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 SET OF INTERROGATORIES

UNDER FED.R.BANKR.P. 7033 AND RULE 33 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. 7033 and 7026 and Rules 33 and 26(b) F.R.Civ.P., Plaintiff 

requests Defendant to answer under oath the Interrogatories which follow and serve a copy of 

such answers on Plaintiff’s Attorney within 30 days after service of these Interrogatories.

INSTRUCTIONS FOR INTERROGATORIES

You must answer each Interrogatory separately and fully in writing under oath, unless it 

is objected to, in which event the reasons for objection shall be stated in lieu of an answer. 

Space has been provided below each Interrogatory for your answer. If you require additional 

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

Interrogatory.

Fed.R.Bankr.P. 7033 and Fed.R.Civ.P. 33 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 Interrogatories upon you. The Answers must be signed by the 

Defendant and any objections must be signed by you or your attorney.

In answering each Interrogatory:

a. Identify the location, custodian and source of each document relied upon 

in answering each Interrogatory; or which forms a basis for the answer given; or which 

corroborates the answer given to each Interrogatory.

b. State whether the information furnished is within your personal 

knowledge and, if not, the name of each person to whom the information is a matter of personal 

knowledge.

c. Identify each person who assisted or participated in preparing and/or 

supplying any of the information given in answer to or relied upon in preparing the answer to 

each Interrogatory.

If you object to an Interrogatory, you must nevertheless answer any portion thereof that is 

not objectionable.

If an Interrogatory is objected to on the ground of privilege, identify the privilege 

asserted and the facts on which the assertion is based. If the Interrogatory objected to relates to 

documents, identify each document pursuant to the definition of “identify” contained in these 

Interrogatories.

If the Answer to an Interrogatory is “do not know,” “unknown,” “that information was 

unavailable” or the like, explain in detail the efforts made to obtain information to answer the 

Interrogatory.

A party is under a duty seasonably to amend a prior response to an Interrogatory if the 

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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 

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:

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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.

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.

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Interrogatories

1. State the exact number of ZeekRewards accounts to which you contributed funds 

and/or from which you received funds, and for each such account, identify the ZeekRewards 

username and the amount of money you contributed, whether for bid purchases, subscription 

payments, or other. 

RESPONSE: 

2. For each and every ZeekRewards account with which you were associated, state 

all amounts paid and/or funds transferred to you and/or to any other payee associated with your 

ZeekRewards account(s), whether as “profit share”, “non-subscription matrix payment”, 

“Diamond pool”, “subscription matrix payments”, “profit points” or other.

RESPONSE:

3. If you assert that you transferred more or less money to ZeekRewards than Plaintiff 

has alleged in Request for Admission No. 1, please provide the complete factual basis of your 

position, including, but not limited to, all dates and amounts of such transfers, and the accounts 

from which the transfers were made, and any other information that would support your position. 

RESPONSE:

 

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4. If you assert that you received more or less money from ZeekRewards than the 

Plaintiff has alleged in Requests for Admission No. 2, please provide the complete factual basis of 

your position, including, but not limited to, all dates and amounts of such transfers, and the 

account(s) in which the transfers were deposited, and any other information that would support 

your position.

RESPONSE:

5. For all funds paid to you and/or transfers you and/or any other payee associated 

with your ZeekRewards account(s), received through ZeekRewards, identify what bank account 

or accounts into which those funds were deposited, including the name of the financial 

institutions, the type of accounts, and the account numbers.

RESPONSE:

6. Describe, in detail, including applicable dates and amounts of each transfer, any 

and all transfers you and/or any other payee, received from ZeekRewards in any way between 

October 20, 2011 and the present.

RESPONSE:

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7. Please describe in detail (i) your educational background, including but not limited 

to any and all degrees and professional certifications (ii) your employment background including, 

for each place of employment, your job title and the responsibilities you had and (iii) any entities 

in which you currently have, or previously held, a financial interest in, the nature of your 

association (i.e. president, board member, etc.), and your responsibilities with such entity. 

RESPONSE: 

8. Please describe in detail your investment history, including, but not limited to, 

stocks, bonds, private investments, loans you made, and/or any other type of investment you have 

made in the past or presently hold, specifically excluding savings and checking accounts, and for 

each identify the applicable dates, and your expected or promised and actual rate(s) of returns 

received for each year such investment was held, and identify any documents relating to the same. 

RESPONSE:

9. Please describe in detail any other multi-level marketing programs or schemes you 

have been involved in either preceding or subsequent to your involvement in ZeekRewards.

