UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

 Case No.: 18-16248-BKC-MAM 

IN RE: Chapter 7 Proceeding

CHANCE & ANTHEM, LLC,

Debtor.

____________________________________/

ROBERT C. FURR, not individually but 

as Chapter 7 Trustee of the estate of the 

Debtor, Chance & Anthem, LLC,

Plaintiff.

v. Adv. Proc. No.: 19-01298-BKC-MAM-A

JEFFREY SISKIND, individually and

d/b/a SISKIND LEGAL SERVICES, 

TANYA SISKIND, individually and as Trustee

of the SISKIND FAMILY TRUST,

FRANK ZOKAITES, individually, 

CANNAMED PHARMACEUTICALS, LLC, a

Maryland Limited Liability Company,

OB Real Estate 1732, LLC, a Florida Limited 

Liability Company, SISKIND LEGAL SERVICES, LLC,

a Florida Limited Liability Company,

SOVEREIGN GAMING & ENTERTAINMENT, LLC, a

Florida Limited Liability Company, FLORIDA’S 

ASSOCIATION OF COMMUNITY BANKS AND

CREDIT UNIONS, INC., a Florida corporation, 

SYMPATICO EQUINE RESCUE, INC., a Florida corporation,

WELLINGTON 3445, LP, a Florida Limited Partnership,

ZOKAITES PROPERTIES, LP, a Pennsylvania Limited Partnership,

and ROBERT GIBSON, individually,

Defendant.

____________________________________/

DEFENDANTS’, CANNAMED PHARMACEUTICALS, LLC, TANYA SISKIND,

SISKIND FAMILY TRUST, SISKIND LEGAL SERVICES, LLC, SOVEREIGN 

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GAMING & ENTERTAINMENT, LLC, FLORIDA’S ASSOCIATION OF 

COMMUNITY BANKS AND CREDIT UNIONS, INC., AND SYMPATICO

EQUINE RESCUE, INC., ANSWER AND AFFIRMATIVE DEFENSES 

Defendants, CannaMed Pharmaceuticals, LLC, Tanya Siskind, Siskind Family 

Trust, Siskind Legal Services, LLC, Sovereign Gaming & Entertainment, LLC, 

Florida’s Association of Community Banks and Credit Unions, Inc., and Sympatico 

Equine Rescue, Inc. (hereinafter collectively referred to as “Defendant” or “Defendants”) 

(hereinafter referred to as “Defendant”) hereby files this its Answer and Affirmative 

Defenses to the Complaint filed by ROBERT C. FURR, not individually but as Chapter 7

Trustee of the estate of the Debtor, Chance & Anthem, LLC (hereinafter referred to as 

“Plaintiff” or “Trustee”), and in support thereof states:

1. Without knowledge.

2. Denied.

3. Denied.

4. Denied.

5. Admitted as to the Trustee is seeking substantive consolidation in this matter; 

deny the Trustee is entitled to such relief.

6. Admitted as to the relief sought by the Trustee; deny the Trustee is entitled to 

such relief.

7. Admitted.

8. Admitted.

9. Without knowledge, as the documents speak for themselves.

10. Admitted an Order transferring the case was entered and the matter was 

transferred; deny the appropriate relief was to transfer this matter.

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11. Admitted.

12. Denied.

13. Denied.

14. Without knowledge.

15. Admitted that CannaMed is a limited liability company existing under the laws 

of the State of Maryland; deny the remaining allegations.

16. Without knowledge.

17. Admitted that Siskind Legal is a limited liability company existing under the 

laws of the State of Florida; deny the remaining allegations.

18. Admitted that Sovereign is a limited liability company existing under the laws 

of the State of Florida; deny the remaining allegations.

19. Admitted that FLACC is a corporation existing under the laws of the State of 

Florida; deny the remaining allegations.

20. Admitted that Sympatico is a corporation existing under the laws of the State 

of Florida; deny the remaining allegations.

21. Without knowledge.

22. Without knowledge.

23. Without knowledge.

24. Without knowledge.

25. Admitted.

26. Admitted.

27. Admitted.

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FACTS SUPPORTING THE CLAIMS

A. The Siskind Bankruptcy Case

28. Without knowledge.

29. Without knowledge.

30. Without knowledge.

31. Without knowledge, as the Statutes speak for themselves.

32. Without knowledge.

Chance & Anthem Transactions

33. Without knowledge.

Sympatico and FLACC Transactions

34. Denied.

35. Denied.

Christopher George and Sovereign

36. Without knowledge.

37. Denied.

B. Chance & Anthem and CannaMed Pharmaceuticals, LLC

38. Without knowledge, as the documents speak for themselves.

39. Without knowledge, as the documents speak for themselves.

40. Denied.

41. Without knowledge.

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C. Christopher George

42. Without knowledge.

43. Without knowledge.

44. Without knowledge.

45. Without knowledge.

46. Without knowledge.

47. Without knowledge.

48. Without knowledge.

D. Carl Stone and Richard Neff

49. Without knowledge.

50. Without knowledge.

51. Without knowledge.

52. Without knowledge.

53. Without knowledge, as the documents speak for themselves.

54. Without knowledge.

55. Without knowledge.

E. Fredrick Volkwein

56. Without knowledge, as the documents speak for themselves.

57. Without knowledge.

58. Without knowledge.

59. Without knowledge.

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F. The Real Estate Transactions

