Filing # 161991383 E-Filed 11/29/2022 11:48:49 AM
`
`IN THE CIRCUIT COURT OF THE
`15th JUDICIAL CIRCUIT, IN AND FOR
`PALM BEACH COUNTY, FLORIDA
`
`CASE NO.: 502021DR009447XXXXSBFX
`
`IN RE:
`
`HARRISON ANDREW BARKER
`
`Petitioner,
`
`And
`
`SHLOMIT OSHRIT AZOULAY,
`
`COMES NOW Petitioner HARRISON ANDREW BARKER by and through undersigned
`
`counsel and serves this Response to Respondent’s Second Request for Production.
`
`Respondent._/HUSBAND’S RESPONSE TO WIFE’S SECOND REQUEST FOR PRODUCTION
`NOT A CERTIFIED COPY
`
`CERTIFICATE OF SERVICE
`I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via Electronic Service of
`the Florida Courts E-Filing Portal to: Phillip Schwartz, Esq., eservice@schwartz-white.com, on this 29th
`day of November, 2022.
`
`/S/ STACEY D. MULLINS,ESQ._
`
`GRAY|ROBINSON, P.A.
`
`STACEY MULLINS, ESQ
`FLA BAR NO. 937193
`Stacey.Mullins@gray-robinson.com
`Daihana.white@gray-robinson.com
`2255 Glades Road, Suite 301E
`Boca Raton, FL 33431
`561-368-3808
`Telephone:
`561-368-4008
`Facsimile:
`Attorneysfor Petitioner
`
`*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 11/29/2022 11:48:49 AM ***
`
`

`

`SCHEDULE “A”
`
`UNLESS SPECIFIED OTHERWISE, THIS REQUEST COVERS DOCUMENTS AND
`INFORMATION FROM YOUR RESPONSE TO 1ST REQUEST FOR PRODUCTION
`THROUGH THE DATE OF PRODUCTION.
`
`A. With regard to personal accounts, produce the following:
`
`1. Books or records or accounts maintained on your separate properties, assets, and liabilities.
`
` RESPONSE: None.
`
`2. All books, records, account statements (monthly, quarterly and/or year-end statements), and
`memoranda pertaining to all stock certificates, bonds, stock exchange or brokerage accounts or
`other securities in your name individually or in conjunction with any person or persons or which
`may be held to your account individually or in conjunction with any other person or persons in
`any corporation, domestic or foreign or issued by the Federal Government, or by the State,
`Municipal or other governmental agency.
`
`RESPONSE:
`
`NOT A CERTIFIED COPY
`
`Vanguard Roth IRA Account Ending No.
`statements for the period at March 2022
`REDA
`through October 2022 are attached hereto.
`
`statements for the period of March
`Vanguard Traditional IRA Account Ending No.
`REDA
`2022 through October 2022 are attached hereto.
`
`Vanguard Account Ending No.
`statements for the period of March 2022 through
`REDA
`October 2022 are attached hereto.
`
`TD Ameritrade Account Ending No.
`statements for the period of March 2022
`REDA
`through October 2022 are attached hereto.
`
`3. All deeds of conveyances of real and personal property on any properties you have owned
`either individually or jointly or of which you are or were the legal or beneficial owner. Also, real
`estate tax bills for said properties.
`
` RESPONSE:
`
`
`
`
`
`
`
` Warranty Deed dated March 4, 2022 related to Whitehall Condos is attached hereto.
`
` Warranty Deed dated March 11, 2003 related to Whitehall Condo is attached hereto.
`
` Real Estate Tax Bill for the 2021 year related to Whitehall Condo is attached hereto.
`
`4. All records, papers and memoranda concerning all checking accounts in your name individually
`or in conjunction with any other person or persons, including statements, check registers, canceled
`checks, wire transfer receipts, deposit slips, and withdrawal slips with their attached documents,
`whether said account is current or may have been closed.
`
`

