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1 UNITED STATES BANKRUPTCY COURT

 SOUTHERN DISTRICT OF FLORIDA

2 WEST PALM BEACH DIVISION

3

4 Case No. 18-16248-MAM

5

6 In re:

7 CHANCE & ANTHEM, LLC,

8 Debtor.

_________________________/

9

10

11

12

13

14 FURR COHEN, P.A.

 2255 Glades Road, Suite 301-E

15 Boca Raton, Florida 33431

 Wednesday, December 19, 2019

16 10:30 a.m. to 2:55 p.m.

17

18 CONTINUED 2004 EXAMINATION

19 OF

20 JEFFREY M SISKIND

21 taken pursuant to notice

 on behalf of Robert C. Furr,

22 Chapter 7 Trustee.

23

 - - - - -

24

25

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1 APPEARANCES:

2

 GENOVESE JOBLOVE & BATTISTA, P.A., by

3 JESUS M. SUAREZ, ESQUIRE

 on behalf of Robert C. Furr, Chapter 7 Trustee.

4

5 JEFFREY M. SISKIND, ESQUIRE, PRO SE

6

 ALSO PRESENT:

7

 ROBERT C. FURR, Chapter 7 Trustee

8 ALAN BARBEE, CPA

9 - - - - - -

10 I N D E X

11

WITNESS DIRECT CROSS

12 JEFFREY M SISKIND

 By Mr. Suarez 4 --

13

14 EXHIBITS MARKED FOR IDENTIFICATION

15 NUMBER PAGE

16 1, Renewed Notice of Rule 2004 Exam 7

 2, CannaMED operating agreement 24

17 3, E-mail dated 2/24/16, executive summary 30

 4, E-mail dated 2/4/16 and attachments 37

18 5, E-mail dated 3/21/16 and attachments 80

 6, E-mail dated 8/2/16 and attachments 84

19 7, E-mail dated 6/9/16 and attachments 87

 8, E-mail and attachment 89

20 9, E-mail dated 10/29/15 and attachments 93

 10, E-mail dated 12/21/15 and business plan 95

21 11, E-mail dated 12/29/15 and business plan 98

 12, Chase Withdrawal dated 9/18/18 99

22 13, SunTrust Withdrawal Ticket dated 11/13/15 101

 14, SunTrust Withdrawal Ticket dated 11/23/15 105

23 15, SunTrust Withdrawal Ticket dated 4/27/15 105

 16, SunTrust Withdrawal Ticket undated 109

24 16, Voluntary petition for bankruptcy 110

25 Continued...

 EXHIBITS MARKED FOR IDENTIFICATION

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1

 NUMBER PAGE

2

 17, Bankruptcy schedules dated 2/12/18 111

3 17-A, SunTrust Withdrawal Ticket dated 12/11/15 114

17-B, SunTrust Withdrawal Ticket dated 12/16/15 115

4 18, Bankruptcy schedules dated 4/24/18 111

 18, SunTrust Withdrawal Ticket dated 12/31/15 115

5 19, Chase Deposit dated 7/18/16 116

 20, Chase Deposit dated 7/19/16 117

6 21, Chase Deposit dated 9/9/16 119

 22, Chance & Anthem Check No. 1026 121

7 22, Chance & Anthem Check No. 1027 123

 23, Chance & Anthem Check No. 1012 123

8 24, Chance & Anthem Check No. 1014 124

 25, Chance & Anthem Check No. 1015 125

9 25, SunTrust statement dated 11/30/15 126

 26, Chance & Anthem Check No. 1030 127

10 27, SunTrust statement dated 11/30/15 128

 28, Chance & Anthem Check No. 1037 128

11 29, Chance & Anthem Check No. 1041 129

 30, Reef Gallery Check No. 7288 130

12 31, Chance & Anthem Check No. 1038 131

 32, Affidavit of Carl Stone 133

13 33, SunTrust Withdrawal Ticket dated 4/10/15 136

 34, SunTrust Withdrawal Ticket dated 12/23/14 137

14 35, SunTrust Withdrawal Ticket dated 4/24/15 138

 36, Chance & Anthem Check No. 1316 138

15 37, SunTrust Deposit Ticket dated 11/7/14 139

 38, SunTrust statement dated 12/31/14 141

16 39, SunTrust Deposit Ticket dated 2/5/15 141

 40, SunTrust Deposit Ticket and Check No. 3903 141

17 41, Chase Deposit and Check No. 2855 142

 42, Chance & Anthem Check No. 1003 143

18 43, Chance & Anthem Check No. 1210 & 315 144

 44, Chance & Anthem Check No. 1308 145

19 45, Chase statement dated 10/30/15 146

 46, Chance & Anthem Check No. 1017 & 1018 147

20 47, Chase statement dated 3/31/16 149

21

22

23

24

25

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1 Thereupon:

2 JEFFREY M SISKIND,

3 after first being duly sworn, was examined and

4 testified under oath as follows:

5 MR. SUAREZ: Let me have the exhibit

6 stickers, please.

7 THE WITNESS: Here's your change, a dollar8 thirty-seven.

9 MR. SUAREZ: Thank you. From the Florida

10 Association of Community Banks and Credit Unions,

11 Incorporated.

12 THE WITNESS: That just happened to be an

13 envelope that I had leftover.

14 DIRECT EXAMINATION

15 BY MR. SUAREZ:

16 Q What's your position with the Florida

17 Association of Community Banks and Credit Unions?

18 A I don't remember whether that was an LLC or a

19 corporation. If my memory serves me correctly, it was

20 an LLC, in which case I was probably the managing

21 member.

22 Q Were there any other members?

23 A I don't remember.

24 Q Did anybody else work for the Florida

25 Association of Community Banks and Credit Unions,

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1 Incorporated?

2 A No one got paid, if that's what you mean. It

3 was an association, so I -- at various times I do

4 believe I had people doing work for that entity, but I

5 don't remember what they did.

6 Q What was the Florida Association of Community

7 Banks and Credit Unions?

8 A It was an association to serve community

9 banks and credit unions.

10 Q Was there ever a community bank or credit

11 union associated with the entity?

12 A I don't know what you mean by "associated."

13 Q Did a community bank or credit union ever pay

14 dues to --

15 A No, no, there were no dues.

16 Q Did a community bank or credit union ever

17 become a member of the Florida Association of

18 Community Banks and Credit Unions?

19 A I don't know what that has to do with today's

20 2004 Examination.

21 Q You can either answer the question or you can

22 decline to answer the question.

23 A I'm going to decline to answer that question,

24 because it's outside the scope of today's 2004

25 deposition.

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1 Q Well, you just handed me money in an envelope

2 from the Florida Association of Community Banks and

3 Credit Unions, Incorporated. I would like to know

4 what that entity is, and why it's --

5 A That entity has lapsed, but it is an envelope

6 that I just happened to have in my stack of unused

7 envelopes, so I figured since it wasn't going in the

8 mail, why not used it to put your dollar and 37 cents

9 in.

10 Q Is any other individual, other than yourself,

11 associated with the Florida Association of Community

12 Banks and Credit Unions, Incorporated?

13 A Now, no. But remember, this is outside the

14 scope of this 2004 Examination.

15 Q Has any bank ever been associated with the

16 Florida Association of Community Banks and Credit

17 Unions?

18 A I don't know what you mean by "associated."

19 But, again, these questions are outside the scope.

20 Florida Association of Community Banks and Credit

21 Unions has not been noticed.

22 Q Did it ever have any legitimate business

23 operations?

24 A Outside the scope. But, yes, the answer to

25 that is, yes, of course.

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1 Q What was its legitimate business operations?

2 A Outside the scope. I know where you're going

3 with this, and I'm not going to fall into this trap.

4 You are outside the scope of this 2004 Examination.

5 (Thereupon, a document was marked as Exhibit

6 No. 1 for identification by Mr. Suarez.)

7 BY MR. SUAREZ:

8 Q All right. I've marked as Exhibit 1 --

9 A Next time I'm going to be a lot more careful

10 with what envelope I use to deliver money to you.

11 Q I've marked as Exhibit 1 today's notice of

12 examination.

13 A Yes.

14 Q You are Jeffrey Siskind?

15 A I indeed am Jeffrey Siskind.

16 Q Have you ever gone by any other name?

17 A No. Well, Jeffrey Mark Siskind, Jeffrey M.

18 Siskind, Jeff Siskind, a few nicknames in different

19 circles that I care not to repeat sometimes.

20 Q All right. And you're here today

21 individually and as the managing member of CannaMED

22 Pharmaceuticals, LLC?

23 A I am, and I didn't want to trouble you with a

24 motion, but I really don't understand why I'm here

25 individually, because I think the Judge's order said

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1 that I appear as the managing member of CannaMED.

2 Q Well, you're here individually and CannaMED,

3 aren't you?

4 A Right, because I don't want to come back

5 again. I like seeing you, but not that much.

6 Q If you could please turn to Page 8, there are

7 a list of documents that were to be produced in

8 advance of today's examination.

9 A Right.

10 Q The first is "Any and all communications

11 between the Debtor and CannaMED Pharmaceuticals, LLC."

12 A Right.

13 Q What, if anything, did you do to ascertain

14 whether responsive documents existed?

15 A I don't remember. Didn't I respond to that?

16 I thought I filed something. I think I filed

17 something.

18 Q Was anyone other than yourself involved in

19 preparing for the examination of CannaMED

20 Pharmaceuticals, LLC?

21 A No.

22 Q What is your position with CannaMED

23 Pharmaceuticals, LLC?

24 A Well, that has lapsed, but I was the managing

25 member.

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1 Q What do you mean by, it has "lapsed"?

2 A It was a Maryland limited liability company

3 which lapsed.

4 Q What do you mean by "lapsed"?

5 A It's not registered to do business any more.

6 Q Why is it no longer registered to do

7 business?

8 A Because it lapsed.

9 Q Who allowed it to lapse?

10 A I did.

11 Q How did you make the decision to lapse

12 CannaMED Pharmaceuticals, LLC?

13 A I looked in my checking account and didn't

14 have the money to pay to renew it, so I let it lapse.

15 Q Was there a resolution of the members of

16 CannaMED Pharmaceuticals, LLC permitting it to lapsed?

17 A No.

18 Q Were the members of CannaMED Pharmaceuticals,

19 LLC ever advised that you would allow its registration

20 to lapse?

21 A Not that I recall.

22 Q So going back to my initial question --

23 A But you can always renew it if you want to.

24 Do you want to pay for it? Be my guest.

25 Q Going back to my initial question.

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1 What, if anything, did you ascertain -- did

2 you do to ascertain whether any communications existed

3 between the debtor and CannaMED Pharmaceuticals, LLC?

4 A I know that there were none. There were no

5 communications between the debtor and CannaMED.

6 Q And how is it that you know that?

7 A That's an interesting question. I know it

8 because I know it. I just know it. There are no

9 communications.

10 Q Is that because you were the sole control

11 person of the debtor and the sole control person of

12 CannaMED Pharmaceuticals, LLC?

13 A That may be the case, yes.

14 Q Any other reason why?

15 A No.

16 Q All right. What, if anything, did you do to

17 ascertain what books and records of CannaMED

18 Pharmaceuticals, LLC exist?

19 A I know there were no books and records of

20 CannaMED. There was no business conducted by

21 CannaMED. So there was no book or record.

22 Q Category No. 3 in front of you.

23 What, if anything, did you do to ascertain

24 whether there were any documents responsive to

25 Category No. 3?

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1 A I know that I don't have any of those files,

2 because as I've told you before, they were taken.

3 Q I'm sorry, can you remind me -- Category No.

4 3 calls for, "Any and all documents, including but not

5 limited to, bank statements, escrow accounts,

6 operating accounts, checking accounts, cancelled

7 checks, checkbooks, drafts, cash receipts, deposit

8 slips, wire transfers, and/or any other writings of

9 any kind that refer, relate to and evidence any monies

10 transferred by you" -- I'm sorry, "transferred to you

11 by or from the debtor."

12 A Right. I don't have any of that.

13 Q Did CannaMED Pharmaceuticals ever have a bank

14 account?

15 A No.

16 Q What records would have existed that are no

17 longer in your possession that would be responsive to

18 Category No. 3?

19 A The only records that I can think of while I

20 look here at the descriptions are just the online

21 check register, which I've already given you.

22 Q The online check register of the debtor?

23 A Correct. That's it.

24 Q All right. What, if anything, did you do to

25 ascertain whether any documents responsive to Category

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1 No. 4 existed?

2 A I just looked through the closet where I have

3 whatever files I have left from my old offices, and

4 there was nothing in there that was responsive to that

5 question, and they wouldn't be anywhere else.

6 Q Did you search your e-mails?

7 A I provided you with all the e-mails.

8 Q Did you search your e-mails in responding to

9 this subpoena?

10 A I searched my e-mails only to the extent that

11 I located the e-mail that I sent to you previously

12 with all those e-mails attached to it and discerned

13 that it did get sent to you.

14 Q In responding to this subpoena, did you on

15 behalf of CannaMED Pharmaceuticals search your e-mails

16 to see if there were any documents responsive to

17 Category No. 4?

18 A Oh, no, because I know there aren't. I

19 thought you were talking about the debtor.

20 Q No.

21 A Oh, four. We were talking about three. I

22 didn't know you jumped to four.

23 Did you jump to four?

24 Q Let's look at No. 4.

25 A Okay. We're jumping to four. There are no

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1 document responsive to No. 4.

2 Q How do you know that?

3 A I know it because I know. Remember CannaMED

4 didn't do any business. All the business was handled

5 by Chance & Anthem.

6 Q I'm sorry, can you remind me -- and I'm sorry

7 if you've testified to this before -- how it was that

8 Chance & Anthem handled all of CannaMED's business?

9 A Chance & Anthem did business. CannaMED was

10 an applicant for a medical cannabis license in

11 Maryland, which it did not get. So CannaMED never had

12 the chance to go into business.

13 Q What's the status of the litigation regarding

14 that license?

15 A It was appealed. We're overdue to file the

16 brief. I guess they could dismiss that appeal any

17 day, but I just haven't had the time or the energy to

18 do the brief.

19 Q Are you counsel of record for CannaMED in

20 that litigation?

21 A Yes.

22 Q Is there any other lawyer that's of record in

23 that litigation?

24 A No.

25 Q Please look at Category No. 5, "Copies of any

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1 all lease agreements, business leases, lease option

2 agreements, guarantees, addendums, security agreements

3 between the Debtor and CannaMed Pharmaceuticals, LLC."

4 What, if anything, did you do to ascertain

5 whether any responsive documents exist to that

6 request?

7 A I didn't have to do anything, because I know

8 that there are none.

9 Q How do you know that?

10 A Because I know that. Because I operated

11 Chance & Anthem, which, as I said, was the company

12 that did business, and I know for a fact that there

13 are no records which would fall under that category.

14 Q Did Chance & Anthem have an agreement with

15 CannaMED Pharmaceuticals that memorialized the way

16 that the two entities did business?

17 A Yes. A one-page funding agreement, which I

18 already gave to you.

19 Q Please take a look at Paragraph No. 6.

20 What, if anything, did you do to ascertain

21 whether responsive documents to Category No. 6

22 existed?

23 A Hmm. Nothing. I know that I don't have that

24 information.

25 Q And how is it that you know that?

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1 A Because although I maintained it properly at

2 the time, my records were taken.

3 Q Is it your contention that any documents

4 responsive to Category No. 6 would fall in the traunch

5 of documents that you claim Robert Gibson stole from

6 you?

7 A Robert Gibson took all my files.

8 Q What documents would have existed responsive

9 to Category No. 6 that you claim are no longer in your

10 possession?

11 A Well, let's go through it. There were

12 ledgers, which pertained to the employees. There were

13 reconciliations. There were no trading and savings

14 account statements from any financial, investment

15 and/or lending institution. There were no QuickBooks

16 or other accounting program materials. There were no

17 cancelled checks. There were no operating trusts

18 and/or escrow accounts. Check books, other than the

19 one I gave you. Drafts, cash receipts, deposit slips,

20 wire transfers, statements of account, those only

21 would have been online, and, of course, you had a

22 subpoena duces tecum to the banks to get that for

23 yourselves. There were no account summaries, no stock

24 statements, summaries or reports. Nothing that was

25 responsive, other than what I did mention.

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1 I also objected, I think, to that request, so

2 far as it didn't relate directly either to the debtor

3 of CannaMED.

4 Q Have you withheld any documents that are in

5 your possession on the basis of that objection?

6 A No.

7 Q With respect to Category No. 7, what, if

8 anything, did you do to ascertain whether any

9 documents existed responsive to Category No. 7?

10 A On Category No. 7, I already gave you

11 everything I have on that.

12 Q Is that the folder you handed me in court?

13 A I remember handing you the folder. I don't

14 remember where I handed it to you. Were we in court

15 or maybe sitting in a conference rooms outside? I

16 don't remember, but, yes, I remember handing you a

17 folder.

18 Q Would there be any other documents

19 responsive?

20 A Not that I recall, no.

21 Q How about No. 8, "All operating agreements,

22 including all versions and amendments of CannaMed

23 Pharmaceuticals, LLC"?

24 A Well, wait, before we move on to No. 8,

25 remember we never really purchased that real estate.

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1 It was a lease purchase that we defaulted on. You

2 know that, right?

3 Q Sir, you're an attorney, correct?

4 A Yeah, had to be.

5 Q Do you believe CannaMED or Chance & Anthem

6 have any claims against 27120 Ocean Gateway, LLC

7 arising out of that transaction?

8 A No. I mean, there's one attenuated claim,

9 but I don't think it would succeed.

10 Q And what would that be?

11 A The only claim that I could possibly imagine

12 being brought is something which would -- well, I'd be

13 taking a flyer on that explanation. I once thought

14 there was a claim for what was really a loan that

15 could arguably be disguised as a lease purchase, if

16 the lender could be proved to have made numerous

17 loans, and, therefore, wasn't properly licensed. But

18 I decided that it wouldn't be worth bringing, because

19 the likelihood of success on it would be very slim,

20 and because it really would be, I believe, less than

21 forthcoming to do something like that. Because,

22 remember, the group that put up the money to allow us

23 to have an option on that building did so in good

24 faith, and I believe that we should act in good faith

25 in response and not play that -- what I thought would

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1 be sort of a game.

2 Q And please remind me who that group was?

3 A I don't remember the exact name of the group.

4 It may have been in the name the Alan Bias'

5 (phonetic). Oh, no, strike that, because that's an

6 incorrect response.

7 The gentleman that I dealt with, and he is a

8 gentleman, is a fellow by the name of Alan Bias, and

9 he was kind enough to provide funds to permit Chance &

10 Anthem to have an option on that building at 27120

11 Gateway, but the entity that he created to do it was

12 27120 Ocean Gateway, LLC.

13 Q Let's move on to Category No. 8, please.

14 What, if anything, did you do to ascertain

15 whether documents responsive to Category No. 8 exist?

16 A I sent that to you.

17 Q You sent me an operating agreement?

18 A Yeah. Isn't that what you asked for?

19 Q Were there any amendments to the operating

20 agreement?

