UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

In re: DARD DEFRAND, Chapter 13

Bankr. No. 20-22409-PDR

Debtor.

__________________________________________/

NATIONWIDE JUDGMENT RECOVERY, INC., Judge Peter D. Russin

Plaintiff, Adversary No. 21-01047

v.

DARD DEFRAND

aka PLUS20,

Defendant.

/

PLAINTIFF'S FIRST REQUESTS FOR ADMISSION

UNDER FED.R.BANKR.P. 7036 AND RULE 36 F.R.CIV.P.

To: Dard Defrand

c/o Tarek K. Kiem, Esquire

KIEM LAW, PLLC

8461 Lake Worth Road, Suite 114

Lake Worth, FL 33467

Pursuant to Fed.R.Bank.P. 7036 and 7026 and Rules 36 and 26(b) F.R.Civ.P., Plaintiff 

Nationwide Judgment Recovery, Inc. (“Plaintiff” or “Nationwide”) requests Defendant make the 

following admissions within 30 days of service of these Requests for the purpose of this action 

only and subject to all pertinent objections to admissibility which may be interposed at the trial.

INSTRUCTIONS FOR REQUESTS FOR ADMISSIONS

Space has been provided below each Request For Admission for your answer. If you require 

additional space, you may attach an additional sheet or sheets of paper which refer to the 

appropriate Request For Admission.

Fed.R.Bankr.P. 7036 and Fed.R.Civ.P. 36 provide that:

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You must serve your written answer or objection to each Request upon Plaintiff’s

attorney within 30 days of service of these Requests For Admission upon you. The Answers 

must be signed by you or your attorney. Failure to answer or object within 30 days may be 

deemed an admission.

An answer shall admit the Request, specifically deny the matter, or set forth in detail the 

reasons why you cannot truthfully admit or deny the matter.

You may not give lack of information or knowledge as a reason for failing to admit or 

deny unless you have made a reasonable inquiry and after such reasonable inquiry the 

information known or readily obtainable is still insufficient for you to admit or deny.

If you fail to admit the genuineness of any document or the truth of any matter requested 

in these Requests For Admission, and if Plaintiff thereafter proves the genuineness of the 

document or the truth of the matter, Plaintiff may apply to the Court for an order under 

Fed.R.Bankr.P. 7037 and Fed.R.Civ.P. 37(c) for an order requiring you to pay the reasonable 

expenses incurred in making that proof, including reasonable attorney’s fees.

A party is under a duty seasonably to amend a prior response to a Request for Admission 

if the party learns that the response is in some material respect incomplete or incorrect and if the 

additional or corrective information has not otherwise been made known to the other parties 

during the discovery process or in writing.

DEFINITIONS

1. “You” and “your” mean the names of the party or parties to whom these 

Interrogatories are directed and all parties acting on behalf of such party or parties, including but 

not limited to, attorneys and their associates and employees, investigators, agents, employees, 

representatives, or others who are in possession of or who may have obtained information for or 

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on behalf of the party or parties to whom these Interrogatories are directed.

2. “Document” or “writing” means any written or graphic matter or other means of 

preserving thought or expression and all tangible things in which information can be processed 

or transcribed including, but not limited to, correspondence, messages, telegrams, contracts, 

memoranda, studies, surveys, charts, reports, minutes, notes, diaries, schedules, canceled checks, 

drafts, photographs, releases, newspaper or magazine articles, books, financial statements, 

ledgers, transcripts, affidavits, tapes, tape recordings, video tapes or recordings, motion pictures, 

phonograph recordings, compact disks, optical disks, material read by laser scanning, computer 

disks, computer tapes, computer printouts, and information stored in data processing or retrieval 

systems, whether originals, copies or drafts, however produced or reproduced.

3. “Judgment” refer to the Final Judgment entered on August 14, 2017 in Bell v. 

Disner, Case 3:14 – cv-00091-GCM (W.D.N.C. 2014).

4. “Person” means any natural person, any legal or business entity, and any public 

or quasi-public entity.

5. “Identify” referring to a natural person means:

a. The full name of each person.

b. The present or last known address and telephone number of the person 

including, but not limited to, the street address, city, state and zip code.

c. The occupation and employer of the person at the time referred to in these 

Interrogatories.

6. “Identify” referring to an entity other than a natural person means:

a. The full legal and trade name(s) or title(s) of such entity.

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b. The present or last known address and telephone number of the entity 

including, but not limited to, the street address, city, state and zip code.

7. “Identify” referring to a document, means:

a. A brief summary of its contents.

b. An identification of the person(s) drafting, preparing, compiling, and 

signing it.

c. The date the document was prepared or received.

d. The date noted on the document itself.

