IN
THE CIRCUIT COURT OF THE 11TH
JUDICIAL
CIRCUIT IN AND FOR DADE
COUNTY,
FLORIDA
FAMILY
DIVISION
CASE
NO.93-13312 FC-16 (PJ)
IN RE: THE MARRIAGE OF
SYBIL ZISKIND n/k/a SYBIL HART,
Petitioner-Former-Wife,
and NOTICEOF
5ER VICE OF
DAVID ZISKIND, ANSW£RS
TO INTERROGATORIES..
Respondent-Former
Husband
_____________________________________________________/
The Petitioner-Forrner-Wife, SYBIL HART, files this Notice and states
that on February 18,
1999, she served her ori~inal Answers to
Interrogatories to Former Wife dated November 16.1998
as well as to the 2nd Request for
Interrogatorries to Former Wife dated February 8, 1999.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the Notice of Service of Answers to
Interrogatorries
and the original answers were mailed to DAVID ZISKIND,
Pro Se, 721 Amherst Avenue, Davie,
Florida 33325S, this 18th day of February,
1999.
MARKS & WEST, P.A.
Suite 2700 - NationsBank Tower
100 S.E. Second Street
Miami, Florida 33131
Tel: (305)
374-0210
Fax (305) 374-7441
By: (Signed) Naseem Dhannani for
EVAN MARKS ESQUIRE
Florida Bar No.: 325554
MARKS & WEST, P.A.
Suite 2700
NationsBank Tower, 100 SE. Second 5treet, Miami, Florida 33131 Ph: (305)
374.0210 Fax: (305) : 374-7441
STANDARD
FAMILY LAW INTERROGATORIES
1. BACKGROUND INFORMATION:
a. State your full legal
name and any other name by which you have been known.
Sybil Hart
b. State your present
residence and employment or business addresses and telephone
numbers.
Residence: 2551 22nd Street
Lubbock, TX 79410
(806) 749-1922
Employment:
Texas Tech University
Box 4162
Lubbock, TX 79409
(806)
742-2011
c. State your Social
Security Number.
Removed for privacy
d. State your date of
birth.
January
15, 1954
e. List all business,
commercial, and professional licenses which you now hold
or which you have held
in the last 3 years.
N/A
f. List all of your education
after high school, including but not limited to,
vocational or
specialized training, including the following information:
(I) Name and address of each
educational institution.
McGill
University
Tufts
University
(2) Dates
of attendance.
McGill
University - 1971 through 1979
Tufts
University - 1979 through 1995
(3) Degrees or certificates
obtained.
McGill
University - B. Ed. & M.A.
Tufts
University - Ph.D.
2. EMPLOYMENT:
a. For each place of your
employment or self~employment during the last 3 years
state the following
information:
I
was unemployed for the period of July 1997 through September 1997
(1) Name, address, and
telephone number of your employer.
University of Miami School of Medicine
1400 Northwest
10th Avenue
Miami, Florida
(305) 248-6631
Texas Tech University
P.O. Box 41162
Lubbock, Texas 79409
(806) 742-2011
(2) Dates
of employment.
University of Miami School of Medicine
September 1995 - July 1997
Texas Tech University
September 1997 through Present
(3) Job
title and brief description ofjob duties.
University of Miami School of Medicine
Post Doctoral Student - Research
Texas Tech University
Assistant Professor - Research & Teaching
(4) Starting
and ending salaries.
University of Miami School of Medicine
1 If you have
been unemployed at any time during the last 3 years.. show the dates of
unemployment. If you have
not been
etnployed at any time in the last 3 years. give the requested information for
your last period of
employment.
$24,000.00 - $24,650.00 per year
Texas Tech University
$38,500.00 - $39,616.00 per year
(5) Name
of your direct supervisor.
N/A
(6) All
benefits received, including, for example, health, life, and disability
insurance,
expense account, use of automobile or automobile expense
reimbursement,
reimbursement for travel, food, or lodging expenses,
payment
of dues in any clubs or associations, and pension or profit-sharing plans.
N/A
b. If you have been
engaged in or associated with any business, commercial, or
professional activity
within the last 3 years that was not detailed above, state the
following information
for each such activity:2
(1) Name,
address, and telephone number of each activity.
N/A
(2) Dates
you were connected with such activity.
N/A
(3) Position
title and breif description of activities.
N/A
(4) Starting
and ending salaries.
N/A
(5) Name
of your direct supervisor.
