Deponent: Scot Gordon Young
On Behalf Of the Respondent

No. of Exhibits: 4
Date Sworn: IO November 2009
Date Filed: JO November 2009

IN THE HIGH COURT OF JUSTICE
CASE NO: FD07D02865
FAMILY DIVISION

MICHELLE DANIQUE YOUNG
Applicant/Petitioner
-and-

SCOT GORDON YOUNG
Respondent

AFFIDAVIT OF SCOT GORDON YOUNG
BUSINESS HISTORY 2001 - 2009

I, SCOT GORDON YOUNG of Flat 20, Barrie House, Lancaster Gate, London, W2 3QJ,
the above named Respondent, MAKE OATH and say as fo11ows:1.

I make this affidavit in accordance with numbered paragraph 9 of the Order made by
,'

Mrs. Justice Parker dated 28th September 2009 ("Parker J.'s Septeruber Order") to
provide a full history of my business activities for the period 200 I to 2009.
2.

As well as this affidavit, I have been ordered to provide Replies to the Petitioner's
Supplementary Questionnaire dated 25 July 2008 and a further (third) Questionnaire

/

dated 3 June 2009. This affidavit wilJ provide a context in which to place the detail
which I address in my Replies and which I further substantiate in 51 separate lever
arch files of supporting documentation.

 3. Where necessary, I shall refer 10 the Petitioner as "Michelle" Bundle references

relate \o the lever arch mes accompanying my Replies as reiteWs. Bundle/rub,

Background
General business 

4. Broadiy speaking, my business affairs dyer the last eight years can be piaeed into

three separuic and calcgoncsi>>

Property deniing prineipsiiy by way ofshon term rnvesimeni designed to
generate an early rctum on capital Invested I would use capital profits
generated nern propen) deals to pmide both working capital for my other

corporate business and \0 provide funds for everyday

expenses;

 

 

 

Lvm'z'u: wxmn'

Alhdi'. the farm ofuapllal {1 fits 'primar) source during Ihis . 

a: 1mm 3 number 01 gnlficam deals cerh pmduuing a su remm

The capmi I End hum these es. we: m-dir: . st

 

  

ln ll>> rumlmg or pulcllase of Ill: shares in -as working capital {or

 

or financing ofmum mudesl speculalwe 

  

 

Proper/y 1/ 200172002

17.

IS

On 22 March 2001, sold for GBP13.: and pulcllased chlwonh
Park Prune Green, Surrey and a parcel of adjacml land
("Wontworlh Park") for GBP16 paymg a funher for fixmres and
fittings. Coulls Co provlded a or and the propefly was
Subseqllenlly refinanced wilh Ban]: of Scotland who a mortgage gr

GBP12 million

[Fur 11m" durumemalion viz Gram mum) (re Woaripeny}
and Green mam) (r5 Park)]

On 24 Scplembcr 2001 I sold Park for million plus a furlhel

for fixtures and fittings.

[For (Mai! supporting dacumenmtl'un viz Green 0mm) 

 

 

Sam-m rgfinrome

Agu n, a, inth previous |wn year): 1 mminucd nplemsm my amuraic "My

and speuflam mm dealin . These again not only :nabled me

17 mm: working capital for mg current and fmurc moms but also allow-Nd me

Ii [1/1510 "mm-mm L'omL-accusmmed

F71 ,y Tmmurlmv

 

 

new] Buxinm AEHYIUEJ

Uncc the sale 0 hcen com}. eled my majl-r pm .l and focus
was a vellum. 'hxch rm: to be known as "Project Moscow This was a large

properly dual the lean cm which had the potential [u b: highly profitable

In 01 around l< - "as appmached by a friend,1\1rRl Fommhev, Wm

. Involved mm. Hus pmlcu came to

utpuragmy'll 45m

 

38. Wlulst Moscow was my main focus, during [his period I also Inukcd at ulhcr

potential business opponunmes By way of example only, I consumed and

ultimately refined a scnes ofpolentla] ideas Wm

     

[For detail A: Supporting (lucmnenmtiun re the various 'rra/eclx" viz Blue [7/38]

42V

44.