21 A There was one amendment that I was not able

22 to find that dealt with stakeholders who did things

23 that could be damaging to CannaMED's chances of

24 obtaining licensure. In fact, I relied on that

25 amendment once to forfeit the one stakeholder's claim.

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1 Q And who was that stakeholder?

2 A I don't see why that would be in the scope of

3 this examination. That's confidential. That has

4 nothing to do with the shares owned by Chance &

5 Anthem, the debtor.

6 Q Remind me, what percentage of Chance & Anthem

7 you claim --

8 A CannaMED has --

9 Q The other way around.

10 A Yeah, 70 percent.

11 Q Seventy percent?

12 A (Witness nods his head.)

13 Q So there was a stakeholder that was

14 terminated?

15 A Correct. I forfeited that stakeholder's

16 shares, because that individual did things, which I

17 believed endangered CannaMED's chance of obtaining a

18 license.

19 Q Based on an amendment to the operating

20 agreement that you're unable to locate?

21 A Correct.

22 Q Would you be able to tell me the name of that

23 stakeholder?

24 A No. I already said no. I think that's

25 confidential. I don't want to embarrass that person

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1 or reveal what I believe would be confidential

2 information.

3 Q How is that information confidential?

4 A Because it's CannaMED's information, not --

5 Q And this is a 2004 Examination of CannaMED --

6 A I understand that.

7 Q -- and the debtor owns 70 percent of

8 CannaMED?

9 A Correct. But the debtor has no right to

10 manage CannaMED.

11 Q Are you claiming that the debtor has no right

12 to know why there was a stakeholder in CannaMED that

13 was terminated based on an operating agreement -- an

14 amendment to the operating agreement that you're

15 unable to produce?

16 A Yes, that's my position.

17 MR. SUAREZ: We'll certify the question on

18 that one.

19 BY MR. SUAREZ:

20 Q Or you can just tell me who it is, you don't

21 have to make this difficult.

22 A I don't want to do that to the individual or

23 release information which I believe may be

24 confidential.

25 Q Would you be willing to tell me that off the

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1 record?

2 A No. If I was willing to tell you off the

3 record, I'd be willing to tell you on the record.

4 Q All right. So we'll take that one up with

5 the Court. All membership agreements of CannaMED

6 Pharmaceuticals, LLC.

7 What, if anything, did you do to ascertain

8 whether there were any membership agreements with

9 respect to CannaMED Pharmaceuticals?

10 A I knew that I didn't have any, because

11 although I had some in my files, I no longer have my

12 files.

13 Q Those are the ones you claim --

14 A Which number are we on?

15 Q Number 9.

16 A No, and I also objected based on

17 confidentiality and attorney/client privilege.

18 Q What document have you withheld on the basis

19 of that privilege?

20 A I don't think I withheld any, because I

21 couldn't find any, because I know all my files were

22 taken. When you first asked for records, I did a

23 really exhaustive search, and then I did it again.

24 And then I thought maybe there were boxes in this

25 trailer, where I had a lot of furniture stored, but

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1 there's nothing in there. No records came -- the only

2 boxes that came out to the storage house, which were

3 then placed in the storage trailer, were boxes of

4 books.

5 Q Was there ever a valuation of CannaMED

6 Pharmaceuticals performed?

7 A Yes.

8 Q And has that been produced?

9 A Yes.

10 Q And where was that valuation maintained?

11 A What do you mean?

12 Q How did you get it? Who did it?

13 A I did it.

14 Q You did it?

15 A Yeah.

16 Q What qualifications, if any, do you have to

17 value businesses?

18 A What of qualifications do I need? I'm going

19 to answer your question with a question.

20 I did that valuation based on my own

21 perception of what the entity is worth, and I think

22 it's been proved by what similar entities that were

23 licensed are selling for. If you remember, I

24 evaluated the company based on its income stream, and

25 then set that against the probability of being

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1 successful in getting the license by litigating it in

2 Maryland, which I think, I think, I recall was 50

3 percent. I don't remember now.

4 Q And how would you value of the likelihood of

5 that litigation being successful today?

6 A Not at all now.

7 Q Why not?

8 A I really can't proceed with it at this point.

9 I've got to do other things to make a living.

10 Q Paragraph 11 or Request No. 11.

11 What, if anything, did you do to ascertain

12 whether there were responsive documents to Category

13 No. 11?

14 A Category 11, I didn't need to do anything,

15 because I know there was that singular document that I

16 had already given you, and there were no other

17 documents.

18 Q Which document is that?

19 A The funding letter.

20 Q Okay. How about No. 12, the membership table

21 of CannaMED Pharmaceuticals?

22 A That was too heavy to transport.

23 Q How is that?

24 A I'm teasing. We never had a membership

25 table, per se. That would be a document I would have

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1 to create, and I think I objected to No. 12 based on

2 confidentiality.

3 Q How can you object based on confidentiality

4 if the document doesn't exist?

5 A I can object to any request you might

6 follow-up with to prepare one.

7 Q I'm not asking you to prepare one.

8 Is there a document that you withheld that

9 would otherwise be responsive to Request No. 12 on the

10 basis of any objection or privilege?

11 A No. No, I know who the people are, but

12 there's no writing to evidence that.

13 Q And who are the members of CannaMED

14 Pharmaceuticals?

15 A Again, I'm objecting based on

16 confidentiality.

17 MR. SUAREZ: Certified the question.

18 (Thereupon, a document was marked as Exhibit

19 No. 2 for identification by Mr. Suarez.)

20 BY MR. SUAREZ:

21 Q Please take a second to review the exhibit

22 marked No. 2.

23 A Yes.

24 Q What is this document?

25 A That appears to be the LLC operating

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1 agreement for CannaMED which I sent to you.

2 Q Has this document ever been amended?

3 A Yes.

4 Q What is the title of the amendment?

5 A Amendment to Operating Agreement, as I

6 recall.

7 Q And is that the copy of the amendment that

8 you were unable to locate?

9 A Yes.

10 Q Was there a resolution that authorized that

11 amendment?

12 A Yes, because I was the only person who had

13 the resolve to do it. There were no other decision

14 makers for CannaMED, except for me.

15 Q What's your membership interest in CannaMED

16 Pharmaceuticals?

17 A As I said before, I was the managing member.

18 Q I understand that you were the managing

19 member, but how many membership interests did you have

20 in CannaMED? What was your percentage of the

21 membership interests in CannaMED?

22 A Five percent.

23 Q Were the other 95 percent of the members of

24 CannaMED consulted when you resolved to amend the

25 operating agreement?

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1 A No.

2 Q Why not?

3 A I didn't think I needed to.

4 Q What was the basis of that belief?

5 A I was the sole managing member.

6 Q Is it your testimony that as the sole

7 managing member you believed you could amend the

8 operating agreement of CannaMED at will?

9 A Yes.

10 Q Was the amendment to the operating agreement

11 ever transmitted to anybody?

12 A I don't recall.

13 Q Was it a secret amendment to the operating

14 agreement?

15 A No, there were no secrets. I may have sent

16 the individual that I terminated a copy of the

17 amendment.

18 Q Okay. Section 2.01 of the operating

19 agreement refers to an advisory board.

20 A One or more advisory boards, yeah.

21 Q Was there an advisory board ever created at

22 CannaMED Pharmaceuticals?

23 A No, I don't believe so. We made initial

24 moves to create two of them, as I remember, but we

25 never formally did.

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1 Q Section 2.02 states that, "Operating

2 decisions shall be executed by the senior management

3 team following mission and policy directives of a

4 Managing Director."

5 A Right.

6 Q Who was the senior management team?

7 A We never established a senior management

8 team.

9 Q Who was the managing director?

10 A I was the managing member, and I think I was

11 also referred to as the managing director.

12 Q How were you appointed managing director?

13 A When I formed the company, I made myself the

14 managing member. But I think in the application to

15 the State of Maryland, I was described as the managing

16 director. Don't quote me on that, because I'm not a

17 hundred percent sure.

18 Q Section --

19 A By the way, remember, I think I might have

20 just confused one of your earlier questions between

21 the debtor and between CannaMED. I don't know if you

22 want to ask me those questions again or not, but --

23 Q No, if you feel you need to clarify --

24 A I don't even remember the question at this

25 point. It was two or three questions ago.

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1 But, remember, I was the managing member of

2 both Chance & Anthem and CannaMED. I might have

3 confused myself with that answer, if you want to read

4 back a few questions, but -- or I can clarify it

5 later. I'll read, and then if I think I didn't answer

6 correctly, I'll let you know.

7 Q All right. Moving to Section 2.03, which

8 refers to company oversight, "The Chief Executive

9 Officer who shall hold ultimate operational oversight

10 of the corporation shall report directly to the

11 Managing Director."

12 Who was the chief executive officer of

13 CannaMED Pharmaceuticals, LLC?

14 A Well, again, we never got into business, but

15 it would have been by a woman by the Angeline Nanni

16 who lives in Maryland, who is a health care executive

17 that we chose.

18 Q Section 2.04 of the operating agreement

19 refers to, "Fiscal control shall be maintained in

20 order to ensure proper record keeping of accounts and

21 funds," and then it goes on.

22 A Absolutely.

23 Q Were fiscal controls ever implemented in

24 CannaMED Pharmaceuticals?

25 A No, because CannaMED Pharmaceuticals never

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1 had one dollar to control.

2 Q Section 2.05 provides that, "The number of

3 advisory board members may vary, but shall not be less

4 than one (1) nor more than seven (7), except by action

5 of majority vote by Members."

6 A Right.

7 Q Was an advisory board member ever appointed?

8 A I already told you that the advisory boards

9 weren't created. The advisory boards, now that I

10 start thinking about it, I believe there were going to

11 be two. One was a business advisory board and the

12 other was a scientific advisory board, and we had a

13 slate of prospects that we either were going to or did

14 contact to try to form those boards. But the

15 intention wasn't to form them until we got into

16 operation.

17 Q What compensation, if any, did you receive

18 from CannaMED Pharmaceuticals?

19 A Nothing. CannaMED Pharmaceuticals never had

20 one dollar. Let me rephrase that, never had one penny

21 or even a tenth of a penny. There was no money in

22 CannaMED Pharmaceuticals.

23 Q Other than yourself, were any officers or

24 directors ever appointed for CannaMED Pharmaceuticals?

25 A Well, I just told you that there would have

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1 been officers. Angeline would have been the chief

2 executive officer and president, and I believe we had

3 a portion of the offices among the people who worked

4 for Chance & Anthem. Yes, the officers would have

5 been Bruce Lowe. I think he was going to be a vice

6 president. Matt Huffman (phonetic), who was our

7 grower, was going to be an officer. Jessie, whose

8 last name I can't think of, who was our security

9 person, was going to be an officer, and Hal -- Hal, I

10 can't think of his last name, would have also been an

11 officer, and I'm probably forgetting somebody. But,

12 again, since we never were licensed and could never

13 get into business, there were no active officers.

14 Q Was Carl Stone ever an investor in CannaMED

15 Pharmaceuticals?

16 A No.

17 Q How about David Fiore?

18 A No.

19 Ah, you do have more files.

20 (Thereupon, a document was marked as Exhibit

21 No. 3 for identification by Mr. Suarez.)

22 BY MR. SUAREZ:

23 Q Please review the document I've marked as

24 Exhibit 3.

25 A Oh, yeah, I remember this.

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1 Q Please identify the document I've marked as

2 Exhibit 3.

3 A This was a document prepared by -- ah, an

4 individual who was trying to obtain money for us.

5 It's labeled Executive Summary Debt Offering, and I

6 think this person was a -- a -- I don't know. I don't

7 know how to describe him. Jonathan Mayer, right, he

8 had a company called Wharton, and they were money

9 scouts, I guess, is the best way to -- he was a

10 venture capitalist agent, how about that, for the best

11 way to describe it. I really never knew exactly what

12 he did, because he didn't do anything for us other

13 than write up this summary for his own use.

14 Q The exhibit to the e-mail reads, "CannaMED

15 Pharmaceuticals, Executive Summary: Debt Offering,

16 Confidential, February 2016, For Informational

17 Purposes Only."

18 A Right.

19 Q Who prepared this document?

20 A We did not prepare this document. I believe

21 it was prepared by Jonathan Mayer or someone on his

22 staff.

23 Q And how did Mr. Mayer acquire the information

24 to prepare this document?

25 A Well, by way of information, do you mean the

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1 pictures that he's got in here of the site?

2 Q How did he get the facts he put in this

3 document?

4 How did he become familiar with CannaMED's

5 business so as to allow him to prepare this document?

6 A I don't remember. I talked to him, but so

7 would other people have talked to him.

8 Q The first line says, on Page 1 of the

9 document, "The Executive Summary prepared by Chance &

10 Anthem, LLC dba CannaMED Pharmaceuticals, LLC" --

11 A Where are you looking?

12 Q Page 1 of the attachment --

13 A Oh, I see --

14 Q -- all the way at the top.

15 A -- all the way at the beginning.

16 Yeah, I can't be responsible for his

17 presentation.

18 Q You would not have reviewed this document?

19 A No. I recall seeing this, but I would not

20 have reviewed it closely, because he never did

21 anything. Actually, I think we paid him a couple

22 thousand dollars to prepare this document.

23 Q Well, turning to the second Page 1 of the

24 document, in the second column, second paragraph from

25 the top, it says, "The founder of the company, Jeffrey

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1 Siskind, has a proven track record in this space,

2 having procured a license and built a fully

3 operational Location Grower Facility in California."

4 Is that an accurate statement?

5 A Yes.

6 Q What license did you procure?

7 A A agricultural license and business license.

8 Actually, maybe it was one in the same, an

9 agricultural business license, correct.

10 Q And how would Mr. Mayer have come to know

11 that?

12 A He probably interviewed either me or Bruce

13 Lowe who ran the California operation for me.

14 Q What was the name of the California

15 operation?

16 A Well, there were two. The management company

17 was called Collective Management Associates. It was a

18 Florida LLC --

19 Q Mm-hmm.

20 A -- and then there was a not-for-profit

21 collective called the Riverside Collective, which had

22 members and was the vehicle which permitted us to grow

23 a certain number of plants for each member that the

24 collective, which was not-for-profit, had.

25 Q And that grower is or was at some point fully

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1 operational?

2 A Yep.

3 Q Generated revenue?

4 A Yeah.

5 Q What happened to that grower?

6 A It was shut down by an individual, who I

7 think his name was Cooley (phonetic), who was under

8 the misapprehension that he could shut down

9 approximately 400 cannabis related businesses as part

10 of his quest to move from Los Angeles County district

11 attorney to California attorney general, but he lost

12 that election because of the -- partly, I imagine,

13 because he went after legitimate enterprises, as well

14 as the illegitimate ones.

15 Q Neither the Riverside Collective, nor CMA

16 currently operates; is that correct?

17 A Correct. I don't think you need the

18 not-for-profit anymore to do business out there, now

19 that they've gone to full recreational.

20 Q I apologize, Mr. Siskind, but it appears

21 there are multiple page ones in this document.

22 Apparently, Mr. Mayer didn't do a very good job in

23 putting this together for you. But if you could turn

24 to the page that's second to last --

25 A Oh, I see.

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1 Q -- also marked No. 1 --

2 A Right.

3 Q -- there's a section there named Site

4 Financing.

5 A Right.

6 Q "CannaMED Pharmaceuticals, LLC is the

7 third-party beneficiary of Chance & Anthem, LLC's

8 assignment of a purchase option contract."

9 A Correct.

10 Q Is that an accurate statement?

11 A I think so.

12 Q "Which was entered into by Sovereign Gaming &

13 Entertainment, LLC."

14 A Correct.

15 Q Is that an accurate statement?

16 A Yes.

17 Q A Florida limited liability company --

18 A Oh, wait a minute, maybe that's not a hundred

19 percent correct. Sovereign Gaming & Entertainment had

20 the original contract on the building, and then, I

21 believe, assigned it to Chance & Anthem.

22 Q And how was CannaMED Pharmaceuticals the

23 third-party beneficiary of that assignment?

24 A Well, because the intent was to utilize the

25 building for CannaMED Pharmaceuticals, LLC, solely for

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1 CannaMED.

2 Q All right. It goes on to say, "SG&E,"

3 Sovereign Gaming & Entertainment, LLC --

4 A Correct.

5 Q -- "has funded approximately $300,000 to the

6 purchase to date."

7 A I believe that's a correct statement.

8 Q And how was that funding accomplished?

9 A I don't remember, but that went into the

10 purchase of the building. That went into what became

11 the lease option of the building, but it was expended.

12 Q And it says there that "Sovereign Gaming &

13 Entertainment is a Florida limited liability company

14 controlled by the family of the company's managing

15 director."

16 A That's not really a hundred percent accurate,

17 but it was a Florida LLC.

18 Q What's inaccurate about that statement?

19 A My father was the managing member, sole

20 managing member, I believe, of Sovereign Gaming.

21 Q And what is the current status of Sovereign

22 Gaming?

23 A It's lapsed. It doesn't do business any

24 more, and my father has passed away, so I don't think

25 you'll see anything happening in Sovereign Gaming.

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1 Q Who currently owns the membership interests

2 of Sovereign Gaming?

3 A I wouldn't know. Not me.

4 Q All right. This site financing section says,

5 in the last sentence, "While SG&E has funded

6 approximately 300,000 toward the purchase to date,

7 C&A," Chance & Anthem, "is obtaining additional

8 capital in the amount of 1.35 million by obtaining

9 finances against the building, which will be used to

10 close and build out the facility."

11 A At that time I believe that was the plan. I

12 don't know that the 1.3 million is correct, but that

13 was before Alan Bias' group got involved.

14 Q And how did that change once Mr. Bias' group

15 got involved?

16 A Well, we weren't working with Mr. Mayer any

17 longer. The people that he wanted to get involved

18 didn't come to fruition, and actually I do remember he

19 did have somebody interested, but they wanted to big a

20 participation interest. So we didn't go forward with

21 his candidate.

22 Q Did Mr. Mayer ever raise any funds for either

23 Chance & Anthem or CannaMED?

24 A No.

25 (Thereupon, a document was marked as Exhibit

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1 No. 4 for identification by Mr. Suarez.)

2 BY MR. SUAREZ:

3 Q Please review the document I've marked as

4 Exhibit 4.

5 A Oh, wow, the appraisal.

6 Okay.

7 Q Who is jjbttrm@aol.com?

8 A I don't know for certain, but I have a

9 feeling it's this Mr. Butrum. B-T-R-M -- B-T-T,

10 Butrum, I don't know.

11 Q Is this an e-mail you sent on February 4,

12 2016?

13 A Looks like it is, yeah.

14 Q The e-mail reads, "Mr. Butrum, I am

15 forwarding the attached files at the behest of Mike

16 Buckingham."

17 A Yes.

18 Q Who is Mike Buckingham?

19 A My sister's former husband, who was

20 attempting to try to raise money for us.

21 Q "Us" being CannaMED Pharmaceuticals?

22 A Well, for the CannaMED Pharmaceuticals

23 operation.

24 Q If it wasn't for --

25 A At this point it looks like it was Sovereign,

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1 if you look at the next page.

2 Q The next page is an Executive Summary.

3 A Looks like it says that, but I don't know if

4 it really is. Looks a little light for an executive

5 summary to me.

