UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

www.flsb.uscourts.gov

In re: 

CHANCE & ANTHEM, LLC, CASE NO. 18-

16248-BKC-MAM 

 Debtor. Chapter 7 

____________________________________/

ROBERT FURR,

Plaintiff,

v. ADV. NO. 19-01298-MAM

ROBERT GIBSON, et al.,

Defendants.

____________________________________/

 

DEFENDANT’S NOTICE OF SERVICE OF INTERROGATORIES TO

PLAINTIFF

Defendant, Jeffrey Siskind, by and through undersigned counsel, pursuant to Rule 33 of the

Federal Rules of Civil Procedure as made applicable to this proceeding by Rule 7033 of the Federal Rules

of Bankruptcy Procedure, hereby requests that the Plaintiff, Robert C. Furr, answer the following

interrogatories, numbered 1 through 10, set forth below, separately and fully in writing, under oath, within

the time prescribed by the Court.

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

_______/s/ Jeffrey M. Siskind_______

Jeffrey M. Siskind, Esq. FBN 138746

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

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

3465 Santa Barbara Drive Wellington, Florida 33414

TELEPHONE (561) 791-9565

FACSIMILE (561) 791-9581

Email: jeffsiskind@msn.com

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served on August 18, 

2020 upon all creditors and parties in interest registered to receive electronic notification on this case via 

the Court’s Case Management/Electronic Case Filing System and/or U.S. Mail or Personal Service of 

Process as reflected on the Service List below. 

_______/s/ Jeffrey M. Siskind_______

Jeffrey M. Siskind, Esq. FBN 138746

SERVICE LIST

Robert C. Furr, Chapter 7 Trustee

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

Jeffrey M. Siskind, individually

Via e-mail to jeffsiskind@msn.com

Tanya Siskind, individually

Via e-mail to philip@philipharris.com

Siskind Legal Services, LLC

Via e-mail to jeffsiskind@msn.com

Second Siskind Family Trust

Via e-mail to philip@philipharris.com

CannaMed Pharmaceuticals, LLC

Via e-mail to philip@philipharris.com

Sovereign Gaming and Entertainment, LLC

Via e-mail to philip@philipharris.com

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

Via e-mail to philip@philipharris.com

Sympatico Equine Rescue, Incorporated

Via e-mail to philip@philipharris.com

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INSTRUCTIONS AND DEFINITIONS

I. Instructions

A. Answers. Answer each interrogatory separately, and as completely as possible. 

The fact that your investigation is continuing or discovery is incomplete is not an excuse for your 

failure to answer each interrogatory as fully and completely as possible. Your answers should 

consist of information known to you through yourself, your agents, your attorneys, your employees,

or your representatives. To the extent that the answer to any interrogatory is not based upon

information known to you, personally, identify the person possessing or providing the

information for your answer. If you cannot, after exercising due diligence to secure the 

information, fully answer an interrogatory, answer the interrogatory to fullest extent possible, 

specifying your inability to answer the remainder, and providing that information or knowledge 

which is known or available concerning the unanswered portion.

B. Conjunctive/Disjunctive. The use of “and” or “or” shall be deemed to include the 

other. The use of “all” or “any” or “each” shall be deemed to include the others, and the words 

“include” and “including” are illustrative, not limiting.

C. Definitions. All words in these interrogatories shall have their plain and ordinary 

meanings unless specifically defined in Part II.

D. Documents. You may, in lieu of identifying any document, attach a true copy of 

that document to your answers, together with an explicit reference to the interrogatory to which 

each such attached document relates. If any of your answers reference a document, please attach 

a copy of the referenced document to your answers.

E. Except as otherwise stated herein, the responses to these interrogatories shall 

cover the period from preparation of the initial solvency report until the date of this request.

II. Definitions

1. As used herein, the term “Debtor” shall re fer to Chanc e & Ant hem, LLC.

2. As used herein, the term “Plaintiff” shall refer to Robert C. Furr, as Trustee of 

Chance & Anthem, LLC, including his accountant, Alan Barbee, and any other affiliates,

subsidiaries, assigns, officers and directors, employees, agents, and others purporting to act on its 

behalf.

3. The words “you”, and “your” shall mean the party upon whom this request is 

being served and all of its affiliates, subsidiaries, assigns, authorized officers and directors, 

employees, agents, and others purporting to act on its behalf.

4. The words “and” and “or” shall be construed as both conjunctive and disjunctive, 

so that a series of persons or things joined by the words “and” and “or” shall refer to any, all, or 

any combination of them.

