UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

www.flsb.uscourts.gov

In re: Case No. 18-16248-BKC-MAM 

 Chapter 7 

CHANCE & ANTHEM, LLC, 

 

 Debtor. 

 / 

ROBERT C. FURR not individually but ADV. NO. 19-01298-MAM 

as Chapter 7 Trustee of the estate of the 

Debtor, Chance & Anthem, LLC, 

 Plaintiff, 

v. 

JEFFREY M. SISKIND, individually and 

d/b/a SISKIND LEGAL SERVICES, 

et al.

 Defendants. 

 / 

TRUSTEE’S INITIAL DISCLOSURES 

Robert C. Furr (the “Trustee” or “Plaintiff”), not individually but as Chapter 7 Trustee of 

the Bankruptcy Estate of the Debtor, Chance & Anthem, LLC (the “Debtor”) by and through 

counsel, hereby files and submits his initial disclosure of the following witnesses and documents: 

I. WITNESSES 

The Trustee states that the following individuals are likely to have discoverable information that 

the Trustee may use to support his claims and defenses:

Name Subject Matter of 

Knowledge 

Contact Information 

(if known) 

Robert C. Furr, Esq. The business affairs of 

the Debtor. 

c/o Jesus M. Suarez, Esq. 

100 SE Second Street, 44th FL 

Miami, FL 33133 

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Name Subject Matter of 

Knowledge 

Contact Information 

(if known) 

Alan Barbee, CPA Chapter 7 Trustee’s 

Forensic Professional 

c/o Jesus M. Suarez, Esq. 

100 SE Second Street, 44th FL 

Miami, FL 33133 

Florida Aero Paint, Inc., as 

Authorized Member and Registered 

Agent of Defendant 

The business affairs of 

the Debtor. 

2633 West Lantana Road 

Lantana, Florida 33462 

Advanced Aircraft Maintenance, 

Inc, as Authorized Member of 

Defendant 

The business affairs of 

the Debtor.

621 Airport Road 

Belle Vernon, Florida 15012 

Jeffrey M. Siskind The business affairs of 

the Debtor. 

3465 Santa Barbara Drive 

Wellington, Florida 33414 

Erik Planet, individually and 

as president of Erik’s EZ Tax 

Service, Inc. 

The business affairs of 

the Debtor. 

2611 SW Cameo Boulevard 

Port St. Lucie, Florida 34953 

Corporate Representative of 

CannaMed Pharmaceuticals, LLC 

Transactions related to 

Debtor. 

c/o Phillip B. Harris, Esq. 

685 Royal Palm Beach Blvd 

Suite 205 

Royal Palm Beach, FL 33411 

Corporate Representative of 

OB Real Estate 1732, LLC 

Transactions related to 

Debtor. 

c/o Phillip B. Harris, Esq. 

685 Royal Palm Beach Blvd 

Suite 205 

Royal Palm Beach, FL 33411 

Corporate Representative of Siskind 

Legal Services, LLC 

Transactions related to 

Debtor. 

c/o Phillip B. Harris, Esq. 

685 Royal Palm Beach Blvd 

Suite 205 

Royal Palm Beach, FL 33411 

Corporate Representative of 

Sovereign Gaming & Entertainment, 

LLC 

Transactions related to 

Debtor. 

c/o Phillip B. Harris, Esq. 

685 Royal Palm Beach Blvd 

Suite 205 

Royal Palm Beach, FL 33411 

Corporate Representative of 

Florida’s Association of Community 

Banks and Credit Unions, Inc. 

Transactions related to 

Debtor. 

c/o Phillip B. Harris, Esq. 

685 Royal Palm Beach Blvd 

Suite 205 

Royal Palm Beach, FL 33411 

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Name Subject Matter of 

Knowledge 

Contact Information 

(if known) 

Corporate Representative of 

Sympatico Equine Rescue, Inc. 

Transactions related to 

Debtor. 

c/o Phillip B. Harris, Esq. 

685 Royal Palm Beach Blvd 

Suite 205 

Royal Palm Beach, FL 33411 

Tanya Siskind 

Transactions related to 

Debtor. 

3465 Santa Barbara Drive 

Wellington, Florida 33414 

Second Siskind Family Trust 

Transactions related to 

Debtor. 

c/o Jeffrey M. Siskind, Trustee 

3465 Santa Barbara Drive 

Wellington, Florida 33414 

Frank Zokaites 

Transactions related to 

Debtor. 

375 Golfside Drive 

Wexford, PA 15090 

Corporate Representative of 

Wellington 3445, LP 

Transactions related to 

Debtor. 

c/o Samantha Haimo, Esq. 

