Preview
Filing # 39790524 E-Filed 04/04/2016 10:39:53 AM
In the Circuit Court of the Seventeenth Judicial Circuit
In and for Broward County, Florida
Case No.: CACE-15-012730
Division: Civil
Stephens Pipe & Steel, LLC f/k/a
Stephens Pipe & Steel, Inc.,
Plaintiff,
vs.
Richard J. Young, and
Action Fence Enterprises, Inc.,
Defendants.
/
PLAINTIFF’S INTERROGATORIES TO
RICHARD J. YOUNG
Pursuant to Fla. R. Civ. P. 1.340, Plaintiff sends the attached interrogatories to
Defendant, Richard J. Young, to be answered in writing under oath within 30 days from
the mailing date below.
I certify that on APR 0 4 2016 a copy of this document was sent by
mail to: Action Fence Enterprises, Inc., c/o Richard J. Young, 3516 5lst Street East,
Bradenton, FL. 34208 and Richard J. Young, 4632 Orlando Circle, Bradenton, FL. 34207.
JERALY! (AN LEYDIG * Florida Bar Number 932248
LAWCR ™, AttQrneys for Plaintiff Matter Number 222011
PO BOX 19359; intation, FL 33318-0359
Phone: 954-587-1968 # Fax: (954) 587-2797
Primary Email: court@LAWCRAFTfirm.com
Secondary Email: jeralyn@lawcraftfirm.com
*** FILED: BROWARD COUNTY. FL HOWARD FORMAN, CLERK 4/4/2016 10:39:53 AM.****WHAT ARE INTERROGATORIES?
We are trying to collect the judgment that was entered against you. Court rules allow us to
ask you ask you questions about your financial situation and your assets. Write your answers in
the space below each question. Make sure you answer the whole question. Send us your answers
in the next 30 days. You cannot refuse to answer a question just because you don’t want us to
know the answer, like your spouse's job. If you have a valid legal objection, write in your
objection and answer whatever you don’t object to. When you are done answering the questions,
sign below, have them notarized, and send them to us at: LAWCRAFT™, Post Office Box 19359,
Plantation, FL 33318. For reference, our file number is
If you have any questions or want to make payments instead of answering the questions,
call us at (954) 587-1968.
The answers to these interrogatories are true and correct to the best of my knowledge and belief.
(signature)
PRINT NAME:
State of _—_—)ss
County of
Before me personally appeared , who after being sworn,
acknowledged that they signed the answers to these interrogatories and that they are true and
correct to the best of their knowledge and belief.
Sworn to and subscribed before me on
Name of Notary Public Signature of Notary Public
My commission expires: Affiant Known
Produced ID
TypeofID._1, State your complete legal name, any aliases or nicknames you used in the past 5 years, your
social security number, driver's license number, date and place of birth, and whether or not
you are a United States citizen.
2, State your home address, who lives there with you, your home telephone number, and your
current mailing address (if it is different than your home address),
3. State the complete address of all the places you lived in the past 5 years, the dates you lived
there, and everyone who lived there with you.
4, Have you ever been married? If so, for each marriage, state your spouse's full name and the
date and place you were married, whether the marriage was dissolved, when it was dissolved,
the case number and court, whether you pay or get any alimony, the amount of the alimony,
and when it is paid.
o
If you are currently married, state your spouse's employer's name and address and how much
your spouse makes.
Page 2 of 66. State the full names and birthdates of your children, each child’s other parent, whether or not
you have custody of the child, and whether you pay or get any child support.
7. For each person you provide support to, state their full name, birthdate, address, telephone
number, their relationship to you, the amount of support you provide them each month, and
the nature of the support, such as alimony, child support, etc.
8. For each job you had within the past 3 years, state the name, address, and phone number of
your employer, your job title and duties, the dates you worked unere, aud wilat you were paid
including salary, bonuses, and commissions.