6 Q Who prepared the executive --

7 A I have no idea.

8 Q -- summary document?

9 A I have no idea.

10 Q Was it you?

11 A I don't remember preparing this.

12 Q Was it Mr. Buckingham?

13 A I don't think so.

14 Q Who else might have prepared a document like

15 this?

16 A Could have been Bruce Lowe in my office,

17 could have been Willy Russell in my office.

18 Q When you say "in my office," do you mean your

19 law firm or at CannaMED?

20 A No, no. In our offices in West Palm Beach,

21 part of which was occupied by my law firm.

22 Q Who would have employed Bruce Lowe?

23 A Chance & Anthem.

24 Q Who would have employed -- I'm sorry, you

25 said his name was Willy?

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1 A Willy, yeah, a British guy who would edit

2 things that were written. His grammatical skills were

3 superior to everyone else's. I don't remember what

4 entity Willy worked for. He didn't work for the law

5 office. I don't remember what entity owned the floor,

6 but he was the receptionist.

7 Q The third paragraph from the bottom states,

8 "SGE plans to lease the property to CannaMED

9 Pharmaceuticals, LLC, a related Maryland limited

10 liability company formed to apply for a license to

11 operate one of 15 medical marijuana cultivation

12 facilities, which license may be awarded in May 2016."

13 A Yeah. That's odd, because I thought the

14 licenses were supposed to be awarded in January of

15 2016.

16 Q Okay. It says in the event that CannaMED is

17 not successful in obtaining a Maryland medical

18 marijuana cultivation center license, SGE plans to

19 leave (sic) the property to another successful

20 applicant."

21 A Lease it. Yeah.

22 Q Did that ever happen?

23 A No.

24 Q Why not?

25 A Nobody won it.

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1 Q The following paragraph reads, "SGE is

2 operated by Jeffrey Siskind, a West Palm Beach real

3 estate attorney, whose resume accompanies this

4 executive summary." Is that accurate?

5 A No.

6 Q Why not?

7 A Well, as I told you, William Siskind was the

8 managing member of Sovereign Gaming & Entertainment.

9 Q Was the elder Mr. Siskind the operator of

10 Sovereign Gaming & Entertainment or was it you?

11 A The elder Siskind was the managing member. I

12 don't know what you mean by "operator."

13 Q Who had authority to sign checks?

14 A I signed a lot of checks for that company on

15 behalf of my father.

16 Q Who had the authority to bind that company?

17 A The managing member.

18 Q Did you ever bind that company independently?

19 A I can't remember doing that. I may have.

20 Q Did you review this document prior to sending

21 it to Mr. Butrum?

22 A Probably not closely. I don't know that I

23 sent this to Mr. Butrum.

24 Q It's attached to the e-mail.

25 A "I am forwarding the attached files at the

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1 behest of Mike Buckingham."

2 So, no, I probably would have caught that

3 inaccuracy had I reviewed it closely. I'm more

4 concerned with these -- oh, I see what this is. They

5 are expenditures. I didn't understand the interest

6 payments. But I guess they were the interest payments

7 made to the seller of the property, and the square

8 footage is -- oh, no the square footage is right.

9 Q And what was the point of sending this to

10 Mr. Butrum?

11 A I guess he was a possible investors.

12 Q Did he ever invest?

13 A No.

14 Q The next attachment is an appraisal report of

15 real property identified as --

16 A Yeah, see that. I didn't even remember we

17 had this, but now that I see it, I remember the

18 appraiser doing it.

19 Q And that was an appraisal on the building?

20 A Yes.

21 Q All right. The following is a purchase

22 option agreement, the following attachment, between

23 Machining Technologies, Inc. --

24 A Oh, sure, this was -- that's right.

25 Q -- and Sovereign Gaming. Do you see that?

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1 A Yeah.

2 Q Is that the purchase option agreement that

3 you referred to?

4 A No. No. There were two purchase option

5 agreements. This was the original purchase option

6 between Sovereign and the seller, which is called

7 Machining Technologies, Inc. There was a shorter name

8 but --

9 Q Was this option agreement ever exercised?

10 A Yes, this was concluded. The building was

11 sold.

12 Q Who was the building sold to?

13 A 27120 Ocean Gateway, which was the LLC

14 established by Alan Bias.

15 Q The Ocean Gateway, LLC exercised Sovereign's

16 right in this purchase option agreement?

17 A Correct.

18 Q All right. The final attachment -- actually

19 the second to last attachment, the last attachment

20 appears to be your resume, the second to last

21 attachment is a company business plan.

22 A Oh, yeah.

23 Q Who prepared the company business plan of

24 CannaMED Pharmaceuticals attached to this e-mail?

25 A I have no idea. I contributed to it.

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1 Q Did you approve it?

2 A What's that?

3 Q Did you approve it?

4 A There was no formal approval process. I

5 think the best thing you could say is I contributed to

6 it.

7 Q You forwarded it to --

8 A There I am, managing director, general

9 counsel.

10 Q You did forward it to someone that was

11 interested in investing in CannaMED Pharmaceuticals,

12 did you not?

13 A It appears that I did, yes. But I can't

14 vouch for whether or not it was changed after I might

15 have reviewed it. I remember reviewing the overview

16 where we talked about the people, the procedures, and

17 the place, which was something that we transposed from

18 our application in the State of Delaware. So I really

19 don't know if I did it for this application or if I'm

20 thinking of the application for the State of Delaware.

21 Q Can you take a look at Section 2.3, which

22 says "Start-up Funding."

23 A Yeah.

24 Q It says, "The company has obtained sufficient

25 funding to accomplish its mission, as follows:

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1 CannaMED Pharmaceuticals, LLC has secured the building

2 and lands which it intends to utilize by means of a

3 related-company purchase for the sum of $950,000."

4 A Right.

5 Q What was the related-company purchase?

6 A I think that was the purchase price,

7 $950,000.

8 Q Well, my question is, what is the related

9 company referred to in that section?

10 A Looks like it was referring to Chance &

11 Anthem.

12 Q Did Chance & Anthem ever --

13 A Well, it explains that, or Sovereign Gaming.

14 You have to read the rest of the paragraph.

15 Q All right. Walk me through it, please.

16 "Chance & Anthem, LLC, a Florida limited

17 liability company, which is solely owned by the

18 Maryland Cannabis Commission Grower Applicant's

19 Managing Director" --

20 A Right, probably was at that time.

21 Q -- "Jeffrey Siskind -- Jeffrey M. Siskind, is

22 the assignee of a purchase option agreement which was

23 entered into by Sovereign Gaming & Entertainment, LLC,

24 a Florida limited liability company controlled by the

25 Siskind family."

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1 A Seems like that was written by the same

2 person that wrote the other document --

3 Q But not you?

4 A -- who didn't -- no, I didn't read that. I

5 mean, I didn't write that, that I recall, no.

6 Q "SG&E has funded $245,000 towards the

7 purchase to date."

8 A Okay.

9 Q And then the next line is, "C&A is obtaining

10 additional capital in the amount of $750,000 by

11 obtaining financing against real property located in

12 Florida, which is expected to close on November 6,

13 2015, in order to enable completion of the purchase of

14 the building and lands, which the company intends to

15 utilize in Wicomico County." And I think I said

16 "Wicomico" correctly.

17 A You did. Took me months to figure it out,

18 but you're right. I always said "Wacomico," and they

19 looked at me like I wasn't not Indian enough, since

20 it's an Indian name.

21 Q Mm-hmm. The $750,000 referenced in that

22 section, was that financing ever obtained?

23 A I think we did obtain that against the

24 residential house flip project in Wellington.

25 Q Is that 3445 Santa Barbara?

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1 A Correct.

2 Q And how was that financing obtained?

3 Who provided that financing?

4 A A company called New Wave Financing or New

5 Wave Loans out of Miami.

6 Q And how were those funds used?

7 A I don't remember, just went into the general

8 fund, general expenses, paying me.

9 Q Of Chance & Anthem?

10 A Mm-hmm, yes.

11 This is interesting, because I'm wondering if

12 this is elements of the application -- oh, no, you

13 know what this is, it looks like a reworking of our

14 Delaware application. Yeah, I didn't do this.

15 Q Was it sourced from another document?

16 A Parts of it appear -- oh, yes, parts of it

17 definitely were sourced from our Delaware application.

18 Q What do you mean by the "Delaware"

19 application? And please excuse me if you've explained

20 that to me before.

21 A Oh, well, prior to this Maryland opportunity,

22 the State of Delaware requested proposals to operate

23 cannabis growing retail locations in the State of

24 Delaware.

25 Q The following paragraph says, "Additional

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1 funds needed to underwrite the initial specific

2 purpose build-out of the facility and projected

3 working capital needed during the ramp up period of

4 operation, which are estimated to total approximately

5 $1 million, are being made available to Mr. Siskind by

6 means of a loan to Mr. Siskind based upon a client and

7 business associate's open line of credit."

8 A That's correct.

9 Q Was that capital ever made available?

10 A No. We never needed it. It would have been

11 had we needed it.

12 Q And who is the individual referred to in that

13 paragraph?

14 A I'm not going to disclose that. It's a

15 client, and it's not relevant. You're way outside the

16 scope, way outside the scope, of this 2004.

17 MR. SUAREZ: Please certify the question.

18 BY MR. SUAREZ:

19 Q The following paragraph says, "Also to

20 provide reserve funding, Mr. Siskind anticipates being

21 able to obtain an additional $550,000 by securing

22 additional financing against the Florida property

23 (which amount, together with the originally obtained

24 financing, brings the financed loan-to-value to

25 approximately 50% of the property's appraised value)."

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1 Is that Florida property referenced in that

2 paragraph 3445 Santa Barbara?

3 A I don't believe that's accurate. I think our

4 intent was to borrow additional funds against the

5 Hebron, Maryland property once it was approved.

6 Q This statement is false?

7 A I don't know that it's false. It doesn't

8 appear correct to me. We had pretty much -- no, no,

9 strike that. I believe that that's in error. I think

10 that the additional financing was supposed to come

11 from the Maryland property once it was improved. I

12 can't swear to that. I don't know that for a fact,

13 but that's my recollection.

14 Q All right. The following paragraph says,

15 "The attached proforma information demonstrates that

16 the above funding is sufficient to meet the company's

17 cash needs at start-up and throughout the ramp-up

18 period of operation. Additional funding required to

19 build out and equip the remainder of the facility will

20 be obtained by means of re-invested earnings."

21 A Right. I'm not looking at the document now,

22 but I do remember that we had a phased operational

23 plan, where we first operated only a portion of the

24 building, the portion that would eventually be given

25 over to the research attribute, because we felt that

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1 the rollout of the Maryland cannabis program would be

2 slow, so why -- it didn't make sense to open the

3 entire 50,000-square-foot facility at one time. So we

4 could get Phase I open, and reinvest those revenues in

5 building out the rest of the facility. I think it was

6 even a three-stage -- I think it was a three-stage

7 ramp up. Yeah.

8 Q Who prepared the attached proforma?

9 A Let's take a look at it. Would that be --

10 let's see, 7.31, beginning at 7.31, even though it

11 comes after 7.4. Yeah, 7.3, it says, "Please refer to

12 these sections.

13 Q Projected --

14 A I think I did that. I think I did all of

15 that. Yeah, I did all the financials based on what we

16 did over in California.

17 Q You answered my next question.

18 All right. The following paragraph says,

19 "Attachments to this application include the appraisal

20 on the Florida property, which indicates a value in

21 excess of 2.6 million" --

22 A Where is that --

23 Q We're back --

24 A -- is there an appraisal attached.

25 Q Yeah, we're back at 2.3.

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1 A I don't see an appraisal.

2 Q I don't see one either. That's my question.

3 A I have no idea what may have happened to that

4 appraisal.

5 Q Please take a look at Section 2.3.

6 A Right.

7 Q Reference to "application."

8 A Where?

9 Q In the third paragraph, it says, "Attachment

10 to this application."

11 A I don't see where you're talking about.

12 Third paragraph on which page.

13 Q The pages are unnumbered.

14 A Oh, okay, I had turned the page. I'm sorry.

15 Q Right, 2.4 -- turn the paragraph -- turn the

16 page.

17 A Turn the page, okay. Turn the paragraph?

18 Q You're in the second page of Section 2.3 --

19 A I am.

20 Q -- prior to 2.4.

21 A Okay.

22 Q The third paragraph.

23 A Okay. "Attachments to the application

24 include" --

25 Q This is not an application is it?

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1 A No.

2 Q What application is that statement making

3 reference to?

4 A I haven't the foggiest idea.

5 Q All right. It says, "Attachments to this

6 application include the appraisal on the Florida

7 property, which indicates a value in excess of $2.6

8 million."

9 What Florida property is that statement

10 referring to?

11 A The only Florida property that could be

12 related to this endeavor would be Chance & Anthem's

13 project house in Wellington.

14 Q And was there ever an appraisal on the

15 project house valuing it in excess of $2.6 million?

16 A Not that I recall right now. There may have

17 been, but I don't recall it.

18 Q A loan commitment for the approximate

19 $750,000 net funding loan expected to close on

20 November 6, 2015.

21 A That was probably correct.

22 Q Is that what you previously described as the

23 New Wave loan?

24 A It would have had to have been, yeah.

25 Q Together with a fee sheet, which indicates

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1 the net available funding.

2 A Okay. Well, there probably was one created

3 if we were far enough along in that loan -- in

4 obtaining that loan.

5 Q Do you know where that fee sheet would exist?

6 A It would exist in the files that were taken

7 from my office, but where they are at this point is

8 anyone's guess.

9 Q Would New Wave --

10 A Oh, they would have it, if you can get in

11 touch with them, sure. It wasn't that long ago.

12 Q All right. Then the next is a bank statement

13 from Mr. Siskind's client, which indicates that just

14 over one million is available by means of the line of

15 credit.

16 A I think I do, at some point, remember seeing

17 that, but, again, I wouldn't have it now.

18 Q And, again, what client is that referencing

19 there?

20 A It's the client that I won't disclose to you,

21 because it's not relevant to -- within the scope of

22 this 2004.

23 Q Mr. Siskind, you're a practicing attorney.

24 You know relevance isn't a basis to not answer a

25 question --

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1 A Yeah, but there's a limitation to --

2 Q -- even setting aside --

3 A -- the 2004. You can't just --

4 Q So are you refusing to answer the question?

5 A It's not something that I believe to be

6 relevant.

7 Q Are you refusing to answer the question?

8 A I am.

9 MR. SUAREZ: Please certified the question.

10 THE WITNESS: And with that I will help

11 myself to a chocolate bar.

12 MR. SUAREZ: I will do you one better, how

13 about we take a five-minute break?

14 THE WITNESS: Why? I want to get out of

15 here. Keep going. No, if you want to break, I will.

16 MR. SUAREZ: Thank you.

17 (Thereupon, a brief recess was taken.)

18 MR. SUAREZ: Back on the record.

19 BY MR. SUAREZ:

20 Q If you could please skip forward to --

21 A I don't skip anymore. I've gotten too heavy.

22 Q -- Section 5.25, Sales Strategy.

23 A Oh, wow, I'm passing through SWAT analysis.

24 This was all from the Delaware application.

25 Okay. I'm on sales strategy.

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1 Q Was any portion of this document part of the

2 Maryland application?

3 A I don't believe so, no. This probably

4 predated the Maryland application.

5 Q What was the date of the Maryland

6 application?

7 A I don't remember.

8 Q Was it --

9 A You can go on the Maryland medical cannabis

10 commission's website. They probably have all that

11 information.

12 Q All right. Sales Strategy, 5.25 says,

13 "CannaMED Pharmaceuticals, LLC will only sell its

14 products, consisting of various strains of medical

15 cannabis, to licensed Maryland processors and

16 dispensaries in order that they be resold to

17 patients."

18 A Correct. That is correct. We were only

19 going for the grower's license.

20 Q Did CannaMED own strains of medical cannabis?

21 A No. CannaMED didn't do anything --

22 Q Did it ever --

23 A -- it never came into being --

24 Q Did it ever develop the --

25 A -- it never owned anything.

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1 Q -- strains of --

2 A No, no. The strains of cannabis already

3 exist.

4 Q It never possessed strains of cannabis?

5 A No.

6 Q What products was it referencing here in

7 Section 5.25 if it didn't have any?

8 Wouldn't it be inaccurate to say that

9 CannaMED would only sell "its products" if it didn't

10 have any?

11 A No.

12 Have you ever started a business, Jesus?

13 This is what you would write. Now, I'm not saying I

14 wrote this, but CannaMED "will" only sell its products

15 consisting of various strains of medical cannabis to

16 Maryland processors and dispensaries." That's an

17 accurate statement, right? The company, once it gets

18 into business, "will do this." It's forward looking.

19 Q Okay.

20 A Proforma, perhaps is the best term to use.

21 Q 5.32, if you forward a couple of pages,

22 Cultivation Program Standard Operating Procedures.

23 A SOPs, yeah.

24 Q It says, "CannaMED Pharmaceuticals, LLC has

25 adopted standard operating procedures" --

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1 A Correct.

2 Q -- "to ensure the implementation of a

3 successful medical cannabis cultivation program."

4 A Correct.

5 Q Where are those standard operating procedures

6 located?

7 A Next sentence, says it right there, "Specific

8 SOPs are contained within a Proprietary Cultivation

9 Handbook, which was developed by" -- and I guess that

10 should be "the" -- "company's master grower and are

11 summarized below." There you have the summaries.

12 Q Where is that cultivation handbook located?

13 A I have no idea. I don't think I've ever seen

14 it.

15 Q What do you mean by proprietary cultivation

16 handbook?

17 A Why do you say what do "I" mean? I am not

18 admitting to having written this.

19 Q Did this form part of the Delaware

20 application?

21 A Probably, yes.

22 Q Would you have submitted it to Delaware?

23 A Yes, but not as CannaMED. I forget what the

24 entity name in Delaware was.

25 Q But you forwarded this document to a

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1 potential lender?

2 A And your point there is, exactly?

3 Q Was the document inaccurate at the time that

4 you forwarded it to the potential lender?

5 A I didn't see any inaccuracies. Tell me where

6 there's an inaccuracy.

7 Q Well, it refers to a proprietary cultivation

8 handbook.

9 Did a proprietary cultivation handbook ever

10 exist?

11 A I presume it did.

12 Q And why do you presume that it did?

13 A Because it says here that it does. Well, let

14 me make this -- let me carefully review this.

15 Okay. Good. There it is, there's a

16 cultivation handbook, "which was developed by the

17 company's master grower," that would be Matt Huffman.

18 Give him a call. He'll probably send it to you. He's

19 a nice guy.

20 Q That would have been a cultivation handbook

21 that the company, being CannaMED, paid to develop?

22 A Matt wrote the SOPs, I believe. He probably

23 took the SOPs we had in Delaware and edited them. But

24 he was the one to do the SOPs. He was the master

25 grower.

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1 Q What, if anything, as the sole managing

2 member of CannaMED Pharmaceuticals, have you done to

3 preserve the value its intellectual property and the

4 cultivation handbook and other cannabis related data?

5 A Well, I don't see that I've preserved value

6 very well if I'm giving it all over to you.

7 Q How have you --

8 A Unless you're going to maintain it as

9 confidential.

