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-BKC-MAM

as Chapter 7 Trustee of the estate of

the Debtor, Chance & Anthem, LLC, 

Plaintiff,

v. 

JEFFREY M. SISKIND, et al.

Defendant/Counter-Plaintiff,

v.

ROBERT C. FURR, individually, JESUS

SUAREZ, ESQUIRE, and GENOVESE,

JOBLOVE AND BATTISTA, P.A.,

Counter-Defendants.

________________________________________/

JEFFREY M. SISKIND’S AMENDED ANSWER, AFFIRMATIVE DEFENSES

AND COUNTERCLAIMS TO PLAINTIFF ROBERT C. FURR’S FIRST AMENDED 

COMPLAINT TO AVOID AND TO RECOVER FRAUDULENT TRANSFERS, FOR 

TURNOVER, FOR AN ACCOUNTING, SUBSTANTIVE CONSOLIDATION,

INJUNCTIVE RELIEF AND FOR OTHER RELIEF

NOW COMES Jeffrey M. Siskind (“Defendant”), pro se, and answers Plaintiff’s First 

Amended Complaint to Avoid and to Recover Fraudulent Transfers, for Turnover, for an 

Accounting, Substantive Consolidation, Injunctive Relief and for other Relief, and states:

1. The allegations made by Plaintiff in Counts 7, 8, 9, 11, 12, 15, 16,20, 23, 24, 25, 

27, 28, 31, 32, 36, 39, 40, 41, 43, 44, 47, 48, 50, 53, 56, 57, 58, 60, 61, 64, 65, 67, 70, 73, 74, 75, 

77, 78, 81, 82, 84 and 87 are denied. Strict proof is demanded.

Case 19-01298-MAM Doc 272 Filed 04/09/20 Page 1 of 6
2. Defendant further denies each and every of Plaintiff’s allegations against any 

related defendant(s), whether said related defendants are characterized as Defendant’s alter 

ego(s) or artifices, to the extent that Defendant owns a direct or beneficial interest in and/or 

controls said related defendants.

2. As a First Affirmative Defense, Defendant states that all transactions which are 

characterized as violative of any provision of the United States Bankruptcy Code or as otherwise 

wrongful by the Chapter 7 Trustee (“Trustee”) were at all times legitimate business dealings. 

The Trustee intentionally mischaracterized and conflated numerous transactions in order to 

intimidate Defendant and others, and for the illegitimate purpose of obtaining negotiated 

settlements on unsubstantiable claims which were advanced by the Trustee in bad faith.

3. As a Second Affirmative Defense, Defendant states that the Chapter 7 Trustee 

committed fraud by wrongfully acquiring its interest in this case and it therefore lacks standing 

to pursue any recovery on behalf of creditors and to obtain remuneration for itself and fees for its 

agents and/or subcontractors, including attorneys and accountants. The fraud perpetuated by the 

Trustee consisted of obtaining its role in this case by means which are inconsistent with the 

manner in which Chapter 7 trustees are randomly assigned their functions by the Office of the 

United States Trustee, which fraud was evidenced both by Steven Newburgh’s announcement to 

his prospective clients that Robert Furr would serve as Trustee, which announcement was made 

prior to the transfer of this case from the District of Maryland, and the absence of a listing for 

this case in the random case assignment schedule. As a result of the Trustee’s fraud, this case 

has been handled in a manner which is inconsistent with the duties of a Chapter 7 Trustee, which 

inconsistency is exhibited by numerous false and unsubstantiable claims made against Defendant 

and others, some but not all of which were made in the Trustee’s initial complaint and were then 

Case 19-01298-MAM Doc 272 Filed 04/09/20 Page 2 of 6
‘dropped’ from the amended version. The fraud perpetuated by the Trustee has caused harm to 

Defendant, both financially and reputationally, which was reasonably foreseeable, and has also 

harmed the public’s perception of fair administration of justice by elucidating the allowance of 

unfair practices within in the Southern District of Florida. The gravity of the fraud perpetuated 

by the Trustee is sufficient reason for the Court to permit leave to Defendant to bring this 

amended affirmative defense in accordance with Federal Rule of Civil Procedure 60(b) as 

applicable to theses proceedings by Federal Rule of Bankruptcy Procedure 9024.