 

On 3 November 2005 purchased Suite at 25/27 Belgravc square for
bus million. Although acquiring the legal and beneficial interest in the property, I
did not make paymenl as 1 had agreed with the vendor, Ekaterina Berezovskaya, thatl
would make a deferred rrom monies was cxpecung to receive lrom Proleot
Moscow The agreement was that 1 would pay the {4,15 million on or before 3
August 2006 Followmg completion, the property was morlgagcd to 80$ for ms
million and funhcr loan 01' million was subsequently granted hy ROS tn
refurbish the property The properly was subsequently repossessed by Has amt was
sold on lo Augu5( 200610 Retreat leing Buckingham Suite Limited for GBP4 million,

[For #911117 4 Supporting viz Green C/ZuIflz) to and 2.202) to 

 

For the previous twelve momhs or :0 Michelle and I llad discussed moving (0 the US

Principally from my financial difficuliics, vur marriage was under pressure
and we both lhoilght that a euonge of envirorunent would he gnarl for us personally
and at same umc provldr' an opportunity lo get away from the centre of our

problems in London a'id perhaps enable as have a {765* slan, We had both Visited

Miami and were keen lo relocme (hares In December 2005 Mlehelle moved [a Mlaml
with llre children and sealed me girls inlo new seheels and en 15 December 2005 
arranged ler lhe purchase of3467 why, Grove, Miaml 
Miami properly") as our pnneipal home. Allhough was not 10 join Michelle and
\he unli] following March) from Dccembex 2005 onwalds (his was 

main home. The Mlami properly was purchased ln the name 01 Greenfield Honzon

 

("Greenfield"), 2: Company incarporaled en 1 December 2005 wl'lh rhe

sole nnrpese elsequirlng prnpeny was the benefierel ewner erGreenlleld anrl/

 

 

GD was he drreerer and shareholder. frhe purchase price was ussa 5 mrllien and

 

was paid for
provided a mortgage em 8 The Miami properly was seld on 23 March
2007 for millron ll was sold Volunlanly by chenficld following a lhreal or

eemems (a total of approxmlalely Mm) 1308

 

foreclosure proceedings by EDS

 

 

knew, at the time, that I did not have amottht a/mottey and would need

ta bum; in nther mm the project In retrospect [know how that h;
commuting in Mr Famiclmv at my [hand to fund the pro/act I took on
rams/hing more than i could imagine and IIHS has contributed substantially to
my demta'c ahdfihahctat dawn/21H over the last six month: Although I know
my mtamtom were gottd at the time, [simply should have been tea/mic with
mysEl/nnd M7 Fomichev and admit that this wax hot xometltihg I could do i
made mm mix/(Ike: FUJI, ta pro/cc] that I knew I had to
tame fiam tam/m: amt, regatta! over reasoned that if 1 was
I could always taka advancz'sfln the pro/ac] against a p] (mused pay-out
that] 1' had at /he end DIDaCL'mbct 2005 in another investment [hat I had tn a
called Dimte Teclmulugiex The pay out wat- based 1717 a
performance payrattl 0/1417 la millton The maney was never paid a:
the company failed to meet [13 targetx at the 1mm, 1 was
already heavily indebted and Simply was hut in [0 take on any more

debt. 

48

Spem a large pan ol' 2005 possible investors. from planning
issues with the Moscow men: was pressure to complele the
deal as soon as possiblz, Thu investor lnvolvcd nr lhe pl'ojccl was a
businessman called Mr Jcnalhan Brawn, whom I had met  

In Jnnuu m, 1 also buy A nmenl 9m, 5nd;

lulal 01' GBP15 mill' I

bu m: deal [all through

 

 

only days later, I subsequently attempted to purchase another the
building, Apartment llte purchase was GBP15 millton (t0 include 6 car
parkmg spaces) The deposit rcquncd was 50 ptm'tded (as
had already been paid as a depostl an Apartment 901). subsequentl)
discovered a sigmficant fault the am units at the propeny and the

transaclton am not proceed.

[For detail :Ilpparling doulmenmlimt viz Cree/t 0/17.] to 17.3]

March 2066 7/10 Fox Wt/ltam: Schedule 

56'

With the collapse of Project Moscuwl was under rncreasmg pressure from shon term
lenders and 1305 to pay back loans had takcn out to fund the venture To try
and ease the financtal pressure, I was desperate to arrange a new {actlity with 1308
and, at a meeting on ll March 2006 with Bus, I produced, wuh lhe help of Fox

Williams, a schedule mveslments There 15 now produced and shown to

me marked exhibit 4" a bundle coptes Ofthc folluwtng;

 

 

 

jl

I

{

I

This

/ 0' day of November 2009

Before me,

--=-

AMBROSE APPELBE
-- SOLICITORS

7 NEW SQUARE
. LINCOLN'S INN
LONDON WC2A 3RA
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