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. 

____________________________________/ 

CHAPTER 7 TRUSTEE ROBERT C. FURR’S RESPONSE IN OPPOSITION 

TO ADVERSARY DEFENDANT JEFFREY SISKIND’S (I) MOTION TO EXTEND 

TIME TO CONDUCT DISCOVERY[ECF NO. 284]; AND (II) MOTION TO CONTINUE 

PRETRIAL AND FOR EXTENSION OF PRETRIAL DEADLINES [ECF NO. 290] 

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

Trustee of the bankruptcy estate of the Debtor Chance & Anthem, LLC (“Debtor” or “C&A”), 

files this Response in Opposition (the “Response”) to the (i) Motion to Extend Time to Conduct 

Discovery [ECF No. 284] (“Motion to Extend”); and (ii) Motion to Continue Pretrial Conference 

and for Extension of Pretrial Deadlines [ECF No. 290] (the “Motion to Continue”) filed by 

Defendant Jeffrey Siskind (“Siskind”), and states: 

1. Defendant Siskind is the architect of every transaction at issue in this Adversary 

Proceeding. Significantly, Siskind chose to file this Chapter 7 case in his capacity as both 

managing member of the Debtor and as its pre-petition counsel [Main Case, ECF No. 1]. 

Case 19-01298-MAM Doc 294 Filed 05/08/20 Page 1 of 19
2 

Siskind has actively participated in this Adversary Proceeding since its inception despite having 

been disqualified as counsel to parties other than himself (i.e., the “Related Defendants”). [ECF 

No. 92]. 

2. Now, on the eve of the pretrial conference, Siskind seeks a belated six (6) month 

extension of the pretrial conference and a continuance of all expired pretrial deadlines. Motion to 

Continue at ¶7. The Trustee opposes the request and requests that the case be set for trial as soon 

as practicable, including through virtual means, to avoid unnecessary delays in adjudicating the 

merits of the remaining counts set forth in the First Amended Complaint [Adv. ECF No. 95]. 

3. This Adversary Proceeding has been pending since August 6, 2019 [ECF No.1]. 

On August 7, 2019, the Court issued its Order Setting Filing and Disclosure Requirements for 

Pretrial and Trial [ECF No. 4] (the “Pretrial Order”). The Pretrial Order was twice amended by 

mutual agreement of all of the parties [ECF Nos. 59, 197]. The current pretrial schedule has 

been in place since December 16, 2019. Notably, apart from Siskind, none of the other coDefendants have sought to modify the Pretrial Order and are separately represented by counsel. 

4. There are at least four independent reasons to deny the Motion to Continue and 

the Motion to Extend. 

5. First, Siskind claims that he has been denied an opportunity to depose witnesses 

including, the Chapter 7 Trustee and his forensic accountant. See Motion to Extend at ¶2. This 

is false. The Trustee’s deposition was scheduled by agreement of the parties on February 11, 

2020. In the middle of the night before the deposition, Siskind unilaterally cancelled the 

deposition [ECF No. 247]. Siskind made no further effort to reschedule the deposition, but 

raised the issue with the Court as recently as March 31, 2020 during the hearing on Siskind’s 

Motion to Lift Preliminary Injunction [ECF No. 259]. At the time, the Court admonished the 

parties to conduct depositions using means consistent with social distancing. 

Case 19-01298-MAM Doc 294 Filed 05/08/20 Page 2 of 19
3 

6. Moreover, Siskind did not attempt to coordinate the deposition of the Trustee or 

his experts until Thursday, April 23, 2020 at 10:39 p.m. The Trustee’s counsel provided him 

dates for the deposition of the Trustee and his experts the following afternoon. At that time, the 

Trustee’s counsel advised Siskind that he would agree to seek a modification of the Pretrial 

Order in order to permit Siskind to depose the witnesses prior to the May 12, 2020 pretrial 

conference. Siskind declined to notice the depositions and instead demanded the Trustee’s 

counsel provide him copies of his firm’s insurance policies (Trustee’s counsel declined this 

invitation). See Correspondence between J. Suarez and Siskind, a copy of which is annexed as 

Composite Exhibit “A”. 

7. Second, Siskind claims that the parties have failed to confer on the joint pretrial 

stipulation. See Motion to Continue at ¶6. This is also false. In compliance with the Pretrial 

Order, the Trustee’s counsel provided Defendants with a proposed draft of a joint pretrial 

stipulation on April 28, 2020 and again inquired on May 7, 2020. Defendants have refused to 

respond, to date, concerning the draft proposed stipulation. See Correspondence between J. 