10 Q Well, how is it that you've preserved it?

11 You haven't given it to us. I don't have a

12 copy --

13 A You have what --

14 Q -- of the cultivation handbook.

15 A -- you got in front of you.

16 What do you mean, the cultivation handbook?

17 I guess I'm preserving it if I haven't given it to

18 you.

19 Q Do you have it? Is it in your possession?

20 A No.

21 Q Who, other than Matt Huffman, has in their

22 possession proprietary information of CannaMED

23 Pharmaceuticals?

24 A The only -- I'm guessing, because I don't

25 know what you would describe as "proprietary," but I

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1 would say the only people who would have anything

2 that's proprietary would be Matt, Jessie, Angeline,

3 and maybe Bruce.

4 Well, I mean, it depends on what you say is

5 proprietary. We had security plans that were

6 developed, so Hal, whose name I cannot recall right

7 now, probably had some of that. Who else was there?

8 That's pretty much it. The other people were

9 construction workers. They wouldn't have anything.

10 Q The master grower referenced in 5.3.2 is Matt

11 Huffman?

12 A Correct.

13 Q And it's your testimony that to the extent

14 that a proprietary cultivation handbook exists, it

15 would be in his possession?

16 A Yes.

17 Q And he would have been the master --

18 A But let me tell you this, the SOPs that we

19 had are customary throughout the industry. So if

20 you're looking for value there, you're barking up the

21 wrong tree.

22 Q Is there anything proprietary about them?

23 A I don't believe so, because at this point,

24 everybody's got them. Back then they didn't, but the

25 whole industry has changed in the last three years.

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1 Q What does the term "proprietary" mean to you?

2 A Means "property of."

3 So let me tell you something, so let's say

4 there's an SOP, right, and the SOP is that when you're

5 using gloves while handling the plants, they are to be

6 gloves that are not powered. They are not to have any

7 kind of a powder on them that could get on the plant,

8 the flower of the plant, which is then sold to a

9 customer who might ingest that powder, right? That's

10 an SOP. If I put CannaMED Pharmaceuticals, LLC on the

11 top of page that spells out that SOP, it seems to me

12 that's CannaMED's SOP, but I can tell you right now

13 that at this point in time every single growing

14 operation across the country is using that SOP.

15 Right?

16 Now, they didn't three years ago, because --

17 if you told me that three years ago, I would go "Huh,

18 whoever thought of that?" But supposedly that was one

19 of the reasons we lost our -- we got points deducted

20 on our application, because we did not spell that out

21 at the time.

22 Now, in the cannabis industry, things are

23 pretty much shared openly, so let me say that too.

24 When we went into the business in California back

25 1996, nobody knew anything about raising marijuana,

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1 much less smoking it, and everybody shared every bit

2 of information, which enabled me to go out there with

3 absolutely zero knowledge and build a successful

4 cannabis operation, mostly remotely from Florida,

5 because people shared everything. So when you talk

6 about "proprietary," it's sort of a relative term.

7 Now, I'll tell you this, and I read this for

8 the first time last week, because everybody right now

9 is talking about the farm bill, which, if it passes,

10 may authorize the growing of industrial hemp across

11 the country, and the federal government may preempt

12 the field, preventing the states from having their own

13 rules. Supposedly, at least in the article I read,

14 and you gotta take everything you read in cannabis

15 with a grain of salt, because you have legitimate

16 publications and those that aren't so legitimate,

17 there are a lot of carefully controlled methods and

18 SOPs relating to the processing of industrial hemp

19 into CBDs. I don't know enough about it to tell you

20 whether that's fact or fiction, because I don't know

21 how you get CBDs out of industrial hemp. But I've

22 never seen that prior to this. That's my point.

23 Q What, if anything, within the cultivation

24 handbook would have been developed by CannaMED?

25 A Well, the entire handbook would have been

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1 proprietary, but if you're asking how many of those

2 SOPs were the same as other people had, I really don't

3 know, because, remember, Matt Huffman came to us from

4 another operation either in Denver or California, and

5 a lot of them were SOPs that he had originally

6 developed for whoever he was working for prior to us.

7 Q How much money, if anything, did CannaMED

8 invest in preparing its proprietary cultivation

9 handbook?

10 A Just Matt's salary.

11 Q And how much was that?

12 A I think he made a thousand a week.

13 Q And who paid --

14 A Remember, CannaMED didn't pay anything,

15 though. This was all paid by Chance & Anthem.

16 Q Under the funding agreement, right?

17 A Well, in accordance with the funding

18 agreement, I imagine, yeah.

19 Q If you could please turn to Section 6.3.

20 A Yes, sir. Jessie Parker, that was Jessie's

21 last name. Matt Burrows (phonetic), don't confuse him

22 with Matt Huffman, he was our security man, so we had

23 SOPs for security too, and they would have been

24 proprietary, but also would have been really just for

25 that physical property.

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1 Q Are you at Section 6.3, Business Advisory

2 Board?

3 A Yep.

4 Q It states that, "In addition to a regularly

5 scheduled meeting with the company's employees, a

6 business advisory board, constituted of leading

7 business people from the Salisbury area, will be

8 consulted in order to best advise the managing

9 director as to matters which ought to be considered in

10 making decisions on conducting the business of the

11 company."

12 A Right.

13 Q "And to strengthen the company's ties with

14 the local community."

15 A Correct.

16 Q Was that business advisory board constituted?

17 A I already told you no.

18 Q After consulting with the Wicomico County

19 Chamber of Commence, the following individuals from

20 the Salisbury, Maryland area are being considered to

21 serve on the company's initial business advisory

22 board."

23 Were any of the individuals listed in this

24 section ever consulted by or on behalf of CannaMED

25 about serving on its business advisory board?

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1 A I have no idea.

2 Q Who would know?

3 A I only know one of these guys, Bob Culver.

4 Q Who is Bob Culver?

5 A I know Mike Lewis, the sheriff.

6 Q Was Mr. Culver, the Wicomico County

7 executive, ever consulted about serving on CannaMED's

8 business --

9 A I have no idea whether they did or not.

10 Q Did you ever consult Mr. Culver about serving

11 on CannaMED's business advisory board?

12 A I don't remember doing that. I do remember

13 at one point working on a letter that they wanted to

14 send out to these people, an invitation. But whether

15 or not it ever got mailed or not, I don't know.

16 Q How about Sheriff Michael Lewis, did you ever

17 consult him about serving on a marijuana grower's --

18 A Yeah --

19 Q -- board, advisory board?

20 A -- I met with Mike a couple of times.

21 Q And you discussed with Sheriff Lewis about

22 serving on CannaMED's business advisory board?

23 A Yeah. He said no. He's a hundred percent

24 against cannabis.

25 Q Is there a reason he was listed in a business

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1 plan that was forwarded to --

2 A I guess at this time we thought he would be a

3 good choice. He would be, too. He's probably changed

4 his tune now that he's stuck with medical cannabis.

5 The others ones, I don't know. I only know Bob Culver

6 and Mike Lewis, and I met with Bob Culver, but I don't

7 remember discussing the board with him.

8 Q Who would have developed the list of

9 individuals being considered for the CannaMED business

10 advisory board?

11 A I have no idea. I didn't.

12 Q If you could turn to Section 6.4.4 labeled

13 Organizational Chart.

14 A God, I had no idea so much work went into

15 this. This picture graph? I don't see a 6.4.4. Oh,

16 there it is, Organization Chart, yep.

17 Q Right above it, "Storage of training and

18 other company records."

19 A Oh, okay.

20 Q It says, "All training records will be

21 permanently stored in a fire resistant locked cabinet

22 in the safety compliance manager's office."

23 A Truthful statement.

24 Q Where are those training records located?

25 A There never were any. Again, it's proforma.

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1 Once the company gets going, all training records

2 "will be" permanently stored.

3 Q I missed the part in this section where it

4 says, "Once the company gets going."

5 A Come on, Jesus. Like I said, you've

6 obviously never started a business. But this is the

7 plan, just as though you were building a project.

8 Just like you would have your set of plans and

9 specifications. That's essentially what this is too.

10 All the training records "will be," I don't know where

11 you're going with that, but you certainly -- you're

12 not going to get anywhere with it.

13 Q So there were never any training records ever

14 produced?

15 A No, there were never trainees.

16 Q How about company records, were any company

17 records ever maintained pursuant to this section of

18 the business plan?

19 A No, the business never got started.

20 Likewise, "All company records including

21 product laboratory testing records, financial records,

22 and records relating to distribution and sales will be

23 stored on and off property." Those were provisions

24 within the regulations as I recall. You had to

25 address that. You had to promise that you would

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1 essentially operate in conformance with the

2 regulations. So that's just a promise that we're

3 going to do that.

4 And let me say as a caveat that that may have

5 been a regulation from Delaware that was just carried

6 over into this paper.

7 Q All right. If you turn to Section 7.4.1,

8 Grower facility fast start phase operation, P&L.

9 A Right, Phase I.

10 Q Expenses --

11 A Right.

12 Q -- general, 200,000, what does that mean?

13 A Are you under general building permits you

14 mean? Where are you looking?

15 Q Section 7.4.1.

16 A Oh, 7.4.1.

17 Q It appears to have a list of salaries.

18 A Okay. General.

19 Q General, who would have been general?

20 A No, general is a category.

21 Q Facility manager --

22 A I would have been a general, but I lost the

23 election by a landslide.

24 Q Facility manager, who would that have been?

25 A No sense of humor.

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1 At that point, I don't know. That may have

2 been designated to be Bruce, but at some point we

3 converted that to be CEO/president of the company,

4 which would have been Angeline.

5 Q All right.

6 A I'm guessing, because I don't remember for

7 certain.

8 Q Is the compensation of the managing director

9 laid out in this section of the --

10 A No.

11 Q -- proforma P&L?

12 A No. I wasn't a salaried employee. I don't

13 believe I was a salaried employee.

14 Q You received no compensation for your work

15 with CannaMED Pharmaceuticals?

16 A CannaMED Pharmaceuticals never got started.

17 Nobody ever did any work for CannaMED Pharmaceuticals.

18 I keep saying that to you.

19 Q So you received no compensation for your work

20 on CannaMED?

21 A I didn't say that. I received lots of

22 compensation for my work on CannaMED, but through

23 Chance & Anthem and elsewhere.

24 Q And how was that compensation from Chance &

25 Anthem recorded?

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1 A I don't know what kind of transfers I took

2 from Chance & Anthem, but they are all summarized in

3 the monthly operating reports, because I was in

4 Chapter 11 bankruptcy at the time.

5 Q Who approved your compensation at Chance &

6 Anthem on behalf of the work that you did for

7 CannaMED?

8 A No one, other than me.

9 Q Were any of the investors consulted in

10 connection with your compensation?

11 A I don't know what you mean by "investors."

12 Lenders?

13 Q Were any of the lenders ever consulted in

14 connection with your compensation at Chance & Anthem?

15 A Yeah, I'm sure they were, not formally. No

16 one ever objected.

17 Q Was your compensation ever disclosed to any

18 lenders or investors in Chance & Anthem?

19 A I don't remember disclosing it, no.

20 Q How was your compensation --

21 A Now, wait a minute, remember -- no, you're

22 correct. There were investors in Chance & Anthem. I

23 started to say that I didn't think there were any

24 investors in Chance & Anthem, but I'm wrong.

25 Go ahead, I didn't mean to cut you off.

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1 Q How was your compensation from Chance &

2 Anthem, as a result of your involvement in CannaMED

3 Pharmaceuticals, fixed?

4 A How was it fixed? Chance & Anthem paid me

5 for the work I did on CannaMED, as well as the project

6 house.

7 Q How were those amounts determined?

8 A By me.

9 Q And how were those amounts calculated?

10 A By the time I put into the various

11 enterprises, and also by reimbursement to me for

12 expenditures I made on their behalf.

13 Q Is the time that you put into the various

14 enterprises recorded anywhere?

15 A Yes, all of it was --

16 Q Where?

17 A -- I kept ledgers on that.

18 In my files which, I have no access to

19 anymore.

20 Q Are those the ones you claim were stolen by

21 Robert Gibson?

22 A Yes. And, remember, when you use the word

23 "stolen," I'm a little reticent about saying that,

24 because he was authorized to take the "closed files,"

25 so if he believed the CannaMED or Chance & Anthem

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1 files were "closed files," you really can't accuse him

2 of stealing. That's why I never did a police report.

3 Whatever files he took not believing that they were

4 "closed files," I think you could assign the statement

5 "stolen" to.

6 Q Was Mr. Gibson authorized to take any ledgers

7 relating to the time that you invested in Chance &

8 Anthem?

9 A Specifically, no, of course not.

10 Q And how were those records maintained?

11 A They were in files, and I maintained them.

12 Any business records I maintained. Any of the non-law

13 office business records, I maintained.

14 Q How did you record the time that you spent

15 working on Chance & Anthem or CannaMED projects?

16 A On ledgers. There may have been some

17 payments to me that were done under a different regime

18 at some point, but I would general equate the time

19 expended in determining the payments that I took.

20 Q Were these ledges notebooks? Were these

21 ledgers loose-leaf ledgers? What did the ledgers look

22 like?

23 A Within the files, they were in small black

24 and white -- and I don't have one with me today, but

25 I buy them for a dollar apiece at Staples or Office

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1 Depot, the things you'd buy when you went to grade

2 school.

3 Q And how did you record the time in these

4 ledgers?

5 A By pen.

6 Q And in increments -- what were the increments

7 of time that these ledgers were recorded in?

8 A It depends. If I was making a trip to

9 Maryland, for instance, or another trip out of town on

10 behalf of the company, I would just, you know, record

11 it by the day. Usually tenths of an hour, like I keep

12 my law office records.

13 Q Do you keep your law office records in a

14 similar --

15 A No, not all always. There I use printed up

16 forms that comported with, you know, the bar rules,

17 essentially. But I do buy -- everybody teases me

18 because I buy those little black and white -- I forget

19 what they call them, but, you know, they are little

20 books that you would get in grade school.

21 Q And the time that you charged to Chance &

22 Anthem or CannaMED --

23 A I never charged anything to CannaMED.

24 Q The time that you charged to Chance & Anthem

25 for work that you did on CannaMED -- is that correct?

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1 A Okay.

2 Q -- at what rate would you have charged that

3 time to CannaMED?

4 A I don't remember. Depends on what I was

5 doing, I guess. So if I was on a trip, I never

6 charged more than a thousand dollars a day. But if I

7 was doing legal work, I probably charged $450 an hour,

8 at the end. At the beginning, probably around 300.

9 Q Was your compensation disclosed in this

10 company business plan?

11 A I don't -- I don't understand the question,

12 because I told you I wasn't supposed to get

13 compensated by CannaMED.

14 Q You were being compensated by Chance &

15 Anthem?

16 A Right. And other entities for other work.

17 Q Who was compensating you for work done on

18 CannaMED? Chance & Anthem?

19 A Chance & Anthem, but maybe also Sovereign,

20 back when Sovereign was the party to the real estate

21 contract. I think that's it. Yeah.

22 Q Were these arrangements ever reduced to

23 writing?

24 A Only by notes really. There was never a

25 formal letter from me to me. But you could glean the

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1 arrangement by just looking at all the time sheets.

2 Q So these were simply arrangements you made

3 with yourself?

4 A Interesting question, you know, because I

5 wore a couple of hats. So you could say,

6 hypothetically I guess, that, you know, I, wearing my

7 blue hat, made it with I, wearing my beige hat. I

8 don't know, I wore different hats. But your question

9 is best answered this way, I controlled the

10 arrangement.

11 Q There was no other individual human being

12 that was involved in fixing or approving your

13 compensation?

14 A Correct. I controlled the arrangement.

15 Q And is the arrangement for your compensation

16 disclosed anywhere in the company's business plan?

17 A No. Because as I told you now three times,

18 Jesus, I wasn't getting compensated by CannaMED, and

19 you're holding up the CannaMED business plan.

20 Q So the answer is no?

21 A The answer is no.

22 Q Okay.

23 A But for the reasons that I stated, and don't

24 paraphrase me when you do some kind of a motion

25 either. Make sure you present the entire explanation.

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1 Q The final attachment to this e-mail is your

2 resume; is that correct? You have it in front of you.

3 A Yes, dated 2015.

4 Q All right. And there you claim to be the

5 president of Chance & Anthem?

6 A Do I? I didn't do this resume.

7 Q Oh, you didn't prepare this resume?

8 A No.

9 Q Who prepared this resume?

10 A I have no idea.

11 Q You did forward your own resume to a

12 potential investor in Canada?

13 A Are you talking about this resume?

14 Q Yes.

15 A I guess it was part of the package, yeah.

16 Q Mm-hmm.

17 A Where does it say I'm president?

18 Q Current civic and business.

19 A Director, director, director, director,

20 president, Chance & Anthem, okay.

21 Q All right.

22 A President, CannaMED, hmm. I might have been

23 the president at that time, I guess. Well, only

24 briefly for CannaMED, because Angeline Nanni became

25 president and CEO by the time we submitted our

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1 application.

2 Q It says that Chance & Anthem is a real

3 property holding and development company.

4 A It was at the time, yeah.

5 Q Right. At the time did it make any reference

6 to Chance & Anthem's funding arrangement with CannaMED

7 Pharmaceuticals?

8 A Well, I mean, in the rest of the package that

9 got mailed, I guess it did. I mean, look at the

10 facts.

11 Are you picking on this explanation in what

12 purports to be my resume?

13 Q Is this your resume or not your resume?

14 A It looks pretty accurate. I mean, it's not

15 totally accurate. I see some missing things and

16 errors. But it's substantially correct.

17 Q Up top, above Chance & Anthem, it says --

18 A I don't know what this means, Chair pro-bono

19 committee member, federal bar association, I mean

20 that's obviously -- that doesn't make sense to me.

21 Chair, I chaired some pro-bono committee? Member?

22 Q Mr. Siskind it's your resume.

23 A Yeah, I didn't write this. Somebody wrote it

24 for me, I guess.

25 Q You forwarded it to an investor?

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1 A Did I? I guess that man didn't invest,

2 though, did he? So he wasn't an investor. He was a

3 prospective investor, wasn't he?

4 Q Up top it says, above Chance & Anthem, it

5 says that you were a "Director of the Florida

6 Association of Community Banks and Credit Unions" --

7 A Okay.

8 Q -- comma "a trade association representing

9 local banking institutions."

10 A Okay. Maybe I was a director. I don't know,

11 I could look it up. Look it up on SunBiz.

12 Q What local banking institutions were

13 represented by the Florida Association of Community

14 Banks and Credit Unions?

15 A If every -- well, first of all, I decline to

16 give you names, but -- and I see you smiling at me,

17 like, "Oh, we gotcha you here," but, no, the

18 association represented all community banks and credit

19 unions.

20 Q "All" community banks and credit unions?

21 A That's correct --

22 Q Were any of these --

23 A -- that was the mission.

24 Q Were any of the community banks and credit

25 union aware that they were being represented --

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1 A Yes.

2 Q -- by the Florida Association of Community

3 Banks and Credit Unions?

4 A Yes.

5 Q Which one?

6 A I'm not going to disclose the individual

7 institutions and what their membership association

8 was, because it's outside the scope of the 2004.

