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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

West Palm Beach Division 

IN RE:

CHANCE & ANTHEM, LLC, CASE NO.: 18-16248-BKC-MAM

Debtor,

_______________________________/

ROBERT C. FURR, not individually but

as Chapter 7 Trustee of the estate of the

Debtor, Chance & Anthem, LLC,

Plaintiff,

v. ADV.PRO.NO.: 19-1298-BKC-MAM-A

JEFFREY M. SISKIND, individually and

d/b/a SISKIND LEGAL SERVICES,

et. al,

Defendants,

_________________________________/

DEFENDANTS', CANNAMED PHARMACEUTICALS, LLC, TANYA SISKIND, 

SECOND 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., OBJECTIONS TO

ADMISSIBILITY OF TRUSTEE'S EXHIBITS

The Defendants, CannaMed Pharmaceuticals, LLC, Tanya Siskind, Second 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., (“Movants” or “Defendants”), by and through undersigned counsel, hereby files 

this, their Objections to the Admissibility of the Plaintiff's, Robert C. Furr, Trustee in 

Bankruptcy for Chance & Anthem, LLC (“Trustee” or “Plaintiff”) Exhibits pursuant to this 

Court’s Order Setting Pretrial as follows: 

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GENERAL OBJECTIONS

Movants object to Trustee's Exhibits because they were filed out of time, with no prior 

request for extension of time or explanation for the late filing. More importantly, many of 

Trustee’s exhibits have no relevance whatsoever to the issues in dispute. 

SPECIFIC OBJECTIONS

1. Movants object to the admission of the Trustee’s Exhibit # 1 through 147, 

inclusive, into evidence pursuant to Federal Rule of Evidence 402, except as stated otherwise 

herein. Movants assert that said aforementioned Exhibits have no relevance to the issues before 

the Court or the issues to be determined at the trial in this matter.

2. Movants object to the admission of Trustee’s Exhibit #31 into evidence pursuant 

to Federal Rule of Evidence 106. Pursuant to Federal Rule of Evidence 106 when a writing is 

introduced into evidence, the entirety of the writing should be considered with it. The Movants

concede the proposed document is complete in and of itself; however, when considered in the 

totality of the situation, this document alone fails to explain or evidence the complete picture. 

3. Movants object to the substance of Trustee’s Exhibits # 1 through 147, inclusive, 

except as stated otherwise herein, and demands cross examination of whomever the Trustee puts 

forth to authenticate each Exhibit; otherwise, pursuant to Federal Rules of Evidence 801, 802, 

803 and 804, which Exhibits should not be admitted into evidence on the grounds that it is 

inadmissible hearsay and otherwise unreliable.

4. Movants object to the admission or utilization of the Trustee's Exhibit #123, 

Expert Report of Alan Barbee. Pursuant to Federal Rule of Civil Procedure 26(e), the Trustee 

was required to provide any expert reports to be relied upon at trial in this matter by a date 

certain. After providing his initial Expert Report, on June 25, 2020, the Trustee provided 

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Movants with a Supplement to the Expert Report. The Supplement to the Expert Report was not 

provided based upon the original expert report being incomplete or incorrect. Rather, the 

Supplement to the Expert Report was merely prepared to annul Movants' allegations as to 

solvency and to perfect the Trustee's litigation strategy. As such, Movants object to the 

admissibility of the Supplement to the Expert Report, and pursuant to Federal Rule of Civil 

Procedure 37(c)(1), seeks to preclude the Supplemented Expert Report. Additionally, to 

whatever extent the Trustee seeks to rely upon the initial expert report, Movants object on the 

basis the initial expert report was supplemented and is not properly before this Court.

5. The Movants object to Trustee exhibit no. 147 based upon relevancy and hearsay.

6. Notwithstanding the foregoing, Movants do not object to Trustee exhibit nos. 28, 

36, 61, 62, 88, 94, 98, 99, 102, 103, 104, 105, 106, 107, 108, 109, 110, 111 and 126.

7. Movants reserve on amending these objections as necessary to respond to exhibits 

intended to be introduced by the Trustee.

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).

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I HEREBY CERTIFY that a true and correct copy of the Defendants’ CannaMed 

Pharmaceuticals, LLC, Tanya Siskind, Second 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., Objections 

to the Admissibility of the Plaintiff's, Robert C. Furr, Trustee in Bankruptcy for Chance & 

Anthem, LLC, has been furnished by CM/ECF to the following on the 10th day of July 2020:

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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