1 

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. 

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, 

TANYA SISKIND, individually and as Trustee of the, 

SECOND SISKIND FAMILY TRUST, 

FRANK ZOKAITES, individually, 

CANNAMED PHARMACEUTICALS, LLC, 

a Maryland Limited Liability Company, 

OB REAL ESTATE HOLDINGS 1732, LLC, a 

Florida Limited Liability Company, 

SISKIND LEGAL SERVICES, LLC, 

a Florida Limited Liability Company, 

SOVEREIGN GAMING & ENTERTAINMENT, LLC, 

a Florida Limited Liability Company 

FLORIDA'S ASSOCIATION OF COMMUNITY 

BANKS AND CREDIT UNIONS, INC. a Florida Corporation, 

SYMPATICO EQUINE RESCUE, INC, a Florida Corporation, 

WELLINGTON 3445, LP, a Florida Limited Partnership, 

ZOKAITES PROPERTIES, LP, a Pennsylvania Limited Partnership, 

and ROBERT GIBSON, individually.1

, 

 Defendants. 

 / 

 

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 Pursuant to Fed. R. Civ. P. 20, as incorporated by Fed. R. Bankr. P. 7020, the Defendants are 

joined in this action because they are liable jointly, severally, or with respect to or arising out of 

the same transaction, occurrence, or series of transactions or occurrences, and questions of law 

and fact common to the Defendants will arise in the action. 

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ADVERSARY COMPLAINT 

TO AVOID AND TO RECOVER FRAUDULENT TRANSFERS, 

FOR TURNOVER, FOR AN ACCOUNTING, ALTER-EGO, SUBSTANTIVE 

CONSOLIDATION, INJUNCTIVE RELIEF AND FOR OTHER RELIEF 

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

bankruptcy estate of the Debtor, Chance & Anthem, LLC (the “Debtor” or “C&A”), files this 

Adversary Complaint against JEFFREY M. SISKIND, individually and doing business as 

SISKIND LEGAL SERVICES (“Siskind”), TANYA SISKIND, individually (T. Siskind) and as 

Trustee of the Second Siskind Family Trust (“Family Trust”), FRANK ZOKAITES 

(“Zokaites”)(Siskind, T. Siskind and Zokaites, are collectively referenced as the “Individual 

Defendants”), CANNAMED PHARMACEUTICALS, LLC, a Maryland Limited Liability 

Company (“Cannmed”), OB REAL ESTATE HOLDINGS 1732, LLC, a Florida Limited 

Liability Company (“OB Real Estate”), SISKIND LEGAL SERVICES, LLC, a Florida Limited 

Liability Company (“Siskind Legal”), SOVEREIGN GAMING & ENTERTAINMENT, LLC, a 

Florida Limited Liability Company (“Sovereign”), FLORIDA'S ASSOCIATION OF 

COMMUNITY BANKS AND CREDIT UNIONS, INC. a Florida Corporation (“FLACC”), 

SYMPATICO EQUINE RESCUE, INC, a Florida Corporation (“Sympatico”) WELLINGTON 

3445, LP, a Florida Limited Partnership (“Wellington”), and ZOKAITES PROPERTIES, LP, a 

Pennsylvania Limited Partnership (“Zokaites Properties”)(Family Trust, Cannmed, OB Real 

Estate, Siskind Legal, Sovereign, Wellington and Zokaites Properties are collectively referenced 

as the “Corporate Defendants”) and ROBERT GIBSON, individually (“Gibson”), to avoid and to 

recover fraudulent transfers from the Debtor to the Defendants, for turnover of property, for an 

accounting, for alter-ego liability, for substantive consolidation, for injunctive relief and for other 

relief pursuant to Sections 105, 542, 544, 548, and 550 of Title 11 of the United States Code (the 

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“Bankruptcy Code”), Chapter 726 of the Florida Statutes, Rule 7001, et seq. of the Federal Rules 

of Bankruptcy Procedure and federal common law, and says: 

INTRODUCTION

1. Jeffrey Siskind is an attorney licensed in Florida since 1998. Siskind was the sole 

member, attorney and control person of the Debtor. Siskind contends that the Debtor’s alleged 

business affairs consisted of two primary ventures: (1) serving as a funding vehicle for a 

cannabis business in Maryland in exchange for 75% of the membership interests in that business; 

and (2) renovating a home in Wellington, Florida. 

2. In truth, Siskind used the Debtor in concert with the Corporate Defendants in 

order to divert over $3 million of creditor, investor and client funds and real estate for his benefit 

and the benefit of the other Individual Defendants. Siskind, acting in concert with the Individual 

Defendants, later concealed the value of these diverted assets through a series of transactions 

involving the Corporate Defendants. During the course of most of these transactions, Defendant 

Siskind was a Chapter 11 debtor before this Court. In re Siskind, Case No. 13-13096-MAM. 

Defendant Siskind failed to properly disclose his interest in these transactions during his five (5) 

years as a debtor. 

3. The Trustee’s investigation, to date, reveals that Siskind transferred his clients’ 

and investors’ funds indiscriminately between entities that he controls and were not used for 

legitimate business purposes. For example, Siskind used investor monies to (i) transfer over 

$800,000 to himself; (ii) make payments in excess of $175,000 for his boats and airplanes; (iii) 

inexplicably transfer over $160,000 into his IOTA Trust account; (iv) fund a series of cash 

withdrawals in excess of $119,000; and (v) place millions of dollars of real estate purchased with 

investor funds in the hand of his associates and nominees. 

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4. By this adversary proceeding, the Trustee seeks to recover the property (or its 

value, products, and replacements) fraudulently transferred by Siskind for the benefit of the 

creditors of the Debtor and its alter-egos. Certain of the transfers identified in this adversary 

Complaint were made by alter-egos of the Debtor. The creditors of those entities, in turn, have 

sought to assert claims against the Debtor on the basis of its alter-ego liability. Accordingly, the 

Trustee is a proper party with standing to pursue these transfers. 

5. The Trustee also seeks to substantively consolidate before this Court the related 

entities used to perpetuate the scheme (Defendants CannaMed, OB Real Estate, Siskind Legal, 

Sovereign, FLACC and Sympatico). 

6. The Trustee further seeks injunctive relief to prevent Siskind and his associates 

from dissipating, encumbering and/or absconding with the property of the Debtor or its alteregos.2

 In conjunction with the foregoing relief, the Trustee alternatively seeks the appointment 

of a monitor over the Corporate Defendants to oversee, manage and preserve the status quo over 

their purported business operations and holdings pending the conclusion of this proceeding. 

THE PARTIES, JURISDICTION AND VENUE

7. On January 29, 2018, the Debtor filed a voluntary petition for bankruptcy relief 

under Chapter 7 of the United States Code (the “Bankruptcy Code”) [ECF No. 1] in the United 

States Bankruptcy Court for the District of Maryland. 

8. On January 29, 2018, George W. Liebman was appointed Chapter 7 Trustee in the 

District of Maryland. 

9. On March 17, 2018, a Section 341 Meeting of Creditors was held in the District 

of Maryland. The Debtor failed to appear. 

 

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 By separate motion, the Trustee will seek a Preliminary Injunction. 

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10. On May 24, 2018, A Memorandum and Order Transferring Venue to the 

Bankruptcy Court for the Southern District of Florida. 

11. On May 25, 2018, Robert C. Furr was appointed as the Chapter 7 Trustee. A 

section 341 Meeting of Creditors occurred on July 9, 2018 at 8:30 am in the Southern District of 

Florida, West Palm Beach Division. The Debtor appeared through its sole managing member, 

Defendant Siskind. 

12. Defendant Siskind is the control person of the Corporate Defendants. Siskind 

resides in Palm Beach County, Florida. Defendant Siskind has at times acted as counsel to 

Defendants Zokaites, CannaMed, OB Real Estate, Siskind Legal, Wellington, and Sovereign. 

Defendant Siskind is also the sole manager and member of the Debtor, the individual who 

prepared and executed its bankruptcy schedules, and served as the Debtor’s pre-petition counsel. 

13. Defendant T. Siskind is Siskind’s wife. She is a beneficiary of Family Trust and 

currently in possession of a Mercedes Benz acquired with funds fraudulently transferred from the 

Debtor. T. Siskind also received funds fraudulently transferred by the Debtor. T. Siskind resides 

in Wellington, Florida. 

14. Defendant Family Trust is a trust that upon information and belief is settled under 

the laws of the State of Florida and its trustee is Tanya Siskind. Additionally, upon information 

and belief, Siskind is a beneficiary or party that asserts dominion and/or control of the Family 

Trust. 

15. Defendant Zokaites is a close business associate of Siskind. He is the principal of 

Zokaites Construction, nominally the general partner of Defendant Wellington. He is also the 

principal of Defendant Zokaites Properties. Defendant Zokaites resides in Wexford, 

Pennsylvania. 

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16. Defendant CannaMed is a limited liability company organized under the laws of 

the State of Maryland. Its principal place of business was 27120 Ocean Gateway, Hebron, 

Maryland 21230. The Debtor purports to own 75% of Defendant CannaMed. The Debtor’s 

bankruptcy schedules reflect investments in CannaMed and liabilities of CannaMed as liabilities 

of the Debtor. The Debtor and CannaMed purported to share a principal place of business in 

Hebron, Maryland. 

17. Defendant OB Real Estate is an inactive Florida Limited Liability Company 

having a principal address of 375 Golfside Drive, Wexford, PA 15090. Its manager is Defendant 

Zokiates and its principal place of business is the same as Defendants Wellington and Zokaites 

Properties. Its registered agent is Defendant Siskind at 525 S. Flagler Drive, Suite 500, West 

Palm Beach, FL 33401. 

18. Defendant Siskind Legal is an inactive Florida Limited Liability Company having 

its principal address of 525 S. Flagler Drive, Suite 500, West Palm Beach, FL 33401. From time 

to time, Defendant Siskind has purported to practice law through Defendant Siskind Legal. 

19. Defendant Sovereign is an inactive Florida Limited Liability Company having its 

principal address of 525 S. Flagler Drive, Suite 500, West Palm Beach, FL 33401. Its sole 

manager and registered agent was William Siskind. Defendant Siskind is believed to control 

Defendant Sovereign as a nominee of William Siskind, his deceased father. 

20. Defendant FLACC is a Florida corporation having its principal address of 525 S. 

Flagler Drive, Suite 500, West Palm Beach, FL 33401. Its sole manager and registered agent is 

Defendant Siskind. Siskind claims that Defendant FLACC provides services to community 

banks and credit unions. FLACC appears to have no legitimate operations and appears to be a 

mere instrumentality created by Siskind to facilitate his scheme. 

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21. Defendant Sympatico is a Florida corporation having its principal address of 

3465 Santa Barbara Drive, Wellington, FL, 33144. Its sole officer and registered agent is 

Defendant Siskind. Siskind claims that Defendant Sympatico is a charity. Sympatico appears to 

have no legitimate operations and appears to be a mere instrumentality created by Siskind to 

facilitate his scheme 

22. Defendant Wellington is a Florida Limited Partnership having its principal 

address of 375 Golfside Drive, Wexforx, P.A. Defendant Wellington’s general partner is 

Zokaites Contracting FL, LLC (“Zokaites Contracting”). Defendant Wellington was formed 

with the Florida Secretary of State on February 16, 2017. The sole member and sole manager of 

Zokaites Contracting is Defendant Zokaites. 

23. Defendant Zokaites Properties is a limited partnership organized under the laws of 

Pennsylvania. Zokaites and his wife are the principal partners. It maintains its principal place of 

business in Wexford, Pennsylvania. Although it is not registered to conduct business in Florida, 

it frequently engages in transactions in Florida, including those at issue in this adversary 

proceeding. 

24. W. Siskind was the elderly father of Defendant Siskind. W. Siskind died during 

the course of this bankruptcy case. The Trustee will contemporaneously record a caveat 

concerning the claims referenced in this adversary proceeding, and reserves the right to join any 

probate estate, his heirs or beneficiaries at a later date. Upon information and belief, a probate 

estate has not been opened to administer the affairs of W. Siskind. 

25. Defendant Gibson is a resident of Palm Beach County. He holds title to certain 

property at issue in this complaint and is joined principally in his capacity as a relief Defendant. 

26. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. 

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§§ 157(a) and 1334(b). 

27. This is a core proceeding pursuant to 28 U.S.C. §§ 157(b)(2)(A), (C), (E), (H) and 

(O). The Trustee consents to the entry of final orders and judgment by the Bankruptcy Court. 

28. Venue is proper in this Court pursuant to 28 U.S.C. §§ 1408 and 1409. 

FACTS SUPPORTING THE CLAIMS

A. Chance & Anthem and CannaMed Pharmaceuticals, LLC 

29. The Debtor purports to have been in the medical cannabis business through its 

ownership of CannaMed Pharmaceuticals, LLC (“CannaMed”). The Debtor has valued its 

interest in CannaMed at over $28 million. Yet, on the Petition Date, the Debtor only had $48 in 

its checking account and approximately $150 worth of office equipment (also dissipated by 

Siskind prior to the Trustee’s appointment). 

30. The Debtor paid many of CannaMed’s expenses and appears to have made itself 

liable for a number of “loans” or “investments” acquired by Defendant Siskind purportedly for 

use in CannaMed. In a recent court filing, Siskind identified litigation involving CannaMed as 

“the Debtor’s only asset.” See Bankruptcy Petition No. 18-11168 (Bankr. D. Md.) at ECF No. 

81, ¶7. 

31. The Debtor’s bankruptcy schedules reflect that it received in excess of $1.3 

million from third parties purportedly to assist it with its cannabis business3

: Among these 

creditors are (a) Frederick Volkwein ($500,000); (b) Richard Neff ($526,000); (c) ABK South 

Properties, LLC ($250,000); (d) Gen VC, LLC ($100,000); and (e) Richard Bell ($50,000). 

 

3

 The Trustee’s investigation into the extent, validity and priority of the investments is ongoing 

and remain subject to further diligence and reconciliation. The Trustee reserves all rights with 

respect to the foregoing claims, including but not limited to the right to seek to subordination or 

disallowance of any claim that is filed against the bankruptcy estate. 

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32. Like the Debtor, CannaMed never operated a bona fide business. In truth, it was 

little more than a shell used by Defendant Siskind to defraud creditors, conceal assets, and 

facilitate his use of assets placed in his trust by clients and investors. 

B. Christopher George 

33. Prior to May 2013, Defendant Siskind was retained as an attorney by Christopher 

George (“George”). George, who is incarcerated, retained Defendants Siskind and Siskind Legal 

to establish a trust for the benefit of his minor child. The Trust was to be funded with $2 million 

in cash and George’s homestead located at 3485 Lago de Talavera, Lake Worth, Florida, 33467 

(the “Talavera House”). 

34. On May 8, 2013, Michael Haggerty (George’s father-in-law) by and through a 

power of attorney, quitclaimed the Talavera House to 3485 Lago de Talavera Trust (“Talavera 

Trust”). The Talavera Trust was settled by Defendants Siskind and Siskind Legal on George’s 

behalf. The quitclaim deed was also prepared by Defendant Siskind. 

35. On December 24, 2013, Defendant Siskind caused George’s wife Dianna George 

to transfer $2 million belonging to George to an attorney trust account denominated “Siskind 

Trust Account” ending in 7721 maintained by Defendants Siskind and Siskind Legal. 

36. Defendant Siskind, as set forth in greater detail below and in Table 1, used the 

Debtor and its alter-egos to abscond with George’s $2 million and the Talavera House. George, 

acting through Dianna George, has filed a claim a proof of claim against the estate in the amount 

of $2,000,000, alleging among other things, conversion, fraud and breaches of fiduciary duty. 

37. Defendant Siskind deposited the funds obtained from George into his IOTA Trust 

account and quickly used them for his own personal benefit. Among other things, Siskind 

purported to structure a loan transaction to Defendant Sovereign in the amount of approximately 

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$1.9 million. The balance of the funds ($70,000) were used to pay a relative’s personal 

expenses. 

38. After transferring the funds to Defendant Sovereign, purportedly for bona fide 

investment purposes, Siskind proceeded to use those funds for his own personal benefit, 

including but not limited to (i) transferring $1.15 million to FLACC, later used to purchase an 

office condominium (defined below as the “Office Space”); (ii) withdrawing $100,000; (iii) 

acquiring an existing mortgage on the Talavera House (defined below); (iv) purchasing real 

estate at 114000 Torchwood Court in Wellington, Florida in the name of Beacon Acquisition & 

David Fiore; (v) transferring $25,000 to Defendant Siskind Legal; (vi) transferring $25,000 to 

Defendant Siskind; and (v) dissipating another $373,379 through a series of other transfers, 

including to third parties (Ocean Reef Club, The Beach Club, Mar-A-Lago Club, Old Guard 

Club & Going Aire) for the benefit of Siskind and his father, William Siskind (collectively, the 

“Sovereign Cash Out”). 

39. In sum, Defendant Siskind obtained $2 million from his client, Christopher 

George, and used that money to fund his family’s lifestyle and other investments through a series 

of artifices used in conjunction with the Debtor to part Mr. George from his money for the 

benefit of Defendant Siskind and his family. Mr. George, in turn, seeks to hold the Debtor liable 

for Siskind’s conduct as an alter-ego or otherwise, as evidence by his proof of claim against the 

Debtor’s bankruptcy estate. Mr. George, notably, received no apparent benefit from Siskind’s 

use of these funds. 

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TABLE 1 – CHRISTOPHER GEORGE RELATED TRANSFERS 

CONFIDENTIAL 

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C. Carl Stone & Richard Neff 

40. On or about August 9, 2015, based on Siskind’s representations, Carl Stone and 

his associate David Fiore (“Stone”) transferred $800,000 to an attorneys’ trust account 

maintained by Defendants Siskind and Siskind Legal for investment purposes in the 

improvements to real estate located at 3445 Santa Barbara Drive, Wellington, FL 33414 (the 

“Santa Barbara House”). 

41. Defendant Siskind purportedly was in the process of renovating the Santa Barbara 

House in order to later sell it for a profit. Defendants Siskind and Siskind Legal Services agreed 

that they would record proper instruments in order to protect Stone’s interest in the Santa 

Barbara House. 

42. Defendants Siskind and Siskind Legal never recorded a security interest in favor 

of Stone against the Santa Barbara House. Instead, Defendant Siskind used his law firm’s bank 

accounts (Defendant Siskind Legal) to (i) transfer $35,000 to FLACC and from those proceeds 

$30,000 to himself; (ii) $750,000 to FLACC of which $725,000 were returned to the Debtor; 

(iii) the balance of the proceeds used to purchase the Santa Barbara House (collectively, the 

“Stone Cash Out”). 

43. In sum, Defendant Siskind obtained $800,000 from Carl Stone for investment 

purposes, and used that money to fund his lifestyle and other investments through a series of 

artifices used in conjunction with the Debtor to part Mr. Stone from his money for the benefit of 

Defendant Siskind. Mr. Stone, in turn, seeks to hold the Debtor liable for Siskind’s conduct as 

evidence by his proof of claim against the Debtor’s bankruptcy estate. 

44. Richard Neff also loaned the Debtor money for use in the renovation of the Santa 

Barbara House. On October 6, 2015, Neff transferred $500,000 to the Debtor. Similarly, 

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Defendant Siskind failed to record a mortgage or perfect any other security protecting Neff’s 

investment in the Santa Barbara House. Instead, Defendant Siskind transferred $59,000 from the 

Debtor to purchase a Mercedes Benz for Defendant Tanya Siskind but purchased in the name of 

the Family Trust (the “Mercedes Transfer”). See Table 2, infra. 

45. As set forth in greater detail below, Defendant Siskind later refinanced the Santa 

Barbara House without recognizing the investments of Stone and Neff, and yet again using those 

proceeds for his own purposes. 

46. In sum, Defendant Siskind obtained $500,000 from Richard Neff for investment 

purposes, and used that money to fund his lifestyle and other investments through a series of 

artifices used in conjunction with the Debtor to part Mr. Neff from his money for the benefit of 

Defendant Siskind. Mr. Neff, in turn, seeks to hold the Debtor liable for Siskind’s conduct as 

evidence by his proof of claim against the Debtor’s bankruptcy estate. 

[REMAINDER OF PAGE INTENTIONALLY BLANK] 

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TABLE 2 – CARL STONE & RICHARD NEFF TRANSFERS 

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D. Fredrick Volkwein 

47. On or about November 17, 2014, based on Siskind’s representations Fred 

Volkwein, either directly or through Sarenil Associates, LLC, deposited $1,157,623 into the 

Debtor. 

48. In this instance, Defendant Siskind deposited the funds in the Debtor’s bank 

account and quickly proceeded to use the funds for his personal benefit by, among other things 

transferring (i) $230,000 to FLACC of which $188,000 was transferred to Defendant Siskind and 

$15,000 was subsequently transferred to Defendant Siskind Legal; (ii) $101,500 to himself 

through six separate transfers; (iii) $100,000 to his IOTA Trust Account; (iv) $58,000 to 

“Fenderhooks” in an apparent repayment to Volkwein; (v) $45,000 to George Maler in 

satisfaction of another debt; (vi) $43,500 to Crystal Title and Equity regarding “Fiore”; and (vii) 

$26,000 to Defendant Sovereign (collectively, the “Volkwein Cash Out”). See Table 3, infra. 

49. Siskind used Volkwein’s own funds to repay $535,109 to Volkwein in 

consideration of his prior investment. 

50. On August 7, 2018, the Sarenil Associates, LLC filed a proof of claim against the 

Debtor’s bankruptcy estate in the amount of $669,124 (Claim No. 3). 

[REMAINDER OF PAGE INTENTIONALLY BLANK] 

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TABLE 3 – FREDERICK VOLKWEIN TRANSFERS 

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E. The Real Estate Transactions 

51. Defendant Siskind used also the Debtor and its alter-egos to conceal his use of 

client and investor assets for his own personal benefit through transactions involving four (4) real 

properties in Palm Beach County, Florida: (1) The Talavera House; (2) The Santa Barbara 

House, (3) The Office Space; and (4) The Cross Creek Condominium. 

3485 Lago de Talavera 

52. On or about December 2013, George instructed his attorney, Defendant Siskind, 

to use a portion of the $2 million held by Defendant Siskind for the benefit of George to satisfy a 

mortgage encumbering the Talavera House. The mortgage was held by Michelle Watson in the 

principal amount of $200,000. 

53. The Legal Description of the Talavera House is: 

TALAVERA PUD LT 29, according to the Plat thereof, as 

recorded in Plat Book 105, Page 44, of the Public Records 

of Palm Beach County, Florida 

Parcel Control Number: 00-42-44-19-09-000-0290 

54. Instead of satisfying the mortgage, however, Defendant Siskind obtained an 

assignment of the mortgage in favor of Defendant Sovereign. The assignment was prepared by 

Defendant Siskind. W. Siskind, Siskind’s deceased father, was the sole member of Defendant 

Sovereign and Defendant Siskind admits to being its control person. Defendant Sovereign is the 

Debtor’s alter-ego. 

55. On November 14, 2014, Defendant Siskind prepared and recorded a Notice of Lis 

Pendens in Palm Beach County (Filing #20558894) purporting to give notice of the foreclosure 

of a mortgage by Defendant Sovereign. 

56. On February 5, 2014, Defendant Siskind prepared and recorded a so-called 

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“indemnity mortgage” against the Talavera House in the amount of $300,000 in order to secure 

legal fees that he or Defendant Siskind Legal could potentially incur at a future date while 

providing legal services to George or Talavera Trust (the “Indemnity Mortgage”). 

57. George alleges that no legitimate fees were incurred by Defendants Siskind or 

Siskind Legal, and that the indemnity mortgage was orchestrated by Defendant Siskind to part 

him from his assets. Upon information and belief, no consideration was ever given to George by 

Defendants Siskind or Siskind Legal in exchange for the Indemnity Mortgage. 

58. On January 8, 2015, Defendant Siskind caused the Talavera Trust, through fraud 

and misrepresentation, to transfer the Talavera House to Defendant Sovereign through a deed-inlieu of foreclosure. At Defendant Siskind’s insistence, the Talavera Trust conveyed to 

Defendant Sovereign all right, title and interest in the Talavera House. The deed in favor of 

Defendant Sovereign was prepared and recorded by Defendant Siskind. 

