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, 

TANYA SISKIND, individually and as Trustee of the, 

SECOND SISKIND FAMILY TRUST, 

FRANK ZOKAITES, individually, 

CANNAMED PHARMACEUTICALS, LLC, 

a Maryland Limited Liability Company, 

OB REAL ESTATE HOLDINGS 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 

 Defendants 

________________________________________________/ 

PLAINTIFF’S EX-PARTE MOTION TO ISSUE ALIAS SUMMONS

 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 

undersigned counsel, pursuant to Bankruptcy Rule 7004(e), hereby files his ex-parte Motion to 

Case 19-01298-MAM Doc 12 Filed 08/20/19 Page 1 of 5
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Issue Alias Summons (the “Motion”), and in support thereof states: 

1. By this Motion, the Trustee requests the entry of an Order directing the Clerk to 

issue an alias summons on Defendant, Sovereign Gaming & Entertainment, LLC. 

2. On January 29, 2018 (the “Petition Date”), the Debtor filed a voluntary petition 

for relief under Chapter 7, Title 11 of the United States Code (the “Bankruptcy Code”). [Main 

Case, ECF No. 1]. Shortly thereafter, the Trustee was appointed as the duly acting Chapter 7 

trustee for the Debtor’s bankruptcy estate. 

3. On August 06, 2019, the Trustee filed an adversary complaint (the “Complaint”) 

against numerous Defendants, including Sovereign Gaming & Entertainment, LLC 

(“Sovereign”) to, among other things, avoid and recover certain fraudulent transfers made by the 

Debtors to Defendant pursuant to Sections 544, 548 and 550 of Title 11 of the United States 

Code and Section 726 of the Florida Statutes. 

4. Defendant Sovereign is an inactive Florida Limited Liability Company. Its sole 

manager and registered agent was William Siskind, whom is deceased. Jeffrey Siskind, who is 

also a Defendant in this action, is believed to control Defendant Sovereign as a nominee of 

William Siskind, his deceased father. 

5. On August 07, 2019, the Clerk issued a summons [ECF No. 04]. 

6. On August 09, 2019, the Trustee served the Complaint and Summons upon 

Defendant Sovereign, in care of Jeffrey Siskind, as nominee to William Siskind. 

7. Defendant Jeffrey Siskind has contested the Trustee’s service of the Complaint 

and Summons, inasmuch as he is not a managing member of Defendant Sovereign. 

8. In-light of same, the Trustee moves for the entry of an alias summons to serve the 

Secretary of State, as agent pursuant to Fla. Stat. 48.181. 

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9. A proposed order granting the relief requested has been uploaded to the Court via 

CM/ECF. 

WHEREFORE, the Trustee requests the entry of an Order: (i) directing the Clerk to issue 

an alias summons; and (ii) granting such other and further relief as the Court deems just and 

proper. 

 Respectfully submitted on this 20th day of August, 2019 

GENOVESE JOBLOVE & BATTISTA, P.A. 

 Counsel to the Chapter 7 Trustee 

100 S.E. 2nd Street, Suite 4400 

Miami, FL 33131 

Tel.: (305) 349-2300 

Fax.: (305) 349-2310 

 By:/s/ Jesus M. Suarez 

 Jesus M. Suarez, Esq. 

 Fla. Bar No. 60086 

 jsuarez@gjb-law.com 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on this 20th day of August, 2019, a copy of the foregoing 

was served upon all parties registered to receive electronic notification in this case via the 

Court’s CM/ECF system and/or via U.S. Mail as indicated on the Service List below. 

 By: /s/ Jesus M. Suarez 

 Jesus M. Suarez, Esq. 

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SERVICE LIST 

Notice will be served via CM/ECF upon: 

Samantha T Haimo on behalf of Defendant Wellington 3445, 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 OB Real Estate Holdings 1732, LLC 

jeffsiskind@msn.com, jmsesq500@gmail.com 

Jeffrey M Siskind on behalf of Defendant Siskind Legal Services 

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: 

Second Siskind Family Trust 

c/o Tanya Siskind, Trustee 

3465 Santa Barbara Drive 

Wellington, Florida 33414 

Frank Zokaites 

375 Golfside Drive 

Wexford, PA 15090 

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Sovereign Gaming and Entertainment, LLC 

c/o Jeffrey M. Siskind, on behalf of William Siskind, deceased 

3465 Santa Barbara Drive 

Wellington, Florida 33414 

Zokaites Properties, LP 

c/o Frank Zokaites, for General Partner, Zokaites Contracting, Inc. 

375 Golfside Drive 

Wexford, PA 15090 

Robert Gibson 

1709 22nd Avenue North 

Lake Worth, Florida 33460 

Robert Gibson 

7369 Palmdale Drive 

Boynton Beach, Florida 33436

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