Suarez and J. Siskind, a copy of which is annexed as Composite Exhibit “B”. 

8. Third, the Motion to Continue should be denied because it is untimely and 

granting it would be prejudicial to the Trustee particularly where, as here, the Motion to 

Continue seeks to extend deadlines that have already passed. The Trustee has complied with all 

of the obligations of the Pretrial Order, including serving his trial exhibits and exhibit register 

[ECF No. 288] and notice of intent to use summaries [ECF No. 287]. Siskind waited until he 

had the benefit of receiving the Trustee’s trial materials before he sought to extend the deadlines. 

9. Fourth, the Trustee timely disclosed his expert witnesses and provided their expert 

reports ahead of schedule. The Pretrial Order required the Trustee to serve his expert reports by 

April 28, 2020. The Trustee served his expert reports on April 21, 2020 together with his expert 

Case 19-01298-MAM Doc 294 Filed 05/08/20 Page 3 of 19
4 

disclosure upon Siskind and other co-Defendants. The Trustee thereafter made his experts 

available to Siskind for deposition immediately upon request. See Exhibit “A.” Siskind has 

similarly declined the opportunity depose the Trustee’s experts through means consistent with 

social distancing. 

10. The Trustee respectfully requests the Court set this Adversary Proceeding for trial 

as soon as practicable given the procedural history of this case. This can be accomplished by way 

of video conference for which the Court is well equipped to conduct such bench trials. While the 

Trustee is sympathetic to the restrictions imposed upon litigants by the Coronavirus pandemic, 

this global tragedy should not be used simply as a shield or excuse for litigants who have failed 

to timely prepare their cases. 

11. Indeed, the practice of conducting bench trials by video conference has been 

successfully implemented in numerous cases with far greater complexity than this Adversary 

Proceeding. See e.g., Jones v. DeSantis, Case No. 19-cv-00300-RH-MJF (N.D. Fla) (virtual trial 

concerning Florida’s implementation of felon voting rights pursuant to Amendment 4 to the 

Florida Constitution). In fact, even the United States Supreme Court has recently conducted oral 

arguments by telephone for the first time in the history of our nation. There is no reason that this 

case cannot similarly and fairly be tried through virtual means. 

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

the Court enter an Order (i) denying the Motion for Extension and Motion to Continue; (ii) 

scheduling trial in this Adversary Proceeding; and (iii) for such further relief as the Court deems 

just and proper. 

Case 19-01298-MAM Doc 294 Filed 05/08/20 Page 4 of 19
5 

Respectfully submitted this 8th day of May, 2020. 

 GENOVESE JOBLOVE & BATTISTA, P.A. 

 Counsel to the Chapter 7 Trustee 

100 S.E. 2nd Street, Suite 4400 

Miami, Florida 33131 

Tel.: (305) 349-2300 

Fax.: (305) 349-2310 

 By: /s/ Jesus M. Suarez 

John H. Genovese, Esq. 

Florida Bar No. 280852 

Jesus M. Suarez, Esq. 

Fla. Bar No. 60086 

Barry P. Gruher, Esq. 

Florida Bar No. 960993 

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 8th day of May, 

2020. 

By: /s/ Jesus M. Suarez 

 Jesus M. Suarez, Esq. 

Case 19-01298-MAM Doc 294 Filed 05/08/20 Page 5 of 19
6 

SERVICE LIST 

Served Via CM/ECF Notification 

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

jf@womenatlawfl.com, way@womenatlawfl.com 

Julie Feigeles on behalf of Defendant Wellington 3445, LP 

jf@womenatlawfl.com, way@womenatlawfl.com 

Julie Feigeles on behalf of Defendant Zokaites Properties, LP 

jf@womenatlawfl.com, way@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 

Philip B Harris on behalf of Defendant CannaMed Pharmaceuticals, LLC 

philip@philipbharris.com 

Philip B Harris on behalf of Defendant Florida's Association of Community Banks and Credit 

Unions, Incorporated 

philip@philipbharris.com 

Philip B Harris on behalf of Defendant OB Real Estate Holdings 1732, LLC 

philip@philipbharris.com 

Philip B Harris on behalf of Defendant Second Siskind Family Trust 

philip@philipbharris.com 

Philip B Harris on behalf of Defendant Siskind Legal Services 

philip@philipbharris.com 

Philip B Harris on behalf of Defendant Sovereign Gaming and Entertainment, LLC 

philip@philipbharris.com 

Case 19-01298-MAM Doc 294 Filed 05/08/20 Page 6 of 19
7 

Philip B Harris on behalf of Defendant Sympatico Equine Rescue, Inc. 