N/A
(6) All
benefits received, including, for example, health, life, and disability
insurance,
expense account, use of automobile or automobile expense
21f you have not been engaged in any such activities at
all in the last 3 years.. give the requested information for
your last period of such activites.
reimbursement, reimbursement for travel, food, or
lodging expenses,
payment of dues in any clubs or associations, and
pension or profit-sharing
plans.
N/A
3. INCOME:3
a. For each of the last 3
years, state the following information:
(1) Each source of your
income.
N/A
(2) The amount of income
you received from each source, including earned,
passive, and
investment income and capital gains;
N/A
b. For each of your
present employment, self employment, business, commercial, or
professional
activities, state the following information:
(1) How
often and on what days you are paid.
Monthly (last business day of the month)
(2) An
itemization of your gross salary, wages, and income, and all
deductions
from that gross salary., wages, and income.
FICA - $246.74
Health Insurance - $76.04
Federal Tax - $280.21
(3) Any additional
compensation or expense reimbursement, including, but
not limited to,
overtime, bonuses, profitsharing, insurance, expense
account, automobile or
automobile allowance that you have received or
anticipate receiving.
None
c. (1) State the annual total among of gifts (in
excess of $100.00) receivable for
each
of the past three (3) years.
3For the
purpose of these questions, the definition of incorne shall be tnat as
contained in Section 61~3O, Florida
Statutes
1996 -$0.00
1997 - $0.00
1998 - $20,000.00 (parents gift to grandchildren)
(2) State the source of
each gift.
N/A
(3) If you have received
gifts other than money, please state the fair market
value of the gift or
describe the gift.
N/A
4. ASSETS:
a. State the street
address and legal description of all real property that you own, use,
or hold under a deed, lease, or contract. For each property, state the
following
information:
(1) The percentage and type
interest you hold.
N/A
(2) The names and addresses
of any other persons or entities holding any
interest
N/A
(3) The date of your
acquisition of your interest.
N/A
(4) The purchase price, the
cost of any improvements made since it was
purchased, and the
amount of any depreciation taken.
N/A
(5) The present market value.
N/A
b. List
all of the items of tangible personal property, that are owned by you or in
which
you have had any interest during the last 3 years, including but not limited
to,
motor vehicles, tools, furniture~ boats, jewelry, art objects or other
collections,
and
collectibles. For each item state the following information:
1992 Chevrolet
(1) The percentage and type
interest you hold.
N/A
(2) The
names and addresses of any other persons or entities holding any interest.
N/A
(3) The date
of your acquisition of your interest.
Bought used cannot recall name of seller
(4) The
purchase price.
$7,000.00
(5) The
present market value.
$6,500.00
c. Other than the
financial accounts listed in the answer to interrogatory 5 below, list
all of the items of
intangible personal property that are owned by you or in which
you have had any
ownership interest within the last 3 years, including but not
limited to,
partnership and business interests; (including good will), stocks, bonds
receivables. choses in
action, and debts owed to you by another entity or person.
For each item state
the following infonnation:
I owe Diversified Collection Services, Inc.
approximately $27,000.00
(1) The percentage and type
interest you hold.
N/A
(2) The names and addresses
of any other persons or entities holding any
interest, and the
names and addresses of the persons and entities who are
indebted to you or
against whom vou are claiming a chose in action.
N/A
(3) The date of your
acquisition of your interest.
N/A
(4) The purchase price.
N/A
(5) The present market
value or the amounts you claim are owed as receivables, choses in action, or
debts.
N/A
d. List all policies of
insurance that you hold, own, or in which you haye any
interest. If the owner
of any policy is anyone other than yourself, state the name
and address of such
person or entity. For each policy, state the following
information:
(1) The name of the
insurance carrier and the name, address, and telephone
number of the agent.
N/A
(2) The policy number.
N/A
(3) The type of insurance.
N/A
(4) The face value of any
life insurance or annuity policy.
N/A
(5) The date the policy was
acquired.
N/A
(6) The
beneficiary.
N/A
(7) The
cash surrender value.
N/A
(8) The loan value.
N/A
(9) The amount and nature
of any loans outstanding against the policy.
N/A
(10) The owner of the policy.
N/A
e. If you are the
beneficiary of any estate, trust, insurance policy, or annuity state
the following
information for each one:
(1) Identification of the
estate, trust, insurance policy, or annuity.
N/A
(2) The nature and amount
of the benefit
N/A
(3) The value of the
benefit.
N/A
(4) Whether the benefit is
vested or contingent.
N/A
f. If you have established any trusts,
state the following infoimation:
1) The
date the trust was established.
N/A
(2) The names and addresses
of the trustees.
N/A
(3) The names and addresses
of the beneficiaries.
