UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

www.flsb.uscourts.gov

In re: Case No. 18-16248-BKC-MAM

Chapter 7

CHANCE & ANTHEM, LLC,

Debtor.

 /

ROBERT C. FURR not individually but ADV. NO. 19-01298-MAM

as Chapter 7 Trustee of the estate of the

Debtor, Chance & Anthem, LLC,

Plaintiff,

v.

JEFFREY M. SISKIND, individually and 

d/b/a SISKIND LEGAL SERVICES,

et al.

Defendants.

/

AGREED EX PARTE MOTION BY PLAINTIFF, ROBERT C. FURR,

TO CONTINUE PRETRIAL CONFERENCE AND EXTEND 

RELATED PRETRIAL DEADLINES

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

the Bankruptcy Estate of the Debtor, Chance & Anthem, LLC (the “Debtor”) by and through 

counsel, files this Agreed Ex Parte Motion to Continue Pretrial Conference and Extend Related 

Pretrial Deadlines (the “Motion”) and in support thereof state, as follows: 

I. BACKGROUND.

1. On January 29, 2019 (the “Petition Date”) the Debtor, Chance and Anthem, LLC

(“Debtor”) filed a voluntary petition for relief under Chapter 7 of the Bankruptcy Code (the 

“Petition”) in the United States Bankruptcy Court for the District of Maryland (the “Maryland 

Bankruptcy Court”), in the matter styled In re Chance & Anthem, LLC, Case No. 18-11168-TJC 

(the “Bankruptcy Case”). The Plaintiff is the duly appointed and acting Trustee of the Debtor’s 

Case 19-01298-MAM Doc 58 Filed 10/04/19 Page 1 of 8
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bankruptcy estate (the “Estate”).

2. On May 24, 2018, the Bankruptcy Court for the District of Maryland entered its 

Memorandum and Order Transferring Venue To The Bankruptcy Court For the Southern District 

of Florida (the “Transfer Order”)[ECF No. 73], transferring the Bankruptcy Case to this Court.

3. On May 25, 2018, the Plaintiff, Robert C. Furr, was duly appointed and is acting 

Chapter 7 Trustee of the Estate [ECF No. 76].

4. On August 06, 2019, the Plaintiff filed the Adversary Complaint to Avoid and 

Recover Fraudulent Transfers, For Turnover, For an Accounting, Alter-Ego, Substantive 

Consolidation, Injunctive Relief and for Related Relief (the “Adversary Complaint”) [ECF No. 

1] in the above adversary proceeding (the “Adversary Proceeding”) against Jeffrey Siskind (“J. 

Siskind”), Tanya Siskind, (“T. Siskind”), CannaMED Pharmaceuticals, LLC (“CannaMED”), 

Siskind Legal Services, LLC (“Siskind Legal”), Second Siskind Family Trust (“Siskind Trust”), 

Florida’s Association of Community Banks and Credit Unions (“Florida’s Association”), 

Sympatico Equine Rescue, Inc. (“Sympatico”), Sovereign Gaming & Entertainment, LLC 

(“Sovereign”), Frank Zokaites (“F. Zokaites”), OB Real Estate 1732, LLC (“OB Real Estate”), 

Wellington 3445, LP (“Wellington”), Zokaites Properties, LP (“Zokaites Properties”) and Robert 

Gibson (“R. Gibson”)(collectively, the “Defendants”).

5. On August 07, 2019, the Court issued the Summons and Notice of Pretrial/Trial in 

an Adversary Proceeding, scheduling the Pretrial Conference for November 14, 2019 at 10:00 

a.m. [ECF No. 03]. 

6. On same date, the Court entered an Order Setting Filing and Disclosure 

Requirements for Pretrial and Trial Setting Pretrial Conference (the “Pretrial Order”) [ECF No.

04] which references all corresponding pretrial deadlines.

Case 19-01298-MAM Doc 58 Filed 10/04/19 Page 2 of 8
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II. RELIEF REQUESTED.

7. The Parties have agreed to a continuance of the Pretrial Conference to January 14, 

2020 at 10:00 a.m. Further, the Parties seek a concomitant enlargement of the deadlines set forth 

in the Pretrial Order to coincide with the continued Pretrial Conference.

8. Counsel for the Plaintiff has conferred with the Defendants, or their counsel,

regarding the filing of this Motion and certifies that the Defendants have agreed to the relief 

requested herein.

9. The filing of this Motion and continuance of the Pretrial Conference and 

extensions of the deadlines under the Pretrial Order are necessary in order to preserve time and 

resources of the Parties. This Motion has been filed in good faith and not for any dilatory 

purpose or improper delays of this adversary proceeding. 

WHEREFORE, the Plaintiff, Robert C. Furr, as the Chapter 7 Trustee, respectfully 

requests the entry of an order attached hereto as Exhibit “A”: (i) granting this Motion; (ii) 

continuing the Pretrial Conference to January 14, 2020 at 10:00 a.m.; (iii) extending all 

corresponding pretrial deadlines accordingly; and (iv) granting such other and further relief as 

the Court deems appropriate. 

Dated this 4th day of October, 2019

GENOVESE JOBLOVE & BATTISTA, P.A.

Counsel for Plaintiff

100 S.E. Second Street, 44th Floor

Miami, FL 33131

Tel: (305) 349-2300

Fax: (305) 349-2310

By: /s/ Jesus M. Suarez 

 Jesus M. Suarez, Esq.

