UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

FT. LAUDERDALE DIVISION

www.flsb.uscourts.gov

In re: Case No. 20-22409-PDR

DARD DEFRAND Chapter 13

Debtor 

_______________________________/ 

NATIONWIDE JUDGMENT 

RECOVERY, INC.

Plaintiff, 

 v. Adv. Proc. No.: 21-01047-PDR

DARD DEFRAND, 

 Defendant. 

_______________________________/

DEFENDANT’S INITIAL RULE 26 DISCLOSURES 

COME NOW Defendant, DARD DEFRAND (“Defendant” or “Debtor”), by and through 

its undersigned counsel, and without waiving any claim of privilege, work product or other basis

for non-disclosure, and based on information presently available, hereby makes the following

initial disclosures pursuant to Rule 26(a)(1) of the Federal Rules of Civil Procedure, made

applicable to this proceeding under Federal of Bankruptcy Procedure 7026. Defendants reserve 

the right to supplement this disclosure as provided by the Federal of Bankruptcy Procedure, 

Federal Rules of Civil Procedure and the Local Rules of this Court.

1. Rule 26(a)(1)(A)(i) Disclosures: 

Defendant’s initial disclosure of the identities of individuals likely to have discoverable

information is based solely upon such information that Defendant has been able to discover thus 

far in the amount of time available, as well as Defendant’s present analysis of the case, and

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shall not, in any way, be deemed to be a representation that additional witnesses do not exist.

Accordingly, this disclosure is subject to Defendant’s ability to discover additional individuals

with knowledge of facts concerning the material allegations of Plaintiff's Complaint, or any of

the defenses asserted by Defendant. 

a. Plaintiff, NATIONWIDE JUDGMENT RECOVERY, INC., including its 

assigner, Receiver of the estate of Rex Venture Group, LLC, d/b/a 

www.ZeekRewards.com, c/o Martin L Sandler, Esq, Suite 116, 3390 Mary 

Street, Miami, FL 33133, 305-379-6655, Email: martin@sandler-sandler.com. 

Plaintiff is believed to possess information related to Plaintiff’s claims and

Defendant’s defenses alleged in this matter, including, but not limited to, the 

nature and extent of the claims referenced in Plaintiff's Complaint.

b. Defendant, Dard Defrand, c/o Attorney Tarek Kiem, Kiem Law, PLLC, 8461 

Lake Worth Rd., Suite 114, Lake Worth, FL 33467, Telephone 561-600-0406. 

Defendant has discoverable information regarding: (i) Plaintiff's claims; (ii)

communications, or lack thereof, with Plaintiff concerning the claims; and (iii) 

facts relating to Defendant’s defenses.

c. Any other individual or representatives from any other entity that may

have knowledge of the allegations in Plaintiff's Complaint and Defendant’s

defenses.

d. Any witness identified by any other party.

e. Any individual listed in documents produced by either party.

f. Any witness necessary for impeachment or rebuttal.

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Identification of any person does not constitute a representation that such person has

information that is non-privileged, nor does it constitute a waiver of any privilege or objection that 

may be made to such witness' testimony. Defendants also reserve the right to supplement this 

disclosure as discovery is ongoing.

2. Rule 26(a)(1)(A)(ii) Disclosures: 

Defendants’ initial disclosure of documents is based solely upon such information and

documents that Defendant has been able to discover thus far in the amount of time available, as

well as Defendant’s present analysis of the case, and shall not in any way be deemed to be a

representation that additional documents do not exist. Defendant’s investigation of the facts

and circumstances surrounding the case is ongoing, and Defendant’s reserves the right to amend 

and or supplement this disclosure as appropriate. 

Notwithstanding the foregoing, and pursuant to the provisions of Fed. R. Civ. P.

26(a)(1)(A)(ii), Defendants provide a description by category and location of the following

documents:

a. Defendant is actively looking for documents related to the Plaintiff’s 

claims against Defendants that is identified in the Complaint, Defendant’s defenses, 

including but not limited to claim information, correspondence, and payment records.

All documents in Defendant’s possession, custody, or control that may be used to support 

its defenses, if any, will be made available at Kiem Law, PLLC, 8461 Lake Worth Rd., Suite 

114, Lake Worth, FL 33467. 

Defendant reserves the right to use any document produced by other parties or obtained 

from third-parties through discovery. Defendant reserves the right to supplement this disclosure

as applicable documents are made known to counsel. Defendant further reserves the right to 

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object to the production of any documents described above on any basis permitted by the

Federal of Bankruptcy Procedure, Federal Rules of Civil Procedure and the Local Rules of this 

Court.

3. Rule 26(a)(1)(iii) Disclosures:

None at this time. Defendant reserves the right to supplement this disclosure as 

applicable documents are made known to counsel and discovery continues.

4. Rule 26(a)(1)(iv) Disclosures: 

Not applicable.

Defendant reserves the right to supplement these Disclosures pursuant to the Federal of 

Bankruptcy Procedure, Federal Rules of Civil Procedure and the Local Rules of this Court.

Defendant’s Initial Disclosures are made without waiving: (1) the right to object on the ground of 

competency, privilege, relevance, hearsay, or other proper grounds; (2) the right to object to the

use of any information disclosed herein, in whole or in part, for any purpose in this action or any

other action; and (3) the right to object on any and all proper grounds to any discovery request or

proceeding involving or relating to the subject matter of these Disclosures.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing document was 

furnished by Notice of Electronic Filing via CM/ECF to all parties registered to receive such notice 

in this case on this the 9th day of June 2021 on: 

21-01047-PDR Notice electronically mailed to:

Martin L Sandler, Esq on behalf of Plaintiff Nationwide Judgment Recovery, Inc.

martin@sandler-sandler.com

KIEM LAW, PLLC

Attorney for Defendant

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8461 Lake Worth Road, Suite 114 

Lake Worth, Florida 33467 

Telephone: 561-600-0406, Facsimile: 561-763-7355

Email: tarek@kiemlaw.com

 By: /s/ Tarek K. Kiem

Tarek K. Kiem

Florida Bar No 0637041

Dated: June 9, 2021.

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