IN THE CIRCUIT COURT OF THE
ELEVENTH JUDICIAL CIRCUIT IN AND
FOR DADE COUNTY, FLORIDA
CASE NO.: 93-13312 FC16
IN RE: THE MARRIAGE OF FLORIDA BAR NO.: 209376
SYBIL ZISKIND n/k/a SYBIL
HART, INTERROGATORIES
Former/Wife, PROPOUNDED TO FORMER-WIFE
vs.
DAVID ZISKIND,
Former/Husband.
__________________________________/
COMES NOW, the Former/Husband, DAVID ZISKIND, by and
through his
undersigned attorney and requests
the Former-Wife, SYBIL ZISKIND n/k/a SYBIL HART
to answer, in writing, under oath,
the attached original set of Interrogatories within
(30) days from the date of service, pursuant to F.R.Civ.P..
I HEREBY CERTIFY that a true and correct copy of the
above and foregoing
together with attached original
Interrogatories were mailed this 16th day of November,
1998, Evan R. Marks, Marks &
West, P.A., Suite 2700 - NationsBank Tower, 100 S.E. Second Street, Miami,
Florida 33131
ROBERT M. HOFFMAN
Attorney for the Respondent/
Former-Husband
5975 Sunset Drive, PH 802
South Miami, Florida
33143
Tel. No.: (305) 447-1680
_____________________
ROBERT M. HOFFMAN
STANDARD FAMILY
LAW INTERROGATORIES
1. BACKGROUND
INFORMATION:
a. State your full legal name and any other name by which you
have been known.
b. State your present residence and employment or business
addresses and telephone
numbers.
c. State your Social Security Number.
d. State your date of birth.
e. List all business, commercial, and professional licenses which
you now hold or
which you have held in the last 3 years.
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.
(2) Dates of attendance.
(3) Degrees or certificates obtained.
I
2. EMPLOYMENT:
a. For each place of your employment or self-employment during
the last 3 years
state the following information:'
(1) Name, address, and telephone number of your employer.
(2) Dates of employment.
(3) Job title and brief description of job duties.
(4) Starting and ending salaries.
(5) Name of your direct supervisor.
(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.
'If you have been unemployed
at any time during the last 3 years, show the dates of unemployment.
lf you have not been
employed at any time in the last 3 years, give tile requested information for
your last
period of employment.
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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
(I) Name, address, and telephone number of each activity.
(2) Dates you were connected with such activity.
(3) Position, title and brief description of activities.
(4) Starting and ending salaries.
(5) Name of your direct super\risor.
(6) All benefits receive& 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.
2 If 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 activities.
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3. INCOME:3
a. For each of the last 3 years, state the following information:
(I) Each source of your income.
(2) The amount of income you received from each source, including
carried,
passive, and
investment income and capital gains.
b. For each of your present employment, self-employment,
business, commercial, or
professional activities, state the following information:
(I) How often and on what days you are paid.
(2) An itemization of your gross salary, wages, and income, and all
deductions from that
gross salary, wages, and income.
(3) Any additional compensation or expense reimbursement, including,
but
not limited to, overtime,
bonuses, profit sharing, insurance, expense
account, automobile
or automobile allowance that you have received or
anticipate receiving.
c. (I) State the annual total among of gifts (in
excess of $100.00) received for
each of the past three
(3) years.
(2) State the source of each gift.
(3) If you have received gifts other than money, please state the
fair market
value of the gift or
describe the gift.
3For the
purpose of these questions, the definition of Income shall be that as contained
in Section
61.39, Florida Statutes.
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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.
(2) The names and addresses of any other persons or entities
holding any interest.
(3) The date of your acquisition of your interest.
(4) The purchase price, the cost of any improvements made since it
was
purchased, and the amount of any depreciation taken.
(5) The present market value.
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:
(I) The percentage and type interest you hold.
(2) The names and addresses of any other persons or entities
holding any
interest.
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(3) The date of your acquisition of your
interest.
(4) The purchase price.
(5) The present market value.
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,
chooses in action, and debts owed to you by another entity or person.