59. On February 25, 2016, Defendant Sovereign gave a mortgage against the Talavera 

House in favor of Tatarow Family Partners, Ltd. (“Tatarow”) in the amount of $300,000. Upon 

information and belief, the proceeds of the loan collateralized by the Talavera House were 

wholly misappropriated by Defendants Siskind for his own personal use and never provided any 

value to Defendant Sovereign (the “First Talavera Cash Out”). 

60. On July 19, 2016, Defendants Siskind and Siskind Legal sold the Indemnity 

Mortgage to George Maler and Jeri Maler for $100,000 (the “Second Talavera Cash Out”). The 

proceeds of the First Talavera Cash Out were transferred to Defendants Siskind and Siskind 

Legal for their own benefit and never provided any value to the Debtor or its alter-ego Defendant 

Sovereign. 

61. Subsequently, Tatarow initiated a foreclosure proceeding against the Talavera 

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House in a case captioned Tatarow Family Partners LTD v. Sovereign Gaming & Entertainment, 

LLC, etc., Case No. 50-2016-CA-012892-XXXX-MB, pending in the Seventeenth Judicial 

Circuit of Florida (the “Talavera Foreclosure Case”). 

62. On March 5, 2018. Tatarow assigned its mortgage to Defendant Zokaites 

Properties, which was substituted as plaintiff in the Talavera Foreclosure Case (the “Tatarow 

Mortgage Transfer”). Defendant Siskind structured this transaction in order to fraudulently 

obtain ownership of the Talavera House below market value and without paying value to 

Defendant Sovereign, the Debtor’s alter-ego. 

63. The Talavera Foreclosure case remains pending. The Talavera House is presently 

believed to be occupied by Defendant Siskind’s elderly mother Judy Siskind. Although it was 

titled in the name of Defendant Sovereign, the title to same has been transferred to Defendant’s 

Siskind former paralegal, Robert Gibson, through a series of quit claim deeds allegedly executed 

by Defendant Sovereign to the Maler’s and finally to Defendant Siskind’s former paralegal 

Robert Gibson (the “Gibson Transfer”). It is believed that Mr. Gibson has further pledged a 

mortgage against the house in favor of the Maler’s and that Mr. Gibson is attempting to facilitate 

a repayment of the Maler’s debt and preserve the value of the Talavera House for the benefit of 

Mr. Siskind’s creditors. 

64. The First Talavera Cash Out, Second Talavera Cash Out, Tatarow Mortgage 

Transfer and Gibson Transfer shall collectively be referred to as the “Talavera Transfers”) 

The Santa Barbara House 

65. On August 25, 2015, the Debtor purchased the Santa Barbara House from JP 

Morgan Chase Co. for $1,250,000. Upon information and belief, the Debtor used at least $1 

million in funds from Neff and Stone to fund the purchase of the Santa Barbara House. 

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66. The Legal Description of the Santa Barbara House is: 

SOUTHFIELDS PHASE 1 WELLINGTON 

COUNTRYPLACE LT 2 PUD, according to the Plat 

thereof, as recorded in Plat Book 39, Pages 19 through 22, 

of the Public Records of Palm Beach County, Florida 

Parcel Control Number: 73-41-44-21-03-000-0020 

67. On November 13, 2015, Defendant Siskind encumbered the Santa Barbara House 

with a mortgage in favor of New Wave Loans Residential, LLC in the amount of $812,500. The 

mortgage instrument was executed by Defendant Siskind as managing member of the Debtor. 

The Mortgage purported to secure a balloon loan in the amount of $812,500 plus accumulated 

interest which matured in December 2018 (the “First Santa Barbara Cash Out”). 

68. The funds obtained from the First Santa Barbara Cash Out were deposited in the 

Debtor and quickly thereafter used by Siskind to fund his own personal expenses, including (i) 

five payments to Siskind for $107,500; (ii) a transfer of $61,719.63 to K Title Company LLC fbo 

Jeffrey Siskind; (iii) two payments of $145,950 to George Maler; (iv) two payments totaling 

$117,000 for aircraft related expenses; (v) thirteen cash withdrawals totaling $82,000; (vi) a 

payment of $62,506 to Defendant Zokaites Properties for a “loan payoff;” (vii) two transfers 

totaling $60,000 to Siskind’s IOTA trust accounts; and (viii) four transfers totaling $30,000 to 

Defendant Sovereign. 

69. On March 23, 2016, Defendant Siskind further encumbered the Santa Barbara 

House with a mortgage in favor of ABK South Properties, LLC in the amount of $500,000. The 

mortgage instrument was executed by Defendant Siskind as managing member of the Debtor. 

The Mortgage purported to secure a balloon loan in the amount of $812,500 plus accumulated 

interest which matured on December 2018. Upon information and belief, the proceeds of this 

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loan incurred by the Debtor were transferred to Defendant Siskind for his own personal use and 

were never of any value to the Debtor or its alter-egos (the “Second Santa Barbara Cash Out”). 

70. The proceeds of the Second Santa Barbara Cash Out, to date identified as 

$100,000 deposited in the Debtor’s bank account, were again quickly used by Siskind to fund his 

own personal expenses including (i) six transfers totaling $48,625 to FLACC; (ii) a transfer of 

$10,000 to Defendant Siskind Legal; and (iii) $30,231 to fund a payment to Long Badger & 

Sheller purportedly in consideration of Cannamed’s rent expense. 

71. On November 8, 2016, New Wave Lenders initiated a foreclosure proceeding 

against the Santa Barbara House. New Wave Lenders 2015 B LP v. Chance & Anthem, LLC,

Case No. 50-2016-CA-012543. 

72. On January 23, 2017, Defendant Wellington acquired the first position mortgage 

in favor of New Wave Lenders for $898,231 and subsequently substituted itself as plaintiff in the 

foreclosure case. 

73. On June 12, 2017, the Santa Barbara House was sold at a foreclosure sale to 

Defendant Wellington for $1,000,100 (“Santa Barbara Foreclosure Transfer”). 

74. The Santa Barbara House, in summary, was used by Defendant Siskind to (1) 

conceal the use of $1 million he wrongfully obtained from Stone and Neff; (2) obtain over 

$800,000 in additional cash from the equity in the house mortgaged by New Wave Lenders and 

ABK South Properties, LLC; and (3) transfer the value of the Santa Barbara House from the 

Debtor free and clear of all liens, claims and encumbrances to his nominee Defendant Zokaites 

through the use of Defendant Wellington in the Santa Barbara Foreclosure Transfer. 

75. Notably, the Santa Barbara House is adjacent to Siskind’s personal residence 

located within the municipality of Wellington, Florida. It is believed that Defendant Siskind 

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22 

replatted the Santa Barbara House in order to add land to the home he owns with Tanya Siskind 

(the “Siskind Parcel Transfer”). 

76. The First Santa Barbara Cash Out, the Second Santa Barbara Cash Out, the Santa 

Barbara Foreclosure Transfer and the Siskind Parcel Transfer shall collectively be referred to as 

the “Santa Barbara Transfers”) 

 The Trump Office Suite / OB Real Estate Holdings 1732, LLC 

77. Defendant OB Holdings was the fee simple owner of the suite of offices where 

Defendants Siskind, W, Siskind, Siskind Legal and Sovereign operated. The suite consisted of 

the entire fifth (top) floor of the Trump Office Center on 525 S. Flagler Drive, West Palm Beach 

Florida (the “Office Suite”). 

78. The Legal Description of the Office Suite is: 

Condominium Units CCU3A2, CCU3B2 and CCU3C2, 

Trump Plaza of the Palm Beaches, a condominium, 

according to the Declaration of Condominium thereof, 

recorded in Official Records Book 4800, Page 457, with all 

exhibits and amendments thereof, Public Records of Palm 

Beach County, Florida, and any and all amendments thereto, 

together with an undivided interest in the common elements 

appurtenant thereto a set forth in said declaration, together 

with an undivided 16.93% interest in Unit No. CCU3 as set 

forth in the Declaration of Agreement for Commercial Unit 

Parking Facilities as recorded in Official Records Book 

19010, Page 70, Public Records of Palm Beach County, 

Florida 

Parcel Control Number 74-43-43-22-25-003-0012 

79. On February 27, 2014, Defendant OB Holdings acquired the Office Suite through 

a foreclosure proceeding captioned Optimum Bank v. TP5, LLC, et al, Case No. 50-2010-CA026014 (17th Judicial Circuit). In this original proceeding, Optimum Bank foreclosed on a first 

position mortgage recorded against the Office Suite, which at the time was owned by TP5, LLC, 

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a limited liability company. Defendant Siskind was the sole managing member and registered 

agent for TP5, LLC. He was also a guarantor of the indebtedness to Optimum Bank. Ultimately, 

through the foreclosure case, Optimum Bank took title to the Office Suite through Defendant OB 

Holdings. 

80. On April 30, 2014, Defendant Siskind acquired the shares of Defendant OB 

Holdings from Optimum Bank and placed them in the name of W. Siskind. Through Defendant 

OB Holdings, Defendant Siskind acquired fee simple ownership of the Office Suite (the “Office 

Suite Repurchase”). 

81. Defendant Siskind used the $1 million from Christopher George to fund the 

Office Suite Repurchase. Defendant Siskind accomplished the Office Suite Repurchase by 

purporting to “lend” $1 million allegedly held in trust by Defendants Siskind and Siskind Legal 

to Defendant Sovereign (an alter-ego of the Debtor). Although Defendant Sovereign funded the 

purchase of Defendant OB Real Estate, it received no consideration or reasonably equivalent 

value in connection with the transaction (the “First Office Suite Cash Out”). 

82. After acquiring the Office Suite, Defendant Siskind proceeded to encumber and 

cash out of the Office Suite much as he did with the Talavera House and the Santa Barbara 

House. 

83. On September 3, 2014, Defendant Siskind encumbered the Office Suite with a 

mortgage in favor of George Maler and others (the “Maler Lenders”) in the amount of $200,000. 

The mortgage instrument was executed by W. Siskind (deceased) as managing member of the 

Debtor’s alter-ego Defendant OB Real Estate. Upon information and belief, the proceeds of this 

loan incurred by the Defendant OB Real Estate were transferred to Defendants Siskind through 

his IOTA Trust Account for his own personal use and were never of any value to the Debtor or 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 23 of 59
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its alter-ego Defendant OB Real Estate (the “Second Office Suite Cash Out”). 

84. On November 28, 2014, Defendant Siskind further encumbered the Office Suite 

by increasing the indebtedness to the Maler Lenders by $150,000 to $350,000. The mortgage 

instrument was executed by W. Siskind as managing member of the Debtor’s alter-ego 

Defendant OB Real Estate. Upon information and belief, the proceeds of this loan incurred by 

Defendant OB Real Estate were transferred to Defendants FLACC, Siskind and W. Siskind for 

their own personal use and were never of any value to the Debtor or its alter-ego Defendant OB 

Real Estate (the “Third Office Suite Cash Out”). 

85. On March 28, 2015, Defendant Siskind further encumbered the Office Suite by 

increasing the indebtedness to the Maler Lenders by $150,000 to $500,000. The mortgage 

instrument was executed by W. Siskind as managing member of the Debtor’s alter-ego 

Defendant OB Real Estate. Upon information and belief, the proceeds of this loan incurred by 

Defendant OB Real Estate were transferred to Defendants FLACC and Sovereign for the 

personal use of Siskind and W. Siskind and were never of any value to the Debtor or its alter-ego 

Defendant OB Real Estate (the “Fourth Office Suite Cash Out”). 

86. On September 20, 2015, Defendant Siskind further encumbered the Office Suite 

by increasing the indebtedness to the Maler Lenders by $250,000 to $750,000. The mortgage 

instrument was executed by W. Siskind as managing member of the Debtor’s alter-ego 

Defendant OB Real Estate. Upon information and belief, the proceeds of this loan incurred by 

Defendant OB Real Estate were transferred to Defendants Siskind and W. Siskind for their own 

personal use and were never of any value to the Debtor or its alter-ego Defendant OB Real Estate 

(the “Fifth Office Suite Cash Out”). 

87. On November 28, 2016, W. Siskind resigned as the sole managing member of OB 

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real Estate and was replaced with Defendant Zokaites. 

