about his pimp activities
and relationship with sex worker Shawnee Burke aka Austin Monroe and his dispute with Sauce
Walker.
Request Number 8;
Admit that PLAINTIFF called the DEFENDANT on or around February 2019.
Request Number 9;
Admit that PLAINTIFF has done several interviews with the DEFENDANT in the year of 2012.
Request Number 10;
Admit that PLAINTIFF has known and interacted with DEFENDANT since 2012.
Request Number 11;
3
Admit that PLAINTIFF is a public figure who’s made headlines for being the first person to be
prosecuted and convicted under the “Adam Walsh Child Protection and Safety Act” for failure to
register as sex offender.
Request Number 12;
Admit that PLAINTIFF suffered no actual damages as a direct and proximate result of statement
published by DEFENDANT.
Request Number 13;
Admit that PLAINTIFF received no complaints from members of the public, customers, or
potential customers regarding any statements made by DEFENDANT.
Request Number 14;
Admit that the statements made by DEFENDANT are true or substantially true.
Request Number 15;
Admit that PLAINTIFF's filing of the instant lawsuit against DEFENDANT was calculated to
prevent DEFENDANT from releasing a documentary about PLAINTIFF title “The Blue Print -
A Dangerous Sex Offender (Young Lace)”.
Request Number 16;
Admit that PLAINTIFF' spoke with and recorded Sandra Koch phone conversation.
4
Request Number 17;
Admit that the instant litigation is a SLAPP Suit.
Request Number 18;
Admit that PLAINTIFF is listed on the Texas Sex Offender and National Sex Offender register.
Request Number 19;
Admit that PLAINTIFF Twitter user profile is https://twitter.com/younglace and Instagram use
profile is http://instagram.com/moneytoblowmusicgroup
Request Number 20;
Admit that PLAINTIFF posted a video to his Youtube account titled “LACE REVEALS
KEKO.mp4”.
Request Number 21;
Admit that PLAINTIFF posted a video to his Youtube account titled “Where’s Keko.mp4”.
Request Number 22;
Admit that PLAINTIFF posted a video to his Youtube account titled “KEKO IS CAUGHT
READ HANDED BEING A JANITOR.mp4”.
Request Number 23;
5
Admit that PLAINTIFF know the individual Tyler Dickens.
Request Number 24;
Admit that PLAINTIFF posted DEFENDANT mother’s full name and address on his Twitter
and Youtube account.
Request Number 25;
Admit that PLAINTIFF instructed unknown individuals to follow DEFENDANT to record video
footage of him.
Request Number 26;
Admit that PLAINTIFF filed DMCA copyright takedown claims with Apple and had
DEFENDANT’s album titled “Gorilla Exploratory” removed .
Request Number 27;
Admit that PLAINTIFF on or around February 2019 did an Instagram Live with Warren K.
Barconia aka GGov who’s instagram username is “ggovthagovernor”.
Request Number 28;
Admit that PLAINTIFF had contents removed from his Twitter account because he violated the
company’s user policy.
Request Number 29;
6
Admit that PLAINTIFF’s instagram and Youtube accounts were deleted because PLAINTIFF’s
violations to the company's user policy.
Request Number 30;
Admit that PLAINTIFF has or had relationships with the sex workers Arnela Niksic, Brittany
Redding, Heather Hayhurst, Angelica Disiena and Angela Delgado-Williams within the past 10
years.
Respectfully submitted,
RAYON SHERWIN PAYNE, PRO SE
/s/ Rayon Payne
_______________________________
8815 Conroy Windermere Rd
Ste. #208
Orlando Florida 32835
Tel: 646-543-6557
Email: info@folksalert.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
via the Florida Courts E-Filing Portal this 6th d ay of August, 2019, to: ERIC P. LARUE
II, 501 S. New York Ave. Winter Park Fl 32789.
RAYON SHERWIN PAYNE, PRO SE

/s/ Rayon Payne
___________________________

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Filing # 93696738 E-Filed 08/06/2019 06:10:17 AM

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL

JERMAINE CARLOS DIAZ,

V. CASE NO: 2019-CA-8025-O

RAYON SHERWIN PAYNE

DEFENDANT, FIRST REQUESTS FOR ADMISSION

Pursuant to Fla.R.Civ.P. Rule 1.370, Defendant RAYON SHERWIN PAYNE d/b/a

FOLKSALERT APP. (hereinafter referred to as "DEFENDANT") serves the following requests

for admission to Plaintiff, JERMAINE CARLOS DIAZ, (hereinafter referred to as

PROPOUNDING PARTY: RAYON SHERWIN PAYNE d/b/a FOLKSALERT APP

RESPONDING PARTY: JERMAINE CARLOS DIAZ

SET NUMBER: ONE

prostitution using a gun.

Admit that PLAINTIFF himself or had individuals call DEFENDANT’s job.

url: https://youtu.be/e_LBLHMwifU .. he could be heard saying to Angelica Disiena and an

Admit that PLAINTIFF called the DEFENDANT on or around February 2019.

Request Number 10;

Request Number 11;

register as sex offender.

Request Number 12;

Request Number 13;

potential customers regarding any statements made by DEFENDANT.

Request Number 14;

Request Number 15;

A Dangerous Sex Offender (Young Lace)”.

Request Number 16;

Admit that the instant litigation is a SLAPP Suit.

Request Number 18;

Request Number 19;

Request Number 20;

Request Number 21;

Request Number 22;

READ HANDED BEING A JANITOR.mp4”.

Request Number 23;

Request Number 24;

and Youtube account.

Request Number 25;

Request Number 26;

DEFENDANT’s album titled “Gorilla Exploratory” removed .

Request Number 27;

Barconia aka GGov who’s instagram username is “ggovthagovernor”.

Request Number 28;

company’s user policy.

Request Number 29;

violations to the company's user policy.

Request Number 30;

II, 501 S. New York Ave. Winter Park Fl 32789.

RAYON SHERWIN PAYNE, PRO SE

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