9 Q I'm simply trying to determine whether

10 CannaMED, through you, made a misrepresentation to a

11 potential investor?

12 A First of all, this would have been Chance &

13 Anthem's representation, not CannaMED. CannaMED never

14 represented anything to anybody. Your real question

15 is whether Chance & Anthem misrepresented.

16 Q Did Chance & Anthem misrepresent?

17 A I don't believe so. I wish I had the files

18 from Florida Association of Community Banks and Credit

19 Unions, because I can tell you there were lists in

20 there of the various banks and the roles which we

21 assigned to them. And, then, come to think of it, we

22 had a huge undertaking and we spent a lot of money on

23 but never did --

24 Q Who is "we"?

25 A The company, that's the company "we."

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1 Q Oh, the company "we." No other individuals

2 involved in the company?

3 A Well, yeah, a lot of other people were

4 involved.

5 Q Like who?

6 A People in the office that helped with this --

7 I'm about to tell you about this conference that we

8 were going to have down at Ocean Reef Club. I can't

9 remember what year it was, but we actually did an

10 expensive mailing on it, but there weren't enough

11 people that were interested in coming, so we cancelled

12 it. But, yeah, none of that was ever e-mailed, so --

13 but there was a legitimate business there. You can

14 try to say otherwise. But I don't think you'll get

15 very far. Even though you are smirking at me.

16 Q Mr. Siskind, I don't know what you're talking

17 about.

18 A You're smirking.

19 Q I'm just trying to take a deposition.

20 A I know when you're smiling and when you're

21 smirking and when you're not.

22 Q I've marked as Exhibit 5 a document. Please

23 review it.

24 (Thereupon, a document was marked as Exhibit

25 No. 5 for identification by Mr. Suarez.)

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1 THE WITNESS: Okay. Mortgage program.

2 BY MR. SUAREZ:

3 Q Would you please identify the document marked

4 as Exhibit 5.

5 A It looks like something involving -- oh,

6 okay. Looks like something else that was shared or

7 created with or by Mr. Mayer at the Wharton Companies

8 again.

9 Q Well, this is an e-mail from you to

10 Mr. Mayer.

11 A Correct. Okay. Attached to which are some

12 documents that eventually found their way into the

13 application.

14 Q Are these documents that you created?

15 A No.

16 Q Who would have created these documents?

17 A Someone in the office.

18 Q And how would they have sent you these --

19 A Oh, no, wait a minute. Like I said to you

20 before, the P&L I did.

21 Q How about on the next page, the document

22 entitled Sovereign Gaming & Entertainment, LLC, did

23 you create that document?

24 A I don't remember.

25 Q How would you have received this document?

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1 A Well, if I didn't create it -- now, I can

2 tell you, I've seen this before, but I don't remember

3 if I actually wrote it.

4 Q Sir, you attached it to an e-mail and sent it

5 to Mr. Mayer and Angeline Nanni on March 21, 2016.

6 How would you have obtained this document if

7 you didn't create it?

8 A Anybody in the office could have created it.

9 We probably worked on it jointly, but I obviously had

10 knowledge of it, because I don't think anybody would

11 have sent anything out under my e-mail. In fact, I

12 know for a fact that if I e-mailed it, I reviewed it.

13 Q Where would the file CannaMEDmortgage14 program.pdf have been stored when you attached it to

15 this e-mail?

16 A I have no idea. Well, on my computer, I

17 guess. Where do you see that?

18 Q The e-mail, it says "Attachments."

19 A I don't see that.

20 Q There is a --

21 A Oh, I do see it, yeah, yeah, yeah.

22 CannaMEDmortgageprogram.pdf, would have been

23 on the old computer.

24 Q Which old computer is that?

25 A The computer that I believe is now missing

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1 forever.

2 Q How did that computer go missing again?

3 A I have no idea. It was left at the property,

4 I presume.

5 Q Got it.

6 A But I can tell you that these are the figures

7 that I worked up. No one else worked up the proforma

8 figures except me, but this looks like it was way back

9 in the beginning where it wasn't really fleshed out.

10 Yeah, this was way back in the beginning. So this

11 would have been sent to Mayer for approval, I would

12 imagine. In fact, these were the pictures that I

13 believe we got from the sales brochure of the

14 building, yeah.

15 Q The second page says, "Executive Summary" --

16 A Second page? Oh, yeah.

17 Q Second attachment.

18 A Didn't we see this before?

19 Q Second paragraph from the bottom, it says,

20 "CannaMED is owned and operated by Jeffrey Siskind."

21 A Yeah, it does say that.

22 Q Is that an accurate statement?

23 A No. I don't know if it's accurate or not at

24 that time.

25 Q Who owned CannaMED at that time?

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1 A Remember, I formed CannaMED. So I don't know

2 the date of this. March 21, 2016. I presume it's

3 accurate. I don't believe I wrote this.

4 I think what you're looking at here is ideas

5 we came up with to send to John Mayer to give him

6 information as to how to go about writing his

7 executive summary. So this was never sent to an

8 investor. Your statement was incorrect. This was

9 sent to the finder, okay, with which he prepare --

10 maybe he relied on this to some extent to prepare his

11 executive summary.

12 Q And what was the finder supposed to find?

13 A Money.

14 Q Investments?

15 A Well, loans or investments.

16 Q Okay.

17 A And, like I said, he didn't find anything.

18 Well, that's not quite true. He did come up with

19 somebody, but the participation was objectionable.

20 Q Who is Frank Wise?

21 A Frank is the attorney for -- I forget the

22 name of company, 3VGen, does that -- yeah, 3VGen, LLC.

23 (Thereupon, a document was marked as Exhibit

24 No. 6 for identification by Mr. Suarez.)

25 BY MR. SUAREZ:

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1 Q Please review the document I've marked as

2 Exhibit 6?

3 A 3Gen VC, LLC, yeah, I remember this.

4 Q All right. The attachment is dated August 2,

5 2016 --

6 A Correct.

7 Q -- and is referred to in your e-mail as a

8 subscription agreement, short-form subscription

9 agreement.

10 A Correct, I remember this.

11 Q Who prepare the short-form subscription

12 agreement attached to this e-mail?

13 A I did this.

14 Q Were there any other short-form subscription

15 agreements prepared for CannaMED?

16 A Oh, yeah, very definitely.

17 Q And to whom were they circulated?

18 A The one that mirrored this one was to -- I

19 cannot remember the name of the company. They were

20 one of mortgagees on the project house. Mike Kamentiz

21 is the -- was the person I dealt with at that company,

22 and then there was something similar also sent to the

23 Delaware investor.

24 Q Who was the Delaware investor?

25 A I think that's all of our investors.

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1 I can't remember him name.

2 I think that's everybody.

3 Q The file that's attached to this e-mail

4 3Gensubscript.docx --

5 A This?

6 Q Yes.

7 A Yeah.

8 Q Where is that file located?

9 A I have not seen this file. When I went

10 looking for stuff for you, I couldn't find it.

11 Q On August 2, 2016 what computer were you

12 using?

13 A I have no idea. I was using three different

14 computers, home, office, and the Maryland computer.

15 Q And were the files in any way networked?

16 A No --

17 Q Were they stored --

18 A -- I'm trying to figure out how to do that.

19 I'd love to be able to do that.

20 Q -- on a cloud?

21 A No. And I don't store stuff in the cloud

22 intentionally.

23 Q Because it might be lost?

24 A No, because I'm distrustful of the cloud.

25 You know, I'm trying to figure out how to back up my

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1 stuff on a cloud.

2 Q Did 3Gen execute this subscription agreement?

3 A I don't remember whether they did or not.

4 3Gen was operated by a good friend of mine, a guy by

5 the name of Richard Swirnow, who I've known for years.

6 Whether he actually signed this, I can't remember.

7 Q That's Swirnow Capital?

8 A Yes.

9 (Thereupon, a document was marked as Exhibit

10 No. 7 for identification by Mr. Suarez.)

11 BY MR. SUAREZ:

12 Q Please review the document I've marked as

13 Exhibit 7.

14 A Oh, okay, this is the other person I was

15 talking about.

16 Q And who is this person?

17 A I can't remember the name of the entity.

18 This is like a working document. It doesn't have it.

19 But Mike Kamenitz, if you look at who this document

20 was sent to, Blake, Jeff, and Kamcorp are Blake, Jeff,

21 and Mike. I think Blake and Jeff are lawyers and Mike

22 is the person on the ground more or less, and, right,

23 they put up a hundred thousand.

24 Q And how were those hundred thousand dollars

25 funded?

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1 A Checks, wires, I don't know --

2 Q Where was that money --

3 A -- probably wire.

4 Q -- deposited?

5 A I don't remember.

6 Q Was it deposited in Chance & Anthem's bank

7 account?

8 A I don't remember.

9 Q Would it --

10 A You're talking about years ago.

11 Q Would it have been deposited anywhere other

12 than Chance & Anthem's bank account?

13 A Yeah. It could have gone into one of the

14 other entities or my trust account. It would not have

15 gone into any CannaMED account, if that's what you're

16 looking at, because there was none.

17 Q Well, if it had gone into your trust account

18 how would that transaction been recorded?

19 A By me or by the bank?

20 Q By you, sir?

21 A Well, it would have been ledgered, obviously.

22 Q And where are those ledgers?

23 A That's a good question. We've been over and

24 over that, haven't we? Right?

25 Q Is that part of ledgers that you contend were

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1 taken by Mr. Gibson?

2 A Yes, exactly.

3 Q Were you ever counsel to 3Gen?

4 A No.

5 Q And did they engage in any transactions with

6 anyone other than Chance & Anthem, to your knowledge?

7 A Not to my knowledge, no.

8 Q The second -- or rather the attachment to

9 this e-mail relates to the sale by Chance & Anthem of

10 two non-dilutable units of CannaMED Pharmaceuticals.

11 A Right, 50,000 a unit.

12 Q Which units comprise two percent of the total

13 outstanding units of CannaMED.

14 A Correct.

15 Q Did Chance & Anthem, in fact, sell those two

16 non-dilutable units of CannaMED to 3Gen?

17 A Yes, with an option for two more.

18 (Thereupon, a document was marked as Exhibit

19 No. 8 for identification by Mr. Suarez.)

20 BY MR. SUAREZ:

21 Q Please review the document I've marked as

22 Exhibit 8.

23 A Oh, yeah, I forgot about this.

24 Q What is this?

25 A This is -- I thought this was Mayer, but

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1 maybe it's a different person, I don't know.

2 Q Meyers & Associates, L.P.

3 A Oh, he was related to Mayer somehow. Mayer,

4 I think, when he was getting involved with us to try

5 to raise some capital, worked with this person from

6 New York.

7 Q Is this John Telfer?

8 A I guess so. I don't recognize that name, but

9 probably.

10 Q Was this agreement ever executed?

11 A I don't remember executing it. It may have

12 been, but we never got any money out of these people.

13 Q Did you ever provide them with any

14 information about CannaMED and Chance & Anthem?

15 A I don't think so. I can't swear to that.

16 But I would presume anything they got went through the

17 Wharton Company.

18 Oh, here, it says here that there's a working

19 relationship with Wharton Capital Partners.

20 Q Sir, from what computer did you retrieve this

21 document?

22 A Well, this was with the e-mails that I sent

23 you, so this would have been on my computer.

24 Q When you refer to "my computer," where is

25 that computer located?

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1 A My home now. It was the office computer.

2 I see you circled CannaMED Farms, by the way.

3 Q Oh, did I give you my copy? Yeah, I think I

4 marked my copy.

5 A I don't know what that was. That seems

6 familiar to me, CannaMED Farms, but I don't remember

7 ever forming CannaMED Farms. I think maybe that was

8 something we were talking about doing in Florida. But

9 this would have been a misnomer, because this

10 individual was never hired to obtain any money for any

11 Florida operation. We just never went ahead with

12 anything in Florida.

13 See, he hid all those files, making me think

14 this was a going to be a quick deposition. Are these

15 the exhibits that are going to go to the reporter?

16 Q Typically the marked ones, yes.

17 A So we should probably get rid of some things

18 now, before they start getting intertwined with my

19 stuff. You know what, I'm screwing up a little on 5.

20 I only have the cover sheet. Oh, I think this went

21 with 5. I don't know what went with 5. I'm presuming

22 that maybe 5 was everything with this big clip.

23 Q Yeah, there was a big -- here, I'll tell you

24 what it is.

25 A Oh, okay. Well, this went with the executive

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1 summary.

2 Q No, No. 4. Four is the one with the big

3 clip. It's an e-mail you sent on February 4th?

4 A Is that the next page on 4, executive

5 summary?

6 Q The next page on 4 is the executive summary.

7 A Then what --

8 Q Then the appraisal.

9 A Oh, okay, all of this.

10 Q The appraisal, the purchase option.

11 A Right.

12 Q A letter from the City of Salisburg (sic) to

13 you.

14 A Salisbury, a zoning letter.

15 Q And then the company business plan, and your

16 resume is the last part of that exhibit.

17 A I'm glad we said something now. All right.

18 So there's 4, so what was 5?

19 Q There's 3.

20 A Three looks in tact.

21 Q Five is an e-mail that you sent to

22 jmayer@whartoncompanies.com and Angeline Nanni on

23 March 21st. You got it right there in front of you.

24 A Oh, okay, that's it. That's all there is?

25 Q And the attachment is Sovereign Gaming &

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1 Entertainment.

2 A Okay. So we're good.

3 Q Who is Ken Bortnick?

4 A Ken Bortnick is, I think, an eye doctor in

5 Salisbury. Ken Bortnick? Yeah, I'm pretty sure

6 that's him. Yeah, he was interested. We never did

7 anything with him, luckily.

8 Q Why do you say "luckily"?

9 A Because I -- he was, you know -- he's just

10 another sweet guy, just like Alan Bias, who was very

11 interested, but because things didn't go successfully

12 there, I'm glad that he didn't get involved.

13 (Thereupon, a document was marked as Exhibit

14 No. 9 for identification by Mr. Suarez.)

15 BY MR. SUAREZ:

16 Q Please review the document that I've marked

17 as Exhibit 9.

18 A Okay.

19 Q Is this an e-mail you sent to

20 Kenbortnick@comcast.net on October the 29th of 2015?

21 A Yeah, it looks like it. Oh, it's the same

22 document we sent to the other guy.

23 Q What is C&A Holdings?

24 A That was the entity that we were forming to

25 somehow be involved with this --

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1 Q Was it --

2 A -- it ended up not being though.

3 Q On the following page, there's an executive

4 summary that we've been through before.

5 A Right. What's it say?

6 Q It says there at the top, "C&A Holdings, also

7 known as Chance & Anthem, LLC."

8 A Right.

9 Q So would C&A Holdings be the same as Chance &

10 Anthem, LLC?

11 A I guess we didn't use the C&A Holdings

12 acronym. We just used -- or whatever you call it --

13 we just used Chance & Anthem instead, yeah, correct.

14 Hmm, I forgot about that.

15 Q In this version of the executive summary, if

16 you look to the bottom, second paragraph from the

17 bottom, it says "C&A was formed 2014 to function as a

18 1031 exchange intermediary."

19 A I don't think that's correct. I don't think

20 we formed C&A until 2016. That's not right. We did

21 have a 1031 intermediary, and I don't know what the

22 name of it was.

23 Q It wasn't Chance & Anthem, LLC?

24 A I don't think so. Maybe it was. I don't

25 remember. I guess this was before we got money to get

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1 the building. 2015, so maybe I did I form Chance &

2 Anthem in 2014. I don't remember.

3 Q All right. Who is Richard Bardenstein?

4 A I have no idea.

5 (Thereupon, there is an inaudible discussion

6 off the record between Mr. Suarez and Mr. Barbee.)

7 BY MR. SUAREZ:

8 Q When did you retain Mr. Mayer to produce

9 documents for Chance & Anthem?

10 A I don't remember.

11 Q Was it in 2016?

12 A I don't remember. I would have thought it

13 was earlier than that. I can tell you it was after

14 Chance & Anthem purchased the project house, because

15 Jonathan Mayer came through someone who was employed

16 to work on the project house.

17 (Thereupon, a document was marked as Exhibit

18 No. 10 for identification by Mr. Suarez.)

19 BY MR. SUAREZ:

20 Q Did I already asked you who Richard

21 Bardenstein was?

22 A You did.

23 Q And you said?

24 A I said what I said.

25 Q Who is Richard Bardenstein?

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1 A You asked me that already.

2 Q Would you please indulge me and answer it

3 again?

4 A I have no idea.

5 Q I've marked as Exhibit 10 an e-mail that you

6 sent to Richard Bardenstein. Take a second to review

7 it.

8 A Jerusalem. Wow, no kidding. I have no idea

9 who this person is. This might have been somebody I

10 met in Israel when I went there.

11 Q Why would you have sent Mr. Bardenstein a

12 business plan?

13 A I have no idea.

14 Q Do you contend that CannaMED's business plan

15 is proprietary?

16 A I contend that CannaMED's application, which

17 contains portions or all the business plan is

18 proprietary.

19 Q But not the actual business plan itself?

20 A Well, I don't real really care about the

21 business plan. I mean, you know, I think my numbers

22 should be proprietary. As for the rest of it, it's

23 pretty much what everybody else is doing nowadays.

24 Q Well, the numbers are numbers that are

25 attached to the debtor, Chance & Anthem's, schedules,

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1 numbers that you've attached to the --

2 A Oh, yeah, yeah, yeah.

3 Q -- Chance & Anthem schedules?

4 A So what's proprietary anymore?

5 I would have to say in order to -- I guess my

6 duty is to say yes as to anything that's not otherwise

7 published.

8 Q And who makes the decision to publish or not

9 publish CannaMED's proprietary information?

10 A That's a good question, but I don't know how

11 to answer that. You know, who makes the decision?

12 Different things were published at different times as

13 we've seen here. If you --

14 Q Was there an individual, other than yourself,

15 that was involved in publishing CannaMED's proprietary

16 information?

17 A Oh, sure. Sure.

18 Q Who?

19 A Bruce Lowe.

20 Q Anyone else?

21 A Angeline Nanni, and the different employees

22 that worked with us to try to establish ourselves in

23 Maryland, like, Hal.

24 Q What would Mr. Lowe have published?

25 A Oh, I don't know, a lot of this stuff Bruce

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1 worked on, if not, in fact, wrote.

2 Q Did Mr. Lowe ever independently from you make

3 the decision to make any of this information public?

4 A I don't know.

5 Q How about Ms. Nanni?

6 A I don't know what Angeline did. I will say

7 this, that I'm sure anything she did was in the best

8 interest of the enterprise.

9 Q Was Mr. Bardenstein representing an investor

10 or a potential investor in CannaMED or --

11 A I told you already a couple of times, I don't

12 know who he is.

13 Q How about haybenfc1@aol.com?

14 A Can I see it?

15 Q Sure.

16 (Thereupon, a document was marked as Exhibit

17 No. 11 for identification by Mr. Suarez.)

18 BY MR. SUAREZ:

19 Q It's somebody that you sent the company's

20 business plan to on December 29, 2015?

21 A Hayben, I have no idea who this is.

22 Haybenfc1, something financial consultants? I have no

23 idea.