9. Did you file tax returns in the past 3 years? If so, state the name and address of anyone who
has a copy of the return, whether you are entitled to a refund, the name and address of anyone
you filed with jointly, and the name and address of any dependents you listed on the return. If
not, state why you did not file.
Page 3 of 610. Did you have a bank account in the past 3 years? If so, state where you had the account, the
account number, the highest balance on the account in the past 6 months, the current balance
on the account, the name and address of anyone else named on the account, and if the account
is closed the date and reason it was closed.
11. Did you own any investments or securities in the past 3 years, including stocks, bonds, mutual
funds, certificates of deposit, or investment accounts? If so, state the name and address of the
bank or broker you used, who issued it, the number of the shares you own, the current value,
and if you sold it the date you sold, the price you sold it for, and who you sold it to.
12. Did you own any real estate in the past 3 years? If so, state the street address, the name and
address of anyone else that has an interest in it, the date and price you paid for it, and if you
sold it, the date you sold, the price you sold it for, and who you sold it to.
Page 4 of 613. Do you own or lease a car, motorcycle, boat, or other vehicle? If so, state the year, the make
and model, the serial or VIN number, the license and registration number, and the date and
price you paid for it. If there is a lien on it, state the amount of the lien and the name and
address of who holds the lien. If you leased it, state the name and address of the leasing
company.
14, Do you have a safe deposit box? If so, state where the box is, the box number, the name and
address of anyone who has the right to open the box, and a list of what is in the box.
15. Were you an owner or officer of any business in the past 3 years? If so, state the name, the
address and telephone number, what kind of business it is, and your role title.
16. Do you own any personal property you did not alrcady list? If so, state what it is, where you
got it, when you got it, how much it cost, and how much it is worth now.
17. Do you owe anyone uny money? If so, state who you owe, how much you owe, and why you
owe it.
Page 5 of 618, Does anyone owe you any money? (Such as a security deposit, unpaid wages, personal loans,
insurance benefits, trust payments, etc.) If so, state who owes you, how much they owe, and
why they owe it.
19. Did you have any other income in the last 3 years that you did not already list? If so, state how
much it was, where it came from, the date you got it, and why you got it.
Page 6 of 6
Preview
Filing # 39790524 E-Filed 04/04/2016 10:39:53 AM In the Circuit Court of the Seventeenth Judicial Circuit In and for Broward County, Florida Case No.: CACE-15-012730 Division: Civil Stephens Pipe & Steel, LLC f/k/a Stephens Pipe & Steel, Inc., Plaintiff, vs. Richard J. Young, and Action Fence Enterprises, Inc., Defendants. / PLAINTIFF’S INTERROGATORIES TO RICHARD J. YOUNG Pursuant to Fla. R. Civ. P. 1.340, Plaintiff sends the attached interrogatories to Defendant, Richard J. Young, to be answered in writing under oath within 30 days from the mailing date below. I certify that on APR 0 4 2016 a copy of this document was sent by mail to: Action Fence Enterprises, Inc., c/o Richard J. Young, 3516 5lst Street East, Bradenton, FL. 34208 and Richard J. Young, 4632 Orlando Circle, Bradenton, FL. 34207. JERALY! (AN LEYDIG * Florida Bar Number 932248 LAWCR ™, AttQrneys for Plaintiff Matter Number 222011 PO BOX 19359; intation, FL 33318-0359 Phone: 954-587-1968 # Fax: (954) 587-2797 Primary Email: court@LAWCRAFTfirm.com Secondary Email: jeralyn@lawcraftfirm.com *** FILED: BROWARD COUNTY. FL HOWARD FORMAN, CLERK 4/4/2016 10:39:53 AM.****WHAT ARE INTERROGATORIES? We are trying to collect the judgment that was entered against you. Court rules allow us to ask you ask you questions about your financial situation and your assets. Write your answers in the space below each question. Make sure you answer the whole question. Send us your answers in the next 30 days. You cannot refuse to answer a question just because you don’t want us to know the answer, like your spouse's job. If you have a valid legal objection, write in your objection and answer whatever you don’t object to. When you are done answering the questions, sign below, have them notarized, and send them to us at: LAWCRAFT™, Post Office Box 19359, Plantation, FL 33318. For reference, our file number is If you have any questions or want to make payments instead of answering the questions, call us at (954) 587-1968. The answers to these interrogatories are true and correct to the best of my knowledge and belief. (signature) PRINT NAME: State of _—_—)ss County of Before me personally appeared , who after being sworn, acknowledged that they signed the answers to these interrogatories and that they are true and correct to the best of their knowledge and belief. Sworn to and subscribed before me on Name of Notary Public Signature of Notary Public My commission expires: Affiant Known Produced ID TypeofID._1, State your complete legal name, any aliases or nicknames you used in the past 5 years, your social security number, driver's license number, date and place of birth, and whether or not you are a United States citizen. 