`

` RESPONSE:
`
`Ally Bank Combined Statements for the period of March 2022 through November 2022 are
`attached hereto related to accounts ending in:
` and
`REDACTED
`
`REDA
`
`statements for the period of March 2022; June
`Bank of America Account Ending No
`REDA
`through October 2022. Statements for the period of April 2022 through May 2022 are
`nonexistent due to inactivity.
`
`statements for the period of March 2022 through
`Capital One Account Ending No.
`REDA
`April 2022; June 2022 through October 2022 are attached hereto. Statements for May 2022
`is nonexistent due to inactivity.
`
`PNC Account Ending No.
`2022 are attached hereto.
`
`statements for the period of March 2022 through October
`REDA
`
`5. All records, papers and memoranda concerning all digital currency accounts in your name
`individually or in conjunction with any other person or persons, whether said account is current
`or may have been closed.
`
`RESPONSE: Gain/Loss Report for the period of January 1, 2022 through November 22,
`2022 is attached hereto. Coinbase does not provide monthly and/or quarterly statements.
`
`6. All writings reflecting, directly or indirectly, your transfer of any funds to any bank, broker,
`individual, entity or financial institution outside of the United States and any records that reflect
`bank, brokerage, or other accounts in which you hold an interest outside the United States.
`
`NOT A CERTIFIED COPY
`
` RESPONSE: None.
`
`7. Any and all records, documents, papers and memoranda pertaining to monies and other
`compensation which have been received or being presently receivable by you from all sources
`including, but not limited to salaries, wages, drawings, dividends, bonuses, sick pay, pensions,
`retirement funds, reimbursement expenses, commissions, bonuses, and promissory notes.
`
` RESPONSE:
`
`Husband’s Paystubs for the period of March 2022 through November 2022 are attached
`hereto.
`
`8. All charge accounts including, but not limited to credit cards, club memberships, executive
`memberships you have access to or you have used or presently use including the relevant addresses
`of said accounts, all account statements regardless of whether the account is in your name or in
`your name jointly with any other person or whether it is a corporate account or other entity account
`on which you have charge privileges.
`
` RESPONSE:
`
`statements for the period of March 2022
` American Express Account Ending No.
`REDA
`through November 2022 are attached hereto.
`
`

`

`statements for the period of March 2022
`American Express Account Ending No.
`REDA
`through November 2022 are attached hereto.
`
` statements for the period of March 2022
`American Express Account Ending No.
`REDA
`through November 2022 are attached hereto.
`
`statements for the period of March 2022
`Bank of America Account Ending No.
`REDA
`through November 2022 are attached hereto.
`
`statements for the period of August 2022 through
`Chase Account ending No.
`REDA
`November 2022 are attached hereto. Account opened in August 2022.
`
` statements for the period of March 2022 through April
`Chase Account Ending No.
`REDA
`2022; June 2022 through August 2022; and October 2022 are attached hereto. No
`statements exists for May 2022 and September 2022 due to inactivity.
`
`statements for the period of January 2022 through
`Chase Account Ending No.
`REDA
`November 2022 are attached hereto.
`
`9. All Wills, Trusts, and other instruments evidencing disposition of property during your lifetime
`or upon your death.
`
` RESPONSE: None.
`
`NOT A CERTIFIED COPY
`
`10.
` All documents reflecting your personal monthly expenses for the past three years, whether it
`is paid or invoiced, whether it is your personal account or accounts of others, including corporate or
`otherwise, for your use and benefit or on which you are either reimbursed or you can obligate.
`
`RESPONSE: Husband refers to Response 8 and 4. Husband previously produced copies of
`bank statements and credit card statements were previously provided in Husband’s
`Supplemental Response to Wife’s Request for Production and Husband’s Certificate of
`Compliance with Mandatory Disclosure dated March 4, 2022. Husband’s previously
`produced copies of bank statements and credit card statements in Husband’s Supplemental
`Response to Wife’s Request for Production dated September 14, 2022.
`
`11.
` All written premarital or marital agreements entered into at any time between the parties to this
`marriage, whether before or during the marriage. Additionally, in any modification proceeding, each
`party shall serve on the opposing party all written agreements entered into between them at any time
`since the order to be modified was entered.
`
` RESPONSE: None.
`
`12.
` Copies of federal income tax return(s) and records of all earnings from beginning of current
`year up to and including the date of production.
`
`RESPONSE: Husband refers to Response 8 and 7. See Husband’s 2021 tax return form
`attached hereto.
`
`
`
`