Julie Feigeles Esq. 

7900 Peters Road, Suite B-200

Fort Lauderdale, FL 33324 

Corporate Representative of 

Zokaites Properties, LP 

Transactions related to 

Debtor. 

c/o Samantha Haimo, Esq. 

Julie Feigeles Esq. 

7900 Peters Road, Suite B-200

Fort Lauderdale, FL 33324 

Robert Gibson Transactions related to 

Debtor. 

1709 22nd Avenue North 

Lake Worth, Florida 33460 

Records Custodian and/or 

agents, representatives and 

control persons of JP Morgan 

Chase, N.A. 

Debtor’s Banking 

Records 

Records Custodian and/or 

agents, representatives and 

control persons of PNC Bank, 

N.A. 

Debtor’s Banking 

Records 

Records Custodian and/or 

agents, representatives and 

control persons of Bank of 

America 

Debtor’s Banking 

Records 

Records Custodian and/or 

agents, representatives and 

control persons of Suntrust 

Bank. 

Debtor’s Banking 

Records 

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Name Subject Matter of 

Knowledge 

Contact Information 

(if known) 

Records Custodian and/or 

agents, representatives and 

control persons of Wells Fargo 

Bank 

Debtor’s Banking 

Records 

All other witnesses learned 

through discovery 

 (Names and addresses to be 

determined) 

All witnesses to be used for 

rebuttal and impeachment 

purposes. 

 (Names and addresses to be 

determined) 

All witnesses and experts listed 

on the Defendant’s Initial 

Disclosures to the extent not 

objected to by the Plaintiff. 

 (Names and addresses to be 

determined) 

All persons identified in the 

Debtor’s books and records 

The allegations of the 

Complaint. 

All persons having filed claims 

against the Debtor’s bankruptcy 

estate, referenced in the Claim 

The allegations of the 

Complaint. 

27120 Ocean Gateway, LLC Claim filed by Creditor 

or scheduled by Debtor. 

7745 Dawson Court Lake 

Worth, FL 33467 

3485 Lago De Talavera Trust Claim filed by Creditor 

or scheduled by Debtor. 

c/o Sofiye Williams, PA 

500 E. Broward Blvd, #1710 

Fort Lauderdale, FL 33394 

3GEN VC, LLC Claim filed by Creditor 

or scheduled by Debtor. 

c/o Gerald Cantor 4000 

Hollywood Boulevard #500-N 

Hollywood, FL 33021 

ABK South Properties, LLC Claim filed by Creditor 

or scheduled by Debtor. 

c/o George Booras, Esq. 

1371 Hill Avenue 

Melbourne, FL 32940 

All Pro Pool Service Claim filed by Creditor 

or scheduled by Debtor. 

13557 Barberry Drive 

Wellington, FL 33414 

Apostle Construction Claim filed by Creditor 

or scheduled by Debtor. 

716 Naylor Mill Road 

Salisbury, MD 21801 

Bay Area Disposal Claim filed by Creditor 

or scheduled by Debtor. 

P.O. Box 189 

Owings, MD 20736 

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Name Subject Matter of 

Knowledge 

Contact Information 

(if known) 

Beaver Tree Service Claim filed by Creditor 

or scheduled by Debtor. 

P.O. Box 2476 

Salisbury, MD 21802 

Christopher George and 

Dianna George 

Claim filed by Creditor 

or scheduled by Debtor. 

c/o Dianna George 

6126 Park Lane W. 

Lake Worth, FL 33449 

Comptroller of the Treasury Claim filed by Creditor 

or scheduled by Debtor. 

Compliance Division, Room 

409 301 W. Preston Street 

Baltimore, MD 21201 

David Fiore and Carl Stone Claim filed by Creditor 

or scheduled by Debtor. 

c/o Carl Stone 

1714 Hunters Path Lane 

Pittsburgh, PA 15241 

David Fiore, et al. Claim filed by Creditor 

or scheduled by Debtor. 

c/o Sofiye Williams, Esq. 

500 E. Broward Blvd. #1710 

Fort Lauderdale, FL 33394 

Delmarva Power Claim filed by Creditor 

or scheduled by Debtor. 

5 Collins Drive #2133 

Mail Stop 84CP42 

Carneys Point, NJ 08069 

Delmarva Power & Light Co. Claim filed by Creditor 

or scheduled by Debtor. 

500 N Wakefield Dr, Fl 2 

Newark, DE, 19702 

Edgar A. Baker, Jr., Esq. 

Wicomico County Dept of Law 

Claim filed by Creditor 

or scheduled by Debtor. 