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5. The word “person” shall mean any natural person, individual, proprietorship, 

partnership, corporation, association, organization, joint venture, business trust, or other business 

enterprise, governmental body or agency, legal or business entity, or group of natural persons, or 

other entity, whether sui juris or otherwise and includes both the singular and plural.

6. The terms “communication” and “communications” shall interchangeably mean 

any oral or written statement, dialogue, colloquy, discussion or conversation or exchange of 

information of any type, and any transfer of thoughts or ideas between any two or more persons, 

including but not limited to documents, telephone or face-to-face conversations, meetings, 

conferences, or transfer of data from one location to another by electronic or similar means.

7. The term “documents” shall mean any kind of written, typed, recorded or graphic 

matter, however produced or reproduced, of any kind or description, whether sent or received, 

including originals, non-identical copies and drafts of both sides thereof, and including, but not 

limited to, papers, books, letters, correspondence, telegrams, bulletins, notices, announcements, 

instructions, charts, manuals, brochures, schedules, memoranda, notes, notations, transcripts, 

minutes, agendas, reports and recordings of telephone or other conversations, interviews, 

conferences, or other meetings, affidavits, statements, summaries, opinions, reports, studies, 

analysis, evaluations, contracts, agreements, journals, diaries, lists, tabulations, drawings, sketches,

photographs, film, computer print-outs, data processing input/output, microfilms and all other 

records kept by electronic, photographic or mechanical means, and other things similar to any of

the foregoing, including items in the possession, custody, or control of any other person, 

including your attorneys.

8. The word “correspondence” shall mean any and all letters, facsimiles, transmitted 

memoranda, memorialized oral communications, e-mails, or other communications or documents 

exchanged or transmitted with another person or entity.

9. The words “support,” “evidence,” “relate to,” “relating to,” “related to,” “referred 

to,” “concerning,” “pertaining to,” and “regarding” shall mean anything which directly, or 

indirectly, concerns, consists of, pertains to , reflects, evidences, describes, sets forth, constitutes, 

contains, shows, underlies, supports, refers to in any manner, is or was used in the preparation of, 

appended to, legally, logically or factually connected with, proves, disproves, or tends to prove 

or disprove. 

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INTERROGATORIES

1. Please describe with specificity the basis for the removal of the entries “due to/from 

FLACC” of $100,000.00, $272,350.00, $320,685.95 and $321,035.95 for the years 2014 through 

and including 2017 from the Trustee’s initial solvency report and the entry not being included in 

the supplemental solvency report, including but not limited which one of the three following reasons 

were the basis for the removal. The three reasons are as follows: a) the receivable was not required 

to be included in the solvency analysis based upon the definition of solvency contained within 

Section 101; b) if the amounts were legitimate the amount would be an expense rather than a 

receivable; or c) the receivable is uncollectible. In responding to this Interrogatory, please explain 

with specificity any and all documents reviewed in making your determination. 

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2. Please describe with specificity the basis for the removal of the entry “due to/from 

Jeffrey Siskind” of $13,233.88, $296,953.51, $297,794.91 and $293,748.91for the years 2014 

through and including 2017 from the Trustee’s initial solvency report and the entry not being 

included in the supplemental solvency report, including but not limited which one of the three 

following reasons were the basis for the removal. The three reasons are as follows: a) the receivable 

was not required to be included in the solvency analysis based upon the definition of solvency 

contained within Section 101; b) if the amounts were legitimate the amount would be an expense 

rather than a receivable; or c) the receivable is uncollectible. In responding to this Interrogatory, 

please explain with specificity any and all documents reviewed in making your determination.

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3. Please describe with specificity the basis for the removal of the entry “due to/from 

Siskind-aircraft” of $117,000, $117,091 and $117,091 for the years 2015 through and including 

2017 from the Trustee’s initial solvency report and the entry not being included in the supplemental 

solvency report, including but not limited which one of the three following reasons were the basis 

for the removal. The three reasons are as follows: a) the receivable was not required to be included 

in the solvency analysis based upon the definition of solvency contained within Section 101; b) if 

the amounts were legitimate the amount would be an expense rather than a receivable; or c) the 

receivable is uncollectible. In responding to this Interrogatory, please explain with specificity any 

and all documents reviewed in making your determination.

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4. Please describe with specificity the basis for the removal of the entry “due to/from 

OB Real Estate” of $15,000, $22,500, $37,125.00 and $37,125.00 for the years 2014 through and 

including 2017 ” from the Trustee’s initial solvency report and the entry not being included in the 

supplemental solvency report, including but not limited which one of the three following reasons 

were the basis for the removal. The three reasons are as follows: a) the receivable was not required 

to be included in the solvency analysis based upon the definition of solvency contained within 

Section 101; b) if the amounts were legitimate the amount would be an expense rather than a 

receivable; or c) the receivable is uncollectible. In responding to this Interrogatory, please explain 

with specificity any and all documents reviewed in making your determination.