`

`13.
`
` Copies of estimated federal tax payments for the current year.
`
` RESPONSE: None.
`
`14.
`
` Copies of gift tax returns.
`
` RESPONSE: None.
`
`15.
` All financial statements you have prepared or that someone has prepared on your behalf as
`part of any application for loan, divorce proceeding, preparation of a prenuptial or post-nuptial
`agreement, mortgage, credit application, credit card application, insurance application or business
`venture for financial disclosure.
`
` RESPONSE: None.
`
`16.
` Any records and contracts for the rental and/or lease of safe deposit boxes or vaults to
`which you have authorization to access.
`
` RESPONSE: None.
`
`NOT A CERTIFIED COPY
`
`17.
` Any and all statements, documents, letters, or other writings relating to any pension, profit-
`sharing, or retirement plan in which you have an interest, showing the extent of your or your
`spouse's interest as of the latest statement received and documents evidencing the reason for any
`disbursements.
`
` RESPONSE: Copy of Deloitte Pension Plan is attached hereto.
`
`18.
` All records of insurance policies existing over the past three years of which you have an
`interest as an owner, beneficiary or claimant such as: life, endowments, annuity, liability, accidents,
`hospital, disability, real and personal property and automobile including, but not limited to the
`schedules of benefit, statements, and any and all writings between you and the entity.
`
` RESPONSE:
`
`Copy of MassMutual Term Life Insurance Policy for the period of 2020 and 2021 were
`previously provided in Husband’s Certificate of Compliance with Mandatory Disclosure.
`
`Copy of MassMutual Term Whole Insurance Policy for the period of 2020 and 2021 were
`previously provided in Husband’s Certificate of Compliance with Mandatory Disclosure.
`
`Confirmation of Coverage Letter related to Husband’s renters insurance policy Policy
`No. Ending 2284 is attached hereto.
`
`Geico Car Insurance card related to Policy Ending No. 1026 is attached hereto.
`
`
`
`
`
`

`

`19.
` All records of health and dental insurance policies currently in existence including the
`premium breakdown for employee, employee plus one dependent and employee plus family.
`
`RESPONSE:
`
`Copy of 2023 Benefit Premiums related to Medical, Dental, Vision, and Long-Term
`Disability Plans.
`
`20.
` The original and/or copies of every Certificate of Deposit you have opened or caused to be
`opened, purchased, or caused to be purchased, executed, or caused to be executed in your name
`or the name of any other person.
`
` RESPONSE: None.
`
`21.
` The stocks, bonds, or debentures purchased by you or on your behalf and the monthly
`statements for any brokerage account in your name or held for your benefit.
`
` RESPONSE: Husband refers to Response 2.
`
`22.
` The original and/or true copies of every trust account opened or caused to be opened,
`created or caused to be created, deposited into or caused the depositing into of every trust account
`for your behalf or for the benefit of another at your direction including, but not limited to the trust
`agreements or instruments establishing said trust, bank statements, writings, deposit slips, wire
`transfer receipts, so as to account for all money deposited or withdrawn to or from said accounts
`in which you had an interest or at your direction.
`
` RESPONSE: None.
`
`NOT A CERTIFIED COPY
`
`23.
` All appraisals on all real and personal property you own or have an interest in, directly,
`indirectly, individually, or jointly with another person or entity or by way of a partnership, limited
`partnership, or corporation.
`
` RESPONSE: None.
`
`24.
` List, if presently in existence by either a writing or by electronic data, of all assets and
`liabilities of a personal nature that you may have either individually or in connection with other
`persons or entities.
`
` RESPONSE: None.
`
`25.
` All invoices that have been received for attorneys, accountants or other experts in this matter,
`redacting information which you claim may be privileged since inception in this lawsuit through the
`date of production. All retainer agreements in this matter since inception in this lawsuit through the
`date of production. All evidence of payments (cancelled checks, credit card receipts, etc.) made to
`attorneys, accountants, or other experts in this matter, including payments made by a third party on
`your behalf since inception in this lawsuit through the date of production.
`
`RESPONSE: Husband objects to this Request as not likely to lead to relevant admissible
`evidence.
`
`

