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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

West Palm Beach Division 

IN RE:

CHANCE & ANTHEM, LLC, CASE NO.: 18-16248-BKC-MAM

Debtor,

_______________________________/

ROBERT C. FURR, not individually but

as Chapter 7 Trustee of the estate of the

Debtor, Chance & Anthem, LLC,

Plaintiff,

v. ADV.PRO.NO.: 19-1298-BKC-MAM-A

JEFFREY M. SISKIND, individually and

d/b/a SISKIND LEGAL SERVICES,

et. al,

Defendants,

_________________________________/

DEFENDANT'S, JEFFREY M. SISKIND, OBJECTIONS TO

ADMISSIBILITY OF TRUSTEE'S EXHIBITS

JEFFREY M. SISKIND (“Movant” or “Siskind”), by and through undersigned counsel, 

hereby files this, his Objections to the Admissibility of the Plaintiff's, Robert C. Furr, Trustee in 

Bankruptcy for Chance & Anthem, LLC (“Trustee” or “Plaintiff”) Exhibits pursuant to this 

Court’s Order Setting Pretrial as follows: 

GENERAL OBJECTIONS

Movant objects to Trustee's Exhibits because they were filed out of time, with no prior 

request for extension of time or explanation for the late filing. More importantly, many of 

Trustee’s exhibits have no relevance whatsoever to the issues in dispute. 

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SPECIFIC OBJECTIONS

1. Siskind objects to the admission of the Trustee’s Exhibit # 1 through 147, 

inclusive, into evidence pursuant to Federal Rule of Evidence 402, except as stated otherwise 

herein. Siskind asserts that said aforementioned Exhibits have no relevance to the issues before 

the Court or the issues to be determined at the trial in this matter.

2. Siskind objects to the admission of Trustee’s Exhibit #31 into evidence pursuant 

to Federal Rule of Evidence 106. Pursuant to Federal Rule of Evidence 106 when a writing is 

introduced into evidence, the entirety of the writing should be considered with it. The Movant 

concedes the proposed document is complete in and of itself; however, when considered in the 

totality of the situation, this document alone fails to explain or evidence the complete picture. 

3. Siskind objects to the substance of Trustee’s Exhibits # 1 through 147, inclusive, 

except as stated otherwise herein, and demands cross examination of whomever the Trustee puts 

forth to authenticate each Exhibit; otherwise, pursuant to Federal Rules of Evidence 801, 802, 

803 and 804, which Exhibits should not be admitted into evidence on the grounds that it is 

inadmissible hearsay and otherwise unreliable.

4. Siskind objects to the admission or utilization of the Trustee's Exhibit #123, 

Expert Report of Alan Barbee. Pursuant to Federal Rule of Civil Procedure 26(e), the Trustee 

was required to provide any expert reports by a date certain, after which the Trustee provided 

Siskind with another expert report, intending that the latter one be used at trial. On June 25, 

2020, after the deadline to provide expert reports, the Trustee provided Siskind with a 

Supplement to the Expert Report. The Supplement to the Expert Report was not provided based 

upon the original expert report being incomplete or incorrect. Rather, the Supplement to the 

Expert Report was merely prepared to annul Siskind's allegations as to solvency and to perfect 

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the Trustee's litigation strategy. As such, Siskind objects to the admissibility of the Supplement 

to the Expert Report, and pursuant to Federal Rule of Civil Procedure 37(c)(1), seeks to preclude 

the Supplemented Expert Report. Additionally, to whatever extent the Trustee seeks to rely upon 

the initial expert report, Siskind objects on the basis the initial expert report was supplemented 

and is not properly before this Court.

5. The Debtor objects to Trustee exhibit no. 147 as protected by the confidentiality 

order, as well as relevancy and hearsay.

6. Notwithstanding the foregoing, Siskind does not object to Trustee exhibit nos. 28, 

36, 61, 62, 88, 94, 98, 99, 102, 103, 104, 105, 106, 107, 108, 109, 110, 111 and 126.

7. Siskind reserves on amending these objections as necessary to respond to exhibits 

intended to be introduced by the Trustee.

CERTIFICATE OF SERVICE

I hereby certify that a true copy of the foregoing was furnished on this 10th day of July, 

2020, via CM/ECF to all persons authorized to receive notices, electronically, as set forth on the 

attached Service List and by U.S. Mail, postage prepaid, to all parties listed on the attached 

Service List who are not authorized to receive notices, electronically, through the Court’s 

CM/ECF system.

S I S K I N D L E G A L, P L L C

_______/s/ Jeffrey M. Siskind_______

Jeffrey M. Siskind, Esq. FBN 138746

1629 K Street, Ste. 300, NW Washington, DC 20006

113 N. Monroe Street, 1st Floor Tallassee, Florida 32301

3465 Santa Barbara Drive Wellington, Florida 33414

TELEPHONE (561) 791-9565 FACSIMILE (561) 791-9581

Emails: jeffsiskind@msn.com & jeffsiskind@gmail.com

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SERVICE LIST

Robert C. Furr, Chapter 7 Trustee

Via email to jgenovese@gjb-law.com, jsuarez@gjb-law.com, bgruher@gjb-law.com

Jeffrey M. Siskind, individually

Via e-mail to jeffsiskind@msn.com

Tanya Siskind, individually

Via e-mail to philip@philipharris.com

Siskind Legal Services, LLC

Via e-mail to jeffsiskind@msn.com

Second Siskind Family Trust

Via e-mail to philip@philipharris.com

CannaMed Pharmaceuticals, LLC

Via e-mail to philip@philipharris.com

Sovereign Gaming and Entertainment, LLC

Via e-mail to philip@philipharris.com

Florida’s Association of Community Banks and Credit Unions, Incorporated

Via e-mail to philip@philipharris.com

Sympatico Equine Rescue, Incorporated

Via e-mail to philip@philipharris.com

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