60. Without knowledge.

3485 Lago de Talavera

61. Without knowledge.

62. Without knowledge.

63. Without knowledge.

64. Without knowledge.

65. Without knowledge.

66. Without knowledge.

67. Without knowledge.

68. Without knowledge.

69. Without knowledge.

70. Without knowledge.

71. Without knowledge.

72. Without knowledge.

73. Without knowledge.

The Santa Barbara House

74. Without knowledge.

75. Without knowledge.

76. Without knowledge.

77. Without knowledge.

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78. Without knowledge.

79. Without knowledge.

80. Without knowledge.

81. Without knowledge.

82. Without knowledge.

83. Without knowledge.

84. Without knowledge.

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

85. Without knowledge.

86. Without knowledge.

87. Without knowledge.

88. Without knowledge.

89. Without knowledge.

90. Without knowledge.

91. Without knowledge.

92. Without knowledge.

93. Without knowledge.

94. Without knowledge.

95. Without knowledge.

96. Without knowledge.

97. Without knowledge.

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98. Without knowledge.

99. Denied.

The Cross Creek Condominium

100. Without knowledge.

101. Without knowledge.

102. Without knowledge.

103. Denied.

G. The Transfers at Issue

104. Without knowledge.

105. Denied.

106. Without knowledge.

107. Without knowledge.

108. Denied.

109. Denied.

H. Conditions Precedent

110. Without knowledge.

I. The Causes of Action

COUNTS 1-6

ACTION FOR SUBSTANTIVE CONSOLIDATION OF DEFENDANTS

CANNAMED, SISKIND LEGAL, SOVEREIGN, FLAC, SYMPATICO, AND

WELLINGTON WITH THE DEBTOR’S BANKRUPTCY ESTATE

111. The Defendants reassert and reallege each response as if alleged herein.

112. Without knowledge as the Statute speaks for itself.

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113. Without knowledge as the Statute speaks for itself.

114. Denied.

115. Denied.

COUNTS 7 – 22

AVOIDANCE AND RECOVERY OF FRAUDULENT TRANSFERS PURSUANT TO

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

116. The Defendants reassert and reallege each response as if alleged herein.

117. Without knowledge as the Statute speaks for itself.

118. Without knowledge as the Statute speaks for itself.

119. Denied.

120. Denied.

121. Denied.

122. Denied.

123. Denied.

COUNTS 23-38

AVOIDANCE AND RECOVERY OF FRAUDULENT TRANSFERS PURSUANT TO

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

124. The Defendants reassert and reallege each response as if alleged herein.

125. Without knowledge as the Statute speaks for itself.

126. Without knowledge as the Statute speaks for itself.

127. Denied.

128. Denied.

129. Denied.

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130. Denied.

131. Denied.

COUNTS 39-55

AVOIDANCE AND RECOVERY OF FRAUDULENT TRANSFERS

PURSUANT TO SECTION 544 OF THE BANKRUPTCY CODE

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

132. The Defendants reassert and reallege each response as if alleged herein.

133. Without knowledge as the Statute speaks for itself.

134. Without knowledge as the Statute speaks for itself.

135. Without knowledge as the Statute speaks for itself.

136. Denied.

137. Denied.

138. Denied.

139. Denied.

140. Denied.

141. Denied.

142. Denied.

143. Without knowledge as the Statute speaks for itself.

COUNTS 56--72

AVOIDANCE AND RECOVERY OF FRAUDULENT TRANSFERS

PURSUANT TO SECTION 544 OF THE BANKRUPTCY CODE

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

144. The Defendants reassert and reallege each response as if alleged herein.

145. Without knowledge as the Statute speaks for itself.

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146. Without knowledge as the Statute speaks for itself.

147. Without knowledge as the Statute speaks for itself.

148. Denied.

149. Denied.

150. Denied.

151. Denied.

152. Denied.

153. Denied.

154. Denied.

155. Without knowledge as the Statute speaks for itself.

COUNTS 73--89

AVOIDANCE AND RECOVERY OF FRAUDULENT TRANSFERS

PURSUANT TO SECTION 544 OF THE BANKRUPTCY CODE

AND SECTION 726.106(1) OF THE FLORIDA STATUTES

156. The Defendants reassert and reallege each response as if alleged herein.

157. Without knowledge as the Statute speaks for itself.

158. Without knowledge as the Statute speaks for itself.

159. Denied.

160. Denied.

161. Denied.

162. Denied.

163. Denied.

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164. Denied.

