Plaintiff Staffords (Zen Investments) invested money in 1999 in a company controlled by defendant Robert Vito. The latter owns several related entities referred to as the unbreakable entities (also defendants). Unbreakable propounded 43 requests for admission, including the following: If there was a contractual undertaking by Lawman to guarantee the Stafford entities or Stafford affiliates two seats on Lawman's board in Exchange for the Stafford Entities or Affiliates investment into Lawman, then the length or duration of that contract was from October 20, 1999, the date the Staffords were elected, until April 1, 2000.