24 Q Your e-mail makes reference to a website,

25 Cannamedpharmaceuticals.com.

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1 What happened to that website?

2 A I have no idea, probably discontinued. It

3 was a great website. It was done by Bruce. It was a

4 great website.

5 Q Hayden, haydenfc1.

6 A Haydenfc1.

7 Q Who is haydenfc1?

8 A I have no idea. Now, this time I made you

9 smirk. You didn't see that coming? I really have no

10 idea. So maybe the first one bounced back, you think?

11 Q Yeah, so I take it haydenfc1 never invested

12 in CannaMED or Chance --

13 A I don't think so --

14 Q -- & Anthem or never --

15 A -- send an e-mail to them and say, "Who are

16 you?" Say, "We're investigating CannaMED and Jeff

17 Siskind, did you ever do any business with him?"

18 MR. SUAREZ: All right. Let's take five.

19 I'm plugging along here. We're doing an hour at a

20 time. We've made headway. Let's take a five-minute

21 break.

22 (Thereupon, a brief recess was taken.)

23 MR. SUAREZ: Back on the record.

24 (Thereupon, a document was marked as Exhibit

25 No. 12 for identification by Mr. Suarez.)

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1 BY MR. SUAREZ:

2 Q Look at Exhibit 12, please.

3 A Yeah.

4 Q Is this a Chance & Anthem withdrawal slip?

5 A Yeah. It's not my writing, but yes.

6 Q Whose writing is that?

7 A I have no idea.

8 Q Who besides you had authority to withdraw

9 money from Chance --

10 A That's my signature. Somebody wrote it out

11 for me, that's all.

12 Q Why did Chance & Anthem purchase a cashier's

13 check for Mercedes Benz of Palm --

14 A Oh, was it --

15 Q -- Beach?

16 A -- for a cashier's check? I don't know. We

17 purchased a Mercedes SUV to replace the Lincoln that I

18 gave it Bruce to take up to Maryland to use for the

19 company.

20 Q In whose name was the Mercedes titled?

21 A In the trust.

22 Q And what's the trust's name?

23 A Second Siskind Family Trust.

24 Q Does the Second Siskind Family Trust still

25 own that Mercedes?

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1 A Yes, worth about $30,000. It's got a lien on

2 it for about that amount.

3 Q What kind of Mercedes is it?

4 A GLE 350.

5 Q How many miles does it have?

6 A I have no idea.

7 Q What year is it?

8 A 2016.

9 Q If it was paid for with Chance & Anthem

10 funds, why does the Mercedes have a lien on it?

11 A I borrowed against it at some point.

12 Q And what were the funds borrowed against it

13 used for?

14 A I don't remember, um -- I don't remember.

15 Q Who drives the car now?

16 A My wife.

17 Q What is your wife's name?

18 A Tanya.

19 (Thereupon, a document was marked as Exhibit

20 No. 13 for identification by Mr. Suarez.)

21 BY MR. SUAREZ:

22 Q Please take a look at the document I marked

23 as Exhibit 13.

24 A Okay.

25 Q It's a withdrawal slip --

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1 A Correct --

2 Q -- in the amount of $5,000.

3 A -- that's my writing.

4 Q All right. And is that your signature?

5 A Well, I don't know about the 5,000. But

6 Chance & Anthem is my writing.

7 Could be my signature, I don't know. It

8 doesn't look very much like my signature, but nobody

9 would have been able to get money from SunTrust except

10 for me.

11 Q All right.

12 A So it's just a lousy version of my signature.

13 Q What happened to those $5,000?

14 A I have no idea.

15 Q What were those $5,000 used for?

16 A I have no idea.

17 Q What was the purpose of withdrawing $5,000 in

18 cash from Chance & Anthem's bank account?

19 A I would presume it was to pay some expenses

20 from Chance & Anthem, but I'm not sure.

21 Q What expenses would you have paid on behalf

22 of Chance & Anthem in cash?

23 A Travel expenses, probably.

24 Q What travel expenses?

25 A Usually I would go to Maryland and back. I

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1 might have gone to some sort of conference.

2 Q In November of 2015, why would you have gone

3 to Maryland?

4 A I have no idea.

5 Q And what --

6 A Oh, and it could be -- actually, it could

7 have been cash to use towards to the house project

8 too. I don't know. I didn't realize it was back in

9 2015.

10 Q What expenses of the house project, did you

11 pay in cash?

12 A I have no idea.

13 Q Did you pay any expenses of the house in

14 cash?

15 A Sure.

16 Q Such as?

17 A Occasional labor.

18 Q And who was the labor that was paid in cash?

19 A I have no idea. They were all Hispanic

20 names.

21 Q How, if at all, were those labor payments

22 reported to the taxing authorities?

23 A Why would they have been?

24 Q How, if at all, were the payments reported to

25 the taxing authorities, is the question.

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1 A Which taxing authorities are you talking

2 about?

3 Q Any taxing authority.

4 A I have no recollection.

5 Q Did you ever, on behalf of Chance & Anthem,

6 pay taxes on wages paid to day laborers?

7 A No, huh-uh.

8 Q Did you issue 1099s to those day laborers?

9 A No, never. Nobody ever made more than $600.

10 Q Do you recall the name of any of the day

11 laborers?

12 A No. That was years ago.

13 Q Are those the ones that you described as

14 "Hispanic names"?

15 A Mostly Hispanic, I think.

16 Q And how do you determine that a name is a

17 Hispanic name?

18 A Because it sounds Hispanic. I'm a human

19 being. I know what sounds Hispanic.

20 Q Do all of the Hispanic names sound the same

21 to you?

22 A Not all. Most.

23 MR. SUAREZ: Is this 15 or 14?

24 MR. BARBEE: Fourteen, 13 is the one you just

25 did.

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1 (Thereupon, a document was marked as Exhibit

2 No. 14 for identification by Mr. Suarez.)

3 BY MR. SUAREZ:

4 Q On November 23, 2015 you withdrew another

5 5,000 in cash from Chance & Anthem's bank account.

6 A Okay.

7 Q What was the purpose of that withdrawal?

8 A I don't remember.

9 (Thereupon, a document was marked as Exhibit

10 No. 15 for identification by Mr. Suarez.)

11 BY MR. SUAREZ:

12 Q On April 27th of 2015, you withdrew another

13 $4,000 -- I'm sorry, $40,000 from Chance & Anthem's

14 bank account.

15 Do you know what the purpose of that

16 withdrawal was for?

17 A No, what's that -- oh, that's my driver

18 license number. No. Maybe a transfer, probably a

19 transfer. But I don't think I would have withdrawn

20 $40,000 cash. I never remember walking out of the

21 bank with $40,000 cash. This was probably the

22 purchase of a cashier's check.

23 Q And what would that cashier's check have been

24 used for?

25 A I have no idea. Or it may have been a

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1 transfer into a different account. You'll have to

2 check that against the account records you have. In

3 fact, all of these could have transfers.

4 Q The document actually says "cash."

5 A Yeah. It would have been a cash withdrawal

6 and then a cash deposit, if we needed the money for

7 something else at that time, like if a bill would come

8 up, we were trying to get something done. In fact, I

9 would say all these need to be -- except for the car,

10 need to be looked at in conjunction with all the other

11 account records you have to see if there's a

12 corresponding deposit. I can't do that, because you

13 have the records and I don't.

14 Q These are all cash withdrawals, sir.

15 A Yeah, well, that's right. I do remember --

16 Q Would you have deposited it in another Chance

17 & Anthem bank account?

18 A No.

19 Q No.

20 A If that were a cash withdrawal from Chance &

21 Anthem, it went into a different account. It would've

22 either had to not gone into a different account, or

23 gone into a different account at SunTrust -- and I

24 don't know why you're smirking, because I can tell

25 you, like I started to tell you, I did not walk out of

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1 the bank with $40,000. Five thousand dollars, maybe.

2 But you need to check the other accounts for which you

3 have the records to see if there's a corresponding

4 deposit.

5 MR. BARBEE: There's no deposits.

6 THE WITNESS: No corresponding deposits?

7 MR. SUAREZ: There are no corresponding

8 deposits.

9 THE WITNESS: Well, you'll have to prove that

10 to me.

11 MR. SUAREZ: No, actually --

12 THE WITNESS: Because I can tell you --

13 MR. SUAREZ: Actually, sir, I don't have to

14 prove anything to you.

15 THE WITNESS: Well, then don't.

16 BY MR. SUAREZ:

17 Q I'd like to know --

18 A I can tell you this, I didn't walk out of --

19 Q -- why you withdrew $40,000 from the debtor's

20 bank account and can't explain where it went.

21 A Well, because it's in 2015 for one thing.

22 Q Well, 40,000 is a pretty significant sum of

23 money.

24 A Yeah.

25 Q It's a notable sum of money.

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1 A Yeah, well, I can tell you, I didn't walk out

2 of the bank with $40,000. That would have been a big

3 roll of cash.

4 Q So what did you do with it?

5 A I don't remember. But I can tell you this,

6 it was used for a business purpose. I didn't gamble

7 it away. I didn't buy drugs.

8 Q What business purpose was that?

9 A I don't remember.

10 Q All right.

11 A I'll tell you this, if you provide me with

12 the banking records you got, I could look and probably

13 discern what that was used for.

14 Q That is the banking record I have, a 40 --

15 A No, no, you have all the records from all the

16 accounts.

17 Q You have a $40,000 cash withdrawal that you

18 can't explain where it went.

19 A Yeah, because it was three years ago.

20 Q Okay.

21 A Okay. But I can tell you --

22 Q How frequently --

23 A -- like I said three times --

24 Q -- do you withdraw $40,000 from a bank?

25 A I don't know what "frequently" means.

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1 Q In any event, have you ever withdrawn $40,000

2 from a bank account?

3 A Well, it looks like I did here, but I didn't

4 remember this until you showed it to me.

5 Q Mm-hmm.

6 A Do you think that's a bad thing to do? It

7 was obviously needed for something. Now, you say that

8 it wasn't re-deposited into another account. Maybe it

9 wasn't, but then a cashier's check might have been

10 purchased with it.

11 (Thereupon, a document was marked as Exhibit

12 No. 16 for identification by Mr. Suarez.)

13 BY MR. SUAREZ:

14 Q I have another withdrawal slip --

15 A I can tell you one thing about that 40,000,

16 it didn't go in my personal accounts, unless it was

17 reflected on my debtor-in-possession reports.

18 Q -- dated December 2, 2015.

19 A Okay. This is a series of $5,000

20 withdrawals. Do you realize that? Every two weeks it

21 looks like, 11/13, 11/23, and December 2nd of 2015.

22 So I don't remember what these were for, but they were

23 for something obviously.

24 Q You don't recall why you went into the bank

25 every other week and withdrew $5,000 and can't account

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1 for how it was used?

2 A No. But we may have had a payroll account at

3 that time, ah -- we did have a payroll account at

4 SunTrust. These payments may have gone into the

5 payroll account.

6 Q Who is "we"?

7 A The company.

8 Q Chance & Anthem?

9 A I don't know who owned the payroll account.

10 Q Well, CannaMED you said didn't have any bank

11 accounts.

12 A And this was way -- no, CannaMED did not have

13 any bank accounts. I don't need to say that again.

14 I've told you that at least five times today.

15 Q So if it wasn't CannaMED and it wasn't Chance

16 & Anthem, whose bank accounts would have been funding

17 the payroll?

18 A I didn't say it wasn't Chance & Anthem. It

19 may have been Chance & Anthem. There was a payroll

20 account at SunTrust. I remember issuing payroll

21 checks out of a SunTrust account. So look at that or

22 provide me with the records you got from the banks,

23 and I'll look at it.

24 (Thereupon, a document was marked as Exhibit

25 No. 16 for identification by Mr. Suarez.)

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1 BY MR. SUAREZ:

2 Q I've marked as Exhibit 16 Chance & Anthem

3 bankruptcy petition, which you signed.

4 A Yeah.

5 Q And I'll mark as Exhibit 17 Chance & Anthem's

6 bankruptcy schedules which you signed.

7 (Thereupon, a document was marked as Exhibit

8 No. 17 for identification by Mr. Suarez.)

9 THE WITNESS: You gave me two copies of one

10 of them.

11 MR. SUAREZ: You can give me one back. You

12 only need one.

13 THE WITNESS: You gave me three copies, and

14 they are mine now. I'm not giving them back.

15 MR. SUAREZ: That's okay I have more.

16 THE WITNESS: There, two copies back.

17 MR. SUAREZ: And I'll mark as Exhibit 18, the

18 amended schedules for Chance & Anthem that you signed.

19 (Thereupon, a document was marked as Exhibit

20 No. 18 for identification by Mr. Suarez.)

21 BY MR. SUAREZ:

22 Q Is this alleged payroll account at SunTrust

23 Bank disclosed anywhere in the debtor's schedules

24 which you signed and filed under penalty of perjury?

25 A No. So maybe it wasn't a Chance & Anthem

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1 account, or I forgot about it. But I don't have to

2 look at the schedule, I remember I didn't report a

3 payroll account. So I presume it either wasn't Chance

4 & Anthem's or I forgot about it.

5 Q Sir, I should have asked you this at the

6 beginning of the deposition. Is there any reason why

7 you can't testify completely and truthfully here

8 today?

9 Are you under any medications, or are you

10 being treated for any memory disorders that preclude

11 you from testifying truthfully and completely?

12 A You want to ask one question at a time,

13 please?

14 Q No, if you understand --

15 A Your first question --

16 Q -- my question, you can answer.

17 A -- was, is there any reason that I can't

18 testify truthfully and completely? I am testifying

19 truthfully and completely to the best of my knowledge.

20 I am not under any medication.

21 Q Are you being treated for any memory

22 disorders?

23 A No. But if you ask my wife she thinks I've

24 got a thousand of them.

25 Q Have you ever received any medical attention

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1 for any medical disorder?

2 A For any medical disorder.

3 Q I'm sorry, withdraw that.

4 For any memory disorder.

5 A No. But people tell me I forget stuff all

6 the time. I don't think I forget more stuff than

7 anybody else my age.

8 Q This was 16.

9 A Hey, Jesus, on the schedules, I have a

10 question for you, where would you have reported the

11 payroll account?

12 (Inaudible discussion off the record between

13 Mr. Barbee and Mr. Suarez.)

14 THE WITNESS: Let the record show that he

15 refuses to answer the question.

16 BY MR. SUAREZ:

17 Q Mr. Siskind, you've been a practicing lawyer

18 long enough. You know how depositions work --

19 A Yeah, but I --

20 Q -- I'm not going to explain it to you.

21 A -- don't think there was a place to report

22 that payroll account, if there, indeed, was one.

23 Q Mr. Siskind, you're the bankruptcy lawyer

24 that prepared those schedules, submitted them, and

25 signed them under penalty of perjury. I leave that up

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1 to you.

2 A Well, if you remember, we did discover some

3 inconsistencies at the 341, which you were going to

4 take care of -- or which we were going to address at

5 some point.

6 (Thereupon, a document was marked as Exhibit

7 No. 17 for identification by Mr. Suarez.)

8 BY MR. SUAREZ:

9 Q I've marked as Exhibit 17 another $5,000

10 withdrawal from SunTrust dated December 11, 2005?

11 A Okay. Another in the series, every other

12 week, $5,000.

13 Q And what were those $5,000 used for?

14 A Like I said before, Jesus, I believe they

15 could have been transfers to the payroll account. It

16 could have been my payment agreement at the time, I

17 have no idea. But it does appear that it was every

18 other week.

19 Q What's your payment agreement?

20 A Well, I don't have that in writing. I've

21 told you that before.

22 Q Oh, that was the agreement you made with

23 yourself.

24 A Look, you're making me try to guess. I'm not

25 going to guess.

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1 Q No, please don't guess. If you don't

2 remember what you did the $5,000 in cash that you

3 withdrew from the debtor's bank accounts every other

4 week --

5 A Right.

6 Q -- I understand that's your testimony.

7 A That is my testimony.

8 Q All right. How about December 16, 2016, you

9 withdrew another $5,000 from Chance & Anthem's bank

10 account.

11 Do you know what those $5,000 were used for?

12 A Nope. This one has no date. Oh, yes, it

13 does. December 2nd.

14 Q What number are you holding there? What

15 number am I up to, 17?

16 A You've got two 17s.

17 Q All right. We'll call one 17-A and 17-B?

18 A Which one is which? The earlier one A?

19 Q The earlier one A, and the later one B.

20 A All right.

21 (Thereupon, the documents referred to above

22 were marked as Exhibits No. 17-A and 17-B for

23 identification by Mr. Siskind, and a document is

24 marked as Exhibit No. 18 for identification by

25 Mr. Suarez.)

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1 MR. SUAREZ: Thanks.

2 BY MR. SUAREZ:

3 Q Exhibit 18 is another $5,000 withdrawal --

4 A Okay.

5 Q -- on December 31, 2015.

6 A Every other week like clockwork.

7 Q Still don't remember what you were using

8 those $5,000 for every other week?

9 A No, I do not.

10 (Thereupon, a document was marked as Exhibit

11 No. 19 for identification by Mr. Suarez.)

12 BY MR. SUAREZ:

13 Q Exhibit 19 is a $7,000 cash withdrawal from

14 Chance & Anthem's bank account -- I'm sorry, a $7,000

15 deposit, cash deposit, from Chance -- into Chance &

16 Anthem's bank account.

17 A Hmm.

18 Q Oh, I'm sorry, there's two pages to this

19 document.

20 Why would Chance & Anthem have deposited

21 $7,000 in cash into its bank account?

22 A I have no idea.

23 Q How would Chance & Anthem have generated cash

24 in order to deposit into its bank account?

25 A I have no idea.

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1 Q Did Chance & Anthem ever generate any

2 revenue?

3 A No. I or one of the other companies may have

4 loaned Chance & Anthem $7,000, but other than that, I

5 don't know where that money came from.

6 Q How would that loan have been documented?

7 A In that case it may not have been documented

8 at all. Like I said, I don't have any records, so I

9 can't tell you. Again, you should check the other

10 accounts at SunTrust to see if came out of one of the

11 other accounts on the very same day.

12 Q Mr. Siskind, on September --

13 A And you should check my debtor-in-possession

14 accounts to see if I recorded these as payments to me.

15 Q Strike that. On July 19, 2016 --

16 A Strike what? Wait a minute.

17 THE WITNESS: Don't strike the wrong thing.

18 Don't strike what I said. Strike what he started to

19 say.

20 BY MR. SUAREZ:

21 Q Are you done?

22 A I think so. Just keeping the record clear.

23 (Thereupon, a document was marked as Exhibit

24 No. 20 for identification by Mr. Suarez.)

25 BY MR. SUAREZ:

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1 Q And July 19, 2016, there was a $25,000

2 deposit representing a cash in ticket, according to

3 the bank's records, into Chance & Anthem's bank

4 account.

5 Do you know where Chance & Anthem would

6 have --

7 A No.

8 Q -- attained $25,000 in cash to deposit into

9 its bank account?

10 A No. I don't think it's cash, though. It

11 says "checks."

12 Q Please take a look at the second page.

13 A Oh, that says checking account. This is a

14 substitute document. So I don't know what that means.