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RESPONSE:

10. Please describe in detail when and how you came to learn about the ZeekRewards 

scheme and identify any persons who were present at the time, and the complete nature of such 

meetings, conversations, and/or correspondence. 

RESPONSE:

11. Please describe all steps you took to learn about the ZeekRewards scheme, 

ZeekRewards and Rex Venture’s Group’s financial condition, the use of funds invested in 

ZeekRewards before deciding to invest in ZeekRewards, including, but not limited to, 

identifying any persons that you spoke with and/or relied upon, correspondence and/or 

documentation that you sent and/or reviewed, and identify all information learned when you took 

such action(s). 

RESPONSE: 

12. Please describe in detail any and all reasons why you decided to invest in 

ZeekRewards, including, but not limited to, identifying any documents, references, and/or persons 

that you relied upon or consulted.

RESPONSE:

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13. Identify every loan, line of credit, or other indebtedness you have incurred or 

extended from the date you first received transfers from ZeekRewards through the present, 

excluding credit cards. For each such loan, line of credit, or other indebtedness, please state the 

complete terms of such indebtedness, including, but not limited to, the rate of interest, the amount 

of the indebtedness (including the limit if a line of credit), the holder of the indebtedness, whether 

such indebtedness was secured (including describing the securing collateral, if so).

RESPONSE: 

14. If you claim that ZeekRewards received reasonably equivalent value for some or 

all of the transfers made to you over the life of your investment, please identify such transfers, 

state your entire factual basis for your position, including any and all witnesses you intend to call, 

the anticipated testimony of such witnesses at trial, any other persons having knowledge of the 

facts forming the basis of your position, a description of a of any and all documents relating to 

such claim, and the location and custodian of such documents.

RESPONSE:

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15. If you did not admit one or more of the Requests for Admission in their entirety, 

please state in detail the complete factual basis for each denial or partial denial including 

identifying any persons who have knowledge concerning the same or witnesses you intend to call, 

such witnesses’ anticipated testimony at trial, identifying any documents relating to the same, and 

including an identification of each and every transfer as set forth on Appendix B that you assert 

that you did not receive.

RESPONSE:

16. Identify each person answering or furnishing information for answering these 

interrogatories. For each such person, list the interrogatory number(s) which each person answered 

or for which that person furnished information for answering.

RESPONSE:

17. Identify each person you intend to call as a fact witness at trial of this action and 

state the areas of their expected testimony.

RESPONSE:

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18. Please state in detail the complete factual and legal basis for each of your 

affirmative defenses, including identifying any and all witnesses you intend to call in support of 

your affirmative defenses, the anticipated testimony of such witness at trial, any other persons 

having knowledge of the facts forming the basis of your affirmative defense, a description of any 

and all documents related to your affirmative defense, and the location and custodian of such 

documents. 

RESPONSE:

19. Please identify all phone numbers from which you made phone calls to any 

person associated with ZeekRewards, and all e-mail addresses used by you to communicate with 

any person associated with ZeekRewards or other investors or persons regarding ZeekRewards.

RESPONSE:

20. Please describe in detail any referrals or recommendations you made of any person 

or entity to the ZeekRewards program, including, but not limited to, identifying the person or entity 

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referred or recommended, applicable dates, a complete description of all communications 

regarding the referral or recommendation and an identification of all Documents relating in any 

manner to the foregoing. 

RESPONSE:

21. For all funds paid to you and/or transfers you and/or any other payee, received

through ZeekRewards, state how those funds were spent or utilized.

RESPONSE:

22. Were all funds paid to you and/or transfers you received through ZeekRewards 

listed as income or other earnings on your Federal and/or State tax returns for the years in which 

the funds were received? 

RESPONSE:

23. State the full names, last known addresses, and ZeekRewards username of the 

person or persons who “sponsored” and/or “recruited” you in the ZeekRewards program.

RESPONSE:

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24. State the full names, last known addresses, and ZeekRewards username of all 

persons in your ZeekRewards “upline” and “downline,” including any persons you “sponsored” 

in ZeekRewards.

RESPONSE:

25. Describe the specific language and techniques you used to recruit “downline”

investors in ZeekRewards and whether, at the time of recruitment, you advised your recruits that 

you would profit from their participation.

RESPONSE:

Attorneys for Plaintiff

SANDLER & SANDLER

By M. L. Sandler, P.A.

3390 Mary Street

Suite 116

Miami, FL 33133

Tel: 305-379-6655

___/s/ Martin L. Sandler_______

Martin L. Sandler, Esquire

Florida Bar No. 0070370 

Dated: 

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