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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT LAUDERDALE DIVISION 

CASE NO.: 0:20-cv-61469-XXXX 

AKAI CUSTOM GUNS, LLC, 

a Florida Limited Liability Company, 

and SHAY HOROWITZ, an Individual, 

Plaintiffs, 

vs. 

KKM PRECISION, INC. a Nevada Corporation, 

SHOOTERS CONNECTION, INC., a Kentucky 

Corporation, CHARLES BRADLEY, an Individual 

and Kentucky Resident, TIMOTHY MEKOSH, 

an Individual and Kentucky Resident, and MICHAEL 

DAME, a Canadian Citizen and Kentucky Resident. 

Defendants. 

_____________________________________________/ 

DEFENDANT, SHOOTERS CONNECTION, INC.’S, 

SECOND AMENDED RESPONSES 

TO PLAINTIFFS’ SECOND REQUEST FOR ADMISSIONS 

Defendant, Shooter’s Connection, Inc. (“SCI”), pursuant to Florida Rules of Civil 

Procedure, hereby serves this Second Amended Response to Plaintiffs’ Second Request for 

Admissions (“RFAs”) as follows: 

REQUEST NO. 1: Admit you sold one (1) 1911 style KKM barrels to Plaintiff 

AKAI on April 2, 2018. 

RESPONSE: Admit. 

REQUEST NO. 2: Admit the one (1) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on, was not made from certified 416R gun-barrel quality stainless steel bar 

stock. 

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RESPONSE: Deny. 

REQUEST NO. 3: Admit you sold five (5) 1911 style KKM barrels to Plaintiff 

AKAI on April 4, 2019. 

RESPONSE: Admit. 

REQUEST NO. 4: Admit the five (5) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on April 4, 2019, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 5: Admit you sold three (3) 1911 style KKM barrels to Plaintiff 

AKAI on July 5, 2019. 

RESPONSE: Admit. 

REQUEST NO. 6: Admit the three (3) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on July 5, 2019, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 7: Admit you sold seven (7) 1911 style KKM barrels to Plaintiff 

AKAI on October 2, 2018. 

RESPONSE: Admit. 

REQUEST NO. 8: Admit the seven (7) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on October 2, 2018, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

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REQUEST NO. 9: Admit you sold four (4) 1911 style KKM barrels to Plaintiff 

AKAI on November 8, 2017. 

RESPONSE: Admit. 

REQUEST NO. 10: Admit the four (4) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on November 8, 2017, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny.

REQUEST NO. 11: Admit you sold three (3) 1911 style KKM barrels to Plaintiff 

AKAI on January 27, 2019. 

RESPONSE: Admit. 

REQUEST NO. 12: Admit the three (3) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on January 27, 2019, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny.

REQUEST NO. 13: Admit you sold two (2) 1911 style KKM barrels to Plaintiff 

AKAI on January 28, 2019. 

RESPONSE: Admit. 

REQUEST NO. 14: Admit the two (2) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on January 28, 2019, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny.

REQUEST NO. 15: Admit you sold three (3) 1911 style KKM barrels to Plaintiff 

AKAI on April 22, 2019. 

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RESPONSE: Admit. 

REQUEST NO. 16: Admit the three (3) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on April 22, 2019, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny.

REQUEST NO. 17: Admit you sold three (3) 1911 style KKM barrels to Plaintiff 

AKAI on April 30, 2019. 

RESPONSE: Admit. 

REQUEST NO. 18: Admit the three (3) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on April 30, 2019, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 19: Admit you sold three (3) 1911 style KKM barrels to Plaintiff 

AKAI on May 20, 2019. 

RESPONSE: Admit. 

REQUEST NO. 20: Admit the three (3) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on May 20, 2019, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 21: Admit you sold four (4) 1911 style KKM barrels to Plaintiff 

AKAI on May 29, 2018. 

RESPONSE: Admit. 

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REQUEST NO. 22: Admit the four (4) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on May 29, 2018, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 23: Admit you sold seven (7) 1911 style KKM barrels to Plaintiff 

AKAI on May 30, 2019. 

RESPONSE: Admit. 

REQUEST NO. 24: Admit the seven (7) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on May 30, 2019, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 25: Admit you sold four (4) 1911 style KKM barrels to Plaintiff 

AKAI on May 31, 2018. 

RESPONSE: Admit. 

REQUEST NO. 26: Admit the four (4) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on May 31, 2018, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 27: Admit you sold one (1) 1911 style KKM barrels to Plaintiff 

AKAI on July 11, 2019. 

RESPONSE: Deny. SCI further states that this sale was cancelled. 

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REQUEST NO. 28: Admit the one (1) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on July 11, 2019, was not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 29: Admit you sold thirteen (13) 1911 style KKM barrels to Plaintiff 

AKAI on July 30, 2018. 