9. “Petition Date” means the date on which you filed for bankruptcy, November 12, 

2020.

A. Admit or deny the following.

1. Admit that the total amount you paid to and/or “invested” in Rex Venture Group, 

LLC d/b/a www.ZeekRewards.com is $595.00.

RESPONSE:

2. Admit that you received a total of $25,411.57 from Rex Venture Group, LLC 

d/b/a www.ZeekRewards.com because of your participation in ZeekRewards.

RESPONSE:

3. Admit that you received transfers totaling $25,411.57 from Rex Venture Group, 

LLC d/b/a www.ZeekRewards.com between January 23, 2012 and July 23, 2012 because of your 

participation in ZeekRewards.

RESPONSE:

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4. Admit that any and all funds you received from Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com were because of your participation in ZeekRewards and/or because you 

referred participants to ZeekRewards.

RESPONSE:

5. Admit that over the life of your participation, you received from Rex Venture 

Group, LLC d/b/a www.ZeekRewards.com on account of your participation, a total of 

$24,816.57 more than the amount you paid to ZeekRewards. 

RESPONSE:

6. Admit that you did not review any of Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com’s financial statements (balance sheet, profit and loss statement, income 

statement, statement of cash flows, etc.) or state or federal income tax returns prior to making 

your investment in ZeekRewards.

RESPONSE:

7. Admit that you invested in Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com at least in part because its program promised higher rates of return than 

other investment options. 

RESPONSE: 

8. Admit that a diligent investigation of Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com and its program by you would have revealed that it was a Ponzi

scheme. 

RESPONSE:

9. Admit that Rex Venture Group, LLC d/b/a www.ZeekRewards.com did not 

receive reasonably equivalent value for transfers made to you in excess of your initial 

investment(s). 

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RESPONSE:

10. Admit that the November 29, 2016 Order granting the Receiver’s Motion for 

Summary Judgment Against Remaining Named Defendants and Partial Summary Judgment 

Against the Net Winner Class in Bell v. Disner, Case 3:14 – cv-00091-GCM (W.D.N.C. 2014) 

found that Rex Venture Group, LLC d/b/a www.ZeekRewards.com did not receive reasonably 

equivalent value for transfers made to you in excess of your initial investment. 

RESPONSE:

11. Admit that Rex Venture Group, LLC d/b/a www.ZeekRewards.com. 

was a Ponzi scheme from at least as early as October, 2011.

RESPONSE:

12. Admit that you never requested any of Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com’s financial information.

RESPONSE:

13. Admit that Bell v. Disner, Case 3:14 – cv-00091-GCM (W.D.N.C. 2014) resulted 

in a judgment being entered against you in the amount of $33,327.43.

RESPONSE:

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14. Admit that attached hereto as Appendix “A” is the judgment entered against you 

in Bell v. Disner, Case 3:14 – cv-00091-GCM (W.D.N.C. 2014) in the amount of $33,327.43.

RESPONSE:

15. Admit that you filed for bankruptcy to discharge your personal liability on the 

judgment against you held by Nationwide Judgment Recovery, Inc.

RESPONSE:

16. Admit that Rex Venture Group, LLC d/b/a www.ZeekRewards.com was a Ponzi 

and /or multilevel marketing scheme.

RESPONSE:

17. Admit that at the time of your participation, you knew that Rex Venture Group, 

LLC d/b/a www.ZeekRewards.com was a Ponzi and/or multilevel marketing scheme. 

RESPONSE:

18. Admit that attached hereto as Appendix B is the statement from the records of 

Rex Venture Group, LLC d/b/a www.ZeekRewards.com.

RESPONSE:

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19. Admit that the statement from the records of Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com, attached hereto as Appendix B, accurately represent the funds you paid 

to, and the transfers you received from, ZeekRewards.

RESPONSE:

20. Admit that the records of Rex Venture Group, LLC, attached hereto as Appendix 

B, show that you paid in a total of $595.00 to Rex Venture Group, LLC d/b/a

www.ZeekRewards.com. 

RESPONSE:

21. Admit that the statements from the records of Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com, attached hereto as Appendix B, show that you received commission 

payments from “RPP “Profit Share”, Non-Subscription Matrix Payments, Diamond Pool, and 

Subscription Matrix Payments.

RESPONSE:

22. Admit that the funds and/or transfers you received from Rex Venture Group, LLC 

d/b/a www.ZeekRewards.com were fraudulent transfers.

RESPONSE:

23. Admit that the Order Granting Motion for Summary Judgment in Bell v. Disner, 

Case 3:14 – cv-00091-GCM (W.D.N.C. 2014), found that the transfers from the ZeekRewards 

Ponzi scheme were fraudulent.