N/A
(4) The
names and addresses of the persons or entities who possess the trust
documents.
N/A
(5) Each
asset that is held in each trust. with its present fair market value.
N/A
g. If you or the children of the marriage
are the beneficiary of any trust, state the
following information:
(1) The name of the asset.
N/A
(2) The date you acquired the
asset or the date you first obtained the use
or benefit of it.
N/A
(3) The name
and address of the person or entity from whom the asset
was acquired or who
allows you the use and benefit of it.
N/A
(4) The fair market value
on the date you acquired the asset or the use or
benefit of it.
N/A
(5) The fair market value
on the date of your separation from your spouse.
N/A
h. Other than the
financial accounts listed in your answer to interrogatory 5 below,
list all the other
assets that you own. in which you have any interest, or of which
you have the use and
benefit that has not already been listed. For each asset,
state the follwing:
(1) The name of the asset
Contents of Home $2,000.00
(2) The date you acquired
the asset or the date you first obtained the use or benefit of it.
U/K
(3) The name and address of
the person or entity from whom the asset was
acquired or who allows
you the use and benefit of it.
N/A
(4) The fair market value
on the date you acquired the asset or the use or
enefit of it.
N/A
(5) The present fair market
value.
U/K
5. FINANCIAL ACCOUNTS:
a. Are you an owner,
participant or alternate payee in any pension, profit sharing,
deferred compensation,
or retirement plan? If so, p~ase state the following:
(1) The precise legal name
of the plan, and the name and address of the plan
administrator or Trustee.
TIAA - CREF
(2) A description of the
type of plan, whether profit sharing, defined benefit, defined contribution,
Keogh, or other.
IRA
(3) The account balance of
any money held for your benefit or to which you
are entitled, and your
accrued monthly benefit.
$219.54
(4) The
location and last valuation date of said asset, the amount currently
vested,
and the schedule of vesting.
(5) An itemization of any
loans that you have made against the plan during the
last 5 years, the
outstanding balance of the loans, and the amounts of the
loans.
b. List all accounts,
including checking, money market, brokerage, or any other
investments that you
have had any legal or equitable interest in, regardless of
whether the interest
is or was held in your own name individually, in your name
with another person,
or in any other name, within the last 3 years Give the name
and address of each
institution, the name in which each account is or was
maintained, the
account numbers, and the names of each person authorized
to make withdrawals
from the accounts. State the present balance in each account,
giving the largest
balance during the ~ast 12 months.
Current - American State Bank – (account
number removed) - $4,561.00 current balance
Former - Nations Bank -(account
number removed)--- now closed -
highest balance $6,000.00
c. State
whether, during the past 3 years, you have prepared any financial
statements,
loan applications, or lists of your assets and liabilities. If so,
for
each document state: the date of preparation; the purpose for which the
document was
prepared;
the name and address of the person or firm who prepared the document;
and the
names and addresses of any persons or financial institutions to whom the
statements,
applications, or lists were presented.
No
d. State the names,
addresses, and telephone numbers of your accountant and any
other persons who
possess your financial records, and as to each state which
records they possess.
e. State the location of
all safes, vaults, or other similar depositories in which you
maintained property at
any time during the period commencing l year before the
initiation of the
action pending before this court until the date of furnishing
answers to this
interrogatory. State the names and addresses of all banks or other
depositories where you
had a safe deposit box; where you were a signatory or co
-signatory on a safe
deposit box; where you have access to a safe deposit box; or
where you maintained
property in a safe deposit box at any time during the period
commencing l year
before the initiation of the action before this court until the
date of your answering
this interrogatoty. Provide the name and address of each
other person who has
had access to any such depository during the same time
period. List any items
removed from any depository by you or your agent
during that time,
together with the present location and fair market value of each item.
6. LIABILITIES:
a. List all of your
liabilities, debts, and other obligations, indicating for each: the
name and address of
the creditor; the nature of the security, if any; the payment schedule; the
current status of your payments; and the total amount of arrearage, if any.
Diversified Collection Services, Inc. - approximately
$27,000.00
Arrearage approximately $17,000,00
b. List all charge
accounts and credit cards upon which you are a signatory, which
you use, or whch are
issued to you. For each account listed give the account
number, the current
status of your payments, the balance presently owed, and the
minimum monthly
payments.
7. MISCELLANEOUS:
a. List all other assets
that you own, have an interest in, or have the use or benefit of
setting forth for each your interest in the
asset and its value. For each, set forth the
date of your
acquisition, receipt, or inheritance, or the date of your first being
given use or benefit;
the party from whom it was received; the value on the date
of your acquisition or
use.