`

`26.
` All titles, registrations, certificates and any writings regarding ownership or lease of any
`automobiles, boats, airplanes, or other vehicles in your control or possession.
`
` RESPONSE:
`
`
`
` Florida State Vehicle Information Check is attached hereto.
`
`27.
` All correspondence and documents sent to or received from any public relations entity or
`investment banker, or consultant or other individual hired by you or your corporation or
`partnership which you have a direct or indirect interest in.
`
` RESPONSE: None.
`
`28.
` Copies of all pages (including blank pages) of the party’s current passport and, if said
`passport was issued within the immediately preceding eighteen (18) months, copies of all pages
`of prior passport.
`
` RESPONSE: Copy of Husband’s Passport is attached hereto.
`
`29.
`
` Any power of attorney which has been given to you to act for any person.
`
` RESPONSE: None.
`
`NOT A CERTIFIED COPY
`
`30.
` Copies of all judgments that you presently hold against any other party, regardless of
`whether said judgments have been satisfied within the years.
`
` RESPONSE: None.
`
`31.
` All records of any legal or administrative proceedings brought by you or against you, or any
`entity in which you own an interest of more than 10 percent, or against any entity in which you own
`an interest of more than 10 percent including, but not limited to copies of all complaints, demands
`for arbitration, settlements, depositions, sworn statements and affidavits in those proceedings.
`
` RESPONSE: None.
`
`32.
` Any reports which you have knowledge of or have received from a detective, investigator
`or any other person based upon surveillance of the Husband or Wife in this action.
`
` RESPONSE: None.
`
`33.
` Any and all employment agreements or consulting agreements made by you in connection
`with your employment.
`
` RESPONSE: Husband previously provided copy of Deloitte employment contract in
`response to Wife’s Request for Production filed January 10, 2022. Otherwise, none.
`
`
`
`
`
`

`

`34.
` All medical reports, records, etc., which involve any claimed medical, mental, or emotional
`condition/disability which prevents you from working full-time, part-time or at all in any capacity.
`
`RESPONSE: Non-applicable as Husband has not placed his medical, mental, and/or
`emotional status at issue.
`
`35.
` All contracts, documents or other writings which relate to or show your interest in any
`other asset which is not specifically covered by the preceding requests for production.
`
` RESPONSE: None.
`
`36.
` Any and all documents which substantiate in any way any claims you may have concerning
`gifts made by third parties to you individually, or jointly with your Husband or Wife, either before
`or after the marriage.
`
` RESPONSE: None.
`
`37.
` Any and all documentation substantiating any claims for unequal equitable distribution, or
`non-marital property.
`
`RESPONSE: See Husband’s Quarterly September 2019 account statement related to
`Vanguard Account Ending No.
` Statement related to Vanguard Account Ending No.
`REDA
` for October 2019 is nonexistent. Husband is in the process of obtaining additional
`REDA
`certain documentation to substantiate his claims(s) of non-marital property and will
`supplement under separate cover.
`
`38.
` All writings relating to gifts or transfer of properties to any trust, family limited
`partnership, or any other person or entity.
`
` RESPONSE: None.
`
`39.
` All frequent flyer mileage accounts in which you have any interest, whether personally or
`through any corporation, partnership or otherwise, whether for hotels, airlines, cars, or
`memberships and the like.
`
`NOT A CERTIFIED COPY
`
`RESPONSE:
`
`Husband incorporates response to Request 8. Mileage points are reflected in Husband’s
`credit card statements. Otherwise, none.
`
`40.
` All electronic or other computerized data or information in which you place any financial
`information for yourself or your spouse or in which you or your spouse has an interest including
`disks used or made for backups and printed materials made from these electronic bits of
`information.
`
` RESPONSE: None.
`
`41.
`
` Any Buy/Sell Agreements in which you are a party.
`
` RESPONSE: None.
`
`