15 Q It says it's a "Cash In Ticket."

16 A Well, I can tell you I never walked into

17 Chase with $25,000 cash to deposit into Chance &

18 Anthem's account. This is not my writing, any of it.

19 Maybe someone else did, but where it came from, I have

20 no idea.

21 Q Did anybody besides you ever have access to

22 Chance & Anthem's bank account?

23 A For deposits, I would imagine, yes. But not

24 for withdrawals. You know, that went in as cash, but

25 it may have been a check from that bank. Nobody

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1 walked in with $25,000, believe me.

2 (Thereupon, a document was marked as Exhibit

3 No. 21 for identification by Mr. Suarez.)

4 BY MR. SUAREZ:

5 Q Exhibit 21 is a $4,000 cash withdrawal on

6 September the 9th of 2016.

7 What was the purpose of that cash withdrawal?

8 A I have no idea.

9 Q Chance & Anthem ever own an airplane?

10 A No.

11 Q Helicopter?

12 A No.

13 Q Anything that flies?

14 A No.

15 Q All right. On November 11, 2015 Chance &

16 Anthem paid Advanced Avionics $100,000.

17 A Right, this was a bill we paid for my father.

18 Q Okay.

19 A Instead of giving him the hundred thousand

20 dollars, we paid that on his behalf.

21 Q Why did Chance & Anthem owe your father a

22 hundred thousand dollars?

23 A Because he was originally a partner in Chance

24 & Anthem, and he did a lot of advance work for us in

25 Maryland. That was the agreement.

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1 Q How was that agreement memorialized?

2 A I don't know that it was, since it was my

3 father. You know, we just -- that was the arrangement

4 we had.

5 Q Was that agreement ever disclosed to anybody?

6 A No, I don't think it was. No. I was

7 thinking for a second that Bruce Lowe might have known

8 about or Willy. Willy might have known about it,

9 because Willy was living with my parents at the time.

10 He was assisting my father.

11 Q Did Chance & Anthem ever generate a profit?

12 A No. Chance & Anthem never had an income.

13 Q So all the cash that Chance & Anthem obtained

14 or all the money that Chance & Anthem obtained came

15 from either lenders or investors?

16 A Or me.

17 Q All right.

18 A Or my father. My father but in a lot of

19 money. I don't know whether he put in over a hundred

20 thousand dollars, but he put in substantial money.

21 Q What money did your father put into Chance &

22 Anthem and how?

23 A I don't remember. I had a record of it at

24 one time, but it was always transfers from some

25 account that he had.

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1 Q Transfers into where?

2 A I don't remember, Jesus. But a lot of what

3 he put up was used to continue to try to hold onto the

4 building.

5 Q What building?

6 A The building in Hebron. It's about $7,000 a

7 month.

8 Q Those would have been rent payments to the

9 Ocean Gateway entity?

10 A Right.

11 Q Who owned the plane?

12 A What plane?

13 Q The plane that that hundred thousand dollars

14 went --

15 A Oh, the only airplane that -- I don't

16 remember what that was for, that hundred thousand

17 dollars. It might have been for the helicopter or his

18 airplanes. He had a company called Metropolitan Air,

19 Inc. that owned two airplanes, and then I owned a

20 helicopter through my law firm, LLC, even though it's

21 lapsed, called Siskind Legal Services, LLC, and this

22 company did work on both aircraft.

23 Q Including yours?

24 A Yeah. Yeah, they still work on mine.

25 (Thereupon, a document was marked as Exhibit

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1 No. 22 for identification by Mr. Suarez.)

2 BY MR. SUAREZ:

3 Q How about Air Center, Inc., Exhibit 22?

4 A I have no idea what that is.

5 Q You signed that check.

6 A Oh, you know what, that was for parts for his

7 airplane.

8 Q Whose airplane?

9 A Metropolitan Air's, those were for the

10 air-conditioning parts, but, again, he's recontributed

11 all that money and more to Chance & Anthem --

12 Q How did he do that?

13 A -- that $17,000.

14 He provided money to hold on to the building,

15 I don't know exactly how many months, but I can tell

16 you that for whatever length of time we owned the

17 building, after we did not get the license, I believe

18 all that money, all those rents payments, came from

19 him, because we couldn't go out there and legitimately

20 use other people's money after that license was

21 denied.

22 Q Would those rent payments have been funded

23 through any other names or entities other than William

24 Siskind?

25 A They may have been. They could have come

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1 through Sovereign. They could have come through my

2 trust account. They could have come through -- I

3 would say those two -- well, let me think for a

4 second. Where would they have come from?

5 They could have come directly from one of his

6 accounts. I don't remember. But when you get Alan in

7 here, if he provides you with a list of payments, I

8 think anything after we were denied a license, which

9 would have been in August of 2016, would most likely

10 have come from dad.

11 MR. SUAREZ: We're at 22? Twenty-three.

12 (Thereupon, a document was marked as Exhibit

13 No. 23 for identification by Mr. Suarez.)

14 BY MR. SUAREZ:

15 Q Twenty-three is a check issued by Chance &

16 Anthem and signed by you to Jeffrey M. Siskind?

17 A Correct.

18 Q Why did Chance & Anthem pay you $10,000 on

19 March 5, 2015?

20 A I have no idea. That was 2015. I'd imagine

21 for my fees.

22 Q For what fees?

23 A Legal fees, the work I was doing for Chance &

24 Anthem.

25 Q How were your legal fees billed to Chance &

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1 Anthem?

2 A I told you I kept ledgers.

3 Q Why invoices ever generated?

4 A No. There was no need to generate a physical

5 invoice.

6 (Thereupon, a document was marked as Exhibit

7 No. 24 for identification by Mr. Suarez.)

8 BY MR. SUAREZ:

9 Q Twenty-four is a check in the amount of

10 $25,000 payable from Chance & Anthem to you.

11 What was the purpose of that check?

12 A I have no idea. What year was that?

13 Q April 15, 2015.

14 A Oh, I don't know. Back in 2015, I have no

15 idea. Again, I presume for my work on behalf of

16 Chance & Anthem.

17 Q Were any invoices ever generated or submitted

18 to --

19 A No, I already said that, no.

20 Q Let me finish my question before you answer.

21 A Well, it's the same question you asked

22 before.

23 Q For the court reporter's benefit, please.

24 I'm going to ask you the same question a

25 number times about a number of different documents.

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1 A Right.

2 Q Turning back to Exhibit 24, were any invoices

3 or statements ever generated or submitted to Chance &

4 Anthem on account of legal fees you claim may have

5 been due to you on account of this transfer?

6 A No, the records were only ledgers.

7 Q And those are the ledger you claim Mr. Gibson

8 took?

9 A Yes, along with other files.

10 (Thereupon, a document was marked as Exhibit

11 No. 25 for identification by Mr. Suarez.)

12 BY MR. SUAREZ:

13 Q Twenty-five is a $10,000 check issued by

14 Chance & Anthem to you on May 7, 2015.

15 A Correct.

16 Q Do you know why Chance & Anthem issued that

17 check to you in 2015?

18 A For money due to me.

19 Q Were any invoices or statements ever

20 generated by you to Chance & Anthem?

21 A Are you going to ask that same question -- I

22 keep -- were there "ever" any invoices? I already

23 answered no. If you wanted to ask it each time, just

24 ask was there "an invoice" associated with that

25 payment? Otherwise, why do I have to answer that same

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1 question over and over again.

2 Q Well, I'm asking that same question as it

3 relates to different transfers.

4 A Well, you know what, I'm going to say next

5 time, "Asked and answered." You said, "Were there

6 ever any invoices" and I said no --

7 Q Well, I'm --

8 A -- so stop asking the same question.

9 Q I'm asking on account of each individual

10 transfer.

11 A Well, then ask it that way, "Was there an

12 invoice associated with this check?" The answer, no.

13 Q If you'd let me finish my question --

14 A Well, but you -- come on, Jesus, ask the

15 correct question or don't ask it.

16 (Thereupon, a document was marked as Exhibit

17 No. 25 for identification by Mr. Suarez.)

18 BY MR. SUAREZ:

19 Q Exhibit 25, this is a Chance & Anthem bank

20 statement that reflects a $50,000 outgoing wire on

21 November 9th of 2015.

22 Do you know what the purpose of that wire

23 was?

24 A No. Might have been something related to the

25 building purchase.

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1 Q Which building purchase?

2 A In fact, a lot of these other checks, the big

3 40,000, may have been to get cashier's checks to pay

4 them. You gotta look at the record of payments to the

5 building. Remember, we put, like, $300,000 up as a

6 buy-in on the building.

7 Q Who is "we"?

8 A The company, Chance & Anthem. These big, big

9 payments, that's what they may have been for.

10 Q Do you have any records related to that

11 transaction?

12 A Yeah, you showed me the record when you gave

13 me that one document. It had the different dates that

14 we put up the different amounts of money. Remember,

15 at one point that number was $290,000, and I can't

16 remember what document you showed me -- oh, it was the

17 original lease option purchase agreement. It had the

18 deadline. Some of these might correspond to those.

19 (Thereupon, a document was marked as Exhibit

20 No. 26 for identification by Mr. Suarez.)

21 BY MR. SUAREZ:

22 Q Twenty-six is a check dated November 13, 2015

23 in the amount of $10,000 to Jeffrey Siskind.

24 What was that check for?

25 A I don't remember. Don't recall. No invoice

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1 associated with it.

2 Q Twenty-six is a bank statement of Chance &

3 Anthem.

4 A No.

5 Q No? Twenty-seven? Did I already mark 26?

6 A Yeah. That was the one you just gave me.

7 (Thereupon, a document was remarked as

8 Exhibit No. 27 for identification by Mr. Suarez.)

9 BY MR. SUAREZ:

10 Q Twenty-seven is a Chance & Anthem bank

11 statement.

12 A Outgoing wire for sixty-one seven-nineteen

13 sixty-three.

14 Q Do you know where that money went?

15 A I have no idea.

16 (Thereupon, a document was marked as Exhibit

17 No. 28 for identification by Mr. Suarez.)

18 BY MR. SUAREZ:

19 Q Twenty-eight is a check dated December 28,

20 2015 --

21 A You know, let me say this about this one --

22 Q I'm sorry, there's a question pending.

23 A Well, I want to correct my answer to the

24 prior question.

25 Q Go for it.

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1 A Something you should investigate is whether

2 or not on the purchase of the project house, the 3445

3 Santa Barbara, this, because it's such an odd amount,

4 could have been something that was sent to the title

5 company to purchase that. That could have been the

6 amount due from us on the amount of the purchase.

7 Q Okay.

8 A That was about the time that we closed on the

9 house, if not the time.

10 Q On December 8, 2015, there was a check issued

11 by Chance & Anthem to you, signed by you, in the

12 amount of $30,000. What was that check for?

13 A I haven't the foggiest idea.

14 Q That's Exhibit 28?

15 A Correct.

16 (Thereupon, a document was marked as Exhibit

17 No. 29 for identification by Mr. Suarez.)

18 BY MR. SUAREZ:

19 Q Exhibit 29 is a check dated December 10, 2015

20 from Chance & Anthem made payable to you in the amount

21 of $15,000. What was that check for?

22 A I have no idea. I don't remember these 2015

23 checks.

24 Q What's Reef Gallery, Incorporated?

25 A That's a store down in Key Largo.

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1 Q Why would Reef Gallery, Incorporated have

2 issued a check in the amount of $10,000 to Chance &

3 Anthem?

4 A I believe that the owner purchased an option

5 for one unit. Yes.

6 Q One unit in what?

7 A In Chance & Anthem.

8 Q In Chance & Anthem, as opposed to CannaMED?

9 A What's it say here? Oh, it says "loan." I

10 have no idea. Oh, it's ten percent down on two shares

11 in Maryland. That's what it says.

12 (Thereupon, a document was marked as Exhibit

13 No. 30 for identification by Mr. Suarez.)

14 BY MR. SUAREZ:

15 Q Would those have been shares in CannaMED?

16 A Geez, I've forgotten. What were we selling?

17 Was it Chance & Anthem? Yeah, Chance & Anthem sold

18 its shares in CannaMED. Right, correct. It was ten

19 percent down on two shares, which would have been

20 $50,000 each or a hundred thousand dollars.

21 MR. FURR: Jesus, the food is here if you

22 want to eat.

23 MR. SUAREZ: All right. Let's take a break

24 for lunch.

25 (Thereupon, a lunch recess was taken from

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1 1:40 p.m. to 2:00 p.m.)

2 MR. SUAREZ: Back on the record.

3 (Thereupon, a document was marked as Exhibit

4 No. 31 for identification by Mr. Suarez.)

5 BY MR. SUAREZ:

6 Q All right. I've marked Exhibit 31,

7 Mr. Siskind. This is a check from Chance & Anthem to

8 the Second Siskind Family Trust.

9 What was that check for?

10 A I have no idea. I don't think Second Siskind

11 Family Trust ever had a bank account?

12 Hmm. I don't know why we put money back in

13 the trust. We may have advanced money from the trust

14 and then repaid it.

15 Q If money was advanced from the trust, where

16 would it have been deposited?

17 A It could have gone to my trust account, that

18 may be my old trust account number.

19 Q If I wanted to understand all the

20 transactions between Chance & Anthem and third

21 parties, where your trust account was an

22 intermediary --

23 A Yeah.

24 Q -- what would be the best way to do that, in

25 your opinion, given that you don't have trust records

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1 for the applicable periods?

2 A I would say that every disposition of funds

3 was for a valid reason, so we can start there, and

4 then toss the ball back to you and say, "Well, you're

5 going to have to prove it was for an invalid reason,"

6 and of course --

7 Q Is there any way --

8 A -- I'm answering in my best interest.

9 Q No, I get your answer, and it's a genuine

10 question. If I wanted to sit down and go through your

11 trust account records -- because several times today

12 you've told me, it may have gone through my trust

13 account.

14 How are we supposed to know what went through

15 your trust account?

16 A You got the records, give them to me, and

17 then ask me the questions again, and I'll go through

18 them. Just e-mail me whatever you got, and I'll see

19 if the jibes with something on the trust account.

20 Q And how would you be able to tell if a

21 transaction involved the debtor in your trust account?

22 A I would like at the disposition of the funds.

23 You're talking about deposits to the trust account? I

24 only thought the debtor made one trust account deposit

25 of $5,000 at some point. That's all I remember.

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1 Q How about funds that were deposited in your

2 trust account for the benefit of the debtor?

3 A Oh, there were only a couple instances where

4 that could have occurred that I'm aware of. I don't

5 know the answer to that.

6 Q What instances were those?

7 A Well, remember, okay, let's keep it clear,

8 the debtor did two things. It had the cannabis deal

9 in Maryland and the house project here. I believe

10 that David Fiore/Carl Stone's money went into the

11 trust account, that 800,000. Fifty or 40, roughly,

12 went back to David Fiore, and the rest was probably --

13 oh, no, there were thousand-dollar payments out of

14 that that went to Steve Wilkins for working on the

15 house. There was -- look at that state case that

16 Fiore filed. I believe we filed, I filed, a ledger

17 for the disposition of that 800,000. If I didn't file

18 it, I e-mailed it to Sophie Williams who is their

19 attorney, but I think it's either dollar for dollar or

20 maybe I had to put a few dollars in there to make it

21 jibe. No, I think it was dollar for dollar.

22 MR. SUAREZ: I'll mark that as Exhibit 36

23 (sic), I think it's the last page of this document,

24 which is an affidavit of Carl Stone.

25 (Thereupon, the document referred to was

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1 marked as Exhibit No. 32 for identification by

2 Mr. Suarez.)

3 THE WITNESS: Ah, there it is. I didn't even

4 remember that I typed it up to be honest with you.

5 BY MR. SUAREZ:

6 Q How was this produced?

7 A By me. What do you mean how was this

8 produced?

9 Q Yeah.

10 A I prepared it because I wanted to give it --

11 Q Did you type it into a Word document, or was

12 this generated by some sort of software?

13 A No, no. This was a Word document. Yeah,

14 see, I had to put $31 in there from the miscellaneous

15 ledger. Right, $42,000 went back to Fiore.

16 Q Are there any other ledgers like this one

17 that you generated where Chance & Anthem would have

18 been a party to the transaction? So here you've --

19 A From the trust account?

20 Q From the trust account.

21 A Oh, yeah, there would have had to be one, but

22 usually handwritten for every individual that would

23 have put money into the trust account. Now, who could

24 that have been? That guy from Delaware may have

25 transferred that money to the trust account.

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1 Q That's 3Gen?

2 A No. That's the $50,000 from the guy in

3 Delaware whose name I cannot remember. He's a finance

4 guy. Oh, I can't remember his name.

5 Anyway, the hundred thousand from 3Gen might

6 have gone through there. The money from Kamenitz's

7 group might have gone through there, I don't know. I

8 don't know who else would. That's all I can think of.

9 Q The hundred thousand from 3Gen, how would

10 that money have been used?

11 A I don't remember.

12 THE WITNESS: Can I take a picture of this?

13 I just can't find it, you know, or do you have a

14 spare?

15 MR. SUAREZ: Here, here's a copy for you.

16 THE WITNESS: I don't think it was attached

17 to his affidavit, though, was it?

18 MR. SUAREZ: You can keep that.

19 THE WITNESS: Thank. He would not have

20 attached that to his affidavit, because -- oh, well, I

21 guess he did it. Says Exhibit 1. Thank you for this.

22 I've been looking for it.

23 BY MR. SUAREZ:

24 Q And the affidavit that I've marked as Exhibit

25 32, oh --

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1 MR. BARBEE: I thought you said "36."

2 MR. SUAREZ: I said "36," but I actually

3 meant to mark it as 32. So let's call that 32. May

4 the record reflect, the affidavit of Carl Stone --

5 THE WITNESS: Right.

6 MR. SUAREZ: -- that we referred to as

7 Exhibit 36 briefly is Exhibit 33 -- 32.

8 THE WITNESS: Right.

9 (Thereupon, a document was marked as Exhibit

10 No. 33 for identification by Mr. Suarez.)

11 BY MR. SUAREZ:

12 Q Now, you'll notice Exhibit 33 is a SunTrust

13 Bank record for Chance & Anthem, and this is an

14 official check sale, different than the cash

15 withdrawal records that we went through earlier --

16 A I see that --

17 Q -- in the amount of $90,000.

18 A -- yeah.

19 Q What would have been the disposition of that

20 $90,000?

21 A I have no idea. Back in '15, I would say

22 maybe this was a payment on the building.

23 Q April 10, 2015?

24 A I don't know, you gotta look at that purchase

25 agreement with Machine Technologies, because it had

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1 the schedule of payments. This might jibe with one of

2 those.

3 (Thereupon, a document was marked as Exhibit

4 No. 34 for identification by Mr. Suarez.)

5 BY MR. SUAREZ:

6 Q Thirty-four is an official check sale in the

7 name of Chance & Anthem, December 23, 2014 for

8 $58,000.

9 A '14? I have no idea. Fifty-eight thousand?

10 Q Fifty-eight thousand.

11 Do you know what the purpose or use of that

12 cashier's check was?

13 A No. This might have been a payment I made on

14 behalf of Fred Volkwein, that's a guess, because maybe

15 we were working with Chance & Anthem on some sort of a

16 1031 for him, 1031 exchange.