RESPONSE: Admit. 

REQUEST NO. 30: Admit the thirteen (13) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on July 30, 2018, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 31: Admit you sold two (2) 1911 style KKM barrels to Plaintiff 

AKAI on August 22, 2019. 

RESPONSE: Admit.

REQUEST NO. 32: Admit the two (2) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on August 22, 2019, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 33: Admit you sold one (1) 1911 style KKM barrels to Plaintiff 

AKAI on August 23, 2017. 

RESPONSE: Admit. 

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REQUEST NO. 34: Admit the one (1) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on August 23, 2017, was not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 35: Admit you sold five (5) 1911 style KKM barrels to Plaintiff 

AKAI on September 11, 2019. 

RESPONSE: Admit. 

REQUEST NO. 36: Admit the five (5) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on September 11, 2019, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 37: Admit you sold four (4) 1911 style KKM barrels to Plaintiff 

AKAI on September 14, 2017. 

RESPONSE: Admit. 

REQUEST NO. 38: Admit the four (4) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on September 14, 2017, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 39: Admit you sold three (3) 1911 style KKM barrels to Plaintiff 

AKAI on September 27, 2017. 

RESPONSE: Admit. 

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REQUEST NO. 40: Admit the three (3) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on September 27, 2017, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 41: Admit you sold four (4) 1911 style KKM barrels to Plaintiff 

AKAI on October 15, 2019. 

RESPONSE: Admit. 

REQUEST NO. 42: Admit the four (4) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on October 15, 2019, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 43: Admit you sold one (1) 1911 style KKM barrels to Plaintiff 

AKAI on October 16, 2018. 

RESPONSE: Admit. 

REQUEST NO. 44: Admit the one (1) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on October 16, 2018, was not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 45: Admit you sold two (2) 1911 style KKM barrels to Plaintiff 

AKAI on November 22, 2017. 

RESPONSE: Admit. 

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REQUEST NO. 46: Admit the two (2) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on November 22, 2017, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 47: Admit you sold four (4) 1911 style KKM barrels to Plaintiff 

AKAI on November 29, 2017. 

RESPONSE: Admit. 

REQUEST NO. 48: Admit the four (4) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on November 29, 2017, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 49: Admit you sold three (3) 1911 style KKM barrels to Plaintiff 

AKAI on January 27, 2019. 

RESPONSE: Admit. 

REQUEST NO. 50: Admit the three (3) 1911 style KKM barrels that you sold to 

Plaintiff AKAI on January 27, 2019, were not made from certified 416R gun-barrel quality 

stainless steel bar stock. 

RESPONSE: Deny. 

REQUEST NO. 51: Admit that in 2016, you advertised 1911 style KKM barrels for 

sale on the SCI website. 

RESPONSE: Admit. 

REQUEST NO. 52: Admit that in 2016 the 1911 style KKM barrels you advertised 

for sale on the SCI website included the following description: “All KKM barrels are made 

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using U.S. manufactured 416 Stainless steel bar stock which is then heat treated and vacuum 

tempered to 42 to 45 RC.” 

RESPONSE: SCI lacks the knowledge and information necessary to either admit or deny 

this request. SCI has made a reasonable inquiry and the information it knows or can readily obtain 

is insufficient to enable it to admit or deny. In particular, SCI does not maintain copies of its 

previous websites, including product descriptions, and SCI’s computer system does not record a 

history of changes to product description or any data relating to the product pages. It should also 

be noted that SCI sells over 4,000 products, and obtains the product descriptions from the 

manufacturer. 

As part of its reasonable inquiry, SCI consulted with its IT vendor, Ablemods Hosting, 

LLC. Joseph Payne, sole owner and representative of Ablemods, confirmed that Ablemods does 

not maintain copies of SCI’s current or previous websites, including any product descriptions, and 

that SCI’s computer system does not record a history of changes to product descriptions or any 

data relating to SCI’s products. 

REQUEST NO. 53: Admit that subsequent to 2016, you removed the following 

description from the 1911 style KKM barrels you advertised for sale on the SCI website: 

“All KKM barrels are made using U.S. manufactured 416 Stainless steel bar stock which is 

then heat treated and vacuum tempered to 42 to 45 RC.” 

RESPONSE: Objection. The term “subsequent to 2016” is vague, ambiguous, and 

confusing. Without waiving these objections, SCI admits that it removed the above-cited language 

sometime after this lawsuit was filed to in order conform to KKM’s specifications. SCI further 

states that it only advertised the product specifications which were provided by KKM. Sometime 

after this lawsuit was filed, KKM modified its product specifications with regard to 1911 barrels, 

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removing the above-cited language. Consequently, SCI’s then changed its advertised 

specifications of these barrels to conform KKM’s new specifications. 

