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. 

 / 

SECOND UNOPPOSED EX PARTE MOTION BY PLAINTIFF, ROBERT C. FURR, 

TO CONTINUE PRETRIAL CONFERENCE AND EXTEND 

RELATED PRETRIAL DEADLINES 

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, file this Second Unopposed Ex Parte Motion to Continue Pretrial Conference and 

Extend Related Pretrial Deadlines (the “Motion”) and in support thereof state, as follows: 

I. BACKGROUND. 

1. On January 29, 2019 (the “Petition Date”) the Debtor, Chance and Anthem, LLC 

(“Debtor”) filed a voluntary petition for relief under Chapter 7 of the Bankruptcy Code (the 

“Petition”) in the United States Bankruptcy Court for the District of Maryland (the “Maryland 

Bankruptcy Court”), in the matter styled In re Chance & Anthem, LLC, Case No. 18-11168-TJC 

(the “Bankruptcy Case”). The Plaintiff is the duly appointed and acting Trustee of the Debtor’s 

Case 19-01298-MAM Doc 193 Filed 12/13/19 Page 1 of 9
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bankruptcy estate (the “Estate”). 

2. On May 24, 2018, the Bankruptcy Court for the District of Maryland entered its 

Memorandum and Order Transferring Venue To The Bankruptcy Court For the Southern District 

of Florida (the “Transfer Order”)[ECF No. 73], transferring the Bankruptcy Case to this Court. 

3. On May 25, 2018, the Plaintiff, Robert C. Furr, was duly appointed and is acting 

Chapter 7 Trustee of the Debtor’s bankruptcy estate (the “Estate”)[ECF No. 76]. 

4. On August 06, 2019, the Plaintiff filed the Adversary Complaint to Avoid and 

Recover Fraudulent Transfers, For Turnover, For an Accounting, Alter-Ego, Substantive 

Consolidation, Injunctive Relief and for Related Relief (the “Adversary Complaint”) [ECF No. 

1] in the above adversary proceeding (the “Adversary Proceeding”). 

5. On August 07, 2019, the Court issued the Summons and Notice of Pretrial/Trial in 

an Adversary Proceeding, scheduling the Pretrial Conference for November 14, 2019 at 10:00 

a.m. [ECF No. 03]. 

6. On same date, the Court entered an Order Setting Filing and Disclosure 

Requirements for Pretrial and Trial Setting Pretrial Conference (the “Pretrial Order”) [ECF No. 

04] which references all corresponding pretrial deadlines. 

7. On October 4, 2019, the Trustee filed the Agreed Ex Parte Motion to Continue 

Pretrial Conference and Extend Related Pretrial Deadlines [ECF No. 58]. On October 4, 2019, 

the Court entered the Order Granting Agreed Ex Parte Motion to Continue Pretrial Conference 

and Extend Related Pretrial Deadlines [ECF No. 59]. Pursuant to the Order Continuing Pretrial 

Conference, the Pretrial Conference is scheduled for January 14, 2020 at 10:00 a.m. and all 

corresponding deadlines were continued accordingly. 

8. On November 1, 2019, the Trustee filed the Amended Adversary Complaint [ECF 

No. 95]. 

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II. RELIEF REQUESTED. 

9. As the parties are in the process of discovery and preparing this case for trial, to 

the extent necessary, The Trustee respectfully requests the continuance of the Pretrial 

Conference to May 12, 2020 at 10:00 a.m. 

10. Further, the Trustee seeks a concomitant enlargement of the deadlines set forth in 

the Pretrial Order to coincide with the continued Pretrial Conference. 

11. Counsel for the Plaintiff has conferred with parties currently represented in this 

adversary proceeding, regarding the filing of this Motion and stated that the Defendants have not 

objected to the requested relief. 

12. The filing of this Motion and continuance of the Pretrial Conference and 

extensions of the deadlines under the Pretrial Order are necessary in order to preserve time and 

resources of the Parties. This Motion has been filed in good faith and not for any dilatory 

purpose or improper delays of this adversary proceeding. 

WHEREFORE, the Plaintiff, Robert C. Furr, as the Chapter 7 Trustee, respectfully 

requests the entry of an order attached hereto as Exhibit “A”: (i) granting this Motion; (ii) 

continuing the Pretrial Conference May 12, 2020 at 10:00 a.m.; (iii) extending all corresponding 

pretrial deadlines accordingly; and (iv) granting such other and further relief as the Court deems 

appropriate. 