17 Q And why would Chance & Anthem have owed

18 Volkwein $58,000?

19 A I forgot now how we handled his dealings.

20 Can I get a copy of that too, because that

21 might help me explain to Richard -- what's Richard's

22 last name, Robert?

23 MR. SUAREZ: Zaretsky.

24 THE WITNESS: Zaretsky, yeah. You know,

25 prove one of the payments I made.

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1 Thank you.

2 (Thereupon, a document was marked as Exhibit

3 No. 35 for identification by Mr. Suarez.)

4 BY MR. SUAREZ:

5 Q I've marked 35, another official check sale

6 withdrawal ticket from SunTrust from Chance & Anthem's

7 bank account, dated April 24, 2015, in the amount of

8 $45,000.

9 Do you know what the disposition of that

10 cashier's check was?

11 A No. But, again, you gotta check all these

12 against that --

13 Q Machining Technologies?

14 A Yeah, yeah.

15 Q Wendy Buckingham is your sister, correct?

16 A Mm-hmm.

17 (Thereupon, a document was marked as Exhibit

18 No. 36 for identification by Mr. Suarez.)

19 BY MR. SUAREZ:

20 Q There's a check from Chance & Anthem to

21 Ms. Buckingham in the amount of 16,200, which I'll

22 mark as Exhibit 36.

23 A When was that?

24 Q Dated November 1, 2016.

25 A "Partial repayment" it says on it. I don't

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1 know what that was for.

2 Q Why would Chance & Anthem have repaid

3 Ms. Buckingham $16,200?

4 A We, I guess, borrowed money from her.

5 Q Who is "we"?

6 A Well, Chance & Anthem.

7 Q And how would Chance & Anthem have received

8 the money from --

9 A I have no idea.

10 Q -- Ms. Buckingham?

11 A I have no idea.

12 THE WITNESS: What are you looking at Alan?

13 Did you find the other side of that transactions?

14 MR. BARBEE: (Shakes his head.)

15 THE WITNESS: Are you going to ask me

16 anything about this Exhibit 32?

17 MR. SUAREZ: Not anymore.

18 (Thereupon, there was an inaudible discussion

19 off the record between Mr. Barbee and Mr. Suarez,

20 during which a document was marked as Exhibit No. 37

21 for identification by Mr. Suarez.)

22 BY MR. SUAREZ:

23 Q All right. Thirty-seven, finally, we'll do a

24 composite for you?

25 A What's that?

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1 Q We'll do a composite exhibit for you here at

2 37. I've got a number of checks, two checks that

3 total --

4 A This looks like something involving Fred

5 Volkwein.

6 Q -- $1,157,623.77 from First American Title

7 Insurance Company?

8 A Yeah, that had to do with the sale of Fred

9 Volkwein's properties.

10 Q Dated November 6, 2014.

11 A Was it that long ago? I guess it was, yeah.

12 I don't know the 1500. That's weird.

13 Q There are two checks one for 1500 and one for

14 $1,157,623.77.

15 Why would those checks have been made payable

16 to Chance & Anthem?

17 A This must have had to do with Fred Volkwein's

18 property exchange.

19 Q And what did Chance & Anthem do with the

20 $1,159,123 that it received from First American Title?

21 A Well, you gotta look at the -- there's a

22 handwritten ledger that I remember I gave Fred. Where

23 have I seen that recently? Oh, if you look at Fred

24 Volkwein's lawsuit against me in state court, he

25 attached it as an exhibit. That would have been for

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1 the sale of his properties in Northwood.

2 (Thereupon, a document was marked as Exhibit

3 No. 38 for identification by Mr. Suarez.)

4 BY MR. SUAREZ:

5 Q Thirty-eight is another wire coming out of

6 Chance & Anthem in December of 2014 in the amount of

7 $135,109.92.

8 A I think this had to do with Fred Volkwein's

9 transaction too. I don't know who we would have sent

10 that too. Pretty sure that has to do with the

11 Volkwein -- um -- um -- property sale transaction.

12 Q I have an additional deposit on February 5,

13 2015 into Chance & Anthem from First American Title

14 Insurance Company in the amount of $65,092.40?

15 A I think that was some sort of a holdback that

16 had to do with Fred Volkwein's transaction as well.

17 (Thereupon, a document was marked as Exhibit

18 No. 39 for identification by Mr. Suarez.)

19 BY MR. SUAREZ:

20 Q I've marked that one Exhibit 39.

21 A Okay. Again, that handwritten ledger would

22 probably disclose whatever of -- those last few checks

23 had to do with the Volkwein transaction.

24 (Thereupon, a document was marked as Exhibit

25 No. 40 for identification by Mr. Suarez.)

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1 BY MR. SUAREZ:

2 Q Exhibit 40 is another deposit into Chance &

3 Anthem, dated December 28, 2015 in the amount of

4 $19,481.32.

5 A Says here "Second mortgage payoff." I don't

6 have any idea what that is. Oh, that's from Title

7 Trust Services. What the heck is that? I have no

8 idea what this is.

9 West Palm Beach. Oh, this could have been

10 somehow related to the project house purchase, because

11 I think it's in that time period, so maybe we had some

12 sort of an adjustment there. I'm not sure. That's

13 likely what this is, though.

14 Q A refund from the purchase of the project

15 house or an adjustment at the closing?

16 A I guess so. Maybe for insurance. Maybe we

17 paid insurance directly, I'm thinking. That's all I

18 can think of. That's a guess.

19 (Thereupon, a document was marked as Exhibit

20 No. 41 for identification by Mr. Suarez.)

21 BY MR. SUAREZ:

22 Q Forty-one is another deposit dated October

23 31, 2016 in the amount of $23,243.37 from the

24 Associates.com, P.A.

25 A Oh, yeah, yeah, the Associates. They owed us

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1 money for something. Oh, okay, for the Dalton Avenue

2 transaction. That was a little house we loaned money.

3 We loaned money to a flip project up there in Stuart,

4 I guess, or Port St. Lucie or something. That was our

5 repayment.

6 Q Chance & Anthem ever prepare a financial

7 statement?

8 A No. Never had any income either, so it never

9 filed any taxes.

10 Q Chance & Anthem ever fill out a credit

11 application?

12 A Nuh-uh, no.

13 (Thereupon, a document was marked as Exhibit

14 No. 42 for identification by Mr. Suarez.)

15 BY MR. SUAREZ:

16 Q Mark as Composite 42 -- I'm sorry, Exhibit 42

17 is a check from Chance & Anthem to the Ocean Reef

18 Club.

19 A Oh, yeah. I forget what that was for. Oh,

20 that was to pay off two accounts down there.

21 Q Why was Chance & Anthem paying off accounts

22 at Ocean Reef?

23 A I don't know. No idea.

24 Q Did Chance & Anthem ever have a membership at

25 Ocean Reef?

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1 A No, no. We almost -- no, no, no, we didn't.

2 There was a William Siskind membership and a Jeffrey

3 Siskind membership. In fact, the member numbers are

4 right there. Those are the two account numbers. I

5 don't know why Chance & Anthem paid that. Although we

6 utilized the memberships to some extent in Chance &

7 Anthem's fund raising activities.

8 Q What fund raising activities were those?

9 A Prospecting investors.

10 Q Such as?

11 A Such as -- well, the $10,000 we got from the

12 owner of the jewelry store there?

13 Q The Reef folks?

14 A Right.

15 (Thereupon, a document was marked as Exhibit

16 No. 43 for identification by Mr. Suarez.)

17 BY MR. SUAREZ:

18 Q Composite 43 are two checks to Tanya Siskind

19 from Chance & Anthem.

20 A Right. This is just money that -- instead of

21 me taking personally, I had the check made out to her

22 and deposited into her account to save time, or

23 because there was a bill that needed to be paid right

24 away. I think there were more than two checks I gave

25 to her out of Chance & Anthem. Both of these were in

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1 2016. There may be one or two more.

2 Q Who is Scarlet Siskind?

3 A My daughter.

4 Q Why would Chance & Anthem have paid the Palm

5 Beach Riding Academy?

6 A Oh, we were going to do a promotional thing

7 for her riding there. It's a riding school, and --

8 what was it a $6,000 check, as I remember?

9 Q Twenty-five hundred, here, I'll show you the

10 check.

11 A Oh, that's all. I must be thinking of

12 something else.

13 (Thereupon, a document was marked as Exhibit

14 No. 44 for identification by Mr. Suarez.)

15 BY MR. SUAREZ:

16 Q Exhibit 44, October 19, 2016.

17 A Right.

18 Q What business, if any, did Chance & Anthem

19 have with the Palm Beach Riding Academy?

20 A This was -- I forget what this was for

21 involving her. I don't know whether that was an

22 appearance, a show appearance, or whatever that was,

23 that we were sponsoring.

24 Q "We" being Chance & Anthem?

25 A Yeah.

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1 Q Why would Chance & Anthem have sponsored your

2 daughter's show appearance at a riding academy?

3 A Well, these riders get sponsors. You get

4 some advertising privileges, and with the horse crowd

5 out there, Scarlet is a pretty good rider, you get a

6 lot of attention.

7 Q Why would Chance & Anthem have needed to

8 generate attention?

9 A That was just after we didn't get that

10 license, and we were filing an application with the

11 federal government, and we were out of money. We

12 needed money.

13 Well, let me say this, I don't believe we

14 ever took money from investors after we didn't get the

15 Maryland application. But we needed to line up money

16 if we got the federal application approval, because

17 that I think had a six-month deadline to get up and

18 operating. Did you follow that?

19 Q Yep.

20 (Thereupon, a document was marked as Exhibit

21 No. 45 for identification by Mr. Suarez.)

22 BY MR. SUAREZ:

23 Q Exhibit 45 is a Chance & Anthem bank

24 statement. It reflects a $500,000 deposit from an

25 account ending 7527 on October 6, 2015.

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1 A Oh, yeah, Richard Neff. I'm pretty sure

2 that's Richard Neff. He put in a half million dollars

3 originally on that house project.

4 Q The half million dollars from Richard Neff,

5 was that a loan or an equity position in Chance &

6 Anthem? How was that investment --

7 A I think it was done as a loan.

8 Q Was that loan ever --

9 A -- repaid?

10 No, not yet. I have to take care of him

11 myself. I can't let him lose that money. Both him

12 and Fred. The rest of them -- oh, no, I can't really

13 say that, because there are a few others I have to

14 make sure get their money back too.

15 Q How about David Merrill?

16 A David Merrill, we all know him.

17 Q Actually, I don't.

18 A You don't? Robert will give you the inside

19 scoop on David. He's a bankruptcy lawyer.

20 (Thereupon, a document was marked as Exhibit

21 No. 46 for identification by Mr. Suarez.)

22 BY MR. SUAREZ:

23 Q Composite 46, we've got two $10,000 checks to

24 David Merrill --

25 A Right.

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1 Q -- June 15, 2015 and June 19, 2015.

2 A Correct.

3 Q Why would -- well, the memos say, "Loan to

4 relocate," and the second memo says "Additional

5 relocation loan."

6 A Right. We loaned him money to relocate to my

7 office. Twenty-thousand dollars. Jesus.

8 Q Why would Chance & Anthem have loaned him

9 money to relocate to your office?

10 A I forget what the particulars were. He

11 repaid it. That was that 22,000 you saw.

12 Q No, I didn't.

13 A Yes, you did.

14 Q Repaid it to whom?

15 A To Chance & Anthem.

16 I forget what exhibit it was. Let me see if

17 I can find it.

18 Q No. That was money from the Associates.com.

19 A That's David.

20 Q Okay. So it had nothing to do with the

21 closing of a house in Dalton?

22 A I think I loaned it to him on that house as

23 security, yeah, yeah. I don't think I would have

24 forgotten to get that $20,000 back. Yeah, that has to

25 be it.

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1 Q South Properties, LLC.

2 A Oh, that's Mike Kamenitz, I think.

3 Q I'm sorry?

4 A What do you have there?

5 Q A hundred-thousand-dollar deposit into --

6 A Yeah, that's from Mike Kamenitz. Remember

7 the two lawyers and the other guy.

8 Q Exhibit 47.

9 (Thereupon, a document was marked as Exhibit

10 No. 47 for identification by Mr. Suarez.)

11 THE WITNESS: South something Properties,

12 yeah that was Mike. ABK South that is -- the K is

13 Kamenitz.

14 BY MR. SUAREZ:

15 Q Ah, ABK South --

16 A Right.

17 Q -- remind me where we came across them

18 before?

19 A ABK?

20 Q Yep.

21 A They're the ones that put up a hundred

22 thousand for two points in CannaMED. Then I think

23 they also loaned some money --

24 Q The CannaMED purchase that we previously

25 identified at Exhibit 7?

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1 A Maybe.

2 Q Can you take a look at it, Mike?

3 A Mike Kamenitz. Yes.

4 Q Okay.

5 A Yes.

6 MR. SUAREZ: What did you do with my other

7 exhibits, Alan?

8 (Inaudible discussion off the record between

9 Mr. Barbee and Mr. Suarez.)

10 BY MR. SUAREZ:

11 Q I understand you're not here today as the

12 corporate rep of FLACC?

13 A Correct.

14 Q Would you like me to ask you questions about

15 FLACC, or should we do that pursuant to another

16 subpoena?

17 A You're going to have to do that pursuant to

18 another subpoena, because I haven't prepared.

19 Q Okay.

20 A But you could tell me the kinds of questions

21 you're going to ask, and I can try to prepare and see

22 if I can find records for you.

23 MR. SUAREZ: We'll get a 2004 out on that.

24 If you give me one minute, I think we're

25 close to done. I just need to talk to Robert and Alan

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1 for a second.

2 THE WITNESS: Wasn't there some $750,000

3 check to FLACC that you found the last time we met at

4 deposition? Did you ever --

5 MR. SUAREZ: Let's go off the record.

6 (Thereupon, a ten-minute recess was taken.)

7 BY MR. SUAREZ:

8 Q I just have a couple more questions. We'll

9 go back on the record.

10 A You were asking about how many cases I had.

11 Q I'm --

12 A Oh, no, I got Volkwein now too, so it's four.

13 Q That was off the record, but we can talk

14 about it on the record.

15 A No, no, off the record.

16 Q I don't need to. Let's go on, and then we'll

17 finish, and we can -- yeah.

18 Mr. Siskind, there's about a million dollars

19 from Chance & Anthem that goes to the Florida

20 Association of Community Banks and Credit Unions.

21 Why was that?

22 A I have no idea. I remember you told me

23 seven-fifty last time. I have no idea.

24 Q Yeah, we've identified about a million

25 dollars in transfers from Chance & Anthem to the

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1 Florida Association of Community Banks and Credit

2 Unions, including the $750,000 transfer on October 21.

3 A Of what year?

4 Q Of 2015.

5 A I don't know why we did that. But if you can

6 just e-mail me a copy of whatever you got on that

7 account, I'll try to figure it out.

8 Q It's almost immediately after the million-one

9 is received on behalf of Mr. Volkwein that money

10 starts coming out to the Florida Association of

11 Community Banks and Credit Unions.

12 A Might have been somehow related to things for

13 Fred. Somewhere there was a $400,000 payment to buy

14 an annuity for him. I don't know where that came out

15 of, and then I have a handwritten disposition sheet

16 for all his funds.

17 Q But there was no business relationship

18 between Chance & Anthem and the Florida Association

19 Community Banks and Credit Unions?

20 A I don't know how you define a business

21 relationship.

22 Q In any sense.

23 A Well, if there were transactions between

24 them, they are both businesses, so there must have

25 been some sort of business.

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1 Q Well, clearly there is a million dollars

2 going from Chance & Anthem to the Florida Association

3 of Community Banks and Credit Unions.

4 A I have no idea why. Could have been related

5 to try to structure an asset protection plan for Fred.

6 Q Any other reason?

7 A Not that I can think of.

8 Q Okay.

9 A I'm not ruling out any other reason, but

10 there's not one I can think of sitting here today.

11 MR. SUAREZ: All right. Reserving on the

12 questions that we've asked the court reporter certify

13 and we'll take up with the Court, I have no further

14 questions today.

15 THE WITNESS: I'll read.

16 (Whereupon, the deposition was concluded.)

17

 _______________________

18 JEFFREY M SISKIND

______________________________________________

19 STATE OF FLORIDA:

COUNTY OF PALM BEACH:

20

The foregoing instrument was acknowledged before me

21 this ____ day of ______________, 2018, by

____________________________, who is personally known

22 to me or who has produced ________________________ as

identification and who did (did not) take an oath.

23 ________________________________, Notary Public

My commission expires:

24 Commission #:

25

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1 CERTIFICATE OF OATH

2

3 STATE OF FLORIDA:

COUNTY OF PALM BEACH:

4

5 I, Anna M. Meagher, Shorthand Reporter and

6 Notary Public, State of Florida, certify that JEFFREY

7 M SISKIND personally appeared before me on the 19th

8 day of December 2018 and was duly sworn.

9

10 Signed this 16th day of January 2019.

11

12 _________________________

13 My Commission Expires: Anna M. Meagher,

January 9, 2021 Notary Public

14 Commission #GG060693 State of Florida

15

16

17 Personally known: X

 OR Produced Identification:

18 Type of Identification Produced:

19

20

21

22

23

24

25

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1 CERTIFICATE

2 STATE OF FLORIDA:

COUNTY OF PALM BEACH:

3

4 I, Anna M. Meagher, Shorthand Reporter, do

5 hereby certify that I was authorized to and did

6 stenographically report the deposition of JEFFREY M

7 SISKIND, in the cause, at the time and place, and in

8 the presence of counsel as stated in the caption

9 hereto; that reading and signing of the transcript was

10 not waived, and that the foregoing pages, numbered 1

11 through 156 constitute a true record of my

12 stenographic notes.

13 I further certify that I am not of counsel, I

14 am not related to, nor employed by any attorney in

15 this case, nor am I financially interested in the

16 action.

17 Dated this 16th day of January 2019.

18

19 _________________________

 Anna M. Meagher,

20 Shorthand Reporter

21

22

23

24

25

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1 OUELLETTE & MAULDIN COURT REPORTERS

 1550 South Dixie Highway

2 Suite 205 - Riviera Plaza

 Coral Gables, Florida 33146

3 (305)358-8875

4

 January 16, 2019

5

6 MR. JEFFREY M SISKIND

3465 Santa Barbara Drive

7 Wellington, Florida 33414

8 Re: CHANCE & ANTHEM, DEBTOR

 CASE NO. 18-16248-MAM

9

10 Dear Mr. Siskind,

11

 Please be advised that your continued 2004

12 Examination taken by our offices on December 19,2018

has been transcribed and is ready to be read and

13 signed by you.

14 The transcript will be filed with or without your

signature in 30 (thirty) days or at the time of trial,

15 whichever comes first.

16 Our office hours are 9:00 a.m. to 4:30 p.m. Monday

through Friday.

17

 If you have any questions regarding this letter,

18 please feel free to contact us at the above number.

19

 Yours very truly,

20

21

 Anna M. Meagher

22 Court Reporter

23 cc: JESUS M. SUAREZ, ESQUIRE

24

25

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