 Fla. Bar No. 60086

 Email: jsuarez@gjb-law.com

Case 19-01298-MAM Doc 58 Filed 10/04/19 Page 3 of 8
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CERTIFICATE OF SERVICE

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

via CM/ECF notification upon all interested parties registered to receive electronic notification 

on this matter and/or via U.S. Mail as indicated on the Service List below on this 4th day of 

October, 2019.

By: /s/ Jesus M. Suarez

 Jesus M. Suarez, Esq.

SERVICE LIST

Notice was served via CM/ECF upon:

Julie Feigeles on behalf of Defendant OB Real Estate Holdings 1732, LLC 

jf@womenatlawfl.com

Julie Feigeles on behalf of Defendant Wellington 3445, LP 

jf@womenatlawfl.com

Julie Feigeles on behalf of Defendant Zokaites Properties, LP 

jf@womenatlawfl.com

Barry P Gruher on behalf of Plaintiff Robert C Furr 

bgruher@gjb-law.com, vlambdin@gjb-law.com;gjbecf@gjb-law.com;cesser@gjblaw.com;gjbecf@ecf.courtdrive.com;chopkins@gjb-law.com

Samantha T Haimo on behalf of Defendant OB Real Estate Holdings 1732, LLC 

sth@womenatlawfl.com, way@swlawyers.law

Samantha T Haimo on behalf of Defendant Wellington 3445, LP 

sth@womenatlawfl.com, way@swlawyers.law

Samantha T Haimo on behalf of Defendant Zokaites Properties, LP 

sth@womenatlawfl.com, way@swlawyers.law

Jeffrey M Siskind on behalf of Defendant CannaMed Pharmaceuticals, LLC 

jeffsiskind@msn.com, jmsesq500@gmail.com

Jeffrey M Siskind on behalf of Defendant Florida's Association of Community Banks and Credit 

Unions, Incorporated 

jeffsiskind@msn.com, jmsesq500@gmail.com

Jeffrey M Siskind on behalf of Defendant Second Siskind Family Trust 

jeffsiskind@msn.com, jmsesq500@gmail.com

Case 19-01298-MAM Doc 58 Filed 10/04/19 Page 4 of 8
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Jeffrey M Siskind on behalf of Defendant Siskind Legal Services 

jeffsiskind@msn.com, jmsesq500@gmail.com

Jeffrey M Siskind on behalf of Defendant Sovereign Gaming and Entertainment, LLC 

jeffsiskind@msn.com, jmsesq500@gmail.com

Jeffrey M Siskind on behalf of Defendant Sympatico Equine Rescue, Inc. 

jeffsiskind@msn.com, jmsesq500@gmail.com

Jeffrey M Siskind on behalf of Defendant Jeffrey M Siskind 

jeffsiskind@msn.com, jmsesq500@gmail.com

Jeffrey M Siskind on behalf of Defendant Tanya Siskind 

jeffsiskind@msn.com, jmsesq500@gmail.com

Jesus M Suarez on behalf of Plaintiff Robert C Furr 

jsuarez@gjb-law.com, gjbecf@gjb-law.com;chopkins@gjb-law.com;jzamora@gjblaw.com;ecastellanos@gjb-law.com;gjbecf@ecf.courtdrive.com

Notice will be served via U. S. Mail upon:

Robert Gibson

1709 22 Ave N 

Lake Worth, FL 33460 

Frank R. Zokaites

375 Golfside Dr 

Wexford, PA 15090

Case 19-01298-MAM Doc 58 Filed 10/04/19 Page 5 of 8
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EXHIBIT “A”

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[PROPOSED ORDER]

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

www.flsb.uscourts.gov

In re: Case No. 18-16248-BKC-MAM

Chapter 7

CHANCE & ANTHEM, LLC,

Debtor.

 /

ROBERT C. FURR not individually but ADV. NO. 19-01298-MAM

as Chapter 7 Trustee of the estate of the

Debtor, Chance & Anthem, LLC,

Plaintiff,

v.

JEFFREY M. SISKIND, individually and 

d/b/a SISKIND LEGAL SERVICES,

et al.

Defendants.

/

ORDER GRANTING AGREED EX PARTE MOTION BY PLAINTIFF, ROBERT C. 

FURR, TO CONTINUE PRETRIAL CONFERENCE AND EXTEND

RELATED PRETRIAL DEADLINES 

THIS MATTER came before the Court without a hearing upon the Agreed Ex Parte

Motion by Plaintiff, Robert C. Furr, to Continue Pretrial Conference and Extend Related Pretrial 

Case 19-01298-MAM Doc 58 Filed 10/04/19 Page 7 of 8
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Deadlines [ECF No. ____] (the “Motion”), and the Court having reviewed the Motion, the record 

in this case, and noting the agreement of the parties with respect to the relief granted herein, and 

being otherwise duly advised in the premises, it is

ORDERED, as follows: 

1. The Motion is GRANTED. 

2. The Pretrial Conference is hereby continued to January 14, 2020 at 10:00 a.m. at 

the United States Bankruptcy Court, Flagler Waterview Building, 1515 N Flagler Drive, Room 

801 Courtroom A, West Palm Beach, FL 33401

3. The corresponding pretrial deadlines are extended accordingly to coincide with 

the continued Pretrial Conference.

###

Submitted by:

Jesus M. Suarez, Esq.

Counsel for the Plaintiff

Genovese Joblove & Battista, P.A.

100 SE 2nd Street, Suite 4400

Miami, FL 33131

Tel: (305) 349-2300

Email: jsuarez@gjb-law.com

[Attorney Suarez shall serve a copy of this Order to all interested parties and file a certificate of 

service]

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