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-A

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,

JEFFREY M SISKIND, solely in his capacity as Trustee of the,

SECOND SISKIND FAMILY TRUST, 

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, individually1

,

Defendants.

/

 1 Pursuant to Fed. R. Civ. P. 20, as incorporated by Fed. R. Bankr. P. 7020, the Defendants are joined in this 

adversary proceeding because they are liable jointly, severally, or with respect to or arising out of the same 

transaction, occurrence, or series of transactions or occurrences, and questions of law and fact common to the 

Defendants will arise in the action.

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FIRST AMENDED ADVERSARY COMPLAINT TO AVOID AND TO RECOVER

FRAUDULENT TRANSFERS, FOR TURNOVER, FOR AN ACCOUNTING,

SUBSTANTIVE CONSOLIDATION, INJUNCTIVE RELIEF

AND FOR OTHER RELIEF

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 (the “Debtor” or 

“C&A”), files this First Amended Adversary Complaint against JEFFREY M. SISKIND, 

individually and doing business as SISKIND LEGAL SERVICES (“Siskind”), TANYA 

SISKIND, individually (T. Siskind) and Jeffrey Siskind as Trustee of the Second Siskind Family 

Trust (“Family Trust”), CANNAMED PHARMACEUTICALS, LLC, a Maryland Limited 

Liability Company (“Cannmed”), SISKIND LEGAL SERVICES, LLC, a Florida Limited 

Liability Company (“Siskind Legal”), SOVEREIGN GAMING & ENTERTAINMENT, LLC, a 

Florida Limited Liability Company (“Sovereign”), FLORIDA'S ASSOCIATION OF 

COMMUNITY BANKS AND CREDIT UNIONS, INC. a Florida Corporation (“FLACC”), 

SYMPATICO EQUINE RESCUE, INC, a Florida Corporation (“Sympatico”) (Family Trust, 

Cannmed, Siskind Legal, Sovereign, FLACC and Sympatico are collectively referenced as the 

“Related Defendants”), OB REAL ESTATE HOLDINGS 1732, LLC, a Florida Limited 

Liability Company (“OB Real Estate”), WELLINGTON 3445, LP, a Florida Limited Partnership 

(“Wellington”), and ZOKAITES PROPERTIES, LP, a Pennsylvania Limited Partnership 

(“Zokaites Properties”)(OB Real Estate, Wellington and Zokaites Properties are collectively 

referenced as the “Zokaites Defendants,” and together with the Related Defendants, the 

“Corporate Defendants”) and ROBERT GIBSON, individually (“Gibson”), to avoid and to 

recover fraudulent transfers from the Debtor to the Defendants, for turnover of property, for an 

accounting, for substantive consolidation, for injunctive relief and for other relief pursuant to 

Sections 105, 542, 544, 548, and 550 of Title 11 of the United States Code (the “Bankruptcy 

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Code”), Chapter 726 of the Florida Statutes, Rule 7001, et seq. of the Federal Rules of 

Bankruptcy Procedure and federal common law and alleges, as follows:

INTRODUCTION

1. Jeffrey Siskind is an attorney licensed in Florida since 1998. Siskind was the sole 

member, attorney and control person of the Debtor. Siskind contends that the Debtor’s alleged 

business affairs consisted of two primary ventures: (1) serving as a funding vehicle for a 

cannabis business in Maryland in exchange for 70% of the membership interests in that business; 

and (2) renovating and thereafter selling a home in Wellington, Florida.

2. In truth, Siskind used the Debtor in concert with the Related Defendants in order 

to divert over $3 million of creditor, investor and client funds and real estate for his benefit and 

the benefit of his family members and associates. Siskind later concealed the value of these 

diverted assets through a series of transactions involving the Corporate Defendants. During the 

course of most of these transactions, Defendant Siskind was a Chapter 11 debtor before this 

Court. In re Siskind, Case No. 13-13096-MAM. Defendant Siskind failed to properly disclose 

his interest in these transactions during his five (5) years as a debtor.

3. The Trustee’s investigation, to date, reveals that Siskind transferred his clients’

and investors’ funds indiscriminately between entities that he controls and for which the Debtor 

and its affiliates did not receive reasonably equivalent value. For example, Siskind used creditor 

monies to (i) transfer over $800,000 to himself; (ii) make payments in excess of $175,000 for 

airplanes not owned by the Debtor; (iii) transfer over $160,000 into his IOTA Trust account; (iv) 

fund a series of cash withdrawals in excess of $119,000; and (v) place millions of dollars of real 

estate purchased with creditor funds in the hand of companies controlled by his long-term 

business associate Frank Zokaites (“Zokaites”) and identified herein as the Zokaites Defendants.

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4. By this adversary proceeding, the Trustee seeks to recover the property (or its 

value, products, and replacements) fraudulently transferred by Siskind for the benefit of the 

creditors of the Debtor and the Related Defendants. Certain of the transfers identified in this 

adversary Complaint were made by the Related Defendants. In turn, certain creditors of the 

Related Defendants have sought to assert claims against the Debtor on the basis the Related 

Defendants’ transactions with the Debtor. Accordingly, the Trustee is a proper party with 

standing to pursue these transfers. 

5. The Trustee also seeks to substantively consolidate before this Court the Related 

Defendants.

6. The Trustee further seeks injunctive relief to prevent Siskind and his associates 

from dissipating, encumbering and/or absconding with the property of the Debtor or the Related 

Defendants. 

THE PARTIES, JURISDICTION AND VENUE

7. On January 29, 2018, the Debtor filed a voluntary petition for bankruptcy relief 

under Chapter 7 of the United States Code (the “Bankruptcy Code”) [ECF No. 1] in the United 

States Bankruptcy Court for the District of Maryland. 

8. On January 29, 2018, George W. Liebman was appointed Chapter 7 Trustee in the 

District of Maryland. 

9. On March 17, 2018, a Section 341 Meeting of Creditors was held in the District 

of Maryland. The Debtor failed to appear.

10. On May 24, 2018, A Memorandum and Order Transferring Venue to the 

Bankruptcy Court for the Southern District of Florida. 

11. On May 25, 2018, Robert C. Furr was appointed as the Chapter 7 Trustee. A 

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section 341 Meeting of Creditors occurred on July 9, 2018 at 8:30 am in the Southern District of 

Florida, West Palm Beach Division. The Debtor appeared through its sole managing member, 

Defendant Siskind.

12. Defendant, Siskind, is the control person of the Related Defendants. Siskind 

resides in Palm Beach County, Florida. Defendant Siskind is also the sole manager and member 

of the Debtor, the individual who prepared and executed its bankruptcy schedules, and served as 

the Debtor’s pre-petition counsel. 

13. Defendant, T. Siskind, is Siskind’s wife. She is believed to be in possession of a 

Mercedes Benz acquired with funds fraudulently transferred from the Debtor. Additionally, T. 

Siskind also received cash and property fraudulently transferred by the Debtor. T. Siskind 

resides in Wellington, Florida. 

14. Defendant, Family Trust, is a trust that upon information and belief is settled 

under the laws of the State of Florida. Additionally, upon information and belief, Siskind is the 

Trustee of Family Trust, and a beneficiary or party that asserts dominion and/or control of the 

Family Trust.

15. Defendant, CannaMed, is a limited liability company organized under the laws of 

the State of Maryland. Its principal place of business was 27120 Ocean Gateway, Hebron, 

Maryland 21230. The Debtor purports to own 70% of Defendant CannaMed. The Debtor’s 

bankruptcy schedules reflect investments in CannaMed and liabilities of CannaMed as liabilities 

of the Debtor. The Debtor and CannaMed purported to share a principal place of business in 

Hebron, Maryland. 

16. Defendant, OB Real Estate, is an inactive Florida Limited Liability Company 

having a principal address of 375 Golfside Drive, Wexford, PA 15090. Its manager is Zokiates 

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and its principal place of business is the same as Defendants Wellington and Zokaites Properties. 

Its registered agent is Defendant Siskind at 525 S. Flagler Drive, Suite 500, West Palm Beach, 

FL 33401.

17. Defendant, Siskind Legal, is an inactive Florida Limited Liability Company 

having a principal address of 525 S. Flagler Drive, Suite 500, West Palm Beach, FL 33401. From 

time to time, Defendant Siskind has purported to practice law through Defendant Siskind Legal. 

18. Defendant, Sovereign, is an inactive Florida Limited Liability Company having 

its principal address of 525 S. Flagler Drive, Suite 500, West Palm Beach, FL 33401. Its sole 

manager and registered agent was William Siskind. Defendant Siskind is believed to control 

Defendant Sovereign as a nominee of William Siskind, his deceased father.

19. Defendant, FLACC, is a Florida corporation having its principal address of 525 S. 

Flagler Drive, Suite 500, West Palm Beach, FL 33401. Its sole manager and registered agent is 

Defendant Siskind. Siskind claims that Defendant FLACC provides services to community 

banks and credit unions. FLACC appears to have no legitimate operations and appears to be a 

mere instrumentality created by Siskind to facilitate his and the Debtor’s scheme.

20. Defendant, Sympatico, is a Florida corporation having its principal address of 

3465 Santa Barbara Drive, Wellington, FL 33144. Its sole officer and registered agent is 

Defendant Siskind. Siskind claims that Defendant Sympatico is a charity. Sympatico appears to 

be a mere instrumentality used by Siskind to facilitate his and the Debtor’s scheme.

21. Defendant, Wellington, is a Florida Limited Partnership having its principal 

address of 375 Golfside Drive, Wexforx, P.A. Defendant Wellington’s general partner is 

Zokaites Contracting FL, LLC (“Zokaites Contracting”). Defendant Wellington was formed

with the Florida Secretary of State on February 16, 2017. The sole member and sole manager of 

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Zokaites Contracting is Zokaites. 