philip@philipbharris.com 

Philip B Harris on behalf of Defendant Tanya Siskind 

philip@philipbharris.com 

Jeffrey M Siskind on behalf of Defendant Jeffrey M 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 

Case 19-01298-MAM Doc 294 Filed 05/08/20 Page 7 of 19
EXHIBIT A 

Case 19-01298-MAM Doc 294 Filed 05/08/20 Page 8 of 19
1

Suarez, Jesus

From: Suarez, Jesus

Sent: Friday, April 24, 2020 2:57 PM

To: 'Jeffrey Siskind'; philip@philipbharris.com

Cc: Genovese, John; Gruher, Barry; rfurr@furrcohen.com

Subject: RE: Chance & Anthem - Housekeeping Matters and Demand for Insurance Coverage 

Information

We will not agree to reschedule the pretrial conference date or extend any other deadlines.  We encourage you to make 

those dates work.  In our experience, court reporting firms are readily scheduling video conference depositions.  We are 

again declining to provide you our firm’s insurance information.     

Jesus M. Suarez

Genovese Joblove & Battista, P.A. 

Direct 305.913.6682 

jsuarez@gjb-law.com

From: Jeffrey Siskind <jeffsiskind@msn.com>  

Sent: Friday, April 24, 2020 2:54 PM 

To: Suarez, Jesus <jsuarez@gjb‐law.com>; philip@philipbharris.com 

Cc: Genovese, John <jgenovese@gjb‐law.com>; Gruher, Barry <bgruher@gjb‐law.com>; rfurr@furrcohen.com 

Subject: RE: Chance & Anthem ‐ Housekeeping Matters and Demand for Insurance Coverage Information 

Those dates may be too close in time due to the need to schedule the videoconferencing.  I will file the motion for an 

extension and assume that you agree to same.  Finally, I am again requesting that you provide me with your firm’s 

insurance information. 

Thank you,  

Jeffrey M. Siskind, Esquire 

S I S K I N D   L E G A L , P L L C

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 

Emails: jeffsiskind@msn.com & jeffsiskind@gmail.com

Note: Because of the possibility that emails may be automatically sent to a junk mail folder by our servers, or our 

unavailability to timely review all emails, you should NOT presume your email to this writer has been received 

AND READ unless a reply from the recipient to your email has been received by you, which contains the full 

contents of the email you provided to this writer. 

IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, 

we inform you that any tax advice contained in this communication (including any attachments), was not intended or 

written to be used, and cannot be used, by any taxpayer for the purpose of (1) avoiding any penalties under the Internal 

Revenue Code or (2) promoting, marketing or recommending to another party any transaction matter addressed herein. 

THE INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND/OR CONFIDENTIAL 

INFORMATION INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF 

THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, 

DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED 

THIS TRANSMISSION IN ERROR, PLEASE IMMEDIATELY NOTIFY ME BY TELEPHONE AND PERMANENTLY 

DELETE THE ORIGINAL AND ANY COPY OF THIS E-MAIL AND DESTROY ANY PRINTOUT THEREOF. **** 

PLEASE NOTE   Delivery of this communication is not intended to create, and receipt does not constitute, an AttorneyCase 19-01298-MAM Doc 294 Filed 05/08/20 Page 9 of 19
2

Client relationship. We cannot serve as your counsel in any matter unless we mutually agree that I will represent you. No 

Attorney-Client relationship is formed unless specifically agreed to and signed in writing. The information contained in this 

message and any documents accompanying this transmission are protected under the Electronic Communication Privacy 

Act, 18 U.S.C. S2510-2521, and may be Attorney-Client Privileged and confidential information intended only for the use 

of the individual(s) or entity named above. If the reader of this message is not the intended recipient, you are hereby 

notified that any use of, disclosure, dissemination, distribution, reliance on the contents or copying of this communication 

is strictly prohibited and may result in legal action against you. If you have received this message in error, please reply to

the sender advising of the error in transmission and immediately delete/destroy the message and any accompanying 

documents. Alternatively, you may notify us by telephone immediately. No liability is accepted for any loss or damage 

resulting from a computer virus, or resulting from a defect in transmission of this email or any attached file. If you reply to 

this communication, it is the duty and obligation of the sender to take practical measures to purge or safeguard and avoid 

providing sensitive metadata embedded in any electronic document to prevent the disclosure of confidential 

information. A part of this law firm's practice involves the collection of debts on behalf of our clients. If you are 

someone against whom one of our clients has a claim, please be aware that this communication is from a Debt Collector 

as defined by the Fair Debt Collection Practices Act and any information obtained from you may be used for the purpose 

of collecting a debt. Because e-mail can be altered electronically, the integrity of this communication cannot be 

guaranteed. 