88. On January 31, 2018, Defendant Zokaites caused Defendant OB Real Estate to 

transfer its interest in the Office Suite in exchange for $1.2 Million (the “Office Suite Sale”). 

Upon information and belief, the proceeds of the Office Suite Sale were transferred to 

Defendants Siskind and Zokaites for their own personal use and were never of any value to the 

Debtor or its alter-ego Defendant OB Real Estate. 

89. The Office Suite, in summary, was used by Defendant Siskind to (1) conceal the 

use of $1 million he wrongfully obtained from his client Christopher George through Defendant 

Sovereign; (2) obtain over $750,000 in additional cash from the Office Suite in mortgages 

provided by the Maler Lenders; (3) transfer the value of Office Suite from the Defendant OB 

Real Estate to Defendant Zokaites; and (4) consummate the Office Suite Sale in order to 

liquidate the remaining equity in the Office Suite without providing any value to Defendant 

Sovereign (an alter-ego of the Debtor) in exchange for its original $1 million contribution for the 

Office Space Repurchase. 

90. The Office Suite Repurchase, First Office Suite Cash Out, Second Office Suite 

Cash Out, Third Office Suite Cash Out, Fourth Office Suite Cash Out, Fifth Office Suite Cash 

Out, Fifth Office Suit Cash Out and the Office Suite Sale shall collectively be referred to as the 

“Office Suite Transfers”) 

 The Cross Creek Condominium 

91. On December 2, 2015, Defendant Siskind caused the Debtor to obtain an 

Assignment of Mortgage from George A. Maler recorded against real property located in Cross 

Creek Condominium at 1500 N Congress Avenue, Unit B-6, West Palm Beach, Florida 33401 

(the “Cross Creek Condominium”). 

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26 

92. The Legal Description of the Cross Creek Condominium is: 

CROSS CREEK COND UNIT B-6 BLDG 9, a 

condominium according to the Declaration thereof recorded 

in Official Record Book 3262, Page 1812, of the Public 

Records of Palm Beach County, Florida. 

Parcel Control Number 74-43-43-18-05-000-2006 

93. On August 1, 2017, the Debtor, through Defendant Siskind, filed a Notice of Lis 

Pendens concerning the CrossCreek Condominium and initiated a foreclosure proceeding against 

its owners Imitiaz Mohammed and Zoreeda Mohammad, et al. Case No (20-2017-CA008682XXXXMB). 

94. On October 12, 2017, the Debtor executed and Assignment of Mortgage from the 

Debtor to Zokaites Properties concerning the mortgage it owned on the Cross Creek 

Condominium (the “Cross Creek Transfer”). Upon information and belief, the Debtor did not 

receive any value for assignment of its mortgage to Defendant Zokaites Properties. 

E. The Transfers at Issue 

95. During the Four Years prior to the Petition Date, Defendant Siskind using the 

Debtor or its alter-ego Corporate Defendants, engaged in the following transactions which 

reflect transfers of real estate and cash either to him individually or nominally to third parties but 

for his benefit: 

a. The Sovereign Cash Out; 

b. The Stone Cash Out 

c. The Volkwein Cash Out 

d. The Stone Cash Out; 

e. The Mercedes Transfer; 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 26 of 59
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f. The Talavera Transfers 

g. The Santa Barbara Transfers 

h. The Office Suite Transfers 

i. The Cross Creek Transfer; and 

j. Additionally, Siskind withdrew over $119,000 from the Debtor’s bank accounts in 

cash for his own personal benefit in the manner set forth at Exhibit “A,” and 

referred to herein as the “Siskind Cash Transfers” 

96. During the Four Years prior to the Petition Date, Defendants T. Siskind and 

Family Trust engaged in the Mercedes Transfer which reflects the transfer of property of the 

Debtor: Additionally, Tanya Siskind was paid $17,000 by the Debtor for which the Debtor 

received no value (the “Tanya Siskind Cash Transfer”) in the manner set forth at Exhibit “B.” 

Tanya Siksind was also a beneficiary of the Santa Barbara Transfers. 

97. During the Four Years prior to the Petition Date, Defendant Zokaites engaged in 

the following transactions which reflect transfers of real estate and cash either to him 

individually or nominally to third parties but for his benefit: 

a. The Talavera Transfers; 

b. The Santa Barbara Transfers; and 

c. The Office Suite Transfers. 

98. During the Four Years prior to the Petition Date, Defendant Wellington engaged 

in the Santa Barbara Transfer which reflects a transfer of real estate for its benefit: 

99. During the Four Years prior to the Petition Date, Defendant Zokaites Properties 

engaged in the Talavera Transfers and Cross Creek Transfers, each of which reflects transfers of 

real estate and cash either to him individually or nominally to third parties but for its benefit: 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 27 of 59
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a. The Talavera Transfer; 

b. The Cross Creek Transfer. 

100. During the Four Years prior to the Petition Date, Defendant Sympatico

benefitted from the scheme by (i) $11,354.50 from the Debtor; (ii) $12,540 from Siskind Legal; 

(iii) $15.933 from FLACC; and (iv) $11,498.05 from Siskind’s DIP Account (collectively, the 

“Sympatico Transfers”). Additionally, Siskind deposited over $25,000 in cash into Sympatico’s 

bank accounts. 

101. The transfers of cash and real estate described herein were orchestrated by 

Defendant Siskind in order to conceal the source and use of funds that he misappropriated from 

clients and investors alike in a manner adverse to his fiduciary obligations to his clients, the 

Debtor, and its alter-egos, and were designed to hinder, delay and/or defraud creditors of the 

Debtor and its alter-egos. 

102. Additionally, during the Four Years prior to the Petition Date, Defendant Gibson 

engaged in the Talavera Transfer which reflects a transfer of real estate to him individually. 

D. Siskind’s Chapter 11 Bankruptcy Case 

103. On February 11, 2013, Siskind filed a personal bankruptcy petition under Chapter 

11 of the Bankruptcy Code. Notably, Siskind appeared as his own counsel and regularly appears 

as counsel on behalf of clients in the Bankruptcy Court. 

104. On June 11, 2018, Siskind’s personal bankruptcy case was dismissed. The 

transactions at issue in this adversary proceeding occurred during the pendency of his bankruptcy 

case. 

105. During the course of Siskind’s bankruptcy case, Siskind regularly filed operating 

reports and other papers that routinely failed to disclose his interests in the property and 

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transactions identified in this adversary proceeding. 

E. Conditions Precedent 

106. All conditions precedent to the institution of this action have been performed, 

have occurred, have been waived or have otherwise been excused. 

F. The Causes of Action 

COUNTS 1-7 

DECLARATORY JUDGMENT SEEKING ALTER EGO LIABILITY OF CANNAMED, 

OB REAL ESTATE, SISKIND LEGAL, SOVEREIGN, FLACC, SYMPATICO 

AND WELLINGTON 

The Trustee sues Defendants CannaMed, OB Real Estate, Sovereign, Siskind Legal, 

Wellington, FLACC and Sympatico and alleges: 

107. The Trustee restates and realleges paragraphs 1 through 106, as if fully set forth 

herein. 

108. This is an action for a declaratory judgment pursuant to 28 U.S.C. §§ 2201 and 

2202, et seq. seeking a determination that at all times material hereto, the Defendant at issue in 

each respective Count herein was the alter ego of the Debtor and that all of the assets and 

liabilities of said Defendant be deemed assets and liabilities of this bankruptcy estate. 

COUNT DEFENDANT RELATED TRANSACTION 

1 CannaMed Liabilities of the Debtor (¶¶21-24) 

2 OB Real Estate Office Suite Transfers 

3 Sovereign Talavera Transfers 

Office Suite Transfers 

4 Siskind Legal 

Sovereign Cash Out 

Stone Cash Out 

Volkwein Cash Out 

Talavera Transfers 

Santa Barbara Transfers 

Office Suite Transfers 

5 Wellington Santa Barbara Transfers 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 29 of 59
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COUNT DEFENDANT RELATED TRANSACTION 

6 FLACC Sovereign Cash Out, Stone Cash Out, 

Volkwein Cash Out 

7 Sympatico Sympatico Transfers 

109. At all times material hereto, the Defendant at issue in each respective Count 

herein was formed and/or operated for an improper purpose – to, among other things, hinder, 

delay and/or defraud the creditors of the Debtor. 

 WHEREFORE, the Trustee demands the entry of an order and/or judgment against 

Defendants CannaMed, OB Real Estate, Sovereign, Siskind Legal, Wellington, FLACC and 

Sympatico: (i) declaring that each Defendant is the alter ego of the Debtor at all times material to 

this action; (ii) declaring that all of the assets and liabilities of each Defendant be deemed assets 

and liabilities of this bankruptcy estate; and (iii) for any other relief the Court deems appropriate. 

COUNTS 8-14 

ACTION FOR SUBSTANTIVE CONSOLIDATION OF DEFENDANTS CANNAMED, 

OB REAL ESTATE, SISKIND LEGAL, SOVEREIGN, FLAC, SYMPATICO, 

AND WELLINGTON WITH THE DEBTOR’S BANKRUPTCY ESTATE 

The Trustee sues Defendants CannaMed, OB Real Estate, Sovereign, Siskind Legal, 

Wellington, FLACC and Sympatico and alleges: 

110. The Trustee repeats and realleges Counts 1-7 of his Complaint as if fully set forth 

herein, with respect to each applicable Defendant. 

111. This is an action to substantively consolidate Defendants CannaMed, OB Real 

Estate, Siskind Legal, Sovereign and Wellington, as set forth in the table below, into the 

Debtor’s bankruptcy proceedings such that each respective Defendant will be deemed a jointly 

administered bankruptcy debtor pursuant to Section 105 of the Bankruptcy Code 

COUNT DEFENDANT RELATED TRANSACTION 

8 CannaMed Liabilities of the Debtor (¶¶21-24) 

9 OB Real Estate Office Suite Transfers 

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10 Sovereign Talavera Transfers 

Office Suite Transfers 

11 Siskind Legal 

Sovereign Cash Out 

Stone Cash Out 

Volkwein Cash Out 

Talavera Transfers 

Santa Barbara Transfers 

Office Suite Transfers 

12 Wellington Santa Barbara Transfers 

13 FLACC Sovereign Cash Out, Stone Cash Out, 

Volkwein Cash Out 

14 Sympatico Sympatico Transfers 

112. Given the alter ego status of each respective Defendant as set forth in Counts 1-7 

above and the other facts and circumstances set forth above, equity and applicable law require 

that each respective Defendant be substantively consolidated as a jointly administered 

bankruptcy debtor. 

113. Based upon the foregoing, under applicable law the entry of an order and/or 

judgment substantively consolidating the Defendant at issue in each respective Count herein with 

the Debtor is both necessary and appropriate. 

114. In the event the relief requested in this Count is granted, the Trustee will, by 

separate motion to be filed in the main case to be served on all creditors and parties in interest, 

seek entry of an order substantively consolidating Defendant at issue in each respective Count 

herein with the estate of the Debtor. 

 WHEREFORE, the Trustee respectfully requests entry of an order and/or judgment 

against Defendants CannaMed, OB Real Estate, Sovereign, Siskind Legal, Wellington, FLACC 

and Sympatico: (i) declaring that each Defendant be substantively consolidated with the Debtor 

to be jointly administered with the Debtor’s bankruptcy proceeding; and (ii) for any other relief 

the Court deems appropriate. 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 31 of 59
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COUNTS 15 – 30 

AVOIDANCE AND RECOVERY OF FRAUDULENT TRANSFERS PURSUANT TO 

SECTIONS 548(a))(1)(A), 550(a)(1) and 550(a)(2) OF THE BANKRUPTCY CODE 

The Trustee sues Defendants and alleges: 

115. The Trustee restates and realleges paragraphs 1 through 108, as if fully set forth 

herein. 

116. Pursuant to 11 U.S.C. § 548(a)(1)(A) and/or 11 U.S.C. § 544, a Trustee may 

avoid any transfer of an interest of the debtor in property, or any obligation incurred by the 

debtor, that was made or incurred on or within 2 years (under § 548 of the Bankruptcy Code) 

before the date of the filing of the petition, if the debtor voluntarily or involuntarily – 

(a) made such transfer or incurred such obligation with actual 

intent to hinder, delay, or defraud any entity to which the debtor 

was or became, on or after the date that such transfer was made or 

such obligation was incurred, indebted. 