22. Defendant, Zokaites Properties, is a limited partnership organized under the laws 

of Pennsylvania. Zokaites and his wife are the principal partners. It maintains its principal place 

of business in Wexford, Pennsylvania. Although it is not registered to conduct business in 

Florida, it frequently engages in transactions in Florida, including those at issue in this adversary 

proceeding. 

23. W. Siskind was the elderly father of Defendant Siskind. W. Siskind died during 

the course of this bankruptcy case. The Trustee has recorded a caveat concerning the claims 

referenced in this adversary proceeding, and reserves the right to join any probate estate, his 

heirs or beneficiaries at a later date. Upon information and belief, a probate estate has not been 

opened to administer the affairs of W. Siskind.

24. Defendant, Gibson, is a resident of Palm Beach County. He claims to hold legal

title to certain property at issue in this First Amended Complaint.

25. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. 

§§ 157(a) and 1334(b).

26. This is a core proceeding pursuant to 28 U.S.C. §§ 157(b)(2)(A), (C), (E), (H) and 

(O). The Trustee consents to the entry of final orders and judgment by the Bankruptcy Court.

27. Venue is proper in this Court pursuant to 28 U.S.C. §§ 1408 and 1409.

FACTS SUPPORTING THE CLAIMS

A. The Siskind Bankruptcy Case

28. On February 11, 2013, Siskind filed a personal bankruptcy petition under Chapter 

11 of the Bankruptcy Code. Notably, Siskind appeared as his own counsel and regularly appears 

as counsel on behalf of clients in the Bankruptcy Court.

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29. On June 11, 2018, Siskind’s personal bankruptcy case was dismissed. 

Notwithstanding this, the transactions at issue in this adversary proceeding occurred during the 

pendency of his bankruptcy case. 

30. During the course of Siskind’s bankruptcy case, Siskind was required to file 

timely Monthly Operating Reports and periodic financial reports pursuant to Federal Rule of 

Bankruptcy Procedure 2015.3.

31. Specifically, Rule 2015.3(a) provides:

(a) Reporting Requirement. In a chapter 11 case, the trustee or debtor in 

possession shall file periodic financial reports of the value, operations, and 

profitability of each entity that is not a publicly traded corporation or a debtor 

in a case under title 11, and in which the estate holds a substantial or 

controlling interest. The reports shall be prepared as prescribed by the 

appropriate Official Form, and shall be based upon the most recent 

information reasonably available to the trustee or debtor in possession.

32. During the course of Siskind’s Chapter 11 case, he filed four such reports each of 

which is annexed hereto as Composite Exhibit A. The reports fail to disclose his interests in the 

Debtor, Sympatico, Sovereign, CannaMed2 or FLACC. 

Chance & Anthem Transactions

33. Siskind testified in this bankruptcy case that Chance & Anthem did not file tax 

returns because it was “never profitable.” Although the Debtor never generated any revenue 

from operations, it received millions from investors and creditors that were used to make 

substantial transfers to or on behalf of Siskind or his family and insiders. Indeed, the Debtor’s 

bank accounts reflect a pattern of withdrawal transactions for Siskind’s personal benefit, 

including, without limitation, the following transactions which took place between November 7, 

2014 and June 13, 2018:

A. Cash withdrawals with no backup in an amount exceeding $119,000; 

 2 CannaMed allegedly did not have a bank account and was “funded” by Chance & Anthem.

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B. Disbursements to Siskind in the amount of $228,6263

C. The use of $59,000 of funds obtained from clients or investors to purchase 

a Mercedes Benz titled in the name of Siskind Trust; 

D. Payment of $17,000 to his wife Defendant Tanya Siskind;

E. Payment of $16,200 to his sister Wendy Buckingham; and, 

F. Consumer debit card purchases ($14,707).

Sympatico and FLACC Transactions

34. Similarly, it appears that during the pendency of his Chapter 11 case, Siskind used 

FLACC and Sympatico to pay for personal expenses while evading the reporting requirements of 

his Chapter 11 case. Notably, the bank accounts of FLACC and Sympatico reflect that the 

majority of cash receipts originated from bank accounts controlled by Siskind and funded with 

creditor money. 

35. FLACC and Sympatico appear to have been incorporated as non-profit 

corporations in the State of Florida. Neither appears to have used significant funds in 

furtherance of an eleemosynary or legitimate business purpose during the period examined but 

rather appear to reflect a pattern of withdrawals and transactions for Siskind’s personal benefit

and those of his family members, including the following transactions which took place between 

January 28, 2013 and July 16, 2018 (FLACC) and February 7, 2013 and August 14, 2018 

(Sympatico):

A. Disbursements to Siskind from FLACC ($597,490) and Sympatico 

($2,050).

 3 The Trustee’s forensic professionals have identified checks written to his DIP Account(s) from the Debtor 

($28,955), FLACC ($129,685) and Sympatico ($5,582) which are exclusive of the sums otherwise identified here. It 

appears that Siskind may have deposited most of the balance of the funds into his DIP Accounts without identifying 

the DIP account as the payee, the underlying source of the funds or the purpose of the transfers. 

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B. Cash withdrawals from FLACC in the amount of $36,882 and from 

Sympatico in the amount of $500.

C. Disbursement from FLACC for personal expenses to the Ocean Reef Club 

($53,890). Mar-a-Lago Club ($48,104), Travel and Entertainment 

($40,917), Gas and Auto ($10,568), Meals ($11,118), Taxes ($26,006) and 

transfers to Sympatico ($15,933). FLACC additionally made 

disbursements to Ozment Merril, Siskind’s sometimes bankruptcy 

counsel, in the amount of $20,000; and,

D. Disbursements for consumer debit card purchases from FLACC ($37,222) 

and Sympatico ($70,150). 

Christopher George & Sovereign

36. On December 24, 2013, Siskind deposited $2,000,000 obtained from Christopher 

George in his attorney’s IOTA Trust Account. Siskind proceeded to use the funds obtained from 

George to make the following payments which appear to have been for his personal benefit and 

the benefit of his family members:

A. On December 24, 2013, Siskind wired $100,000 to Sovereign Gaming and 

Entertainment, LLC. Siskind alleges that this entity belonged to his 

elderly father, but it appears that Siskind controlled the entity and was the 

signatory for checks out of this entity. 

B. After receipt of this transfer, the balance in Sovereign’s account was 

$100,094.93. The balance was subsequently used to make payment 

related toward an Ocean Reef property at 401 Carysfort (formerly owned 

by Siskind and believed to have been transferred to his parents), W 

Aviation LLC, Mar-A-Lago Club, Dillard’s, First Insurance, Old Guard 

Club, Big Lots, Brooks Brothers, ER Bradley’s Saloon and to purchase 

cashier’s checks in excess of $18,000.

C. On December 30, 2013, Siskind made two transfers each from his IOTA 

Trust Account in the amount of $70,000 to a private membership club. 

Siskind is known to have been either a member of the club or a frequent 

visitor. 

D. On January 9, 2014, Siskind wired $1,800,000 to Sovereign. Siskind 

claims this was a loan to Sovereign authorized by Christopher George. 

a. The proceeds were then again used to pay what appear to be 

personal expenses (Home Depot, Publix, Staples, Ocean Reef 

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Club, W Aviation, US Airways, Marriott, etc.) and to fund cash 

withdrawals/purchases of official checks in excess of $130,000. 

b. Siskind then transferred $1,100,000 to FLACC. He thereafter 

$1,000,000 million to purchase an office condominium in the name 

of OB Real Estate 1732, LLC. Siskind later caused OB Real 

Estate 1732, LLC to become fully encumbered and did not use the 

funds to repay either Sovereign or Christopher George. Siskind 

later transferred ownership of OB Real Estate 1732, LLC from 

William Siskind to Frank Zokaites, again without any 

compensation to either Sovereign or Mr. George. Mr. Zokaites 

later caused the condominium to be sold, and again, no 

consideration was ever paid to Sovereign or George;

c. Siskind thereafter transferred $215,620 to purchase a home located 

at 11400 Torchwood Court in Wellington in the name of Beacon 

Acquisition Group, LLC and David Fiore, and

d. the remaining funds were disbursed over the 30 to 45 days and the 

disbursements included $50,000 to FLACC, $25,000 to Jeffrey 

Siskind and $25,000 to Siskind Legal Services.

37. Although Sovereign was nominally owned by William Siskind, it appears that 

Jeffrey Siskind dominated the entity and controlled all of its financial and business affairs. 

Indeed, most of the checks written from Sovereign’s accounts during the relevant time period

appear to be signed by Jeffrey Siskind. It does not appear that Sovereign had any meaningful 

legitimate business operations during the course of these transactions other than to serve as a 

conduit for the transfers identified herein. As with the Debtor, FLACC and Sympatico, Siskind 

did not disclose his interest in Sovereign despite the fact that he appears to have controlled the 

entity and directed the transactions described above. 

B. Chance & Anthem and CannaMed Pharmaceuticals, LLC

38. The Debtor purports to have been in the medical cannabis business through its 

ownership of CannaMed Pharmaceuticals, LLC (“CannaMed”). The Debtor has valued its 

interest in CannaMed at over $28 million. Yet, on the Petition Date, the Debtor only had $48 in 

its checking account and approximately $150 worth of office equipment (also dissipated by 

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Siskind prior to the Trustee’s appointment).The Debtor paid many of CannaMed’s expenses and 

appears to have made itself liable for a number of “loans” or “investments” acquired by 

Defendant Siskind purportedly for use in CannaMed. In a recent court filing, Siskind identified 

litigation involving CannaMed as “the Debtor’s only asset.” See Bankruptcy Petition No. 18-

11168 (Bankr. D. Md.) at ECF No. 81, ¶7.

39. The Debtor’s bankruptcy schedules reflect that it received in excess of $1.3 

million from third parties purportedly to assist it with its cannabis business4

: Among these 

creditors are (a) Frederick Volkwein ($500,000); (b) Richard Neff ($526,000); (c) ABK South 

Properties, LLC ($250,000); (d) Gen VC, LLC ($100,000); and (e) Richard Bell ($50,000).