For
each item state the following information:
(1) The percentage and type interest you hold.
(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 you are claiming a chose in action.
(3) The date of your acquisition of your
interest.
(4) The purchase price.
(5) The present market value or the amounts
you claim are owed as
receivables,
chooses in action, or debts.
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d. List
all policies of insurance that you hold, own, or in which you or any of the
children
of the marriage have 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.
(2) The policy number.
(3) The type of insurance.
(4) The face value of any life insurance or annuity policy.
(5) The date the policy was acquired.
(6) The beneficiary.
(7) The cash surrender value.
(8) The loan value.
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(9) The amount and nature of any loans outstanding against the
po]icy.
(10) The
owner of the policy.
e. Ifyou
or any of the children of the marriage are the beneficiary of any estate,
trust,
insurance policy, limited liability family corporation, partnership or annuity
state the fol]owing information for each one:
(1) Identification of the estate, trust, insurance policy, company,
partnership
or annuity.
(2) The nature and amount of the benefit.
(3) The value of the benefit.
(4) Whether the benefit is vested or contingent.
f. If you
have established any trusts, state the following information.
(1) The date the trust was established.
(2) The names and addresses of the trustees.
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(3) The names and addresses of the beneficiaries.
(4) The names and addresses of the persons or entities who possess
the trust
documents.
(5) Each asset that is held in each trust, with its present fair
market value.
g. If you
or the children of the marriage are the beneficiary of any trust, state the
following
information:
(I) The date the trust was established.
(2) The names and addresses of the trustees.
(3) The names and addresses of the beneficiaries.
(4) The names and addresses of the persons or entities who possess
the trust
documents.
(5) Each asset that is held in each trust, with its present fair
market value.
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h. Other than the financial accounts listed in your answer to
interrogatory 5 below,
list all 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
following:
(1) The name of the asset.
(2) The date you acquired the asset or the date you first obtained
the use or
benefit of it.
(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.
(4) The fair market value on the date you acquired the asset or the
use or
benefit of it.
(5) The present fair market value.
5. FINANCIAL
ACCOUNTS:
a Are you an owner, participant or alternate payee in any
pension, profit sharing,
deferred compensation, or retirement plan? if so, please
state the following:
(1) The precise legal name of the plan, and the name and address of
the plan
administrator or trustee.
(2) A description of the type of plan, whether profit sharing,
defined benefit,
defined contribution, IRA, Keogh, or other.
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(3) The account balance of any money held for your benefit or to
which you
are entitled, and your accrued monthly benefit.
(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 last 12 months.
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 who
the statements, applications, or lists were
presented.
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 1 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
11
I
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
1 year before the initiation of the action before this court until the
date of
your answering this interrogatory. 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 narure of the
security, if any; the payment
schedule; the current status of your payments; and the total
amount of arrearage, if
any.
b. List all charge accounts and credit cards upon which you are a
signatory, which
you use, or which 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 ii was received;
the value on the date of
your acquisition or use
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b. If the mental or physical condition of you or your child is an
issue, identiify the
person and state the name and address of all health care
providers involved in the
treatment of that person.
I AM AWARE THAT ANY
MATERIALLY FALSE STATEMENT KNOWINGLY MADE WITH THE
TNTENT TO DEFRAUD OR
MISLEAD SHALL SUBJECT ME TO THE PENALTY FOR PERJURY
AN'D MAY BE CONSIDERED A
FRAUD UPON THE COURT.
DATED, this _____
day of _____________ 1998.
SYBIL ZISKIND n/'k/a SYBIL
HART
COUNTY OF MIAMI-DADE
:SS:
STATE OF FLORIDA
BEFORE ME,
the undersigned authority, personally appeared, SYBIL ZISKIND n/k/a
SY'BIL HART who is personally known to me or who has
produced her ____________________ as
identification, and who, after first being duly
sworn, deposes and states that she signed the
foregoing Standard Family Law Interrogatories, and
the contents of same are true and correct.
WITNESS my hand
and seal this _____ day of ______________ 1998.
Print
Narne:
Notary
Public, State of Florida
Commission
No.
13