117. Further, pursuant to 11 U.S.C. § 550(a), in a fraudulent transfer action 

commenced under §§ 544 and 548 of the Bankruptcy Code, the Trustee may recover, for the 

benefit of the estate, the property transferred, or, if the Court so orders, the value of such 

property, from – (1) the initial transferee of such transfer or the entity for whose benefit such 

transfer was made; and (2) any immediate or mediate transferee of such initial transferee, i.e., 

any and all subsequent transferees. 

118. The transfers identified below that occurred within two (2) years of the Petition 

Date to Defendant constitute transfers of an interest in property and/or obligation of the Debtor 

or the alter-ego(s) identified in each count set forth in the table above as set forth herein and are 

therefore avoidable pursuant to 11 U.S.C. § 548(a)(1)(A) as actual intent fraudulent transfers. 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 32 of 59
33 

Count Debtor / Alter-Ego 

Transferor 

Transferee / 

Defendant Property Transferred 

15 Sovereign Siskind, FLACC 

Siskind Legal Sovereign Cash Out 

16 Chance Siskind, Siskind Legal 

FLACC Stone Cash Out 

17 Chance Siskind, Siskind Legal, 

Sovereign, FLACC Volkwein Cash Out 

18 Chance Family Trust 

Tanya Siskind Mercedes Transfer 

19 Sovereign Siskind First Talavera 

Cash Out 

20 Sovereign Siskind Second Talavera Cash 

Out 

21 

Sovereign Zokaites Properties 

Transfer of Tatarow 

Mortgage to Defendant 

Zokaites Properties 

22 Sovereign Gibson Gibson Transfer 

23 Chance Siskind, Sovereign, First Santa Barbara 

Cash Out 

24 Chance Siskind, Siskind Legal, 

FLACC 

Second Santa Barbara 

Cash Out 

25 Chance Wellington 

Zokaites 

Santa Barbara 

Foreclosure Transfer 

26 OB Real Estate Zokaites & Siskind Office Suite Sale 

27 Chance Zokaites Properties Cross Creek Transfer 

28 Chance Siskind Siskind Cash Transfers 

29 Chance Tanya Siskind Tanya Siskind Cash 

Transfers 

30 Various Sympatico Sympatico Transfers 

119. Further, the Debtor and its alter-egos as identified in the table herein did not 

receive reasonably equivalent value for each transfer identified in the table herein, to the extent 

that the Debtor or its alter-ego identified therein (i) were insolvent at the time of each transfer to 

each defendant as set forth above or became insolvent as a result thereof; (ii) were engaged or 

were about to engage in a business or transaction for which the remaining assets of the Debtor or 

the alter-ego identified in each count set forth in the table herein were unreasonably small in 

relation to the business or transaction; or (iii) intended to incur, or believed or reasonably should 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 33 of 59
34 

have believed, that the Debtor or the alter-ego identified in each count set forth in the table 

herein would incur debts beyond their ability to pay as they came due. 

120. Each defendant identified in each count set forth in the table herein was the initial 

transferee or the entity for whose benefit the transfer at issue in each count herein was made, and 

as a result, the Trustee is entitled to avoid each transfer from each Defendant as set forth in each 

Count herein pursuant to 11 U.S.C. § 548(a)(1)(A) as actual intent fraudulent transfers and to 

recover all such property for the benefit of the estate or, should the Court so order, the value 

thereof pursuant to 11 U.S.C. § 550(a)(1). 

121. Alternatively, the Defendant(s) identified in each Count set forth in the table 

above was(were) the immediate or subsequent transferee(s) of the initial transferee for whose 

benefit the transfer at issue in each count herein was made. As a result, the Trustee is entitled to 

recover the transfer at issue in each count herein as referenced above, from each Defendant, 

pursuant to 11 U.S.C. §§ 548(a)(1)(A) and 550(a)(2). 

122. Therefore, in accordance with 11 U.S.C. § 550(a), the recovery of property for the 

benefit of the bankruptcy estate of the Debtor is authorized to the extent that a transfer at issue in 

each count herein occurred within two (2) years of the Petition Date are avoided pursuant to 11 

U.S.C. § 548(a)(1)(A). 

WHEREFORE, the Trustee demands judgment against each Defendant identified in each 

respective Count above and (a) determining that each respective transfer that occurred within 

two (2) years of the Petition Date was fraudulent and avoidable pursuant to 11 U.S.C. § 

548(a)(1)(A); (b) and entering judgment in favor of Plaintiff against each respective Defendant 

in such amounts as are determined at trial, or the value thereof, and as otherwise detailed in the 

amounts set forth herein, plus pre-judgment interest from the date of each such transfer and 

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35 

post-judgment interest and costs of suit, all pursuant to 11 U.S.C. § 550; (c) disallowing any 

claim that each respective Defendant may have against the Debtor, including without limitation, 

pursuant to and as provided in 11 U.S.C. § 502(d); and (d) for such other and further relief as the 

Court deems just and proper. 

COUNTS 31-46 

AVOIDANCE AND RECOVERY OF FRAUDULENT TRANSFERS PURSUANT TO 

SECTION 548(a)(1)(B) OF THE BANKRUPTCY CODE 

The Trustee sues Defendants and alleges: 

123. The Trustee restates and realleges paragraphs 1 through 106, as if fully set forth 

herein. 

124. Pursuant to 11 U.S.C. §§ 548(a)(1)(B) and/or 544, a Trustee may avoid any 

transfer of an interest of the debtor in property, or any obligation incurred by the debtor, that was 

made or incurred on or within 2 years (under § 548 of the Bankruptcy Code) before the date of 

the filing of the petition, if the debtor voluntarily or involuntarily – 

(B) (i) received less than a reasonably equivalent value in 

 exchange for such transfer or obligation; and 

(ii) (I) was insolvent on the date that such transfer was 

made or such obligation was incurred, or became 

insolvent as a result of such transfer or obligation; 

(II) was engaged in business or a transaction, or was 

about to engage in business or a transaction, for 

which any property remaining with the debtor was 

an unreasonably small capital; or 

 (III) intended to incur, or believed that the debtor 

would incur, debts that would be beyond the 

debtor’s ability to pay as such debts matured. 

125. Further, pursuant to 11 U.S.C. § 550, in a fraudulent transfer action commenced 

under §§ 544 and 548 of the Bankruptcy Code, the Trustee may recover, for the benefit of the 

estate, the property transferred or obligation incurred, or, if the Court so orders, the value of such 

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36 

property, from – (1) the initial transferee of such transfer or the entity for whose benefit such 

transfer was made; and (2) any immediate or mediate transferee of such initial transferee, i.e., 

any and all subsequent transferees. 

126. The transfers identified in the table herein that occurred within two (2) years of 

the Petition Date constitute transfers of an interest in property and/or obligations of Debtor or the 

alter-ego(s) identified in each Count set forth in the table herein, which are avoidable pursuant to 

11 U.S.C. § 548(a)(1)(B) as constructively fraudulent transfers. \ 

Count Debtor / Alter-Ego 

Transferor 

Transferee / 

Defendant Property Transferred 

31 Sovereign Siskind, FLACC 

Siskind Legal Sovereign Cash Out 

32 Chance Siskind, Siskind Legal 

FLACC Stone Cash Out 

33 Chance Siskind, Siskind Legal, 

Sovereign, FLACC Volkwein Cash Out 

34 Chance Family Trust 

Tanya Siskind Mercedes Transfer 

35 Sovereign Siskind First Talavera 

Cash Out 

36 Sovereign Siskind Second Talavera Cash 

Out 

37 

Sovereign Zokaites Properties 

Transfer of Tatarow 

Mortgage to Defendant 

Zokaites Properties 

38 Sovereign Gibson Gibson Transfer 

39 Chance Siskind, Sovereign, First Santa Barbara 

Cash Out 

40 Chance Siskind, Siskind Legal, 

FLACC 

Second Santa Barbara 

Cash Out 

41 Chance Wellington 

Zokaites 

Santa Barbara 

Foreclosure Transfer 

42 OB Real Estate Zokaites & Siskind Office Suite Sale 

43 Chance Zokaites Properties Cross Creek Transfer 

44 Chance Siskind Siskind Cash Transfers 

45 Chance Tanya Siskind Tanya Siskind Cash 

Transfers 

46 Various Sympatico Sympatico Transfers 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 36 of 59
37 

127. The Debtor or the alter-ego identified in each Count set forth in the table herein 

did not receive reasonably equivalent value for each transfer identified in the table to the extent 

that the Debtor or the alter-ego identified in each Count set forth in the table (i) were insolvent at 

the time of each transfer at issue in each Count herein was or became insolvent as a result 

thereof; (ii) were engaged or were about to engage in a business or transaction for which the 

remaining assets of the Debtor or the alter-ego identified in each Count set forth in the table were 

unreasonably small in relation to the business or transaction; or (iii) intended to incur, or 

believed or reasonably should have believed, that the Debtor or the alter-ego identified in each 

Count set forth in the table would incur debts beyond their ability to pay as they came due. 

128. Each Defendant identified in each Count set forth in the table herein was the 

initial transferee or the entity for whose benefit each transfer at issue was made, and as a result, 

the Trustee is entitled to avoid and recover each transfer at issue herein pursuant to 11 U.S.C. § 

548(a)(1)(B) as constructively fraudulent transfers. 

129. Alternatively, each defendant identified in each count set forth in the table herein 

was the immediate or subsequent transferee of the initial transferee for whose benefit each 

transfer at issue herein was made, and as a result, the Trustee is entitled to recover each transfer 

at issue herein as referenced above from each Defendant identified herein pursuant to 11 U.S.C. 

§ 548(a)(1)(B) and 11 U.S.C. § 550(a)(2). 

130. Therefore, in accordance with 11 U.S.C. § 550(a), the recovery of property for the 

benefit of the bankruptcy estate of the Debtor is authorized to the extent that each transfer at 

issue in each Count herein occurred within two (2) years of the Petition Date are avoided 

pursuant to 11 U.S.C. § 548(a)(1)(B). 

WHEREFORE, the Trustee demands judgment against each Defendant identified in each 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 37 of 59
38 

respective Count above and (a) determining that each respective transfer that occurred within 

two (2) years of the Petition Date was fraudulent and avoidable under 11 U.S.C. § 548(a)(1)(B); 

(b) avoiding each respective transfer and entering judgment in favor of Plaintiff against each 

respective Defendant in such amounts as are determined at trial, or the value of thereof, and as 

otherwise detailed in the amounts set forth herein, plus pre-judgment interest from the date of the 

transfers and post-judgment interest, and costs of suit, all pursuant to 11 U.S.C. § 550; (c) 

disallowing any claim that each respective Defendant may have against the Debtor or the estate 

of any of its alter-egos, including without limitation, pursuant to and as provided in 11 U.S.C. § 

502(d); and (d) for such other and further relief as the Court deems just and proper. 

COUNTS 47-63 

AVOIDANCE AND RECOVERY OF FRAUDULENT TRANSFERS

PURSUANT TO SECTION 544 OF THE BANKRUPTCY CODE 

AND SECTION 726.105(1)(A) OF THE FLORIDA STATUTES 

The Trustee sues Defendants Siskind, W. Siskind, Zokaites, Wellington and Zokaites 

Properties and alleges: 

131. The Trustee re-states and re-alleges paragraphs 1 through 106, as if fully set forth 

herein. 

132. Pursuant to 11 U.S.C. § 544(b), the Trustee may avoid any transfer of an interest 

of the Debtor in property or any obligation incurred by the Debtor that is voidable under 

applicable law by a creditor holding an unsecured claim that is allowable under § 502 of this title 

or that is not allowable only under § 502(e) of this title. 

133. § 726.105(1)(a), Florida Statutes, provides: 

(1) A transfer made or obligation incurred by a debtor is fraudulent 

as to a creditor, whether the creditor’s claim arose before or after 

the transfer was made or the obligation was incurred, if the debtor 

made the transfer or incurred the obligation: 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 38 of 59
39 

 (a) With actual intent to hinder, delay, or defraud any creditor 

 of the debtor. 