4. As a Third Affirmative Defense, Defendant states that the Trustee is pursuing 

relief which it is not entitled to pursuant to the United States Bankruptcy Code by virtue of its 

mischaracterizing legitimate business transactions, by fraudulently obtaining its role in this case 

and by tainting the proceedings by bringing false and unsubstantiable claims in bad faith.

The following COUNTERCLAIMS are brought by Defendant in his individual capacity 

and to the extent that Defendant may have an interest in and/or control any related defendant:

5. Defendant counterclaims that the Trustee acquired its role in this matter by 

fraudulent means, and that by doing so has damaged Defendant and others, both financially and 

reputationally, and that said damages which were the direct and proximate result of the Trustee’s 

fraud were reasonably foreseeable.

6. Defendant sues Counter-Defendant Robert C. Furr (“Furr”) individually for 

defrauding Defendant by undertaking actions which were unauthorized and outside of the 

protections afforded to Trustees because of the illegitimate manner in which Furr obtained his 

role in this matter, which actions consisted of bringing false and unsubstantiable claims against 

Defendant which claims caused financial and reputational damage to Defendant and Defendant’s 

business interests. Said damages were the direct and proximate result of Furr’s actions and were 

Case 19-01298-MAM Doc 272 Filed 04/09/20 Page 3 of 6
reasonably foreseeable.

7. Defendant sues Counter-Defendants Jesus Suarez, Esquire (“Suarez”) and 

Genoese Joblove & Battista, P.A. (“Genovese”) for intentionally assisting Furr in undertaking 

actions which were unauthorized and outside of the protections afforded to Trustees because of 

the illegitimate manner in which Furr obtained his role in this matter, which actions were 

comprised of bringing false and unsubstantiable claims against Defendant which caused financial 

and reputational damage to Defendant and Defendant’s business interests; damages which were 

the direct and proximate result of Furr’s actions and were reasonably foreseeable. At all times 

relevant, Suarez and Genovese knew that the Trustee has acquired his role in this matter 

illegitimately but joined their efforts with those of the Trustee in order to wrongfully seek 

settlements from Defendant and others on unsubstantiable claims. Actions undertaken by the 

Trustee, Suarez and Genovese comprised a scheme within which said Counter-Defendants 

undertook an illegal conspiracy against Defendant and others tantamount to extortion. Because 

said Counter-Defendants’ actions were undertaken with knowledge and intent to affect the 

machinery of justice, they also constitute a fraud on the court which precludes any recovery.

WHEREFORE, Defendant prays that this Court deny each and every allegation brought 

by Plaintiff, and brings these amended Affirmative Defenses and Counterclaims, and requests

such other and further relief as appropriate.

_______/s/ Jeffrey M. Siskind_______

Jeffrey M. Siskind, Esq. FBN 138746

1629 K Street, Ste. 300, NW Washington, DC 20006

113 N. Monroe Street, 1st Floor Tallassee, Florida 32301

3465 Santa Barbara Drive Wellington, Florida 33414

TELEPHONE (561) 791-9565

FACSIMILE (561) 791-9581

Email: jeffsiskind@msn.com

Case 19-01298-MAM Doc 272 Filed 04/09/20 Page 4 of 6
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served on 

April 9, 2020 upon all creditors and parties in interest registered to receive electronic 

notification on this case via the Court’s Case Management/Electronic Case Filing System 

and/or email as reflected on the Service List below. 

_______/s/ Jeffrey M. Siskind_______

Jeffrey M. Siskind, Esq. FBN 138746

Case 19-01298-MAM Doc 272 Filed 04/09/20 Page 5 of 6
SERVICE LIST:

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

Nancy Coleman on behalf of Robert Gibson

ncoleman@bartizcolman.com

Frank Zokaites, frank@zokaites.com

Robert Gibson, intelexigent@gmail.com

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