From: Suarez, Jesus <jsuarez@gjb‐law.com>  

Sent: Friday, April 24, 2020 2:43 PM 

To: 'Jeffrey Siskind' <jeffsiskind@msn.com>; philip@philipbharris.com

Cc: Genovese, John <jgenovese@gjb‐law.com>; Gruher, Barry <bgruher@gjb‐law.com>; rfurr@furrcohen.com

Subject: RE: Chance & Anthem ‐ Housekeeping Matters and Demand for Insurance Coverage Information 

Jeffrey– 

1. The Trustee is available for deposition by videoconferencing on April 30 and May 1.  I am copying Mr. Harris in 

order to make sure that all counsel in this adversary proceeding coordinate their participation.  Please confirm 

and notice the deposition by Monday and have your court reporting firm send us their videoconference 

instructions by no later than Tuesday.  We suggest that you file an agreed ex‐parte motion to extend the April 28 

discovery deadline to permit for the scheduling of the deposition.  

2. Mr. Barbee and Mr. Eidson are available on 5/5 and 5/6.  Mr. Barbee has a telephonic court appearance on  5/5 

at 10:30 a.m. but can be available thereafter.  Same caveats as above.  

3. We decline your request to provide you with our insurance information and dispute the balance of your e‐mail. 

Jesus  

Jesus M. Suarez

Genovese Joblove & Battista, P.A. 

Direct 305.913.6682 

jsuarez@gjb-law.com

From: Jeffrey Siskind <jeffsiskind@msn.com>  

Sent: Thursday, April 23, 2020 10:39 PM 

To: Suarez, Jesus <jsuarez@gjb‐law.com> 

Subject: Chance & Anthem ‐ Housekeeping Matters and Demand for Insurance Coverage Information 

Jesus – 

(1) At this point I believe that it is appropriate that we agree that Robert Furr’s deposition will need to be 

conducted remotely by videoconference.  Unless you believe that we first need Judge Mora’s consent to do so, 

we need to coordinate that by no later than the end of next week.   

(2) I also need to set in Alan Barbee for a remote deposition as well as your other expert(s), and I request that you 

suggest some dates in May that everyone can make themselves available so these can be scheduled. 

(3) Also, in view of the present context of the case, I am requesting that you provide me with complete information 

concerning your and your firm’s malpractice insurance coverage.

Case 19-01298-MAM Doc 294 Filed 05/08/20 Page 10 of 19
3

Please attend to these matters expeditiously so that we can move forward with this case.  I realize that you have a lot of 

other work, but the Furr deposition particularly has languished far too long. 

Thank you,  

Jeffrey M. Siskind, Esquire 

S I S K I N D   L E G A L , P L L C

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 

Emails: jeffsiskind@msn.com & jeffsiskind@gmail.com

Note: Because of the possibility that emails may be automatically sent to a junk mail folder by our servers, or our 

unavailability to timely review all emails, you should NOT presume your email to this writer has been received 

AND READ unless a reply from the recipient to your email has been received by you, which contains the full 

contents of the email you provided to this writer. 

IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, 

we inform you that any tax advice contained in this communication (including any attachments), was not intended or 

written to be used, and cannot be used, by any taxpayer for the purpose of (1) avoiding any penalties under the Internal 

Revenue Code or (2) promoting, marketing or recommending to another party any transaction matter addressed herein. 

