V I R G I N I A : IN THE GENERAL DISTRICT COURT OF ARLINGTON COUNTY CIVIL DIVISION RAM AVRAHAMI, : : Plaintiff, : : v. : Civil Action No. 95-7479 : : U.S. NEWS & WORLD REPORT, INC., : : Defendant. : PLAINTIFF REQUEST FOR ADMISSION COMES NOW the Plaintiff, Ram Avrahami, by counsel, and propounds the following requests for admission to Defendant U.S. News and World Report ("U.S. News"): 1. That pursuant to a list exchange agreement dated March 5, 1995, between Defendant U.S News and the Smithsonian Magazine, on or about March 24, 1995, Plaintiff Ram Avrahami's name and address was transferred to the Smithsonian Magazine as a part of a mailing list. 2. That in exchange for the mailing list referred to above in paragraph 1, U.S. News received from the Smithsonian a comparable mailing list and/or the equivalent commercial value. RAM AVRAHAMI By Counsel Law Offices of Jonathan C. Dailey 1050 17th Street, N.W., Suite 600 Washington, D.C. 20036 (202) 496-1290 By: /s/ Jonathan C. Dailey (#37442) ======================================================================