40. Like the Debtor, CannaMed never operated a bona fide business. In truth, it was 

little more than a shell used by Defendant Siskind to defraud creditors, conceal assets, and 

facilitate his use of assets placed in his trust by clients and investors. 

41. On October 29, 2019, Siskind attempted to forfeit the Debtor’s interest in 

CannaMed citing to several nonsensical pretexts. A copy of Siskind’s correspondence is 

annexed hereto as Exhibit B (the “Post-Petition Forfeiture”). Notably, Siskind failed to seek stay 

relief or authority from the bankruptcy court prior to engaging in his conduct. Furthermore, the 

correspondence appears on letterhead titled “Siskind Legal, PLLC” despite Siskind having been 

disqualified as counsel to CannaMed in this adversary proceeding. 

C. Christopher George 

42. Prior to May 2013, Defendant Siskind was retained as an attorney by Christopher 

George (“George”). George, who is incarcerated, retained Defendants Siskind and Siskind Legal 

 4 The Trustee’s investigation into the extent, validity and priority of the investments is ongoing and remain subject 

to further diligence and reconciliation by Plaintiff. The Trustee reserves all rights with respect to the foregoing 

claims, including but not limited to the right to seek to subordination or disallowance of any claim that is filed 

against the bankruptcy estate. 

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to establish a trust for the benefit of his minor child. The Trust was to be funded with $2 million 

in cash and George’s homestead located at 3485 Lago de Talavera, Lake Worth, Florida, 33467 

(the “Talavera House”).

43. On May 8, 2013, Michael Haggerty (George’s father-in-law) by and through a 

power of attorney, quitclaimed the Talavera House to 3485 Lago de Talavera Trust (“Talavera 

Trust”). The Talavera Trust was settled by Defendants Siskind and Siskind Legal on George’s 

behalf. The quitclaim deed was also prepared by Defendant Siskind. 

44. On December 24, 2013, Defendant Siskind caused George’s wife Dianna George 

to transfer $2 million belonging to George to an attorney trust account denominated “Siskind 

Trust Account” ending in 7721 maintained by Defendants Siskind and Siskind Legal. 

45. Defendant Siskind, as set forth in greater detail below and in Table 1, used the 

Debtor and the Related Defendants to abscond with George’s $2 million and the Talavera House. 

George, acting through Dianna George, has filed a claim a proof of claim against the estate in the 

amount of $2,000,000, alleging among other things, conversion, fraud and breaches of fiduciary 

duty. 

46. Defendant Siskind deposited the funds obtained from George into his IOTA Trust 

account and quickly used them for his own personal benefit. Among other things, Siskind 

purported to structure a loan transaction to Defendant Sovereign in the amount of approximately 

$1.9 million. The balance of the funds ($70,000) were used to pay a relative’s personal 

expenses. 

47. After transferring the funds to Defendant Sovereign, purportedly for bona fide 

investment purposes, Siskind proceeded to use those funds for his own personal benefit, 

including but not limited to (i) transferring $1.15 million to FLACC, later used to purchase an 

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office condominium (defined below as the “Office Space”); (ii) withdrawing $100,000; (iii) 

acquiring an existing mortgage on the Talavera House (defined below); (iv) purchasing real 

estate at 114000 Torchwood Court in Wellington, Florida in the name of Beacon Acquisition & 

David Fiore; (v) transferring $25,000 to Defendant Siskind Legal; (vi) transferring $25,000 to 

Defendant Siskind; and (v) dissipating another $373,379 through a series of other transfers, 

including to third parties (Ocean Reef Club, The Beach Club, Mar-A-Lago Club, Old Guard 

Club & Going Aire) for the benefit of Siskind and his father, William Siskind (collectively, the 

“Sovereign Cash Out”).

48. In sum, Defendant Siskind obtained $2 million from his client, Christopher 

George, and used that money to fund his family’s lifestyle and other investments through a series 

of artifices used in conjunction with the Debtor to part Mr. George from his money for the 

benefit of Defendant Siskind and his family. Mr. George, in turn, seeks to hold the Debtor liable 

for Siskind’s conduct as a Related Defendant or otherwise, as evidence by his proof of claim 

against the Debtor’s bankruptcy estate. Mr. George, notably, received no apparent benefit from 

Siskind’s use of these funds. 

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TABLE 1 – CHRISTOPHER GEORGE RELATED TRANSFERS

CONFIDENTIAL

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D. Carl Stone & Richard Neff

49. On or about August 9, 2015, Carl Stone and his associate David Fiore (“Stone”) 

transferred $800,000 to an attorneys’ trust account maintained by Defendants Siskind and 

Siskind Legal for investment purposes in the improvements to real estate located at 3445 Santa 

Barbara Drive, Wellington, FL 33414 (the “Santa Barbara House”).

50. Defendant Siskind purportedly was in the process of renovating the Santa Barbara 

House in order to later sell it for a profit. Defendants Siskind and Siskind Legal Services agreed 

that they would record proper instruments in order to protect Stone’s interest in the Santa 

Barbara House. 

51. Defendants Siskind and Siskind Legal never recorded a security interest in favor 

of Stone against the Santa Barbara House. Instead, Defendant Siskind used his law firm’s bank 

accounts to (i) transfer $35,000 to FLACC and from those proceeds $30,000 to himself; (ii) 

$750,000 to FLACC of which $725,000 were returned to the Debtor; (iii) the balance of the 

proceeds used to purchase the Santa Barbara House (collectively, the “Stone Cash Out”). 

52. In sum, Defendant Siskind obtained $800,000 from Carl Stone for investment 

purposes, and used that money to fund his lifestyle and other investments through a series of 

artifices used in conjunction with the Debtor to part Mr. Stone from his money for the benefit of 

Defendant Siskind. Mr. Stone, in turn, seeks to hold the Debtor liable for Siskind’s conduct as 

evidence by his proof of claim against the Debtor’s bankruptcy estate.

53. Richard Neff also loaned the Debtor money for use in the renovation of the Santa 

Barbara House. On October 6, 2015, Neff transferred $500,000 to the Debtor. Similarly, 

Defendant Siskind failed to record a mortgage or perfect any other security protecting Neff’s 

investment in the Santa Barbara House. Instead, Defendant Siskind transferred $59,000 from the 

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Debtor to purchase a Mercedes Benz for Defendant Tanya Siskind but purchased in the name of 

the Family Trust (the “Mercedes Transfer”). See Table 2, infra. 

54. As set forth in greater detail below, Defendant Siskind later refinanced the Santa 

Barbara House without recognizing the investments of Stone and Neff, and yet again using those 

proceeds for his own purposes.

55. In sum, Defendant Siskind obtained $500,000 from Richard Neff for investment 

purposes, and used that money to fund his lifestyle and other investments through a series of 

artifices used in conjunction with the Debtor to part Mr. Neff from his money for the benefit of 

Defendant Siskind. Mr. Neff, in turn, seeks to hold the Debtor liable for Siskind’s conduct as 

evidence by his proof of claim against the Debtor’s bankruptcy estate.

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TABLE 2 – CARL STONE & RICHARD NEFF TRANSFERS

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E. Fredrick Volkwein

56. On or about November 17, 2014, Fred Volkwein, either directly or through 

Sarenil Associates, LLC, deposited $1,157,623 into the Debtor. 

57. In this instance, Defendant Siskind deposited the funds in the Debtor’s bank 

account and quickly proceeded to use the funds for his personal benefit by, among other things 

transferring (i) $230,000 to FLACC of which $188,000 was transferred to Defendant Siskind and 

$15,000 was subsequently transferred to Defendant Siskind Legal; (ii) $101,500 to himself 

through six separate transfers; (iii) $100,000 to his IOTA Trust Account; (iv) $58,000 to 

“Fenderhooks” in an apparent repayment to Volkwein; (v) $45,000 to George Maler in 

satisfaction of another debt; (vi) $43,500 to Crystal Title and Equity regarding “Fiore”; and (vii) 

$26,000 to Defendant Sovereign (collectively, the “Volkwein Cash Out”). See Table 3, infra.

58. Siskind used Volkwein’s own funds to repay $535,109 to Volkwein in 

consideration of his prior investment.

59. On August 7, 2018, the Sarenil Associates, LLC filed a proof of claim against the 

Debtor’s bankruptcy estate in the amount of $669,124 (Claim No. 3).

[REMAINDER OF PAGE INTENTIONALLY BLANK]

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TABLE 3 – FREDERICK VOLKWEIN TRANSFERS

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 20 of 103
F. The Real Estate Transactions

60. Defendant Siskind used also the Debtor and its Related Defendants to conceal his 

use of client and investor assets for his own personal benefit through transactions involving four 

(4) real properties in Palm Beach County, Florida: (1) The Talavera House; (2) The Santa 

Barbara House, (3) The Office Space; and (4) The Cross Creek Condominium. 

3485 Lago de Talavera

61. On or about December 2013, George alleges that he instructed his attorney, 

Defendant Siskind, to use a portion of the $2 million held by Defendant Siskind for the benefit of 

George to satisfy a mortgage encumbering the Talavera House. The mortgage was held by 

Michelle Watson in the principal amount of $200,000. 

62. The Legal Description of the Talavera House is: 

TALAVERA PUD LT 29, according to the Plat thereof, as 

recorded in Plat Book 105, Page 44, of the Public Records 

of Palm Beach County, Florida

Parcel Control Number: 00-42-44-19-09-000-0290

63. Instead of satisfying the mortgage, however, Defendant Siskind obtained an 

assignment of the mortgage in favor of Defendant Sovereign. The assignment was prepared by 

Defendant Siskind. W. Siskind, Siskind’s deceased father, was the sole member of Defendant 

Sovereign and Defendant Siskind admits to being its control person. 

64. On November 14, 2014, Defendant Siskind prepared and recorded a Notice of Lis 

Pendens in Palm Beach County (Filing #20558894) purporting to give notice of the foreclosure 

of a mortgage by Defendant Sovereign.