RESPONSE:

24. Admit that you knew you were violating federal securities laws by your 

participation in ZeekRewards Ponzi scheme.

RESPONSE:

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25. Admit that you willingly participated in Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com.

RESPONSE:

26. Admit that you willingly participated in Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com because it was financially profitable for you.

RESPONSE:

27. Admit that at the time you signed up to participate in Rex Venture Group, LLC 

d/b/a www.ZeekRewards.com, you were familiar with Ponzi and/or Multi-level marketing 

schemes because you had previously participated in such a scheme and understood how they 

worked.

RESPONSE:

28. Admit that since your involvement in ZeekRewards you have participated in other 

Ponzi and/or Multi-level marketing schemes. 

RESPONSE: 

29. Admit that your net winnings from your participation in the Rex Venture Group, 

LLC d/b/a www.ZeekRewards.com Ponzi scheme were obtained through your false pretenses, a 

false representation, or actual fraud.

RESPONSE:

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30. Admit that when you received transfers from Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com you knew that you were participating in a Ponzi and/or Multi-level 

marketing scheme.

RESPONSE:

31. Admit that your net winnings from your participation in the Rex Venture Group, 

LLC d/b/a www.ZeekRewards.com Ponzi scheme were obtained with the intention and purpose 

of deceiving victims of the Ponzi scheme. 

RESPONSE:

32. Admit that by your participation in the Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com Ponzi scheme, you intended to defraud those participants you recruited 

who were in your “downline.” 

RESPONSE:

33. Admit that all of the transfers and/or payments received as a result of your 

participation in the Rex Venture Group, LLC d/b/a www.ZeekRewards.com Ponzi scheme were 

made to you.

RESPONSE:

34. Admit that all of payments from Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com Ponzi scheme as shown on Appendix “B” were obtained through actual 

fraud.

RESPONSE:

35. Admit that the November 29, 2016 Order granting the Receiver’s Motion for 

Summary Judgment Against Remaining Named Defendants and Partial Summary Judgment 

Against the Net Winner Class in Bell v. Disner, Case 3:14 – cv-00091-GCM (W.D.N.C. 2014) 

found that Rex Venture Group, LLC d/b/a www.ZeekRewards.com was a Ponzi scheme.

RESPONSE:

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36. Admit that the judgment entered against you in Bell v. Disner, Case 3:14 – cv00091-GCM (W.D.N.C. 2017) in the amount of $33,327.43 was for violation of the North 

Carolina Uniform Fraudulent Transfer Act, N.C. Gen. Stat. §§ 39-23.4(a)(1). 

RESPONSE:

37. Admit that the transfers you received as a result of your participation in Rex 

Venture Group, LLC d/b/a www.ZeekRewards.com were in furtherance of the Ponzi scheme.

RESPONSE:

38. Admit that transfers in furtherance of a Ponzi scheme are presumed to have been 

made and/or received with an intent to defraud. 

RESPONSE:

39. Admit that you purchased bids to give away as a promotion to get people to try 

Rex Venture Group, LLC d/b/a www.ZeekRewards.com. 

RESPONSE:

40. Admit that you purchased bids every day to give away as a promotion to get 

people to try Rex Venture Group, LLC d/b/a www.ZeekRewards.com. 

RESPONSE:

41. Admit that Rex Venture Group, LLC d/b/a www.ZeekRewards.com was a “task 

driven” program that allowed you to succeed as the result of performing specific tasks rather 

than selling products or services.

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RESPONSE:

42. Admit that those tasks referenced in Request for Admission No. 41 included 

placing digital ads. 

RESPONSE:

43. Admit that placing digital ads resulted in your receiving a share of the profit pool.

RESPONSE:

44. Admit that you knew that Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com offered several ways to earn money, two of which involved purchasing 

securities in the form of investment contracts.

RESPONSE:

45. Admit that there were six ways to earn money through Rex Venture Group, LLC 

d/b/a www.ZeekRewards.com. 

RESPONSE:

46. Admit that one of the 6 income streams is the “daily profit share,” where you earn 

money based on your VIP point balance.

RESPONSE:

47. Admit that of the six ways to earn money through Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com, four involved recruiting people to participate rather than selling items. 

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RESPONSE:

48. Admit that you purchased securities in the form of investment contracts. 

RESPONSE:

49. Admit that to grow your balance and earn more money, you were required to give 

bids away to your “customers.”

RESPONSE:

50. Admit that as a result of your participation in ZeekRewards, you were paid for 

recruiting other participants in a pyramid “multi-level” sales format.