134. Further, pursuant to 11 U.S.C. § 550, in a fraudulent transfer action commenced 

under Chapter 726 of the Florida Statutes, the Trustee may recover, for the benefit of the estate, 

the property transferred, or, if the Court so orders, the value of such property, from – (1) the 

initial transferee of such transfer or the entity for whose benefit such transfer was made; and (2) 

any immediate or mediate transferee of such initial transferee, i.e., any and all subsequent 

transferees. 

135. The transfers identified in the table herein to each respective Defendant were 

transfers made with the actual intent to hinder, delay, and/or defraud creditors pursuant to § 

726.105(1)(a), Florida Statutes. 

Count Debtor / Alter-Ego 

Transferor 

Transferee / 

Defendant Property Transferred 

47 Sovereign Siskind, FLACC 

Siskind Legal Sovereign Cash Out 

48 Chance Siskind, Siskind Legal 

FLACC Stone Cash Out 

49 Chance Siskind, Siskind Legal, 

Sovereign, FLACC Volkwein Cash Out 

50 Chance Family Trust 

Tanya Siskind Mercedes Transfer 

51 Sovereign Siskind First Talavera 

Cash Out 

52 Sovereign Siskind Second Talavera Cash 

Out 

53 

Sovereign Zokaites Properties 

Transfer of Tatarow 

Mortgage to Defendant 

Zokaites Properties 

54 Sovereign Gibson Gibson Transfer 

55 Chance Siskind, Sovereign, First Santa Barbara 

Cash Out 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 39 of 59
40 

56 Chance Siskind, Siskind Legal, 

FLACC 

Second Santa Barbara 

Cash Out 

57 Chance Wellington 

Zokaites 

Santa Barbara 

Foreclosure Transfer 

58 

OB Real Estate 

Siskind, Siskind Legal, 

FLACC, Sovereign, 

Zokaites 

Office Suite Transfers 

59 OB Real Estate Zokaites & Siskind Office Suite Sale 

60 Chance Zokaites Properties Cross Creek Transfer 

61 Chance Siskind Siskind Cash Transfers 

62 Chance Tanya Siskind Tanya Siskind Cash 

Transfers 

63 Various Sympatico Sympatico Transfers 

136. At the time of each respective transfer identified in the table herein, the Debtor or 

the alter-ego identified in each Count set forth in the table were, and still are, indebted in an 

amount greater than each transfer. 

137. At the time of each respective transfer identified in the table herein, the Debtor or 

the alter-ego identified in each Count set forth in the table had incurred debts beyond their ability 

to pay as they became due. 

138. As set forth above, the Debtor or the alter-ego identified in each Count set forth in 

the table were otherwise insolvent at the time(s) of each respective transfer identified in the table 

herein. 

139. As a result of each respective transfer identified in the table herein, the Trustee 

has been damaged pursuant to 11 U.S.C. §544(b) for the total value of each respective transfer 

identified in the table herein. 

140. Each respective Defendant was the initial transferee or the entity for whose 

benefit each respective transfer as identified in the table above was made, and as a result, the 

Trustee is entitled to avoid and recover each respective transfer from each respective Defendant 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 40 of 59
41 

as identified in the table herein under 11 U.S.C. § 544 of the Bankruptcy Code and § 

726.105(1)(a) of the Florida Statutes as actual intent fraudulent transfers. 

141. Alternatively, each respective Defendant was the immediate or subsequent 

transferee of the initial transferee for whose benefit each transfer identified in the table herein 

was made, and as a result, the Trustee is entitled to recover each respective transfer, as 

referenced above, from each respective Defendant pursuant to § 726.105(1)(a) of the Florida 

Statutes and 11 U.S.C. §550(a)(2). 

142. Therefore, in accordance with 11 U.S.C. § 550(a), the recovery of property for the 

benefit of the Debtor’s bankruptcy estate is authorized to the extent that the respective transfers 

are avoided pursuant to § 726.105(1)(a) of the Florida Statutes. 

WHEREFORE, the Trustee respectfully requests entry of judgment against each 

Defendant identified in each respective Count above and (a) determining that each respective 

transfer that occurred within two (2) years of the Petition Date was fraudulent and avoidable 

pursuant to § 726.105(1)(a), Florida Statutes; (b) avoiding each respective transfer and entering 

judgment in favor of Plaintiff against each respective Defendant in such amounts as are 

determined at trial, or the value of thereof, and as otherwise detailed in the amounts set forth 

herein, plus pre-judgment interest from the date of the transfers and post-judgment interest, and 

costs of suit, all pursuant to 11 U.S.C. § 550; (c) disallowing any claim that each respective 

Defendant may have against the Debtor, including without limitation, pursuant to and as 

provided in 11 U.S.C. § 502(d); and (d) for such other and further relief as the Court deems just 

and proper. 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 41 of 59
42 

COUNTS 64-80 

AVOIDANCE AND RECOVERY OF FRAUDULENT TRANSFERS

PURSUANT TO SECTION 544 OF THE BANKRUPTCY CODE 

AND SECTION 726.105(1)(B) OF THE FLORIDA STATUTES 

The Trustee sues Defendants and alleges: 

143. The Trustee restates and realleges paragraphs 1 through 106 as if fully set forth 

herein. 

144. Pursuant to 11 U.S.C. § 544(b), the Trustee may avoid any transfer of an interest 

of the Debtor in property or any obligation incurred by the Debtor that is voidable under 

applicable law by a creditor holding an unsecured claim that is allowable under § 502 of this title 

or that is not allowable only under § 502(e) of this title. 

145. § 726.105(1)(b), Florida Statutes, provides: 

(1) A transfer made or obligation incurred by a debtor is fraudulent 

as to a creditor, whether the creditor’s claim arose before or after 

the transfer was made or the obligation was incurred, if the debtor 

made the transfer or incurred the obligation: 

 (b) Without receiving reasonably equivalent in value in 

 exchange for the transfer or obligation, and the debtor: 

 (1) Was engaged or was about to engage in a 

business or a transaction for which the remaining 

assets of the debtor were unreasonably small in 

relation to the business or transaction; or 

 (2) Intended to incur, or believed or reasonably 

should have believed that he or she would incur, 

debts beyond his or her ability to pay as they 

became due. 

146. Further, pursuant to 11 U.S.C. § 550, in a fraudulent transfer action commenced 

under Chapter 726 of the Florida Statutes, the Trustee may recover, for the benefit of the estate, 

the property transferred, or, if the Court so orders, the value of such property, from – (1) the 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 42 of 59
43 

initial transferee of such transfer or the entity for whose benefit such transfer was made; and (2) 

any immediate or mediate transferee of such initial transferee, i.e., any and all subsequent 

transferees. 

147. The transfers identified in the table herein to each respective Defendant were 

transfers made without the Debtor or the alter-ego(s) identified in each Count set forth in the 

table herein receiving reasonably equivalent value in exchange for each respective transfer 

pursuant to § 726.105(1)(b), Florida Statutes. 

Count Debtor / Alter-Ego 

Transferor 

Transferee / 

Defendant Property Transferred 

64 Sovereign Siskind, FLACC 

Siskind Legal Sovereign Cash Out 

65 Chance Siskind, Siskind Legal 

FLACC Stone Cash Out 

66 Chance Siskind, Siskind Legal, 

Sovereign, FLACC Volkwein Cash Out 

67 Chance Family Trust 

Tanya Siskind Mercedes Transfer 

68 Sovereign Siskind First Talavera 

Cash Out 

69 Sovereign Siskind Second Talavera Cash 

Out 

70 

Sovereign Zokaites Properties 

Transfer of Tatarow 

Mortgage to Defendant 

Zokaites Properties 

71 Sovereign Gibson Gibson Transfer 

72 Chance Siskind, Sovereign, First Santa Barbara 

Cash Out 

73 Chance Siskind, Siskind Legal, 

FLACC 

Second Santa Barbara 

Cash Out 

74 Chance Wellington 

Zokaites 

Santa Barbara 

Foreclosure Transfer 

75 

OB Real Estate 

Siskind, Siskind Legal, 

FLACC, Sovereign, 

Zokaites 

Office Suite Transfers 

76 OB Real Estate Zokaites & Siskind Office Suite Sale 

77 Chance Zokaites Properties Cross Creek Transfer 

78 Chance Siskind Siskind Cash Transfers 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 43 of 59
44 

79 Chance Tanya Siskind Tanya Siskind Cash 

Transfers 

80 Various Sympatico Sympatico Transfers 

148. At the time(s) of each respective transfer, the Debtor or the alter-ego identified in 

each Count set forth in the table herein were engaged or were about to engage in a business or a 

transaction for which the remaining assets of the Debtor or its respective alter-ego were 

unreasonably small in relation to the business or transactions in which the Debtor or its 

respective alter-ego were engaged. 

149. At the time of each respective transfer identified in the table herein, the Debtor or 

the alter-ego identified in each Count set forth in the table had incurred debts beyond their ability 

to pay as they became due. 

150. As set forth above, the Debtor or the alter-ego(s) identified in each Count set forth 

in the table were otherwise insolvent at the time(s) of each respective transfer identified in the 

table herein. 

151. As a result of each respective transfer identified in the table herein, the Trustee 

has been damaged pursuant to 11 U.S.C. § 544(b) for the total value of each respective transfer 

identified in the table herein. 

152. Each respective Defendant was the initial transferee or the entity for whose 

benefit each respective transfer as identified in the table above was made, and as a result, the 

Trustee is entitled to avoid and recover each respective transfer from each respective Defendant 

as identified in the table herein under 11 U.S.C. § 544 of the Bankruptcy Code and § 

726.105(1)(a) of the Florida Statutes as actual intent fraudulent transfers. 

153. Alternatively, each respective Defendant was the immediate or subsequent 

transferee of the initial transferee for whose benefit each transfer identified in the table herein 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 44 of 59
45 

was made, and as a result, the Trustee is entitled to recover each respective transfer as referenced 

above from each respective Defendant pursuant to § 726.105(1)(b) of the Florida Statutes and 11 

U.S.C. § 550(a)(2). 

154. Therefore, in accordance with 11 U.S.C. § 550(a), the recovery of property for the 

benefit of theestate is authorized to the extent that the respective transfers are avoided pursuant 

to 11 U.S.C. § 548(a)(1)(B). 

WHEREFORE, the Trustee respectfully requests entry of judgment against each 

Defendant identified in each respective Count above and (a) determining that each respective 

transfer that occurred within two (2) years of the Petition Date was fraudulent and avoidable 

under § 726.105(1)(B), Florida Statutes; (b) avoiding each respective transfer and entering 

judgment in favor of Plaintiff against each respective Defendant in such amounts as are 

determined at trial, or the value of thereof, and as otherwise detailed in the amounts set forth 

herein, plus pre-judgment interest from the date of the transfers and post-judgment interest, and 

costs of suit, all pursuant to 11 U.S.C. § 550; (c) disallowing any claim that each respective 

Defendant may have against the Debtor, including without limitation, pursuant to and as 

provided in 11 U.S.C. § 502(d); and (d) for such other and further relief as the Court deems just 

and proper. 

COUNTS 81-97 

AVOIDANCE AND RECOVERY OF FRAUDULENT TRANSFERS 

PURSUANT TO SECTION 544 OF THE BANKRUPTCY CODE 

AND SECTION 726.106(1) OF THE FLORIDA STATUTES 

The Trustee sues Defendants and alleges: 

155. The Trustee restates and realleges paragraphs 1 through 106 as if fully set forth 

herein. 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 45 of 59
46 

156. Pursuant to 11 U.S.C. § 544(b), the Trustee may avoid any transfer of an interest 

of the Debtor in property or any obligation incurred by the Debtor that is voidable under 

applicable law by a creditor holding an unsecured claim that is allowable under § 502 of Title 11 

or that is not allowable only under § 502(e) of this title. 

157. § 726.106(1), Florida Statutes, provides: 

A transfer made or obligation incurred by a debtor is fraudulent as to a creditor 

whose claim arose before the transfer was made or the obligation was incurred if 

the debtor made the transfer or incurred the obligation without receiving a 

reasonably equivalent value in exchange for the transfer or obligation and the 

debtor was insolvent at that time or the debtor became insolvent as a result of 

the transfer or obligation. 

