UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA

WEST PALM I}EACH DTVISION

IN RE:

CHANCE & ANTHEM, LLC,

Debtor.

RoBERrc.e@t

as Chapter 7 Trustee of the estate oitlr. f)ebtor, Chance & Anthem, LLC,

Case No.: l8-16248-BKC-MAM

Chapter 7 proceecting

Adv. Proc. No.: I9.OI30I.BKC.MAM.A

Plaintitf.

v.

ADVANCED AVIONICS, LLC,

Def'endant.

PLAINTI

VANCED AV NI

RT C. FT]RR'S FII SET INT

coMES Now, the Defendant, Advanced avionics, LLC, by and through uldersignecl counscl' and hcrcby rcsponds to thc Plaintiff s, r{obcrt c. Furr, as Trustec in B-ankruptcy for the Estate of chance & Anthem,LLC,First set uf Int*;;og;tories as fblrows:

INTERROGATORIES

l' state the nilme, aclciress' ancl title ol-each and every Person wh<l (i) assisted or contribuled to the collection of infbmratio-n necessary to answer these lntenogatories, (ii) participatetl in the fiaming of such answers.. (iii) may ha"e krrowledge concenrirrg the facts alteged in the complaint; and (iv) tnay havc knowledge concemirig arry potenrial defenses or affirmarive defenses to the causes of action allegecl in ihe Complaini

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ANSWER:

Stephcn Jackowski

c/o JelTrey Siskind, Esq.

3465 Santa Barbara Oiive

Wellington, l'L 33414

Jeffrey Siskind, Esq.

3465 Santa Bartrara Drive

Wellington, FL 33414

2' Identify the date, payor, alnount and account number of the fund(s) allegedly transferrecl to thc Debtor that You claim were earmarked tbr paymeni or tn" mechanical sewices you clainr we'e provided by Defendant in your Third Rtfirmative Def'ense.

ANSWER:

$100,000 bank check paid by Debtor in 2015.

2

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3' Identify the services that you claim were providecl on accor.rlt of t6e transfers you

which 

received fiom the Debtor, including (a) the party th;t receiued the services: (b) the ternrs under

oompensation 

the services were prot'icled; (c) a rlesci'iption of the services provitled; (tl) the total receivcd for said services; ancl (e) the idcntity of the parlies providing oomperlsation' the Pleasc state thc ternrs utrdcr which tlrcse allcged transfers wcrc made to the

l.:r',:Ty"J,',i1li#l'"documents 

corroboratirs same. ptease further itlent*y th" porty th"t

ANSWER:

(a) Serviccs were pcrf,rmed on an aircralt owned bv Metroporitan Air, Inc. (b) $100,000 u'as paid lbr rvork done to datc il;;;r;,;;avionics purchases (c) Fuselageo lving and control surface refinishing, avionics purchase antr panel replacement, electrical wiring- antl harne"ss replacements, engine mounting, f'uel tank and fuer system instailation ano rJpairs, and aircraft storage

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(d) Estimated $7,500 net realized atter payments fo fhird party suppliers ol. labor and materials

(e) chancc & Anthenr, LLC; terms were to appry on account of supplies and labor. Any corroborating documents are in storage in pennsyr'ania, and cannot he identified until the undersigned who is in Florida can travel to the storage location. Parties provicling this inlbrmation are listed in the response to lnterrogatorv No. [.

4' Identify the date, payor' amount and account numbet of the fund(s) allegedly transl'erred to the Debtor by the owner of tlie aircralt as set lorth in your Fourth Alfinnative Del.ense. please

state the terms under which these alleged transfbrs -erc macle to thc Debtor and i<lentify all documeuts corroborating sarnc. Pleasc further identify thc party that provicled you this infonnation.

ANSWER:

This Defendant does not hal'e this information.

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5' Identify the aircraft referettced in your Affirmative Det'errses. please provide the nranufacfurer, model. ycar, registration numbei lalk/atailnurnber) and identify its owner. ANSWER:

Beechcrall Baron C-SS, 1966, N2O*GS, Metropolitan Air, Inc.

Signature

STATE OT.'}.LOIiIDA

COUNTY OF

tPuq bffia*'

)

)ss

)

who is pcrsonally known to mc or who has procluccd

iderrtificati<.rn an<l who ctid (did not) take an oath.

RGE

Prinfed Name of Nqtary

Cornrniso-ion No.

Public

Conrrrission Expirt

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