THE INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND/OR CONFIDENTIAL 

INFORMATION INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF 

THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, 

DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED 

THIS TRANSMISSION IN ERROR, PLEASE IMMEDIATELY NOTIFY ME BY TELEPHONE AND PERMANENTLY 

DELETE THE ORIGINAL AND ANY COPY OF THIS E-MAIL AND DESTROY ANY PRINTOUT THEREOF. ** ** 

PLEASE NOTE   Delivery of this communication is not intended to create, and receipt does not constitute, an AttorneyClient relationship. We cannot serve as your counsel in any matter unless we mutually agree that I will represent you. No 

Attorney-Client relationship is formed unless specifically agreed to and signed in writing. The information contained in this 

message and any documents accompanying this transmission are protected under the Electronic Communication Privacy 

Act, 18 U.S.C. S2510-2521, and may be Attorney-Client Privileged and confidential information intended only for the use 

of the individual(s) or entity named above. If the reader of this message is not the intended recipient, you are hereby 

notified that any use of, disclosure, dissemination, distribution, reliance on the contents or copying of this communication 

is strictly prohibited and may result in legal action against you. If you have received this message in error, please reply to

the sender advising of the error in transmission and immediately delete/destroy the message and any accompanying 

documents. Alternatively, you may notify us by telephone immediately. No liability is accepted for any loss or damage 

resulting from a computer virus, or resulting from a defect in transmission of this email or any attached file. If you reply to 

this communication, it is the duty and obligation of the sender to take practical measures to purge or safeguard and avoid 

providing sensitive metadata embedded in any electronic document to prevent the disclosure of confidential 

information. A part of this law firm's practice involves the collection of debts on behalf of our clients. If you are 

someone against whom one of our clients has a claim, please be aware that this communication is from a Debt Collector 

as defined by the Fair Debt Collection Practices Act and any information obtained from you may be used for the purpose 

of collecting a debt. Because e-mail can be altered electronically, the integrity of this communication cannot be 

guaranteed. 

Case 19-01298-MAM Doc 294 Filed 05/08/20 Page 11 of 19
EXHIBIT B 

Case 19-01298-MAM Doc 294 Filed 05/08/20 Page 12 of 19
1

Suarez, Jesus

From: Jeffrey Siskind <jeffsiskind@msn.com>

Sent: Tuesday, April 28, 2020 4:51 PM

To: Suarez, Jesus

Cc: philip@philipbharris.com

Subject: RE: Furr v. Siskind - ADV. NO. 19-01298-MAM

No.  I disagree.  Settlement discussions are mandatory. 

Thank you,  

Jeffrey M. Siskind, Esquire 

S I S K I N D   L E G A L , P L L C

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 

Emails: jeffsiskind@msn.com & jeffsiskind@gmail.com

Note: Because of the possibility that emails may be automatically sent to a junk mail folder by our servers, or our 

unavailability to timely review all emails, you should NOT presume your email to this writer has been received 

AND READ unless a reply from the recipient to your email has been received by you, which contains the full 

contents of the email you provided to this writer. 

IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, 

we inform you that any tax advice contained in this communication (including any attachments), was not intended or 

written to be used, and cannot be used, by any taxpayer for the purpose of (1) avoiding any penalties under the Internal 

Revenue Code or (2) promoting, marketing or recommending to another party any transaction matter addressed herein. 

THE INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND/OR CONFIDENTIAL 

INFORMATION INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF 

THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, 

DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED 

THIS TRANSMISSION IN ERROR, PLEASE IMMEDIATELY NOTIFY ME BY TELEPHONE AND PERMANENTLY 

DELETE THE ORIGINAL AND ANY COPY OF THIS E-MAIL AND DESTROY ANY PRINTOUT THEREOF. ** ** 

PLEASE NOTE   Delivery of this communication is not intended to create, and receipt does not constitute, an AttorneyClient relationship. We cannot serve as your counsel in any matter unless we mutually agree that I will represent you. No 

Attorney-Client relationship is formed unless specifically agreed to and signed in writing. The information contained in this 

message and any documents accompanying this transmission are protected under the Electronic Communication Privacy 

Act, 18 U.S.C. S2510-2521, and may be Attorney-Client Privileged and confidential information intended only for the use 

of the individual(s) or entity named above. If the reader of this message is not the intended recipient, you are hereby 

notified that any use of, disclosure, dissemination, distribution, reliance on the contents or copying of this communication 

is strictly prohibited and may result in legal action against you. If you have received this message in error, please reply to

the sender advising of the error in transmission and immediately delete/destroy the message and any accompanying 

documents. Alternatively, you may notify us by telephone immediately. No liability is accepted for any loss or damage 

resulting from a computer virus, or resulting from a defect in transmission of this email or any attached file. If you reply to 

this communication, it is the duty and obligation of the sender to take practical measures to purge or safeguard and avoid 

providing sensitive metadata embedded in any electronic document to prevent the disclosure of confidential 

information. A part of this law firm's practice involves the collection of debts on behalf of our clients. If you are 

someone against whom one of our clients has a claim, please be aware that this communication is from a Debt Collector 

as defined by the Fair Debt Collection Practices Act and any information obtained from you may be used for the purpose 

of collecting a debt. Because e-mail can be altered electronically, the integrity of this communication cannot be 

guaranteed. 