158. The transfers identified in the table herein to each respective Defendant were 

transfers made without the Debtor or the alter-ego(s) identified in each Count set forth in the 

table herein receiving reasonably equivalent value in exchange for each respective transfer 

pursuant to § 726.106(1), Florida Statutes. 

Count Debtor / Alter-Ego 

Transferor 

Transferee / 

Defendant Property Transferred 

81 Sovereign Siskind, FLACC 

Siskind Legal Sovereign Cash Out 

82 Chance Siskind, Siskind Legal 

FLACC Stone Cash Out 

83 Chance Siskind, Siskind Legal, 

Sovereign, FLACC Volkwein Cash Out 

84 Chance Family Trust 

Tanya Siskind Mercedes Transfer 

85 Sovereign Siskind First Talavera 

Cash Out 

86 Sovereign Siskind Second Talavera Cash 

Out 

87 

Sovereign Zokaites Properties 

Transfer of Tatarow 

Mortgage to Defendant 

Zokaites Properties 

88 Sovereign Gibson Gibson Transfer 

89 

Chance Siskind, Sovereign, 

First Santa Barbara 

Cash Out 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 46 of 59
47 

90 Chance Siskind, Siskind Legal, 

FLACC 

Second Santa Barbara 

Cash Out 

91 Chance Wellington 

Zokaites 

Santa Barbara 

Foreclosure Transfer 

92 

OB Real Estate 

Siskind, Siskind Legal, 

FLACC, Sovereign, 

Zokaites 

Office Suite Transfers 

93 OB Real Estate Zokaites & Siskind Office Suite Sale 

94 Chance Zokaites Properties Cross Creek Transfer 

95 Chance Siskind Siskind Cash Transfers 

96 Chance Tanya Siskind Tanya Siskind Cash 

Transfers 

97 Various Sympatico Sympatico Transfers 

159. At the time(s) of each respective transfer, the Debtor or the alter-ego(s) identified 

in each Count set forth in the table herein were engaged or were about to engage in a business or 

a transaction for which the remaining assets of the Debtor or its respective alter-ego(s) were 

unreasonably small in relation to the business or transactions in which the Debtor or its 

respective alter-ego(s) were engaged. 

160. At the time of each respective transfer identified in the table herein, the Debtor or 

the alter-ego(s) identified in each Count set forth in the table had incurred debts beyond their 

ability to pay as they became due. 

161. As set forth above, the Debtor or the alter-ego(s) identified in each Count set forth 

in the table were otherwise insolvent at the time(s) of each respective transfer identified in the 

table herein. 

162. As a result of each respective transfer identified in the table herein, the Trustee 

has been damaged pursuant to 11 U.S.C. § 544(b) for the total value of each respective transfer 

identified in the table herein. 

163. Each respective Defendant was the initial transferee or the entity for whose 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 47 of 59
48 

benefit each respective transfer as identified in the table above was made, and as a result, the 

Trustee is entitled to avoid and recover each respective transfer from each respective Defendant 

as identified in the table herein pursuant to 11 U.S.C. § 544 of the Bankruptcy Code and § 

726.106(1) of the Florida Statutes as actual intent fraudulent transfers. 

164. Alternatively, each respective Defendant was the immediate or subsequent 

transferee of the initial transferee for whose benefit each transfer identified in the table herein 

was made, and as a result, the Trustee is entitled to recover these each respective transfer as 

referenced above from each respective Defendant pursuant to § 726.106(1) of the Florida 

Statutes and 11 U.S.C. § 550(a)(2). 

165. Therefore, in accordance with 11 U.S.C. §§544 and 548, the recovery of property 

for the benefit of the estate is authorized to the extent that the respective transfers are avoided 

under 11 U.S.C. § 548. 

WHEREFORE, the Trustee respectfully requests entry of judgment against each 

Defendant identified in each respective Count above and (a) determining that each respective 

transfer that occurred within two (2) years of the Petition Date was fraudulent and avoidable 

under § 726.106(1), Florida Statutes; (b) avoiding each respective transfer and entering judgment 

in favor of Plaintiff against each respective Defendant in such amounts as are determined at trial, 

or the value of thereof, and as otherwise detailed in the amounts set forth herein, plus prejudgment interest from the date of the transfers and post-judgment interest, and costs of suit, all 

pursuant to 11 U.S.C. § 550; (c) disallowing any claim that each respective Defendant may have 

against the Debtor, including without limitation, pursuant to and as provided in 11 U.S.C. § 

502(d); and (d) for such other and further relief as the Court deems just and proper. 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 48 of 59
49 

COUNTS 98-114 

ACTION FOR CONSTRUCTIVE TRUST 

The Trustee sues Defendants and alleges: 

166. The Trustee restates and realleges paragraphs 1 through 106 as if fully set forth 

herein. 

167. The Trustee is the legal title holder to all property of the Debtor and its alter-egos. 

168. The following transfers were fraudulently effected by the Debtor or its alterego(s) or alternatively, without fraud but retained by the transferees set forth below under 

inequitable circumstances. 

Count Debtor / Alter-Ego 

Transferor 

Transferee / 

Defendant Property Transferred 

98 Sovereign Siskind, FLACC 

Siskind Legal Sovereign Cash Out 

99 Chance Siskind, Siskind Legal 

FLACC Stone Cash Out 

100 Chance Siskind, Siskind Legal, 

Sovereign, FLACC Volkwein Cash Out 

101 Chance Family Trust 

Tanya Siskind Mercedes Transfer 

102 Sovereign Siskind First Talavera 

Cash Out 

103 Sovereign Siskind Second Talavera Cash 

Out 

104 

Sovereign Zokaites Properties 

Transfer of Tatarow 

Mortgage to Defendant 

Zokaites Properties 

105 Sovereign Gibson Gibson Transfer 

106 Chance Siskind, Sovereign, First Santa Barbara 

Cash Out 

107 Chance Siskind, Siskind Legal, 

FLACC 

Second Santa Barbara 

Cash Out 

108 Chance Wellington 

Zokaites 

Santa Barbara 

Foreclosure Transfer 

109 

OB Real Estate 

Siskind, Siskind Legal, 

FLACC, Sovereign, 

Zokaites 

Office Suite Transfers 

110 OB Real Estate Zokaites & Siskind Office Suite Sale 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 49 of 59
50 

Count Debtor / Alter-Ego 

Transferor 

Transferee / 

Defendant Property Transferred 

111 Chance Zokaites Properties Cross Creek Transfer 

112 Chance Siskind Siskind Cash Transfers 

113 Chance Tanya Siskind Tanya Siskind Cash 

Transfers 

114 Various Sympatico Sympatico Transfers 

169. As the beneficiary of the transfers set forth herein, each Defendant knew or 

should have known that transfers at issue in each Count set forth herein were improper. 

170. The recipients of each transfer set forth herein have been unjustly enriched to the 

detriment of the Debtor and its alter egos, and as a result, a constructive trust should be 

established against the transfers at issue and all proceeds, products and replacements of each of 

the subject transfers. 

WHEREFORE, the Trustee respectfully requests this Court to enter a judgment against e 

each respective Defendant, for imposition of a constructive trust lien to be established against the 

transfers identified herein and all proceeds, products or replacements of the transfers set forth 

herein, for damages and all such other relief as this court deems just and appropriate. 

COUNT 115-131 

ACTION FOR EQUITABLE LIEN 

The Trustee sues Defendants and alleges: 

171. The Trustee restates and realleges paragraphs 1 through 106 as if fully set forth 

herein. 

172. The Trustee is the legal title holder to all property of the Debtor and its alter-egos. 

173. The following transfers were fraudulently effected by the Debtor or its alter-egos 

or egregiously, or alternatively, without fraud but retained by the transferees set forth below 

under inequitable circumstances. 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 50 of 59
51 

Count Debtor / Alter-Ego 

Transferor 

Transferee / 

Defendant Property Transferred 

115 Sovereign Siskind, FLACC 

Siskind Legal Sovereign Cash Out 

116 Chance Siskind, Siskind Legal 

FLACC Stone Cash Out 

117 Chance Siskind, Siskind Legal, 

Sovereign, FLACC Volkwein Cash Out 

118 Chance Family Trust 

Tanya Siskind Mercedes Transfer 

119 Sovereign Siskind First Talavera 

Cash Out 

120 Sovereign Siskind Second Talavera Cash 

Out 

121 

Sovereign Zokaites Properties 

Transfer of Tatarow 

Mortgage to Defendant 

Zokaites Properties 

122 Sovereign Gibson Gibson Transfer 

123 Chance Siskind, Sovereign, First Santa Barbara 

Cash Out 

124 Chance Siskind, Siskind Legal, 

FLACC 

Second Santa Barbara 

Cash Out 

125 Chance Wellington 

Zokaites 

Santa Barbara 

Foreclosure Transfer 

126 

OB Real Estate 

Siskind, Siskind Legal, 

FLACC, Sovereign, 

Zokaites 

Office Suite Transfers 

127 OB Real Estate Zokaites & Siskind Office Suite Sale 

128 Chance Zokaites Properties Cross Creek Transfer 

129 Chance Siskind Siskind Cash Transfers 

130 Chance Tanya Siskind Tanya Siskind Cash 

Transfers 

131 Various Sympatico Sympatico Transfers 

174. As the beneficiary of the transfers set forth herein, each Defendant knew or 

should have known that transfers at issue in each Count set forth herein were improper. 

175. The recipients of each transfer set forth herein have been unjustly enriched to the 

detriment of the Debtor and its alter egos, and as a result, a constructive trust should be 

established against the transfers at issue and all proceeds, products and replacements of each of 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 51 of 59
52 

the subject transfers. 

WHEREFORE, the Trustee respectfully requests this Court to enter a judgment against 

each respective Defendant, for imposition of an equitable lien to be established against all realty 

and personalty directly traceable from the transfers at issue herein and all proceeds of the their 

products, proceeds or replacements, for damages and all such other relief as this Court deems 

just and appropriate. 

COUNTS 132-138 

ACTION SEEKING APPOINTMENT OF 

A MONITOR FOR THE DEBTOR’S ALTER-EGOS 

 The Trustee sues each defendant as set forth herein and alleges: 

176. The Trustee re-states and re-alleges paragraphs 1 through 106, as if fully set forth 

herein. 

177. This is an action requesting the appointment of a monitor over the Debtor’s alteregos pursuant to Section 105 of the Bankruptcy Code. 

COUNT DEFENDANT RELATED TRANSACTION 

132 CannaMed Liabilities of the Debtor (¶¶21-24) 

133 OB Real Estate Office Suite Transfers 

134 Sovereign Talavera Transfers 

Office Suite Transfers 

135 Siskind Legal 

Sovereign Cash Out 

Stone Cash Out 

Volkwein Cash Out 

Talavera Transfers 

Santa Barbara Transfers 

Office Suite Transfers 

136 Wellington Santa Barbara Transfers 

137 FLACC Sovereign Cash Out, Stone Cash Out, 

Volkwein Cash Out 

138 Sympatico Sympatico Transfers 

178. Given the nature of the related transactions at issue and the facts and 

circumstances surrounding such transfers as alleged above, it is necessary and appropriate for a 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 52 of 59
53 

monitor to be appointed for each respective alter-ego entity. 

 WHEREFORE, the Trustee respectfully requests entry of an order and/or judgment 

against the alter-ego Defendants as set forth in each Count hereinabove: (i) appointing a monitor 

for each; and (ii) for any other relief the Court deems appropriate. 

COUNT 139 

ACTION SEEKING A PERMANENT 

INJUNCTION AGAINST ALL DEFENDANTS 

The Trustee sues all Defendants and alleges: 

179. The Trustee realleges Counts 1-138 above. 

180. This is an action requesting the entry of a permanent injunction against 

Defendants and others pursuant to Fed. R. Civ. P. 65 as incorporated by Fed. R. Bankr. P. 7065. 

181. Given the nature of the transfers and transactions at issue in this Complaint and 

the facts and circumstances surrounding such transfers as alleged above, it is necessary and 

appropriate for a permanent injunction to be issued against the Defendants, and all others in 

custody, possession or control of funds or other property that is the subject of the transfers and 

transactions at issue in this complaint, in order to fully protect the interests of the estate in regard 

to recovering such transfers. 