65. On February 5, 2014, Defendant Siskind prepared and recorded a so-called 

“indemnity mortgage” against the Talavera House in the amount of $300,000 in order to secure 

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legal fees that he or Defendant Siskind Legal could potentially incur at a future date while 

providing legal services to George or Talavera Trust (the “Indemnity Mortgage”). 

66. George alleges that no legitimate fees were incurred by Defendants Siskind or 

Siskind Legal, and that the indemnity mortgage was orchestrated by Defendant Siskind to part 

him from his assets. Upon information and belief, little or no consideration was ever given to 

George by Defendants Siskind or Siskind Legal in exchange for the Indemnity Mortgage. 

67. On January 8, 2015, Defendant Siskind caused the Talavera Trust, alleged by 

George to have occurred through fraud and misrepresentation, to transfer the Talavera House to 

Defendant Sovereign through a deed-in-lieu of foreclosure. George alleges that at Defendant 

Siskind’s insistence, the Talavera Trust conveyed to Defendant Sovereign all right, title and 

interest in the Talavera House. The deed in favor of Defendant Sovereign was prepared and 

recorded by Defendant Siskind. 

68. On February 25, 2016, Defendant Sovereign gave a mortgage against the Talavera 

House in favor of Tatarow Family Partners, Ltd. (“Tatarow”) in the amount of $300,000. Upon 

information and belief, the proceeds of the loan collateralized by the Talavera House were 

wholly misappropriated by Defendants Siskind for his own personal use and never provided any 

value to Defendant Sovereign (the “First Talavera Cash Out”).

69. On July 19, 2016, Defendants Siskind and Siskind Legal sold the Indemnity 

Mortgage to George Maler and Jeri Maler for $100,000 (the “Second Talavera Cash Out”). The

proceeds of the First Talavera Cash Out were transferred to Defendants Siskind and Siskind 

Legal for their own benefit and never provided any value to the Debtor or Defendant Sovereign. 

70. Subsequently, Tatarow initiated a foreclosure proceeding against the Talavera 

House in a case captioned Tatarow Family Partners LTD v. Sovereign Gaming & Entertainment, 

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LLC, etc., Case No. 50-2016-CA-012892-XXXX-MB, pending in the Seventeenth Judicial 

Circuit of Florida (the “Talavera Foreclosure Case”).

71. On March 5, 2018. Tatarow assigned its mortgage to Defendant Zokaites 

Properties, which was substituted as plaintiff in the Talavera Foreclosure Case (the “Tatarow 

Mortgage Transfer”). 

72. The Talavera Foreclosure case remains pending. The Talavera House is presently 

believed to be occupied by Defendant Siskind’s elderly mother Judy Siskind. Although it was 

titled in the name of Defendant Sovereign, the title to same has been transferred to Defendant’s 

Siskind former paralegal, Robert Gibson, through a series of quit claim deeds allegedly executed 

by Defendant Sovereign to the Maler’s and finally to Defendant Robert Gibson (the “Gibson 

Transfer”). It is believed that Mr. Gibson has further pledged a mortgage against the house in 

favor of the Malers.

73. The First Talavera Cash Out, Second Talavera Cash Out, Tatarow Mortgage 

Transfer and Gibson Transfer shall collectively be referred to as the “Talavera Transfers”)

The Santa Barbara House 

74. On August 25, 2015, the Debtor purchased the Santa Barbara House from JP 

Morgan Chase Co. for $1,250,000. Upon information and belief, the Debtor used at least $1 

million in funds from Neff and Stone to fund the purchase of the Santa Barbara House. 

75. The Legal Description of the Santa Barbara House is: 

SOUTHFIELDS PHASE 1 WELLINGTON 

COUNTRYPLACE LT 2 PUD, according to the Plat 

thereof, as recorded in Plat Book 39, Pages 19 through 22, 

of the Public Records of Palm Beach County, Florida

Parcel Control Number: 73-41-44-21-03-000-0020

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76. On November 13, 2015, Defendant Siskind encumbered the Santa Barbara House 

with a mortgage in favor of New Wave Loans Residential, LLC in the amount of $812,500. The 

mortgage instrument was executed by Defendant Siskind as managing member of the Debtor. 

The Mortgage purported to secure a balloon loan in the amount of $812,500 plus accumulated 

interest which matured in December 2018 (the “First Santa Barbara Cash Out”). 

77. The funds obtained from the First Santa Barbara Cash Out were deposited in the 

Debtor and quickly thereafter used by Siskind to fund his own personal expenses, including (i) 

five payments to Siskind for $107,500; (ii) a transfer of $61,719.63 to K Title Company LLC fbo 

Jeffrey Siskind; (iii) two payments of $145,950 to George Maler; (iv) two payments totaling 

$117,000 for aircraft related expenses; (v) thirteen cash withdrawals totaling $82,000; (vi) a 

payment of $62,506 to Defendant Zokaites Properties for a “loan payoff;” (vii) two transfers 

totaling $60,000 to Siskind’s IOTA trust accounts; and (viii) four transfers totaling $30,000 to 

Defendant Sovereign. 

78. On March 23, 2016, Defendant Siskind further encumbered the Santa Barbara 

House with a mortgage in favor of ABK South Properties, LLC in the amount of $500,000. The 

mortgage instrument was executed by Defendant Siskind as managing member of the Debtor. 

The Mortgage purported to secure a balloon loan in the amount of $812,500 plus accumulated 

interest which matured on December 2018. Upon information and belief, the proceeds of this 

loan incurred by the Debtor were transferred to Defendant Siskind for his own personal use and 

were never of any value to the Debtor or Related Defendant(s) (the “Second Santa Barbara Cash 

Out”). 

79. The proceeds of the Second Santa Barbara Cash Out, to date identified as 

$100,000 deposited in the Debtor’s bank account, were again quickly used by Siskind to fund his 

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own personal expenses including (i) six transfers totaling $48,625 to FLACC; (ii) a transfer of 

$10,000 to Defendant Siskind Legal; and (iii) $30,231 to fund a payment to Long Badger & 

Sheller purportedly in consideration of CannaMed’s rent expense. 

80. On November 8, 2016, New Wave Lenders initiated a foreclosure proceeding 

against the Santa Barbara House. New Wave Lenders 2015 B LP v. Chance & Anthem, LLC,

Case No. 50-2016-CA-012543.

81. On January 23, 2017, Defendant Wellington acquired the first position mortgage 

in favor of New Wave Lenders for $898,231 and subsequently substituted itself as plaintiff in the 

foreclosure case. 

82. On June 12, 2017, the Santa Barbara House was sold at a foreclosure sale to 

Defendant Wellington for $1,000,100 (“Santa Barbara Foreclosure Transfer”).

83. The Santa Barbara House, in summary, was used by Defendant Siskind to (1) 

conceal the use of $1 million he wrongfully obtained from Stone and Neff; (2) obtain over 

$800,000 in additional cash from the equity in the house mortgaged by New Wave Lenders and 

ABK South Properties, LLC; and (3) transfer the value of the Santa Barbara House from the 

Debtor free and clear of all liens, claims and encumbrances to Defendant Wellington in the Santa 

Barbara Foreclosure Transfer. 

84. Notably, the Santa Barbara House is adjacent to Siskind’s personal residence 

located within the municipality of Wellington, Florida. It is believed that Defendant Siskind 

recorded an easement on the Santa Barbara House in favor of his personal residence in order to 

add value to the home he owns with Tanya Siskind (the “Siskind Parcel Transfer”). 

85. Hereinafter, the First Santa Barbara Cash Out, the Second Santa Barbara Cash 

Out, the Santa Barbara Foreclosure Transfer and the Siskind Parcel Transfer shall be collectively 

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referred to as the “Santa Barbara Transfers”).

The Trump Office Suite / OB Real Estate Holdings 1732, LLC

86. Defendant, OB Holdings, was the fee simple owner of the suite of offices where 

Defendants Siskind, Siskind Legal and Sovereign operated. The suite consisted of the entire fifth 

(top) floor of the Trump Office Center on 525 S. Flagler Drive, West Palm Beach Florida (the 

“Office Suite”). 

87. The Legal Description of the Office Suite is: 

Condominium Units CCU3A2, CCU3B2 and CCU3C2, Trump Plaza of 

the Palm Beaches, a condominium, according to the Declaration of 

Condominium thereof, recorded in Official Records Book 4800, Page 457, 

with all exhibits and amendments thereof, Public Records of Palm Beach 

County, Florida, and any and all amendments thereto, together with an 

undivided interest in the common elements appurtenant thereto a set forth 

in said declaration, together with an undivided 16.93% interest in Unit No. 

CCU3 as set forth in the Declaration of Agreement for Commercial Unit

Parking Facilities as recorded in Official Records Book 19010, Page 70, 

Public Records of Palm Beach County, Florida

Parcel Control Number: 74-43-43-22-25-003-0012

88. On February 27, 2014, Defendant OB Holdings acquired the Office Suite through 

a foreclosure proceeding captioned Optimum Bank v. TP5, LLC, et al, Case No. 50-2010-CA026014 (17th Judicial Circuit). In this original proceeding, Optimum Bank foreclosed on a first 

position mortgage recorded against the Office Suite, which at the time was owned by TP5, LLC, 

a limited liability company. Defendant Siskind was the sole managing member and registered 

agent for TP5, LLC. He was also a guarantor of the indebtedness to Optimum Bank. Ultimately, 

through the foreclosure case, Optimum Bank took title to the Office Suite through Defendant OB 

Holdings. In his personal bankruptcy case, Defendant Siskind claimed that TP5, LLC was his 

Related Defendant. 

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89. On April 30, 2014, Defendant Siskind acquired the shares of Defendant OB 

Holdings from Optimum Bank and placed them in the name of W. Siskind. Through Defendant 

OB Holdings, Defendant Siskind acquired fee simple ownership of the Office Suite (the “Office 

Suite Repurchase”). 