From: Suarez, Jesus <jsuarez@gjb‐law.com>  

Sent: Tuesday, April 28, 2020 4:47 PM 

Case 19-01298-MAM Doc 294 Filed 05/08/20 Page 13 of 19
2

To: philip@philipbharris.com; Jeffrey Siskind (jeffsiskind@msn.com) <jeffsiskind@msn.com> 

Cc: Gruher, Barry <bgruher@gjb‐law.com>; Genovese, John <jgenovese@gjb‐law.com>; rfurr@furrcohen.com 

Subject: Furr v. Siskind ‐ ADV. NO. 19‐01298‐MAM 

Counsel, 

Attached is our proposed draft joint pre‐trial stipulation. 

Please provide us your proposed revisions in red‐line. 

The local form requires us to certify that we have conferred regarding settlement of this case.  The Trustee proposes to 

certify that settlement discussions in this case are unwarranted. 

Jesus  

Jesus M. Suarez

100 SE 2nd Street, Suite 4400 

Miami, Florida 33131 

Main 305.349.2300

Direct 305.913.6682 

Fax 305.428.8831 

jsuarez@gjb‐law.com|www.gjb-law.com

Miami | Fort Lauderdale | Tampa

Case 19-01298-MAM Doc 294 Filed 05/08/20 Page 14 of 19
1

Suarez, Jesus

From: Suarez, Jesus

Sent: Tuesday, April 28, 2020 5:21 PM

To: 'Jeffrey Siskind'; philip@philipbharris.com

Cc: Gruher, Barry; Genovese, John; rfurr@furrcohen.com

Subject: RE: Furr v. Siskind - ADV. NO. 19-01298-MAM

We need to submit the pretrial stipulation one business day prior to the pretrial conference.  

Jesus M. Suarez

Genovese Joblove & Battista, P.A. 

Direct 305.913.6682 

jsuarez@gjb-law.com

From: Jeffrey Siskind <jeffsiskind@msn.com>  

Sent: Tuesday, April 28, 2020 5:10 PM 

To: Suarez, Jesus <jsuarez@gjb‐law.com>; philip@philipbharris.com 

Cc: Gruher, Barry <bgruher@gjb‐law.com>; Genovese, John <jgenovese@gjb‐law.com>; rfurr@furrcohen.com 

Subject: RE: Furr v. Siskind ‐ ADV. NO. 19‐01298‐MAM 

When do you need to have this back? 

Thank you,  

Jeffrey M. Siskind, Esquire 

S I S K I N D   L E G A L , P L L C

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 

Emails: jeffsiskind@msn.com & jeffsiskind@gmail.com

Note: Because of the possibility that emails may be automatically sent to a junk mail folder by our servers, or our 

unavailability to timely review all emails, you should NOT presume your email to this writer has been received 

AND READ unless a reply from the recipient to your email has been received by you, which contains the full 

contents of the email you provided to this writer. 

IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, 

we inform you that any tax advice contained in this communication (including any attachments), was not intended or 

written to be used, and cannot be used, by any taxpayer for the purpose of (1) avoiding any penalties under the Internal 

Revenue Code or (2) promoting, marketing or recommending to another party any transaction matter addressed herein. 

THE INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND/OR CONFIDENTIAL 

INFORMATION INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF 

THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, 

DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED 

THIS TRANSMISSION IN ERROR, PLEASE IMMEDIATELY NOTIFY ME BY TELEPHONE AND PERMANENTLY 

DELETE THE ORIGINAL AND ANY COPY OF THIS E-MAIL AND DESTROY ANY PRINTOUT THEREOF. ** ** 

PLEASE NOTE   Delivery of this communication is not intended to create, and receipt does not constitute, an AttorneyClient relationship. We cannot serve as your counsel in any matter unless we mutually agree that I will represent you. No 

Attorney-Client relationship is formed unless specifically agreed to and signed in writing. The information contained in this 

message and any documents accompanying this transmission are protected under the Electronic Communication Privacy 

Act, 18 U.S.C. S2510-2521, and may be Attorney-Client Privileged and confidential information intended only for the use 

of the individual(s) or entity named above. If the reader of this message is not the intended recipient, you are hereby 