`

`42.
` All statements and transactional history detailed line-item records detailing your use,
`whether on behalf of yourself or another party, for accounts such as, but not limited to PayPal,
`Mint, Zelle, Venmo, CashApp or similar accounts used to transfer money and/or pay for
`goods/services, or to track assets/debts and/or budget. Including any monthly and if applicable,
`annual statements of activity for the accounts produced.
`
` RESPONSE:
`
` Venmo Transaction History from March 2022 through November 2022 is attached hereto.
`
` Zelle Transaction Activity from September 2022 through October 2022 is attached hereto.
`
`43.
` All statements and transactional history detailed line-item records detailing your use,
`whether on behalf of yourself or another party, for Amazon and Uber.
`
`RESPONSE: Husband objects to this Request as an improper fishing expedition,
`overbroad, vague, and not likely to lead to admissible evidence. Husband refers to
`Response 8 reflecting Amazon, Lyft, and Uber charges.
`
`44.
` Documents identifying all property interests or beneficial interest of your, your spouse or
`both parties in this suit which you have now or have had within the last three years in any or all
`of the type of entities listed below:
`
`(A)
`
`Partnerships of any nature or description including but not limited to Limited
`Partnerships and General Partnerships.
`
`NOT A CERTIFIED COPY
`
`Page 7 of 8
`
`(B)
`(C)
`(D)
`(E)
`
`Joint Ventures.
`Corporate interests of any kind or description.
`Proprietorship.
`Direct or indirect interest in real or personal, tangible, or intangible property of any
`kind.
`
`RESPONSE: Husband previously provided operating agreement related to AMH
`Realty, LLC. Otherwise, none.
`
`45. With regard to any interest you may have or have had within the last three (3) years in any or
`all of the business interests identified in item 44 provide the following records for each entity:
`
`(A) All corporate or business records such as records of accounts receivable, records of
`accounts payable, notes payable, stock transfer ledgers, journals, and all other ledgers including
`detailed electronic general ledgers (in native format) and subledgers if any.
`
`RESPONSE: None related to AMH Realty, LLC. Otherwise, none in Husband’s
`
`possession, custody, and control.
`
`(B) Articles of Incorporation, Articles of Organization, minute books containing by-laws,
`resolutions and all notices and minutes of corporate meetings; all annual reports or other documents
`filed with the Secretary of State of every state in which the corporation(s) engages in business;
`
`

`

`excepting any public traded companies (which companies should be listed as an exception to this
`request) all income, payroll or other tax returns filed by the corporation(s).
`
`RESPONSE: Husband previously provided operating agreement related to
`AMH Realty, LLC. Otherwise, none.
`
`(C) All fictitious name affidavits and registrations filed or caused to be filed by you or on
`your behalf for any business venture in which you own for yourself or any other person.
`
`
`
`
`
`RESPONSE: None.
`
`(D) All occupational licenses obtained by you or anyone on your behalf as a partner, joint
`venturer, officer in a corporation or person owing a proprietary interest in any business enterprise.
`
`
`
`
`
`RESPONSE: None in Husband’s possession, custody, and control.
`
`(E) All stock account records with any brokerage firm, evidence of bonds or certificates
`of deposit you may own or own with any other person for the past three years up to and including
`the date of production, including but not limited to all books, records, statements (monthly,
`quarterly and/or year-end statements), statements of transactions, confirmation and all other papers
`and memoranda.
`
`
`
`
`
`RESPONSE: None.
`
`(F) All deeds of conveyance, deeds, mortgages and any other evidence of title or
`ownership of property, both real and personal, in which there may be a legal or equitable interest
`for the past three years up to and including the date of production.
`
`NOT A CERTIFIED COPY
`
`
`
`
`
`RESPONSE: Husband refers to Response 3. Otherwise, none.
`
`(G) All bank statements, check book, check book stubs, deposit slips with the attached
`documents, withdrawal slips, wire transfer records and canceled checks.
`
`RESPONSE: None in Husband’s possession, custody, and control.
`
`(H) Copies of federal, state or any other income tax returns, and each County's tangible
`tax returns.
`
`RESPONSE: AMH Realty, LLC’s Schedule K-1 for the period of 2021 is
`nonexistent. Otherwise, none in Husband’s possession, custody, and control.
`
`(I) All financial statements you or any agent of said legal entity, or category has prepared
`or that someone has prepared on your behalf which shows your properties, assets, liabilities, and
`receivables.
`
`
`
`RESPONSE: None in Husband’s possession, custody, and control.
`
`
`
`
`
`END OF SCHEDULE
`
`