90. Defendant Siskind used the $1 million from Christopher George to fund the 

Office Suite Repurchase. Defendant Siskind accomplished the Office Suite Repurchase by 

purporting to “lend” $1 million allegedly held in trust by Defendants Siskind and Siskind Legal 

to Defendant Sovereign. Although Defendant Sovereign funded the purchase of Defendant OB 

Real Estate, it received no consideration or reasonably equivalent value in connection with the 

transaction (the “First Office Suite Cash Out”). 

91. After acquiring the Office Suite, Defendant Siskind proceeded to encumber and 

cash out of the Office Suite much as he did with the Talavera House and the Santa Barbara

House. 

92. On September 3, 2014, Defendant Siskind encumbered the Office Suite with a 

mortgage in favor of George Maler and others (the “Maler Lenders”) in the amount of $200,000. 

The mortgage instrument was executed by W. Siskind (deceased) as managing member of 

Defendant OB Real Estate. Upon information and belief, the proceeds of this loan incurred by 

the Defendant OB Real Estate were transferred to Defendants Siskind through his IOTA Trust 

Account for his own personal use and were never of any value to the Debtor or Defendant OB 

Real Estate (the “Second Office Suite Cash Out”). 

93. On November 28, 2014, Defendant Siskind further encumbered the Office Suite 

by increasing the indebtedness to the Maler Lenders by $150,000 to $350,000. The mortgage 

instrument was executed by W. Siskind as managing member of Defendant OB Real Estate. 

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Upon information and belief, the proceeds of this loan incurred by Defendant OB Real Estate 

were transferred to Defendants FLACC, Siskind and W. Siskind for their own personal use and 

were never of any value to the Debtor or Defendant OB Real Estate (the “Third Office Suite 

Cash Out”). 

94. On March 28, 2015, Defendant Siskind further encumbered the Office Suite by 

increasing the indebtedness to the Maler Lenders by $150,000 to $500,000. The mortgage 

instrument was executed by W. Siskind as managing member of Defendant OB Real Estate. 

Upon information and belief, the proceeds of this loan incurred by Defendant OB Real Estate 

were transferred to Defendants FLACC and Sovereign for the personal use of Siskind and W. 

Siskind and were never of any value to the Debtor or Defendant OB Real Estate (the “Fourth

Office Suite Cash Out”). 

95. On September 20, 2015, Defendant Siskind further encumbered the Office Suite 

by increasing the indebtedness to the Maler Lenders by $250,000 to $750,000. The mortgage 

instrument was executed by W. Siskind as managing member of Defendant OB Real Estate. 

Upon information and belief, the proceeds of this loan incurred by Defendant OB Real Estate 

were transferred to Defendants Siskind and W. Siskind for their own personal use and were 

never of any value to the Debtor or Defendant OB Real Estate (the “Fifth Office Suite Cash 

Out”). 

96. On November 28, 2016, W. Siskind resigned as the sole managing member of OB 

real Estate and was replaced with Zokaites. 

97. On January 31, 2018, Zokaites caused Defendant OB Real Estate to transfer its 

interest in the Office Suite in exchange for $1.2 Million (the “Office Suite Sale”). 

98. The Office Suite, in summary, was used by Defendant Siskind to (1) conceal the 

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use of $1 million he wrongfully obtained from his client Christopher George through Defendant 

Sovereign; (2) encumber the property in the face amount of $750,000 from the Office Suite in 

mortgages provided by the Maler Lenders; (3) transfer the interests in Defendant OB Real Estate 

to Zokaites; and (4) consummate the Office Suite Sale in order to liquidate the remaining equity 

in the Office Suite without providing any value to Defendant Sovereign in exchange for its 

original $1 million contribution for the Office Space Repurchase. 

99. Hereinafter, the Office Suite Repurchase, First Office Suite Cash Out, Second 

Office Suite Cash Out, Third Office Suite Cash Out, Fourth Office Suite Cash Out, Fifth Office 

Suite Cash Out, Fifth Office Suit Cash Out and the Office Suite Sale shall collectively be 

referred to as the “Office Suite Transfers”).

The Cross Creek Condominium

100. On December 2, 2015, Defendant Siskind caused the Debtor to obtain an 

Assignment of Mortgage from George A. Maler recorded against real property located in Cross 

Creek Condominium at 1500 N Congress Avenue, Unit B-6, West Palm Beach, Florida 33401 

(the “Cross Creek Condominium”). 

101. The Legal Description of the Cross Creek Condominium is: 

CROSS CREEK COND UNIT B-6 BLDG 9, a condominium 

according to the Declaration thereof recorded in Official Record 

Book 3262, Page 1812, of the Public Records of Palm Beach 

County, Florida. 

Parcel Control Number: 74-43-43-18-05-000-2006

102. On August 1, 2017, the Debtor, through Defendant Siskind, filed a Notice of Lis 

Pendens against the CrossCreek Condominium and also initiated a foreclosure proceeding

against its owners in the matter Imitiaz Mohammed and Zoreeda Mohammad, et al. Case No. 20-

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 29 of 103
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2017-CA-008682XXXXMB, which case was pending the Palm Beach County Circuit Court.

103. On October 12, 2017, the Debtor executed and Assignment of Mortgage from the 

Debtor to Zokaites Properties concerning the mortgage it owned on the Cross Creek 

Condominium (the “Cross Creek Transfer”). Upon information and belief, the Debtor did not 

receive any value for assignment of its mortgage to Defendant Zokaites Properties. 

G. The Transfers at Issue 

104. During the Four Years prior to the Petition Date, Defendant Siskind using the 

Debtor or the Related Defendants, engaged in the following transactions which reflect transfers 

of real estate and cash either to him individually or nominally to third parties but for his benefit: 

a. The Sovereign Cash Out;

b. The Stone Cash Out

c. The Volkwein Cash Out 

d. The Stone Cash Out;

e. The Mercedes Transfer; 

f. The Talavera Transfers 

g. The Santa Barbara Transfers 

h. The Office Suite Transfers

i. The Cross Creek Transfer; 

j. The Post Petition Forfeiture; and

k. Additionally, Siskind withdrew over $119,000 from the Debtor’s bank accounts in 

cash for his own personal benefit in the manner set forth at Exhibit “C,” and 

referred to herein as the “Siskind Cash Transfers”

105. During the Four Years prior to the Petition Date, Defendant Family Trust 

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engaged in the Mercedes Transfer which reflects the transfer of property of the Debtor: 

Additionally, Defendant Tanya Siskind was paid $17,000 by the Debtor for which the Debtor 

received no value (the “Tanya Siskind Cash Transfer”) in the manner set forth at Exhibit “D.” 

Defendant Tanya Siksind was also a beneficiary of the Santa Barbara Parcel Transfer.

106. During the Four Years prior to the Petition Date, Defendant Wellington engaged 

in the Santa Barbara Transfer which reflects a transfer of real estate for its benefit: 

107. During the Four Years prior to the Petition Date, Defendant Zokaites Properties 

engaged in the Talavera Transfers and Cross Creek Transfers, each of which reflects transfers of 

real estate and cash either to him individually or nominally to third parties but for its benefit: 

a. The Talavera Transfer;

b. The Cross Creek Transfer.

108. During the Four Years prior to the Petition Date, Defendant Sympatico

benefitted from the scheme by receiving (i) $11,354.50 from the Debtor; (ii) $12,540 from 

Siskind Legal; (iii) $15.933 from FLACC; and (iv) $11,498.05 from Siskind’s DIP Account

(collectively, the “Sympatico Transfers”). Additionally, Siskind deposited over $25,000 in cash 

into Sympatico’s bank accounts.

109. Additionally, during the Four Years prior to the Petition Date, Defendant Gibson 

engaged in the Talavera Transfer which reflects a transfer of the bare legal title the Talavera 

House to himself individually. 

H. Conditions Precedent

110. All conditions precedent to the institution of this action have been performed, 

have occurred, have been waived or have otherwise been excused.

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I. The Causes of Action

COUNTS 1-6

ACTION FOR SUBSTANTIVE CONSOLIDATION OF DEFENDANTS 

CANNAMED, SISKIND LEGAL, SOVEREIGN, FLAC, SYMPATICO, 

AND WELLINGTON WITH THE DEBTOR’S BANKRUPTCY ESTATE

The Trustee sues Defendants CannaMed, Sovereign, Siskind Legal, Wellington, FLACC 

and Sympatico and alleges: 

111. The Trustee repeats and realleges paragraphs 1-110 of his Complaint as if fully 

set forth herein, with respect to each applicable Defendant. 

112. This is an action to substantively consolidate Defendants CannaMed, Siskind 

Legal, Sovereign and Wellington, as set forth in the table below, into the Debtor’s bankruptcy 

proceedings such that each respective Defendant will be deemed a jointly administered 

bankruptcy debtor pursuant to Section 105 of the Bankruptcy Code

COUNT RELATED

DEFENDANT RELATED TRANSACTION 

1 CannaMed Liabilities of the Debtor 

2 Sovereign Talavera Transfers

Office Suite Transfers

3 Siskind Legal

Sovereign Cash Out

Stone Cash Out

Volkwein Cash Out

Talavera Transfers

Santa Barbara Transfers

Office Suite Transfers

4 Wellington Santa Barbara Transfers

5 FLACC Sovereign Cash Out, Stone Cash Out, 

Volkwein Cash Out

6 Sympatico Sympatico Transfers

113. Given the facts and circumstances set forth above, equity and applicable law 

require that each respective Defendant be substantively consolidated as a jointly administered 

bankruptcy debtor. 

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114. Based upon the foregoing, under applicable law the entry of an order and/or 

judgment substantively consolidating the Defendant at issue in each respective Count herein with 

the Debtor is both necessary and appropriate.

115. In the event the relief requested in this Count is granted, the Trustee will, by 

separate motion to be filed in the main case to be served on all creditors and parties in interest, 

seek entry of an order substantively consolidating Defendant at issue in each respective Count 

herein with the estate of the Debtor. 