Case 19-01298-MAM Doc 294 Filed 05/08/20 Page 15 of 19
2

notified that any use of, disclosure, dissemination, distribution, reliance on the contents or copying of this communication 

is strictly prohibited and may result in legal action against you. If you have received this message in error, please reply to

the sender advising of the error in transmission and immediately delete/destroy the message and any accompanying 

documents. Alternatively, you may notify us by telephone immediately. No liability is accepted for any loss or damage 

resulting from a computer virus, or resulting from a defect in transmission of this email or any attached file. If you reply to 

this communication, it is the duty and obligation of the sender to take practical measures to purge or safeguard and avoid 

providing sensitive metadata embedded in any electronic document to prevent the disclosure of confidential 

information. A part of this law firm's practice involves the collection of debts on behalf of our clients. If you are 

someone against whom one of our clients has a claim, please be aware that this communication is from a Debt Collector 

as defined by the Fair Debt Collection Practices Act and any information obtained from you may be used for the purpose 

of collecting a debt. Because e-mail can be altered electronically, the integrity of this communication cannot be 

guaranteed. 

From: Suarez, Jesus <jsuarez@gjb‐law.com>  

Sent: Tuesday, April 28, 2020 4:47 PM 

To: philip@philipbharris.com; Jeffrey Siskind (jeffsiskind@msn.com) <jeffsiskind@msn.com> 

Cc: Gruher, Barry <bgruher@gjb‐law.com>; Genovese, John <jgenovese@gjb‐law.com>; rfurr@furrcohen.com

Subject: Furr v. Siskind ‐ ADV. NO. 19‐01298‐MAM 

Counsel, 

Attached is our proposed draft joint pre‐trial stipulation. 

Please provide us your proposed revisions in red‐line. 

The local form requires us to certify that we have conferred regarding settlement of this case.  The Trustee proposes to 

certify that settlement discussions in this case are unwarranted. 

Jesus  

Jesus M. Suarez

100 SE 2nd Street, Suite 4400 

Miami, Florida 33131 

Main 305.349.2300

Direct 305.913.6682 

Fax 305.428.8831 

jsuarez@gjb‐law.com|www.gjb-law.com

Miami | Fort Lauderdale | Tampa

Case 19-01298-MAM Doc 294 Filed 05/08/20 Page 16 of 19
1

Suarez, Jesus

From: Suarez, Jesus

Sent: Wednesday, May 6, 2020 3:05 PM

To: 'Jeffrey Siskind'; 'philip@philipbharris.com'

Cc: Gruher, Barry; Genovese, John; rfurr@furrcohen.com

Subject: SERVICE OF COURT DOCUMENT- Furr v. Siskind - ADV. NO. 19-01298-MAM

Attachments: Trustee's Exhibit Register.pdf; Attachments.html

 

Citrix Attachments  Expires August 4, 2020 

Exhibits wo Trust Records.zip  1 GB 

Download Attachments 

Jesus Suarez uses Citrix Files to share documents securely.  

Attached is our trial exhibit register.  Also, you can download our trial exhibits through the link above.  We sent you both 

a copy on a USB drive via FEDEX.  The tracking indicates that you received it earlier today.  We have not sent Mr. Harris 

the exhibit containing Mr. Siskind’s trust records and it is not in the Sharefile above. Please get back to me on the 

pretrial stip.  Thank you. 

Jesus  

Jesus M. Suarez

Genovese Joblove & Battista, P.A. 

Direct 305.913.6682 

jsuarez@gjb-law.com

From: Suarez, Jesus  

Sent: Tuesday, April 28, 2020 5:21 PM 

To: 'Jeffrey Siskind' <jeffsiskind@msn.com>; philip@philipbharris.com 

Cc: Gruher, Barry <bgruher@gjb‐law.com>; Genovese, John <jgenovese@gjb‐law.com>; rfurr@furrcohen.com 

Subject: RE: Furr v. Siskind ‐ ADV. NO. 19‐01298‐MAM 

We need to submit the pretrial stipulation one business day prior to the pretrial conference.  

Jesus M. Suarez

Genovese Joblove & Battista, P.A. 