125 North Division Street, 

Room 101 

Salisbury, MD 2180 

Frederick R. Volkwein Claim filed by Creditor 

or scheduled by Debtor. 

2727 Rosemary Avenue, #3 

West Palm Beach, FL 33407 

Haynes Scaffolding & Supply, 

Inc. 

Claim filed by Creditor 

or scheduled by Debtor. 

1210 Ortega Road 

West Palm Beach, FL 33405 

PTM Electric, Inc. Claim filed by Creditor 

or scheduled by Debtor. 

16971 W. Hialeah Drive 

Loxahatchee, FL 33470 

Richard Barclay Neff, Jr. Claim filed by Creditor 

or scheduled by Debtor. 

2760 Meadowlark Lane West 

Palm Beach, Florida 33409 

Richard Bell Claim filed by Creditor 

or scheduled by Debtor. 

16192 Coastal Highway 

Lewes, DE 19958 

Richard Neff Claim filed by Creditor 

or scheduled by Debtor. 

2760 Meadowlark Lane 

West Palm Beach, FL 33409 

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Name Subject Matter of 

Knowledge 

Contact Information 

(if known) 

Richard P. Zaretsky, Esq. Claim filed by Creditor 

or scheduled by Debtor. 

1615 Forum Place, Suite 3A 

West Palm Beach, FL 33401 

Sarenil Associates, LLC c/o 

Frederick Volkwein 

Claim filed by Creditor 

or scheduled by Debtor. 

1615 Forum Place Suite 3A 

West Palm Beach, FL 33401 

State of Maryland DLLR 

Division of Unemployment 

Insurance 

Claim filed by Creditor 

or scheduled by Debtor. 

1100 N. Eutaw Street, 

Room 401 

Baltimore, MD 21201 

Steven S. Newburgh, Esq. 

McLaughlin & Stern PLLC 

Claim filed by Creditor 

or scheduled by Debtor. 

CityPlace Tower - Suite 1700 

525 Okeechobee Blvd 

West Palm Beach, FL 33401 

T.E. Smith & Son, Inc. Claim filed by Creditor 

or scheduled by Debtor. 

2043 Northwood Drive 

Salisbury, MD 21801 

The Trustee states that discovery is ongoing and reserves the right to amend this list at 

any time upon discovery of additional witnesses or a determination that such above-listed 

witnesses are not necessary. 

II. DOCUMENTS 

The Trustee has already produced documents that support his claims to Defendants. 

Moreover, additional documents that may be used to support the Plaintiff’s claims are already in 

the Defendant’s possession, custody, or control. In addition, the Trustee may use the following 

documents to support his claims: 

1. All documents filed in the Main Bankruptcy Case, In Re: Chance & Anthem, 

LLC, 18-16248-BKC-MAM 

2. All hearing and Rule 2004 examination transcripts, including exhibits, In Re: 

Chance & Anthem, LLC, 18-16248-BKC-MAM 

3. All documents referenced in the Adversary Complaint. 

4. All deposition transcripts and exhibits to depositions in this adversary proceeding. 

Case 19-01298-MAM Doc 274 Filed 04/10/20 Page 6 of 11
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5. All documents produced by Defendants to the extent not objected to by the 

Plaintiff. 

6. All documents produced by Plaintiff to the Defendants. 

7. All documents to be used for rebuttal and impeachment purposes.

8. All documents evidencing the transfer of money or anything of value by the 

Debtor to the Defendants. 

9. All financial statements, bank statements, credit card statements, invoices, checks, 

deposits, wire statements and other documents which pertain to the allegations contained in the 

Adversary Complaint. 

10. All financial statements, bank statements, credit card statements, invoices, checks, 

deposits, wire statements and other documents which pertain to the allegations contained in the 

Adversary Complaint. 

11. All witness statements and/or sworn statements by any party or non-party which 

pertain to the allegations contained in the Complaint. 

12. The Debtor’s books and records. 

13. The books and records of the Related Defendants (as set forth in the amended 

complaint). 

14. The exhibits provided to Defendants in connection with the preliminary injunction 

hearing. 

15. The bank account records of the related defendants. 

16. All documents filed in the Main Bankruptcy Case, In re Siskind, Case No. 13-

13096-MAM. 

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17. All hearing and Rule 2004 examination transcripts, including exhibits, In re 

Siskind, Case No. 13-13096-MAM. 

18. All claims, documents and transcripts in the matter of Fiore v. Siskind, et al., Case 

No. 50-2016-CA-008765-XXXX-MB (15th Judicial Circuit of Florida). 

19. All documents filed in Fiore v. Siskind, et al., Case No. 50-2016-CA-008765-

XXXX-MB (15th Judicial Circuit of Florida). 