WHEREFORE, the Plaintiff, Robert C. Furr, as Chapter 7 Trustee of the Debtor, 

Chance & Anthem, LLC, respectfully requests entry of an order and/or judgment against 

Defendants CannaMed, Sovereign, Siskind Legal, Wellington, FLACC and Sympatico: (i) 

declaring that each Defendant be substantively consolidated with the Debtor to be jointly 

administered with the Debtor’s bankruptcy proceeding; and (ii) for any other relief the Court 

deems appropriate.

COUNTS 7 – 22

AVOIDANCE AND RECOVERY OF FRAUDULENT TRANSFERS PURSUANT TO 

SECTIONS 548(a))(1)(A), 550(a)(1) and 550(a)(2) OF THE BANKRUPTCY CODE

The Trustee sues Defendants and alleges: 

116. The Trustee restates and realleges paragraphs 1 through 110, as if fully set forth 

herein. 

117. Pursuant to 11 U.S.C. § 548(a)(1)(A) and/or 11 U.S.C. § 544, a Trustee may 

avoid any transfer of an interest of the debtor in property, or any obligation incurred by the 

debtor, that was made or incurred on or within 2 years (under § 548 of the Bankruptcy Code) 

before the date of the filing of the petition, if the debtor voluntarily or involuntarily –

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(a) made such transfer or incurred such obligation with actual 

intent to hinder, delay, or defraud any entity to which the debtor 

was or became, on or after the date that such transfer was made or 

such obligation was incurred, indebted.

118. Further, pursuant to 11 U.S.C. § 550(a), in a fraudulent transfer action 

commenced under §§ 544 and 548 of the Bankruptcy Code, the Trustee may recover, for the 

benefit of the estate, the property transferred, or, if the Court so orders, the value of such 

property, from – (1) the initial transferee of such transfer or the entity for whose benefit such 

transfer was made; and (2) any immediate or mediate transferee of such initial transferee, i.e., 

any and all subsequent transferees. 

119. The transfers identified below that occurred within two (2) years of the Petition 

Date to Defendant constitute transfers of an interest in property and/or obligation of the Debtor 

or the Related Defendant(s) identified in each count set forth in the table above as set forth 

herein and are therefore avoidable pursuant to 11 U.S.C. § 548(a)(1)(A) as actual intent 

fraudulent transfers. 

Count

Debtor/

Related Defendant 

Transferor

Transferee / 

Defendant Property Transferred

7 Sovereign Siskind, FLACC

Siskind Legal Sovereign Cash Out

8 Chance Siskind, Siskind Legal 

FLACC Stone Cash Out

9 Chance Siskind, Siskind Legal, 

Sovereign, FLACC Volkwein Cash Out

10 Chance Family Trust Mercedes Transfer

11 Sovereign Siskind First Talavera 

Cash Out

12 Sovereign Siskind Second Talavera Cash 

Out

13

Sovereign Zokaites Properties

Encumbrance of 

Tatarow Mortgage 

transferred to 

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Defendant Zokaites 

Properties

14 Sovereign Gibson Gibson Transfer

15 Chance Siskind, Sovereign, First Santa Barbara 

Cash Out

16 Chance Siskind, Siskind Legal, 

FLACC

Second Santa Barbara 

Cash Out

17 Chance Wellington Santa Barbara 

Foreclosure Transfer

18 Sovereign OB Real Estate Office Suite Sale

19 Chance Zokaites Properties Cross Creek Transfer

20 Chance Siskind Siskind Cash Transfers

21 Chance Tanya Siskind Tanya Siskind Cash 

Transfers

22 Chance 

Siskind Legal Sympatico Sympatico Transfers

120. Further, the Debtor and its Related Defendants as identified in the table herein did 

not receive reasonably equivalent value for each transfer identified in the table herein, to the 

extent that the Debtor or its Related Defendant identified therein (i) were insolvent at the time of 

each transfer to each defendant as set forth above or became insolvent as a result thereof; (ii) 

were engaged or were about to engage in a business or transaction for which the remaining assets 

of the Debtor or the Related Defendant identified in each count set forth in the table herein were 

unreasonably small in relation to the business or transaction; or (iii) intended to incur, or 

believed or reasonably should have believed, that the Debtor or the Related Defendant identified 

in each count set forth in the table herein would incur debts beyond their ability to pay as they 

came due.

121. Each defendant identified in each count set forth in the table herein was the initial 

transferee or the entity for whose benefit the transfer at issue in each count herein was made, and 

as a result, the Trustee is entitled to avoid each transfer from each Defendant as set forth in each 

Count herein pursuant to 11 U.S.C. § 548(a)(1)(A) as actual intent fraudulent transfers and to 

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recover all such property for the benefit of the estate or, should the Court so order, the value 

thereof pursuant to 11 U.S.C. § 550(a)(1).

122. Alternatively, the Defendant(s) identified in each Count set forth in the table

above was(were) the immediate or subsequent transferee(s) of the initial transferee for whose 

benefit the transfer at issue in each count herein was made. As a result, the Trustee is entitled to 

recover the transfer at issue in each count herein as referenced above, from each Defendant,

pursuant to 11 U.S.C. §§ 548(a)(1)(A) and 550(a)(2).

123. Therefore, in accordance with 11 U.S.C. § 550(a), the recovery of property for the 

benefit of the bankruptcy estate of the Debtor is authorized to the extent that a transfer at issue in 

each count herein occurred within two (2) years of the Petition Date are avoided pursuant to 11 

U.S.C. § 548(a)(1)(A).

WHEREFORE, the Plaintiff, Robert C. Furr, as Chapter 7 Trustee of the Debtor, 

Chance & Anthem, LLC, demands judgment against each Defendant identified in each 

respective Count above and (a) determining that each respective transfer that occurred within 

two (2) years of the Petition Date was fraudulent and avoidable pursuant to 11 U.S.C. § 

548(a)(1)(A); (b) and entering judgment in favor of Plaintiff against each respective Defendant 

in such amounts as are determined at trial, or the value thereof, and as otherwise detailed in the 

amounts set forth herein, plus pre-judgment interest from the date of each such transfer and 

post-judgment interest and costs of suit, all pursuant to 11 U.S.C. § 550; (c) disallowing any 

claim that each respective Defendant may have against the Debtor, including without limitation, 

pursuant to and as provided in 11 U.S.C. § 502(d); and (d) for such other and further relief as the 

Court deems just and proper.

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COUNTS 23-38

AVOIDANCE AND RECOVERY OF FRAUDULENT TRANSFERS PURSUANT TO 

SECTION 548(a)(1)(B) OF THE BANKRUPTCY CODE

The Trustee sues Defendants and alleges: 

124. The Trustee restates and realleges paragraphs 1 through 110, as if fully set forth 

herein. 

125. Pursuant to 11 U.S.C. §§ 548(a)(1)(B) and/or 544, a Trustee may avoid any 

transfer of an interest of the debtor in property, or any obligation incurred by the debtor, that was 

made or incurred on or within 2 years (under § 548 of the Bankruptcy Code) before the date of 

the filing of the petition, if the debtor voluntarily or involuntarily –

(B) (i) received less than a reasonably equivalent value in 

exchange for such transfer or obligation; and

(ii) (I) was insolvent on the date that such transfer was 

made or such obligation was incurred, or became 

insolvent as a result of such transfer or obligation; 

(II) was engaged in business or a transaction, or was 

about to engage in business or a transaction, for 

which any property remaining with the debtor was 

an unreasonably small capital; or 

(III) intended to incur, or believed that the debtor 

would incur, debts that would be beyond the 

debtor’s ability to pay as such debts matured.

126. Further, pursuant to 11 U.S.C. § 550, in a fraudulent transfer action commenced 

under §§ 544 and 548 of the Bankruptcy Code, the Trustee may recover, for the benefit of the 

estate, the property transferred or obligation incurred, or, if the Court so orders, the value of such 

property, from – (1) the initial transferee of such transfer or the entity for whose benefit such 

transfer was made; and (2) any immediate or mediate transferee of such initial transferee, i.e., 

any and all subsequent transferees. 

127. The transfers identified in the table herein that occurred within two (2) years of 

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38

the Petition Date constitute transfers of an interest in property and/or obligations of Debtor or the 

Related Defendant(s) identified in each Count set forth in the table herein, which are avoidable 

pursuant to 11 U.S.C. § 548(a)(1)(B) as constructively fraudulent transfers. \

Count

Debtor/

Related Defendant 

Transferor

Transferee / 

Defendant Property Transferred

23 Sovereign Siskind, FLACC

Siskind Legal Sovereign Cash Out

24 Chance Siskind, Siskind Legal 

FLACC Stone Cash Out

25 Chance Siskind, Siskind Legal, 

Sovereign, FLACC Volkwein Cash Out

26 Chance Family Trust Mercedes Transfer

27 Sovereign Siskind First Talavera 

Cash Out

28 Sovereign Siskind Second Talavera Cash 

Out

29

Sovereign Zokaites Properties

Encumbrance of 

Tatarow Mortgage 

transferred to 

Defendant Zokaites 

Properties

30 Sovereign Gibson Gibson Transfer

31 Chance Siskind, Sovereign, First Santa Barbara 

Cash Out

32 Chance Siskind, Siskind Legal, 

FLACC

Second Santa Barbara 

Cash Out

33 Chance Wellington Santa Barbara 

Foreclosure Transfer

34 Sovereign OB Real Estate Office Suite Sale

35 Chance Zokaites Properties Cross Creek Transfer

36 Chance Siskind Siskind Cash Transfers

37 Chance Tanya Siskind Tanya Siskind Cash 

Transfers

38 Chance

Siskind Legal Sympatico Sympatico Transfers

128. The Debtor or the Related Defendant identified in each Count set forth in the table 

herein did not receive reasonably equivalent value for each transfer identified in the table to the 

extent that the Debtor or the Related Defendant identified in each Count set forth in the table (i) 

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39

were insolvent at the time of each transfer at issue in each Count herein was or became insolvent 

as a result thereof; (ii) were engaged or were about to engage in a business or transaction for 

which the remaining assets of the Debtor or the Related Defendant identified in each Count set 

forth in the table were unreasonably small in relation to the business or transaction; or (iii) 

intended to incur, or believed or reasonably should have believed, that the Debtor or the Related 

Defendant identified in each Count set forth in the table would incur debts beyond their ability to 

pay as they came due.