Direct 305.913.6682 

jsuarez@gjb-law.com

From: Jeffrey Siskind <jeffsiskind@msn.com>  

Sent: Tuesday, April 28, 2020 5:10 PM 

Case 19-01298-MAM Doc 294 Filed 05/08/20 Page 17 of 19
2

To: Suarez, Jesus <jsuarez@gjb‐law.com>; philip@philipbharris.com

Cc: Gruher, Barry <bgruher@gjb‐law.com>; Genovese, John <jgenovese@gjb‐law.com>; rfurr@furrcohen.com

Subject: RE: Furr v. Siskind ‐ ADV. NO. 19‐01298‐MAM 

When do you need to have this back? 

Thank you,  

Jeffrey M. Siskind, Esquire 

S I S K I N D   L E G A L , P L L C

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 

Emails: jeffsiskind@msn.com & jeffsiskind@gmail.com

Note: Because of the possibility that emails may be automatically sent to a junk mail folder by our servers, or our 

unavailability to timely review all emails, you should NOT presume your email to this writer has been received 

AND READ unless a reply from the recipient to your email has been received by you, which contains the full 

contents of the email you provided to this writer. 

IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, 

we inform you that any tax advice contained in this communication (including any attachments), was not intended or 

written to be used, and cannot be used, by any taxpayer for the purpose of (1) avoiding any penalties under the Internal 

Revenue Code or (2) promoting, marketing or recommending to another party any transaction matter addressed herein. 

THE INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND/OR CONFIDENTIAL 

INFORMATION INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF 

THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, 

DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED 

THIS TRANSMISSION IN ERROR, PLEASE IMMEDIATELY NOTIFY ME BY TELEPHONE AND PERMANENTLY 

DELETE THE ORIGINAL AND ANY COPY OF THIS E-MAIL AND DESTROY ANY PRINTOUT THEREOF. ** ** 

PLEASE NOTE **** Delivery of this communication is not intended to create, and receipt does not constitute, an AttorneyClient relationship. We cannot serve as your counsel in any matter unless we mutually agree that I will represent you. No 

Attorney-Client relationship is formed unless specifically agreed to and signed in writing. The information contained in this 

message and any documents accompanying this transmission are protected under the Electronic Communication Privacy 

Act, 18 U.S.C. S2510-2521, and may be Attorney-Client Privileged and confidential information intended only for the use 

of the individual(s) or entity named above. If the reader of this message is not the intended recipient, you are hereby 

notified that any use of, disclosure, dissemination, distribution, reliance on the contents or copying of this communication 

is strictly prohibited and may result in legal action against you. If you have received this message in error, please reply to

the sender advising of the error in transmission and immediately delete/destroy the message and any accompanying 

documents. Alternatively, you may notify us by telephone immediately. No liability is accepted for any loss or damage 

resulting from a computer virus, or resulting from a defect in transmission of this email or any attached file. If you reply to 

this communication, it is the duty and obligation of the sender to take practical measures to purge or safeguard and avoid 

providing sensitive metadata embedded in any electronic document to prevent the disclosure of confidential 

information. A part of this law firm's practice involves the collection of debts on behalf of our clients. If you are 

someone against whom one of our clients has a claim, please be aware that this communication is from a Debt Collector 

as defined by the Fair Debt Collection Practices Act and any information obtained from you may be used for the purpose 

of collecting a debt. Because e-mail can be altered electronically, the integrity of this communication cannot be 

guaranteed. 

From: Suarez, Jesus <jsuarez@gjb‐law.com>  

Sent: Tuesday, April 28, 2020 4:47 PM 

To: philip@philipbharris.com; Jeffrey Siskind (jeffsiskind@msn.com) <jeffsiskind@msn.com> 

Cc: Gruher, Barry <bgruher@gjb‐law.com>; Genovese, John <jgenovese@gjb‐law.com>; rfurr@furrcohen.com

Subject: Furr v. Siskind ‐ ADV. NO. 19‐01298‐MAM 

Counsel, 

Case 19-01298-MAM Doc 294 Filed 05/08/20 Page 18 of 19
3

Attached is our proposed draft joint pre‐trial stipulation. 

Please provide us your proposed revisions in red‐line. 

The local form requires us to certify that we have conferred regarding settlement of this case.  The Trustee proposes to 

certify that settlement discussions in this case are unwarranted. 

Jesus  

Jesus M. Suarez

100 SE 2nd Street, Suite 4400 

Miami, Florida 33131 

Main 305.349.2300

Direct 305.913.6682 

Fax 305.428.8831 

jsuarez@gjb‐law.com|www.gjb-law.com

Miami | Fort Lauderdale | Tampa

Case 19-01298-MAM Doc 294 Filed 05/08/20 Page 19 of 19