RESPONSE:

51. Admit that Every time you sold Retail Bids or give away VIP Bids as samples to 

retail customers through Rex Venture Group, LLC d/b/a www.ZeekRewards.com, you earned 

points in your ZeekRewards VIP ProfitPoint balance. 

RESPONSE:

52. Admit that the more people you recruited, the more money you would earn from 

Rex Venture Group, LLC d/b/a www.ZeekRewards.com. 

RESPONSE:

53. Admit that you received $20,973.72 in funds and/or transfers solely from RPP 

“Profit Share.”

RESPONSE:

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54. Admit that the statements from the records of Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com, attached hereto as Appendix B, shows that you received $20,973.72

solely from RPP “Profit Share.”

RESPONSE:

55. Admit that in order to receive funds from the RPP “Profit Share,” you were 

required to buy bids.

RESPONSE:

56. Admit that each time you sold Retail Bids or gave away VIP Bids as samples to 

retail customers through Rex Venture Group, LLC d/b/a www.ZeekRewards.com, you earned 

points in your ZeekRewards VIP ProfitPoint balance. 

RESPONSE:

57. Admit that you participated in Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com because it promoted a lucrative “compensation plan” and offered large 

amounts of passive income to entice individuals to participate in the scheme.

RESPONSE:

58. Admit that you were advised by Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com of words and phrases to not say, including “compounder, compound, 

compounded, compounding, 125%, Members, Interest, Investment, Mature.”

RESPONSE:

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59. Admit that you were advised by Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com of words and phrases to say, including “You make a purchase and repurchase; You earn bids; The bids retire on a 90 day timeline averaging 1.5% a day; You get 

cash rewards; Retail Profit Pool; Everyone is an Affiliate and they own business center 

subscriptions; Your Bid balance can increase as oppose to mature.” 

RESPONSE:

60. Admit that you participated in Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com because of the promise of a return on the funds you paid into the 

scheme.

RESPONSE:

61. Admit that you knew that Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com lacked any underlying legitimate product or service or asset.

RESPONSE:

62. Admit that you had to recruit people to participate in Rex Venture Group, LLC 

d/b/a www.ZeekRewards.com in order to earn money.

RESPONSE:

63. Admit that Rex Venture Group, LLC d/b/a www.ZeekRewards.com

told you to not ask questions about how the “business” worked.

RESPONSE:

64. Admit that Rex Venture Group, LLC d/b/a www.ZeekRewards.com

rewarded you for the amount of funds you paid into, and kept, in the system and for recruiting 

people who did the same. 

RESPONSE:

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65. Admit that Rex Venture Group, LLC d/b/a www.ZeekRewards.com rewarded you 

for recruiting people who put, and kept, money in the system.

RESPONSE:

66. Admit that you needed to give away or sell at least 10 bids every day to share in 

ZeekRewards’ profit pool.

RESPONSE:

67. Admit that you knew that Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com sold unregistered securities.

RESPONSE:

68. Admit that you should have known that Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com sold unregistered securities.

 RESPONSE:

 

69. Admit that you purchased securities in the form of investments contracts when 

you bought bids from Rex Venture Group, LLC d/b/a www.ZeekRewards.com. 

RESPONSE:

70. Admit that you knew at the time you recruited them that those participants in your 

“downline” would not realize the same success you had from ZeekRewards.

RESPONSE:

71. Admit that your full legal name, social security number and current address, as 

shown on your Bankruptcy Petition, are accurate.

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RESPONSE:

72. Admit that the information contained in your Statement of Financial Affairs and 

supporting Schedules filed in this bankruptcy is accurate.

RESPONSE:

73. Admit that you read the “Instructions” and “Definitions” accompanying 

Plaintiff’s First Set of Interrogatories, First Request for Production of Documents and First 

Request for Admissions attached hereto.

RESPONSE:

B. Admit that each of the following documents, attached to this Request, is genuine.

1. The judgment entered against you in Bell v. Disner, Case 3:14 – cv-00091-GCM 

(W.D.N.C. 2017) in the amount of $33,327.43 a copy of which is attached hereto as Appendix

“A”.

RESPONSE:

2. The statements from the records of Rex Venture Group, LLC d/b/a 

www.ZeekRewards.com showing cash paid in and commission payments and/or transfers, a 

copy of which is attached hereto as Appendix “B”.

RESPONSE:

Attorneys for Plaintiff

SANDLER & SANDLER

By M. L. Sandler, P.A.

3390 Mary Street

Suite 116

Miami, FL 33133

Tel: 305-379-6655

Fax: 786-472-7077

Case 21-01047-PDR Doc 39 Filed 07/01/21 Page 17 of 19
___/s/ Martin L. Sandler_______

Martin L. Sandler, Esquire

Florida Bar No. 0070370 

Dated: 

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