20. All hearing and deposition transcripts, including exhibits, Fiore v. Siskind, et al.,

Case No. 50-2016-CA-008765-XXXX-MB (15th Judicial Circuit of Florida). 

The Trustee states that discovery is ongoing and reserves the right to amend or 

supplement this list of documents at any time prior to trial upon the discovery of additional 

relevant documents. 

III. DAMAGES 

Trustee requests that the Court enter a judgment against Defendants that: (i) avoids the 

transfers at issue in the Adversary Complaint and recover same for the benefit of the estate; (ii) 

awards to the Trustee the amount or value of the transfers at issue in the Adversary Complaint, 

plus interest and costs; (iii) disallows any claim that Defendants may have against the Debtor 

until such time the as the transfers at issue in the Adversary Complaint are re-paid to the Trustee 

pursuant to 11 U.S.C. § 502(d); and (iv) awards any other relief the Court deems appropriate. 

IV. EXISTENCE OF INSURANCE AGREEMENTS WHICH MAY PROVIDE 

COVERAGE FOR ALL OR PART OF ANY JUDGMENT 

The Trustee is not aware of the existence of any insurance agreement which may provide 

coverage for all or part of any judgment that may be awarded in favor of the Trustee. 

Dated: April 10, 2020 

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GENOVESE JOBLOVE & BATTISTA, P.A. 

Attorneys for Chapter 7 Trustee 

 100 S.E. Second Street, 44th Floor 

Miami, Floirda 33131 

 Telephone: (305) 349-2300 

 Telecopier: (305) 349-2310 

 By: /s/ Jesus M. Suarez 

 Jesus M. Suarez, Esq. 

 Florida Bar No. 60086 

 jsuarez@gjb-law.com 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served via 

CM/ECF Notification to all parties on the attached service list on this 10th day of April, 2020. 

 By: /s/ Jesus M. Suarez 

 Jesus M. Suarez, Esq. 

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SERVICE LIST 

Served via Electronic Mail upon: 

Julie Feigeles on behalf of Defendant OB Real Estate Holdings 1732, LLC 

jf@womenatlawfl.com, way@womenatlawfl.com 

Julie Feigeles on behalf of Defendant Wellington 3445, LP 

jf@womenatlawfl.com, way@womenatlawfl.com 

Julie Feigeles on behalf of Defendant Zokaites Properties, LP 

jf@womenatlawfl.com, way@womenatlawfl.com 

Barry P Gruher on behalf of Plaintiff Robert C Furr 

bgruher@gjb-law.com, vlambdin@gjb-law.com;gjbecf@gjb-law.com;cesser@gjblaw.com;gjbecf@ecf.courtdrive.com;chopkins@gjb-law.com 

Samantha T Haimo on behalf of Defendant OB Real Estate Holdings 1732, LLC 

sth@womenatlawfl.com, way@swlawyers.law 

Samantha T Haimo on behalf of Defendant Wellington 3445, LP 

sth@womenatlawfl.com, way@swlawyers.law 

Samantha T Haimo on behalf of Defendant Zokaites Properties, LP 

sth@womenatlawfl.com, way@swlawyers.law 

Philip B Harris on behalf of Defendant CannaMed Pharmaceuticals, LLC 

philip@philipbharris.com 

Philip B Harris on behalf of Defendant Florida's Association of Community Banks and Credit 

Unions, Incorporated 

philip@philipbharris.com 

Philip B Harris on behalf of Defendant OB Real Estate Holdings 1732, LLC 

philip@philipbharris.com 

Philip B Harris on behalf of Defendant Second Siskind Family Trust 

philip@philipbharris.com 

Philip B Harris on behalf of Defendant Siskind Legal Services 

philip@philipbharris.com 

Philip B Harris on behalf of Defendant Sovereign Gaming and Entertainment, LLC 

philip@philipbharris.com 

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Philip B Harris on behalf of Defendant Sympatico Equine Rescue, Inc. 

philip@philipbharris.com 

Philip B Harris on behalf of Defendant Tanya Siskind 

philip@philipbharris.com 

Jeffrey M Siskind on behalf of Defendant Jeffrey M Siskind 

jeffsiskind@msn.com, jmsesq500@gmail.com 

Jesus M Suarez on behalf of Plaintiff Robert C Furr 

jsuarez@gjb-law.com, gjbecf@gjb-law.com;chopkins@gjb-law.com;jzamora@gjblaw.com;ecastellanos@gjb-law.com;gjbecf@ecf.courtdrive.com

Case 19-01298-MAM Doc 274 Filed 04/10/20 Page 11 of 11