165. Denied.

166. Without knowledge as the Statute speaks for itself.

COUNTS 90-92

ACTION FOR CONSTRUCTIVE TRUST

167. The Defendants reassert and reallege each response as if alleged herein.

168. Denied.

169. Denied.

170. Denied.

171. Denied.

COUNT 93-95

ACTION FOR EQUITABLE LIEN

172. The Defendants reassert and reallege each response as if alleged herein.

173. Denied.

174. Denied.

175. Denied.

176. Denied.

COUNT 96

AVOIDANCE OF POST-PETITION TRANSFERS UNDER 11 U.S.C. §549

177. The Defendants reassert and reallege each response as if alleged herein.

178. Without knowledge as the documents speak for themselves.

179. Without knowledge as the Statute speaks for itself.

180. Denied.

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181. Denied.

COUNT 97

ACTION SEEKING A PERMANENT

INJUNCTION AGAINST ALL DEFENDANTS

182. The Defendants reassert and reallege each response as if alleged herein.

183. Without knowledge as the documents speak for themselves.

184. Denied.

185. Without knowledge.

AFFIRMATIVE DEFNSES

AS AND FOR the Defendants’ First Affirmative Defense, the Defendants assert the 

Trustee/Plaintiff has failed to state a cause of action.

AS AND FOR the Defendants’ Second Affirmative Defense, the Defendants assert

the Debtor was solvent at the time of the transfers as described in the Trustee/Plaintiff’s 

Complaint, which the Trustee is seeking to avoid and recover, or did not become insolvent as 

a result of the transfers.

AS AND FOR the Defendants’ Third Affirmative Defense, the Defendants assert, 

upon information and belief, that at the time of the transfers described within the 

Trustee’s/Plaintiff’s Complaint, the Debtor was not engaged or about to engage in business 

or a transaction for which the remaining assets of the Debtor or its respective Related

Defendant were unreasonably small in relation to the business or transactions in which the

Debtor or its respective Related Defendant were engaged. 

AS AND FOR the Defendants’ Fourth Affirmative Defense, the Defendants assert, 

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upon information and belief, that at the time of the transfers described within the 

Trustee’s/Plaintiff’s Complaint, the Debtor had not incurred debts beyond its ability to pay as 

they became due.

AS AND FOR the Defendants’ Fifth Affirmative Defense, the Defendants assert, 

upon information and belief, in exchange for the transfers as described within the 

Trustee’s/Plaintiff’s Complaint, which the Trustee/Plaintiff is seeking to avoid and recover,

the Debtor received reasonably equivalent value for said transfers.

AS AND FOR the Defendants’ Sixth Affirmative Defense, the Defendants assert

substantive consolidation is not the appropriate remedy by the Trustee/Plaintiff in this 

matter, as each entity was a separate and distinct entity from the Debtor. Moreover, the 

prejudice suffered by each Defendant from the remedy of substantive consolidation far 

outweighs the benefits gained by the Trustee/Plaintiff in obtaining substantive consolidation. 

Finally, if the Trustee/Plaintiff successfully avoids and recovers each of the transfers, which 

he has sought to avoid and recover in the remaining Counts of this Adversary, the same 

result would be reached without any of the potential prejudice that would stem from 

substantive consolidation. Based upon the availability of a remedy without the potential 

prejudice of substantive consolidation, the Court should deny the Trustee/Plaintiff’s request 

of substantive consolidation. 

WHEREFORE the Defendants, CannaMed Pharmaceuticals, LLC, Tanya 

Siskind, Siskind Family Trust, Siskind Legal Services, LLC, Sovereign Gaming & 

Entertainment, LLC, Florida’s Association of Community Banks and Credit Unions, 

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Inc., and Sympatico Equine Rescue, Inc., respectfully requests the Court enter a Final 

Judgment in its favor determining the Trustee/Plaintiff is not entitled to the extraordinary 

remedy of substantive consolidation, not entitled to avoid and recover anything from the 

Defendants, the Trustee/Plaintiff is not entitled to a constructive trust, not entitled to an 

equitable lien, and the Trustee/Plaintiff is not entitled to a permanent injunction, plus grants 

such other and further relief as the Court deems just and proper.

The Defendants reserve the right to amend this Answer and Affirmative Defenses in 

the future if the facts and/or need arises.

I HEREBY CERTIFY that I am admitted to the Bar of the United States District 

Court for the Southern District of Florida and I am in compliance with the additional 

qualifications to practice in this Court set forth in Local Rule 2090-1(A).

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

furnished by the Court’s CM/ECF system on the 31st day of January 2020 to:

Jesus M. Suarez, Esq.

jsuarez@gjb-law.com, gjbecf@gjb-law.com

PHILIP B. HARRIS, P.A. 

685 Royal Palm Beach Boulevard

Suite 205

Royal Palm Beach, FL 33411

Tel: 561-543-7963

Fax: 561-793-1020

By: /s/ Philip B. Harris__________

Philip B. Harris, Esq.

FL Bar ID: 19781

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