Dated this 13th day of December, 2019. 

GENOVESE JOBLOVE & BATTISTA, P.A. 

Counsel for Plaintiff 

100 S.E. Second Street, 44th Floor 

Miami, FL 33131 

Tel: (305) 349-2300 

Fax: (305) 349-2310 

By: /s/ Jesus M. Suarez 

 Jesus M. Suarez, Esq. 

Case 19-01298-MAM Doc 193 Filed 12/13/19 Page 3 of 9
 4 

 Fla. Bar No. 60086 

 Email: jsuarez@gjb-law.com 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished 

via CM/ECF notification upon all interested parties registered to receive electronic notification 

on this matter and/or via U.S. Mail as indicated on the Service List below on this 13th day of 

December, 2019. 

By: /s/ Jesus M. Suarez 

 Jesus M. Suarez, Esq. 

 

Case 19-01298-MAM Doc 193 Filed 12/13/19 Page 4 of 9
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SERVICE LIST 

Notice was served via CM/ECF 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 

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 

19-01298-MAM Notice will not be electronically mailed to: 

CannaMed Pharmaceuticals, LLC 

c/o Siskind Legal 

3465 Santa Barbara Dr 

Wellington, FL 33414 

Case 19-01298-MAM Doc 193 Filed 12/13/19 Page 5 of 9
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Florida's Association of Community Banks and Credit Unions, Incorporated 

c/o Jeffrey M Siskind, President 

3465 Santa Barbara Dr 

Wellington, FL 33414 

Robert Gibson 

1709 22 Ave N 

Lake Worth, FL 33460 

Second Siskind Family Trust 

c/o Tanya Siskind, Trustee 

3465 Santa Barbara Dr 

Wellington, FL 33414 

Tanya Siskind 

3465 Santa Barbara Dr 

Wellington, FL 33414 

Siskind Legal Services 

c/o Jeffrey M Siskind, Managing Member 

3465 Santa Barbara Dr 

Wellington, FL 33414 

Sovereign Gaming and Entertainment, LLC 

c/o Jeffrey M Siskind 

3465 Santa Barbara Dr 

Wellington, FL 33414 

Sympatico Equine Rescue, Inc. 

c/o Jeffrey M Siskind, President 

3465 Santa Barbara Dr 

Wellington, FL 33414 

Frank R. Zokaites 

375 Golfside Dr 

Wexford, PA 15090 

 

Case 19-01298-MAM Doc 193 Filed 12/13/19 Page 6 of 9
EXHIBIT “A” 

 

Case 19-01298-MAM Doc 193 Filed 12/13/19 Page 7 of 9
 2 

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. 

 / 

ORDER GRANTING SECOND UNOPPOSED EX PARTE MOTION BY PLAINTIFF, 

ROBERT C. FURR, TO CONTINUE PRETRIAL CONFERENCE AND EXTEND 

RELATED PRETRIAL DEADLINES 

Case 19-01298-MAM Doc 193 Filed 12/13/19 Page 8 of 9
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THIS MATTER came before the Court without a hearing upon the Second Unopposed 

Ex Parte Motion by Plaintiff, Robert C. Furr, to Continue Pretrial Conference and Extend 

Related Pretrial Deadlines [ECF No. ____] (the “Motion”), and the Court having reviewed the 

Motion, the record in this case, and noting the lack of opposition with respect to the relief 

granted herein, and being otherwise duly advised in the premises, it is 

ORDERED, as follows: 

1. The Motion is GRANTED. 

2. The Pretrial Conference is hereby continued to May 12, 2020 at 10:00 a.m. at the 

United States Bankruptcy Court, Flagler Waterview Building, 1515 N Flagler Drive, Room 801 

Courtroom A, West Palm Beach, FL 33401 

3. The corresponding pretrial deadlines are extended accordingly to coincide with 

the continued Pretrial Conference. 

4. This Order is without prejudice to the parties seeking further extensions of the 

pretrial conference in this matter or any of the pretrial deadlines. 

### 

Submitted by: 

Jesus M. Suarez, Esq. 

Counsel for the Plaintiff 

Genovese Joblove & Battista, P.A. 

100 SE 2nd Street, Suite 4400 

Miami, FL 33131 

Tel: (305) 349-2300 

Email: jsuarez@gjb-law.com

[Attorney Suarez shall serve a copy of this Order to all interested parties and file a certificate of 

service] 

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