129. Each Defendant identified in each Count set forth in the table herein was the 

initial transferee or the entity for whose benefit each transfer at issue was made, and as a result, 

the Trustee is entitled to avoid and recover each transfer at issue herein pursuant to 11 U.S.C. § 

548(a)(1)(B) as constructively fraudulent transfers. 

130. Alternatively, each defendant identified in each count set forth in the table herein

was the immediate or subsequent transferee of the initial transferee for whose benefit each 

transfer at issue herein was made, and as a result, the Trustee is entitled to recover each transfer 

at issue herein as referenced above from each Defendant identified herein pursuant to 11 U.S.C. 

§ 548(a)(1)(B) and 11 U.S.C. § 550(a)(2). 

131. Therefore, in accordance with 11 U.S.C. § 550(a), the recovery of property for the 

benefit of the bankruptcy estate of the Debtor is authorized to the extent that each transfer at 

issue in each Count herein occurred within two (2) years of the Petition Date are avoided 

pursuant to 11 U.S.C. § 548(a)(1)(B).

WHEREFORE, the Plaintiff, Robert C. Furr, as Chapter 7 Trustee of the Debtor, 

Chance & Anthem, LLC, demands judgment against each Defendant identified in each 

respective Count above and (a) determining that each respective transfer that occurred within 

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40

two (2) years of the Petition Date was fraudulent and avoidable under 11 U.S.C. § 548(a)(1)(B); 

(b) avoiding each respective transfer and entering judgment in favor of Plaintiff against each 

respective Defendant in such amounts as are determined at trial, or the value of thereof, and as 

otherwise detailed in the amounts set forth herein, plus pre-judgment interest from the date of the 

transfers and post-judgment interest, and costs of suit, all pursuant to 11 U.S.C. § 550; (c) 

disallowing any claim that each respective Defendant may have against the Debtor or the estate 

of any of its Related Defendants, including without limitation, pursuant to and as provided in 11 

U.S.C. § 502(d); and (d) for such other and further relief as the Court deems just and proper.

COUNTS 39-55

AVOIDANCE AND RECOVERY OF FRAUDULENT TRANSFERS

PURSUANT TO SECTION 544 OF THE BANKRUPTCY CODE 

AND SECTION 726.105(1)(A) OF THE FLORIDA STATUTES

The Trustee sues Defendants Siskind, W. Siskind, Zokaites, Wellington and Zokaites 

Properties and alleges: 

132. The Trustee re-states and re-alleges paragraphs 1 through 110, as if fully set forth 

herein. 

133. Pursuant to 11 U.S.C. § 544(b), the Trustee may avoid any transfer of an interest 

of the Debtor in property or any obligation incurred by the Debtor that is voidable under 

applicable law by a creditor holding an unsecured claim that is allowable under § 502 of this title 

or that is not allowable only under § 502(e) of this title.

134. § 726.105(1)(a), Florida Statutes, provides:

(1) A transfer made or obligation incurred by a debtor is fraudulent 

as to a creditor, whether the creditor’s claim arose before or after 

the transfer was made or the obligation was incurred, if the debtor 

made the transfer or incurred the obligation: 

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41

(a) With actual intent to hinder, delay, or defraud any creditor 

of the debtor.

135. Further, pursuant to 11 U.S.C. § 550, in a fraudulent transfer action commenced 

under Chapter 726 of the Florida Statutes, the Trustee may recover, for the benefit of the estate, 

the property transferred, or, if the Court so orders, the value of such property, from – (1) the 

initial transferee of such transfer or the entity for whose benefit such transfer was made; and (2) 

any immediate or mediate transferee of such initial transferee, i.e., any and all subsequent 

transferees. 

136. The transfers identified in the table herein to each respective Defendant were 

transfers made with the actual intent to hinder, delay, and/or defraud creditors pursuant to § 

726.105(1)(a), Florida Statutes.

Count

Debtor/

Related Defendant 

Transferor

Transferee / 

Defendant Property Transferred

39 Sovereign Siskind, FLACC

Siskind Legal Sovereign Cash Out

40 Chance Siskind, Siskind Legal 

FLACC Stone Cash Out

41 Chance Siskind, Siskind Legal, 

Sovereign, FLACC Volkwein Cash Out

42 Chance Family Trust

Tanya Siskind Mercedes Transfer

43 Sovereign Siskind First Talavera 

Cash Out

44 Sovereign Siskind Second Talavera Cash 

Out

45

Sovereign Zokaites Properties

Encumbrance of 

Tatarow Mortgage 

transferred to 

Defendant Zokaites 

Properties

46 Sovereign Gibson Gibson Transfer

47 Chance Siskind, Sovereign, First Santa Barbara 

Cash Out

48 Chance Siskind, Siskind Legal, Second Santa Barbara 

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42

FLACC Cash Out

49 Chance Wellington Santa Barbara 

Foreclosure Transfer

50

Sovereign

Siskind, Siskind Legal, 

FLACC, Sovereign, 

OB Real Estate 

Office Suite Transfers

51 Sovereign OB Real Estate Office Suite Sale

52 Chance Zokaites Properties Cross Creek Transfer

53 Chance Siskind Siskind Cash Transfers

54 Chance Tanya Siskind Tanya Siskind Cash 

Transfers

55 Chance

Siskind Legal Sympatico Sympatico Transfers

137. At the time of each respective transfer identified in the table herein, the Debtor or 

the Related Defendant identified in each Count set forth in the table were, and still are, indebted 

in an amount greater than each transfer.

138. At the time of each respective transfer identified in the table herein, the Debtor or 

the Related Defendant identified in each Count set forth in the table had incurred debts beyond 

their ability to pay as they became due.

139. As set forth above, the Debtor or the Related Defendant identified in each Count 

set forth in the table were otherwise insolvent at the time(s) of each respective transfer identified 

in the table herein. 

140. As a result of each respective transfer identified in the table herein, the Trustee 

has been damaged pursuant to 11 U.S.C. §544(b) for the total value of each respective transfer

identified in the table herein.

141. Each respective Defendant was the initial transferee or the entity for whose 

benefit each respective transfer as identified in the table above was made, and as a result, the 

Trustee is entitled to avoid and recover each respective transfer from each respective Defendant

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43

as identified in the table herein under 11 U.S.C. § 544 of the Bankruptcy Code and § 

726.105(1)(a) of the Florida Statutes as actual intent fraudulent transfers. 

142. Alternatively, each respective Defendant was the immediate or subsequent 

transferee of the initial transferee for whose benefit each transfer identified in the table herein

was made, and as a result, the Trustee is entitled to recover each respective transfer, as 

referenced above, from each respective Defendant pursuant to § 726.105(1)(a) of the Florida 

Statutes and 11 U.S.C. §550(a)(2).

143. Therefore, in accordance with 11 U.S.C. § 550(a), the recovery of property for the 

benefit of the Debtor’s bankruptcy estate is authorized to the extent that the respective transfers

are avoided pursuant to § 726.105(1)(a) of the Florida Statutes.

WHEREFORE, the Plaintiff, Robert C. Furr, as Chapter 7 Trustee of the Debtor, 

Chance & Anthem, LLC, respectfully requests entry of judgment against each Defendant 

identified in each respective Count above and (a) determining that each respective transfer that 

occurred within two (2) years of the Petition Date was fraudulent and avoidable pursuant to § 

726.105(1)(a), Florida Statutes; (b) avoiding each respective transfer and entering judgment in 

favor of Plaintiff against each respective Defendant in such amounts as are determined at trial, or 

the value of thereof, and as otherwise detailed in the amounts set forth herein, plus pre-judgment 

interest from the date of the transfers and post-judgment interest, and costs of suit, all pursuant to 

11 U.S.C. § 550; (c) disallowing any claim that each respective Defendant may have against the 

Debtor, including without limitation, pursuant to and as provided in 11 U.S.C. § 502(d); and (d) 

for such other and further relief as the Court deems just and proper.

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44

COUNTS 56--72

AVOIDANCE AND RECOVERY OF FRAUDULENT TRANSFERS

PURSUANT TO SECTION 544 OF THE BANKRUPTCY CODE

AND SECTION 726.105(1)(B) OF THE FLORIDA STATUTES

The Trustee sues Defendants and alleges: 

144. The Trustee restates and realleges paragraphs 1 through 110 as if fully set forth 

herein. 

145. Pursuant to 11 U.S.C. § 544(b), the Trustee may avoid any transfer of an interest 

of the Debtor in property or any obligation incurred by the Debtor that is voidable under 

applicable law by a creditor holding an unsecured claim that is allowable under § 502 of this title 

or that is not allowable only under § 502(e) of this title.

146. § 726.105(1)(b), Florida Statutes, provides:

(1) A transfer made or obligation incurred by a debtor is fraudulent 

as to a creditor, whether the creditor’s claim arose before or after 

the transfer was made or the obligation was incurred, if the debtor 

made the transfer or incurred the obligation: 

(b) Without receiving reasonably equivalent in value in 

exchange for the transfer or obligation, and the debtor:

(1) Was engaged or was about to engage in a 

business or a transaction for which the remaining 

assets of the debtor were unreasonably small in 

relation to the business or transaction; or

(2) Intended to incur, or believed or reasonably 

should have believed that he or she would incur, 

debts beyond his or her ability to pay as they 

became due.