2, State your home address, who lives there with you, your home telephone number, and your current mailing address (if it is different than your home address), 3. State the complete address of all the places you lived in the past 5 years, the dates you lived there, and everyone who lived there with you. 4, Have you ever been married? If so, for each marriage, state your spouse's full name and the date and place you were married, whether the marriage was dissolved, when it was dissolved, the case number and court, whether you pay or get any alimony, the amount of the alimony, and when it is paid. o If you are currently married, state your spouse's employer's name and address and how much your spouse makes. Page 2 of 66. State the full names and birthdates of your children, each child’s other parent, whether or not you have custody of the child, and whether you pay or get any child support. 7. For each person you provide support to, state their full name, birthdate, address, telephone number, their relationship to you, the amount of support you provide them each month, and the nature of the support, such as alimony, child support, etc. 8. For each job you had within the past 3 years, state the name, address, and phone number of your employer, your job title and duties, the dates you worked unere, aud wilat you were paid including salary, bonuses, and commissions. 9. Did you file tax returns in the past 3 years? If so, state the name and address of anyone who has a copy of the return, whether you are entitled to a refund, the name and address of anyone you filed with jointly, and the name and address of any dependents you listed on the return. If not, state why you did not file. Page 3 of 610. Did you have a bank account in the past 3 years? If so, state where you had the account, the account number, the highest balance on the account in the past 6 months, the current balance on the account, the name and address of anyone else named on the account, and if the account is closed the date and reason it was closed. 11. Did you own any investments or securities in the past 3 years, including stocks, bonds, mutual funds, certificates of deposit, or investment accounts? If so, state the name and address of the bank or broker you used, who issued it, the number of the shares you own, the current value, and if you sold it the date you sold, the price you sold it for, and who you sold it to. 12. Did you own any real estate in the past 3 years? If so, state the street address, the name and address of anyone else that has an interest in it, the date and price you paid for it, and if you sold it, the date you sold, the price you sold it for, and who you sold it to. Page 4 of 613. Do you own or lease a car, motorcycle, boat, or other vehicle? If so, state the year, the make and model, the serial or VIN number, the license and registration number, and the date and price you paid for it. If there is a lien on it, state the amount of the lien and the name and address of who holds the lien. If you leased it, state the name and address of the leasing company. 14, Do you have a safe deposit box? If so, state where the box is, the box number, the name and address of anyone who has the right to open the box, and a list of what is in the box. 15. Were you an owner or officer of any business in the past 3 years? If so, state the name, the address and telephone number, what kind of business it is, and your role title. 16. Do you own any personal property you did not alrcady list? If so, state what it is, where you got it, when you got it, how much it cost, and how much it is worth now. 17. Do you owe anyone uny money? If so, state who you owe, how much you owe, and why you owe it. Page 5 of 618, Does anyone owe you any money? (Such as a security deposit, unpaid wages, personal loans, insurance benefits, trust payments, etc.) If so, state who owes you, how much they owe, and why they owe it. 19. Did you have any other income in the last 3 years that you did not already list? If so, state how much it was, where it came from, the date you got it, and why you got it. Page 6 of 6