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5. Please describe with specificity the basis for the removal of the entry “Due to/from 

Siskind Legal” of $62,395.00 and 55,810.20 for the years 2016 through and including 2017 from 

the Trustee’s initial solvency report and the entry not being included in the supplemental solvency 

report, including but not limited which one of the three following reasons were the basis for the 

removal. The three reasons are as follows: a) the receivable was not required to be included in the 

solvency analysis based upon the definition of solvency contained within Section 101; b) if the 

amounts were legitimate the amount would be an expense rather than a receivable; or c) the 

receivable is uncollectible. In responding to this Interrogatory, please explain with specificity any 

and all documents reviewed in making your determination.

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6. Please describe with specificity the basis for the removal of the entry “Due to/from 

Sovereign Gaming” of $1,000, $56,000, $60,581.00 and $60,581.00 for the years 2014 through and 

including 2017 from the Trustee’s initial solvency report and the entry not being included in the 

supplemental solvency report, including but not limited which one of the three following reasons 

were the basis for the removal. The three reasons are as follows: a) the receivable was not required 

to be included in the solvency analysis based upon the definition of solvency contained within 

Section 101; b) if the amounts were legitimate the amount would be an expense rather than a 

receivable; or c) the receivable is uncollectible. In responding to this Interrogatory, please explain 

with specificity any and all documents reviewed in making your determination.

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7. Please describe with specificity the basis for the removal of the entry “Due to/from 

Sympatico” of $5,132.50 and 9,442.50 for the years 2016 through and including 2017 from the 

Trustee’s initial solvency report and the entry not being included in the supplemental solvency 

report, including but not limited which one of the three following reasons were the basis for the 

removal. The three reasons are as follows: a) the receivable was not required to be included in the 

solvency analysis based upon the definition of solvency contained within Section 101; b) if the 

amounts were legitimate the amount would be an expense rather than a receivable; or c) the 

receivable is uncollectible. In responding to this Interrogatory, please explain with specificity any 

and all documents reviewed in making your determination.

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8. Please describe with specificity the basis for the removal of the entry “Due to/from 

Unknown – Santa Barbara refi.” of $400,000.00 for the year 2016 from the Trustee’s initial 

solvency report and the entry not being included in the supplemental solvency report, including but 

not limited which one of the three following reasons were the basis for the removal. The three 

reasons are as follows: a) the receivable was not required to be included in the solvency analysis 

based upon the definition of solvency contained within Section 101; b) if the amounts were 

legitimate the amount would be an expense rather than a receivable; or c) the receivable is 

uncollectible. In responding to this Interrogatory, please explain with specificity any and all 

documents reviewed in making your determination.

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9. Please describe with specificity the basis for the removal of the entry “Due to/from 

Tanya Siskind” of $16,500.00 and $16,500.00 for the years 2016 through and including 2017 from 

the Trustee’s initial solvency report and the entry not being included in the supplemental solvency 

report, including but not limited which one of the three following reasons were the basis for the 

removal. The three reasons are as follows: a) the receivable was not required to be included in the 

solvency analysis based upon the definition of solvency contained within Section 101; b) if the 

amounts were legitimate the amount would be an expense rather than a receivable; or c) the 

receivable is uncollectible. In responding to this Interrogatory, please explain with specificity any 

and all documents reviewed in making your determination.

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10. Please describe with specificity the basis for the removal of any other entry from the 

Trustee’s initial solvency report and the entry not being included in the supplemental solvency 

report, including but not limited which one of the three following reasons were the basis for the 

removal. The three reasons are as follows: a) the receivable was not required to be included in the 

solvency analysis based upon the definition of solvency contained within Section 101; b) if the 

amounts were legitimate the amount would be an expense rather than a receivable; or c) the 

receivable is uncollectible. In responding to this Interrogatory, please explain with specificity any 

and all documents reviewed in making your determination.

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Dated this day of , 2020.

ROBERT C. FURR

By

Name: 

Title: 

STATE OF

COUNTY OF

)

) ss

)

Sworn to and subscribed before me on this day of , 2020, by

known to me or who has produced

, on behalf of Robert C. Furr, who is personally as identification and who did

(did not) take an oath.

NOTARY PUBLIC AT LARGE

Signature of Notary Public

(SEAL)

Printed Name of Notary Public

Commission No. 

Commission Expires

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