REQUEST NO. 54: Admit that from January 2017 to October 2019, the 1911 style 

KKM barrels you advertised for sale on the SCI website were not made from the same type 

of steel as the 1911 style KKM barrels advertised on the KKM website. 

RESPONSE: Deny. 

REQUEST NO. 55: Admit that from January 2017 to October 2019, the 1911 style 

KKM barrels you advertised for sale on the SCI website did not include any description of 

the type of steel the KKM barrels were made from. 

RESPONSE: SCI lacks the knowledge and information necessary to either admit or deny 

this request. SCI has made a reasonable inquiry and the information it knows or can readily obtain 

is insufficient to enable it to admit or deny. In particular, SCI does not maintain copies of its 

previous websites, including product descriptions, and SCI’s computer system does not record a 

history of changes to product description or any data relating to the product pages. It should also 

be noted that SCI sells over 4,000 products, and obtains the product descriptions from the 

manufacturer. 

As part of its reasonable inquiry, SCI consulted with its IT vendor, Ablemods Hosting, 

LLC. Joseph Payne, sole owner and representative of Ablemods, confirmed that Ablemods does 

not maintain copies of SCI’s current or previous websites, including any product descriptions, and 

that SCI’s computer system does not record a history of changes to product descriptions or any 

data relating to SCI’s products. 

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REQUEST NO. 56: Admit that from January 2017 to October 2019, the 1911 style 

KKM barrels you advertised for sale on the SCI website did not include any description of 

the Rockwell hardness of the steel for the KKM barrels you sold to the public. 

RESPONSE: SCI lacks the knowledge and information necessary to either admit or deny 

this request. SCI has made a reasonable inquiry and the information it knows or can readily obtain 

is insufficient to enable it to admit or deny. In particular, SCI does not maintain copies of its 

previous websites, including product descriptions, and SCI’s computer system does not record a 

history of changes to product description or any data relating to the product pages. It should also 

be noted that SCI sells over 4,000 products, and obtains the product descriptions from the 

manufacturer. 

As part of its reasonable inquiry, SCI consulted with its IT vendor, Ablemods Hosting, 

LLC. Joseph Payne, sole owner and representative of Ablemods, confirmed that Ablemods does 

not maintain copies of SCI’s current or previous websites, including any product descriptions, and 

that SCI’s computer system does not record a history of changes to product descriptions or any 

data relating to SCI’s products. 

REQUEST NO. 57: Admit that subsequent to the filing of the Plaintiffs’ First 

Amended Complaint, you have not taken any steps to retract any statements you made on 

the SCI Facebook page regarding Plaintiff AKAI and/or Plaintiff HOROWITZ as outlined 

in Plaintiffs’ First Amended Complaint. 

RESPONSE: Objection. This request is vague, ambiguous, confusing, and 

argumentative. Without waiving these objections, SCI denies the statement as worded. SCI 

further states that it never made any false or otherwise defamatory statements regarding Plaintiffs 

and, therefore, there was no reason to retract anything. 

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Respectfully submitted this 10th day of August 2022. 

/s/ John Y. Benford 

Nicholas D. Freeman, Esq. 

Florida Bar No. 118620 

Nicholas.freeman@wilsonelser.com

John Y. Benford, Esq. 

Florida Bar No. 51950 

John.benford@wilsonelser.com

Wilson Elser Moskowitz Edelman & Dicker LLP 

111 North Orange Avenue, Suite 1200 

Orlando, FL 32801 

(407) 203-7599 – Phone 

(407) 648-1376 – Facsimile 

Attorneys for Defendants, Shooters Connection, Inc. 

and Charles Bradley 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on August 10, 2022, I electronically served this document on 

all counsel of record identified on the service list below. 

/s/ John Y. Benford 

JOHN Y. BENFORD, ESQ. 

SERVICE LIST 

Law Offices of Richard Fiato 

Richard J. Fiato 

550 W. Merrill Street, Suite 200 

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Birmingham, MI 48009 

Attorney for Plaintiffs 

fiatolaw@gmail.com 

Edmund Yee 

McKelvie, McKelvie, Yee & Epacs, P.C. 

280 West Maple Road, Suite 220 

Birmingham, Michigan 48009 

eyee@mmyelaw.com

Attorney for Plaintiffs 

Zimmerman Kiser Sutcliffe 

Kevin P. Robinson 

315 East Robinson Street, Suite 600 

Orlando, FL 32801 

Attorney for Defendant KKM 

krobinson@zkslawfirm.com

JWenhold@zkslawfirm.com

service@zkslawfirm.com

Cole, Scott & Kissane, P.A. 

John A. Chiocca 

222 Lakeview Avenue, Suite 120 

West Palm Beach, FL 33401 

Attorneys for SCI and Bradley 

John.chiocca@csklegal.com

Stephanie.chiocca@csklegal.com

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