J.E. Robert Company et al. v. LLC (2010)

ORDER FOR DISCLOSURE OF ASSETS

The plaintiff's Motion for Disclosure of Assets having been presented to the Court, and probable cause sufficient for the issuance of a prejudgment remedy having been established against each and every one of the defendants Maureen Julian, Andrew J. Julian, Michael Murray, and Stephanie Lord Drake (collectively, the “Guarantor Defendants ”) in the amount of $7,308,400.00, it is hereby:

ORDERED that each and every one of the Guarantor Defendants shall, on or before December 10, 2010, provide to counsel for the plaintiff an affidavit disclosing any and all property, real and personal, in which any of the Guarantor Defendants have an interest or any debt owing to any of them sufficient to satisfy a prejudgment remedy against them in the amount of $7,308,400.00, and to disclose the existence, location and extent of the interests in such property or debts as follows:

1. All bank accounts, certificates of deposit and trust accounts of each and every one of the Guarantor Defendants, or all such accounts in which each and every one of the Guarantor Defendants has an interest, including addresses for applicable bank offices and account numbers;

2. All real property in which each and every one of the Guarantor Defendants has an interest, including the location of the property and nature of said interest;

3. All personal property (including but not limited to automobiles, boats, aircraft, art, jewelry, collectibles, and club memberships) in which each and every one of the Guarantor Defendants has an interest, including a description of the property, its location and the nature of the interest in the property;

4. All business and/or investment entities (including both holding and operating entities) of any kind or description in which each and every one of the Guarantor Defendants has an interest, including a description of such interest and the name and address of the officers, members, partners or shareholders in such entities;

5. All stocks, bonds or negotiable securities in which each and every one of the Guarantor Defendants has an interest, including a description of each stock, bond or negotiable security, its location and the nature of the interest in each stock, bond or negotiable security;

6. All mutual funds in which each arid every one of the Guarantor Defendants has an interest, including a description of the fund, its location and the nature of his interest in the fund;

7. All cash or cash equivalents in which each and every one of the Guarantor Defendants has an interest, including the amount and location of said cash or cash equivalents;

8. All promissory notes, accounts, debts or other amounts owed to any of the Guarantor Defendants, and a description of such notes, accounts or debts, including the name and address of the obligor under such notes, accounts or debt;

9. All royalties in which each and every one of the Guarantor Defendants has an interest, including a description of the amount of such royalty, and name and location of the individual or entity obligated to pay such royalties;

10. All life insurance policies and annuities in which each and every one of the Guarantor Defendants has an interest;  and

11. Any and all other property, real or personal, tangible or intangible, liquid or otherwise in which each and every one of the Guarantor Defendants has an interest of any kind whatsoever and wheresoever located.

IT IS FURTHER ORDERED that each and every one of the Guarantor Defendants provide with their affidavit such documents that are sufficient to identify, locate, and describe the extent of any and all property as described above, including, but not limited to, an accounting of the receipt and distribution of all proceeds from the sale of the real property located in New London, Connecticut, previously owned by 698 Bank Street, LLC, commonly known as the “Walgreen's Development.”

IT IS FURTHER ORDERED that each and every one of the Guarantor Defendants appear at Superior Court, judicial district of Hartford at Hartford, 95 Washington Street, on January 6, 2011 at 10:00 a.m., then and there to be examined under oath concerning the information disclosed in and with his or her affidavit.

It is so ordered.

BY THE COURT

Robert B. Shapiro

JUDGE OF THE SUPERIOR COURT

Shapiro, Robert B., J.