 WHEREFORE, the Trustee demands the entry of an order and/or judgment against 

Defendants (i) imposing a permanent injunction against each Defendant, and all others in 

custody, possession or control of funds or other property that are the subject of the transfers at 

issue in this Complaint; and (ii) for any other relief the Court deems appropriate. 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 53 of 59
54 

G. Reservation of Rights 

182. The Trustee reserves his right to amend this Complaint, upon completion of his 

investigation and discovery, to assert any additional claims for relief against the Defendants as 

may be warranted under the circumstances allowed by law. 

Respectfully submitted this 6th day of August, 2019. 

GENOVESE JOBLOVE & BATTISTA, P.A. 

 Counsel to the Chapter 7 Trustee 

100 S.E. 2nd Street, Suite 4400 

Miami, FL 33131 

Tel.: (305) 349-2300 

Fax.: (305) 349-2310 

 By: /s/ Jesus M. Suarez 

 John H. Genovese, Esq. 

 Florida Bar No. 280852 

 jgenovese@gjb-law.com 

 Jesus M. Suarez, Esq. 

 Fla. Bar No. 60086 

 jsuarez@gjb-law.com 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 54 of 59
55 

EXHIBIT “A” 

(Siskind Cash Transfers) 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 55 of 59
Detail

Chance & Anthem, LLC

Detailed of Disbursements - Cash & Withdrawals

Bank Entity Type Date Received From/ Payee

Disbursement/ 

Debit

Chase 1866 Chance & Anthem ATM Withdrawal 10/13/15 Cash 500.00 

Chase 1866 Chance & Anthem ATM Withdrawal 10/30/15 Cash 500.00 

SunTrust 6688 Chance & Anthem Withdrawal 11/09/15 Cash 2,500.00

SunTrust 6688 Chance & Anthem Withdrawal 11/13/15 Cash 5,000.00

SunTrust 6688 Chance & Anthem Withdrawal 11/23/15 Cash 5,000.00

Chase 1866 Chance & Anthem ATM Withdrawal 11/25/15 Cash 500.00 

SunTrust 6688 Chance & Anthem Withdrawal 11/27/15 Cash 40,000.00

SunTrust 6688 Chance & Anthem Withdrawal 12/02/15 Cash 2,000.00

SunTrust 6688 Chance & Anthem Withdrawal 12/02/15 Cash 5,000.00

SunTrust 6688 Chance & Anthem Withdrawal 12/07/15 Cash 1,000.00

Chase 1866 Chance & Anthem ATM Withdrawal 12/11/15 Cash 100.00 

SunTrust 6688 Chance & Anthem Withdrawal 12/11/15 Cash 5,000.00

SunTrust 6688 Chance & Anthem Withdrawal 12/14/15 Cash 2,000.00

SunTrust 6688 Chance & Anthem Withdrawal 12/16/15 Cash 5,000.00

SunTrust 6688 Chance & Anthem Withdrawal 12/21/15 Cash 2,000.00

SunTrust 6688 Chance & Anthem Withdrawal 12/31/15 Cash 5,000.00

SunTrust 6688 Chance & Anthem Withdrawal 01/04/16 Cash 2,500.00 

SunTrust 6688 Chance & Anthem Withdrawal 01/19/16 Cash 2,000.00

Chase 1866 Chance & Anthem ATM Withdrawal 03/07/16 Cash 300.00 

Chase 1866 Chance & Anthem ATM Withdrawal 03/22/16 Cash 2,500.00 

Chase 1866 Chance & Anthem ATM Withdrawal 03/23/16 Cash 63.50 

Chase 1866 Chance & Anthem ATM Withdrawal 03/24/16 Cash 200.00 

Chase 1866 Chance & Anthem Withdrawal 03/25/16 Other Withdrawal 2,00 0.00

Chase 1866 Chance & Anthem Withdrawal 04/04/16 Other Withdrawal 500. 00

Chase 1866 Chance & Anthem ATM Withdrawal 04/21/16 Cash 20.00 

SunTrust 6688 Chance & Anthem Withdrawal 04/22/16 Cash 1,100.00

Chase 1866 Chance & Anthem Withdrawal 06/01/16 Other Withdrawal 200. 00

Chase 1866 Chance & Anthem Withdrawal 06/15/16 Other Withdrawal 750. 00

Chase 1866 Chance & Anthem Withdrawal 06/24/16 Other Withdrawal 750. 00

Chase 1866 Chance & Anthem ATM Withdrawal 07/08/16 Cash 20.00 

Chase 1866 Chance & Anthem Withdrawal 07/29/16 Other Withdrawal 600. 00

Chase 1866 Chance & Anthem Withdrawal 08/08/16 Other Withdrawal 300. 00

Chase 1866 Chance & Anthem Withdrawal 08/26/16 Other Withdrawal 3,30 0.00

SunTrust 6688 Chance & Anthem Withdrawal 08/26/16 Cash 900.00

SunTrust 6688 Chance & Anthem Withdrawal 08/30/16 Cash 300.00

Chase 1866 Chance & Anthem Withdrawal 09/02/16 Other Withdrawal 40.0 0

Chase 1866 Chance & Anthem Withdrawal 09/06/16 Other Withdrawal 3,26 5.00

Chase 1866 Chance & Anthem Withdrawal 09/06/16 Other Withdrawal 500. 00

Chase 1866 Chance & Anthem Withdrawal 09/09/16 Other Withdrawal 300. 00

Chase 1866 Chance & Anthem Withdrawal 09/09/16 Other Withdrawal 4,00 0.00

Chase 1866 Chance & Anthem Withdrawal 09/12/16 Other Withdrawal 40.0 0

Chase 1866 Chance & Anthem Withdrawal 09/14/16 Other Withdrawal 250. 00

Chase 1866 Chance & Anthem ATM Withdrawal 09/16/16 Cash 200.00 

Chase 1866 Chance & Anthem ATM Withdrawal 10/21/16 Cash 400.00 

Chase 1866 Chance & Anthem ATM Withdrawal 10/24/16 Cash 500.00 

Chase 1866 Chance & Anthem Withdrawal 11/01/16 Other Withdrawal 200. 00

Chase 1866 Chance & Anthem ATM Withdrawal 11/28/16 Cash 50.00 

Chase 1866 Chance & Anthem ATM Withdrawal 01/27/17 Cash 20.00 

Chase 1866 Chance & Anthem ATM Withdrawal 01/30/17 Cash 100.00 

Chase 1866 Chance & Anthem ATM Withdrawal 02/27/17 Cash 100.00 

Chase 1866 Chance & Anthem Withdrawal 03/07/17 Other Withdrawal 75.0 0

GlassRatner Advisory & Capital Group, LLC Page 1 of 2

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 56 of 59
Detail

Bank Entity Type Date Received From/ Payee

Disbursement/ 

Debit

Chase 1866 Chance & Anthem ATM Withdrawal 03/30/17 Cash 40.00 

Chase 1866 Chance & Anthem ATM Withdrawal 05/01/17 Cash 200.00 

Chase 1866 Chance & Anthem ATM Withdrawal 05/04/17 Cash 60.00 

Chase 1866 Chance & Anthem Withdrawal 05/15/17 Other Withdrawal 20.0 0

Chase 1866 Chance & Anthem ATM Withdrawal 05/24/17 Cash 180.00 

Chase 1866 Chance & Anthem ATM Withdrawal 06/19/17 Cash 100.00 

Chase 1866 Chance & Anthem ATM Withdrawal 07/26/17 Cash 100.00 

Chase 1866 Chance & Anthem ATM Withdrawal 07/28/17 Cash 20.00 

Chase 1866 Chance & Anthem ATM Withdrawal 08/04/17 Cash 500.00 

Chase 1866 Chance & Anthem Withdrawal 10/03/17 Other Withdrawal 80.0 0

Chase 1866 Chance & Anthem ATM Withdrawal 10/04/17 Cash 100.00 

Chase 1866 Chance & Anthem Withdrawal 10/05/17 Other Withdrawal 400. 00

Chase 1866 Chance & Anthem Card Purchase 10/10/17 Walmart 102.68 

Chase 1866 Chance & Anthem Card Purchase 10/10/17 Walmart 112.05 

Chase 1866 Chance & Anthem Card Purchase 10/10/17 Walmart 102.98 

Chase 1866 Chance & Anthem Card Purchase 10/10/17 Walmart 103.57 

Chase 1866 Chance & Anthem Card Purchase 10/10/17 Walmart 107.46 

Chase 1866 Chance & Anthem Card Purchase 10/10/17 Walmart 103.74 

Chase 1866 Chance & Anthem Card Purchase 10/11/17 Walmart 101.80 

Chase 1866 Chance & Anthem Withdrawal 11/30/17 Other Withdrawal 50.0 0

Chase 1866 Chance & Anthem Card Purchase 12/05/17 Walmart 110.57 

Chase 1866 Chance & Anthem ATM Withdrawal 12/05/17 Cash 500.00 

Chase 1866 Chance & Anthem ATM Withdrawal 12/14/17 Cash 500.00 

Chase 1866 Chance & Anthem ATM Withdrawal 12/15/17 Cash 500.00 

Chase 1866 Chance & Anthem Withdrawal 12/16/17 Other Withdrawal 250. 00

Chase 1866 Chance & Anthem Card Purchase 12/18/17 Walmart 100.98 

Chase 1866 Chance & Anthem Card Purchase 12/18/17 Walmart 104.97 

Chase 1866 Chance & Anthem Withdrawal 12/23/17 Other Withdrawal 300. 00

Chase 1866 Chance & Anthem Card Purchase 01/02/18 Walmart 141.77 

Chase 1866 Chance & Anthem ATM Withdrawal 01/02/18 Cash 200.00 

Chase 1866 Chance & Anthem ATM Withdrawal 01/02/18 Cash 300.00 

Chase 1866 Chance & Anthem ATM Withdrawal 01/04/18 Cash 200.00 

Chase 1866 Chance & Anthem Card Purchase 01/16/18 Walmart 135.94 

Chase 1866 Chance & Anthem Card Purchase 01/16/18 Walmart 115.40 

Chase 1866 Chance & Anthem ATM Withdrawal 01/16/18 Cash 220.00 

Chase 1866 Chance & Anthem ATM Withdrawal 01/22/18 Cash 100.00 

Chase 1866 Chance & Anthem ATM Withdrawal 01/22/18 Cash 200.00 

Chase 1866 Chance & Anthem Card Purchase 02/26/18 Walmart 101.05 

Chase 1866 Chance & Anthem Withdrawal 03/06/18 Other Withdrawal 20.0 0

Chase 1866 Chance & Anthem Withdrawal 03/14/18 Other Withdrawal 200. 00

Chase 1866 Chance & Anthem Withdrawal 03/22/18 Other Withdrawal 2,00 0.00

Chase 1866 Chance & Anthem Card Purchase 03/27/18 Walmart 140.97 

Chase 1866 Chance & Anthem ATM Withdrawal 05/12/16 Cash 500.00 

Chase 1866 Chance & Anthem ATM Withdrawal 05/13/16 Cash 600.00 

Chase 1866 Chance & Anthem Withdrawal 05/31/16 Other Withdrawal 200. 00

Cash & Withdrawal Total 119,769.43 $ 

GlassRatner Advisory & Capital Group, LLC Page 2 of 2

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 57 of 59
56 

EXHIBIT “B” 

(Tanya Siskind Cash Transfers)

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 58 of 59
Chance & Anthem, LLC

Summary of Transfers to Tanya Siskind

Source: Bank Statements, deposit detail and canceled checks

Bank Entity Type Date Check No. Received From/ Payee

 D

Chase 1866 Chance & Anthem Check 03/01/16 1127 Tanya Siskind Chase 1866 Chance & Anthem Check 04/04/16 1151 Tanya Siskind Chase 1866 Chance & Anthem Check 06/29/16 1210 Tanya Siskind Chase 1866 Chance & Anthem Check 11/01/16 1315 Tanya L. Siskind 

Chase 1866 Chance & Anthem Check 03/29/18 1361 Tanya Siskind 

TOTAL 

$ 

GlassRatner Advisory & Capital Group, LLC 

Case 19-01298-MAM Doc 1 Filed 08/06/19 Page 59 of 59