147. Further, pursuant to 11 U.S.C. § 550, in a fraudulent transfer action commenced 

under Chapter 726 of the Florida Statutes, the Trustee may recover, for the benefit of the estate, 

the property transferred, or, if the Court so orders, the value of such property, from – (1) the 

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45

initial transferee of such transfer or the entity for whose benefit such transfer was made; and (2) 

any immediate or mediate transferee of such initial transferee, i.e., any and all subsequent 

transferees. 

148. The transfers identified in the table herein to each respective Defendant were 

transfers made without the Debtor or the Related Defendant(s) identified in each Count set forth 

in the table herein receiving reasonably equivalent value in exchange for each respective transfer 

pursuant to § 726.105(1)(b), Florida Statutes.

Count

Debtor/

Related Defendant 

Transferor

Transferee / 

Defendant Property Transferred

56 Sovereign Siskind, FLACC

Siskind Legal Sovereign Cash Out

57 Chance Siskind, Siskind Legal 

FLACC Stone Cash Out

58 Chance Siskind, Siskind Legal, 

Sovereign, FLACC Volkwein Cash Out

59 Chance Family Trust

Tanya Siskind Mercedes Transfer

60 Sovereign Siskind First Talavera 

Cash Out

61 Sovereign Siskind Second Talavera Cash 

Out

62

Sovereign Zokaites Properties

Encumbrance of 

Tatarow Mortgage 

transferred to 

Defendant Zokaites 

Properties

63 Sovereign Gibson Gibson Transfer

64 Chance Siskind, Sovereign, First Santa Barbara 

Cash Out

65 Chance Siskind, Siskind Legal, 

FLACC

Second Santa Barbara 

Cash Out

66 Chance Wellington Santa Barbara 

Foreclosure Transfer

67 Sovereign Siskind, Siskind Legal, 

FLACC, Sovereign Office Suite Transfers

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OB Real Estate

68 Sovereign OB Real Estate Office Suite Sale

69 Chance Zokaites Properties Cross Creek Transfer

70 Chance Siskind Siskind Cash Transfers

71 Chance Tanya Siskind Tanya Siskind Cash 

Transfers

72 Chance

Siskind Legal Sympatico Sympatico Transfers

149. At the time(s) of each respective transfer, the Debtor or the Related Defendant

identified in each Count set forth in the table herein were engaged or were about to engage in a 

business or a transaction for which the remaining assets of the Debtor or its respective Related 

Defendant were unreasonably small in relation to the business or transactions in which the 

Debtor or its respective Related Defendant were engaged.

150. At the time of each respective transfer identified in the table herein, the Debtor or 

the Related Defendant identified in each Count set forth in the table had incurred debts beyond 

their ability to pay as they became due.

151. As set forth above, the Debtor or the Related Defendant(s) identified in each 

Count set forth in the table were otherwise insolvent at the time(s) of each respective transfer 

identified in the table herein. 

152. As a result of each respective transfer identified in the table herein, the Trustee 

has been damaged pursuant to 11 U.S.C. § 544(b) for the total value of each respective transfer

identified in the table herein.

153. Each respective Defendant was the initial transferee or the entity for whose 

benefit each respective transfer as identified in the table above was made, and as a result, the 

Trustee is entitled to avoid and recover each respective transfer from each respective Defendant 

as identified in the table herein under 11 U.S.C. § 544 of the Bankruptcy Code and § 

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47

726.105(1)(a) of the Florida Statutes as actual intent fraudulent transfers. 

154. Alternatively, each respective Defendant was the immediate or subsequent

transferee of the initial transferee for whose benefit each transfer identified in the table herein 

was made, and as a result, the Trustee is entitled to recover each respective transfer as referenced 

above from each respective Defendant pursuant to § 726.105(1)(b) of the Florida Statutes and 11 

U.S.C. § 550(a)(2).

155. Therefore, in accordance with 11 U.S.C. § 550(a), the recovery of property for the 

benefit of the estate is authorized to the extent that the respective transfers are avoided pursuant 

to 11 U.S.C. § 548(a)(1)(B).

WHEREFORE, the Plaintiff, Robert C. Furr, as Chapter 7 Trustee of the Debtor, 

Chance & Anthem, LLC, respectfully requests entry of judgment against each Defendant 

identified in each respective Count above and (a) determining that each respective transfer that 

occurred within two (2) years of the Petition Date was fraudulent and avoidable under § 

726.105(1)(B), Florida Statutes; (b) avoiding each respective transfer and entering judgment in 

favor of Plaintiff against each respective Defendant in such amounts as are determined at trial, or 

the value of thereof, and as otherwise detailed in the amounts set forth herein, plus pre-judgment 

interest from the date of the transfers and post-judgment interest, and costs of suit, all pursuant to 

11 U.S.C. § 550; (c) disallowing any claim that each respective Defendant may have against the 

Debtor, including without limitation, pursuant to and as provided in 11 U.S.C. § 502(d); and (d) 

for such other and further relief as the Court deems just and proper.

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COUNTS 73--89

AVOIDANCE AND RECOVERY OF FRAUDULENT TRANSFERS

PURSUANT TO SECTION 544 OF THE BANKRUPTCY CODE

AND SECTION 726.106(1) OF THE FLORIDA STATUTES

The Trustee sues Defendants and alleges: 

156. The Trustee restates and realleges paragraphs 1 through 110 as if fully set forth 

herein. 

157. Pursuant to 11 U.S.C. § 544(b), the Trustee may avoid any transfer of an interest 

of the Debtor in property or any obligation incurred by the Debtor that is voidable under 

applicable law by a creditor holding an unsecured claim that is allowable under § 502 of Title 11 

or that is not allowable only under § 502(e) of this title.

158. § 726.106(1), Florida Statutes, provides:

A transfer made or obligation incurred by a debtor is fraudulent as 

to a creditor whose claim arose before the transfer was made or the 

obligation was incurred if the debtor made the transfer or incurred 

the obligation without receiving a reasonably equivalent value in 

exchange for the transfer or obligation and the debtor was 

insolvent at that time or the debtor became insolvent as a result of 

the transfer or obligation. 

159. The transfers identified in the table herein to each respective Defendant were 

transfers made without the Debtor or the Related Defendant(s) identified in each Count set forth 

in the table herein receiving reasonably equivalent value in exchange for each respective transfer 

pursuant to § 726.106(1), Florida Statutes.

Count

Debtor/

Related Defendant 

Transferor

Transferee / 

Defendant Property Transferred

73 Sovereign Siskind, FLACC

Siskind Legal Sovereign Cash Out

74 Chance Siskind, Siskind Legal 

FLACC Stone Cash Out

75 Chance Siskind, Siskind Legal, Volkwein Cash Out

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49

Sovereign, FLACC

76 Chance Family Trust Mercedes Transfer

77 Sovereign Siskind First Talavera 

Cash Out

78 Sovereign Siskind Second Talavera Cash 

Out

79

Sovereign Zokaites Properties

Encumbrance of 

Tatarow Mortgage 

transferred to 

Defendant Zokaites 

Properties

80 Sovereign Gibson Gibson Transfer

81 Chance Siskind First Santa Barbara 

Cash Out

82 Chance Siskind, Siskind Legal, 

FLACC

Second Santa Barbara 

Cash Out

83 Chance Wellington

Zokaites

Santa Barbara 

Foreclosure Transfer

84

Sovereign

Siskind, Siskind Legal, 

FLACC, 

OB Real Estate

Office Suite Transfers

85 Sovereign OB Real Estate Office Suite Sale

86 Chance Zokaites Properties Cross Creek Transfer

87 Chance Siskind Siskind Cash Transfers

88 Chance Tanya Siskind Tanya Siskind Cash 

Transfers

89 Chance

Siskind Legal Sympatico Sympatico Transfers

160. At the time(s) of each respective transfer, the Debtor or the Related Defendant(s)

identified in each Count set forth in the table herein were engaged or were about to engage in a 

business or a transaction for which the remaining assets of the Debtor or its respective Related 

Defendant(s) were unreasonably small in relation to the business or transactions in which the 

Debtor or its respective Related Defendant(s) were engaged.

161. At the time of each respective transfer identified in the table herein, the Debtor or

the Related Defendant(s) identified in each Count set forth in the table had incurred debts beyond 

their ability to pay as they became due.

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50

162. As set forth above, the Debtor or the Related Defendant(s) identified in each 

Count set forth in the table were otherwise insolvent at the time(s) of each respective transfer 

identified in the table herein.

163. As a result of each respective transfer identified in the table herein, the Trustee

has been damaged pursuant to 11 U.S.C. § 544(b) for the total value of each respective transfer 

identified in the table herein.

164. Each respective Defendant was the initial transferee or the entity for whose 

benefit each respective transfer as identified in the table above was made, and as a result, the 

Trustee is entitled to avoid and recover each respective transfer from each respective Defendant 

as identified in the table herein pursuant to 11 U.S.C. § 544 of the Bankruptcy Code and § 

726.106(1) of the Florida Statutes as actual intent fraudulent transfers. 

165. Alternatively, each respective Defendant was the immediate or subsequent 

transferee of the initial transferee for whose benefit each transfer identified in the table herein

was made, and as a result, the Trustee is entitled to recover these each respective transfer as 

referenced above from each respective Defendant pursuant to § 726.106(1) of the Florida 

Statutes and 11 U.S.C. § 550(a)(2).

166. Therefore, in accordance with 11 U.S.C. §§544 and 548, the recovery of property 

for the benefit of the estate is authorized to the extent that the respective transfers are avoided 

under 11 U.S.C. § 548.

WHEREFORE, the Plaintiff, Robert C. Furr, as Chapter 7 Trustee of the Debtor, 

Chance & Anthem, LLC, respectfully requests entry of judgment against each Defendant 

identified in each respective Count above and (a) determining that each respective transfer that 

occurred within two (2) years of the Petition Date was fraudulent and avoidable under § 

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726.106(1), Florida Statutes; (b) avoiding each respective transfer and entering judgment in favor 

of Plaintiff against each respective Defendant in such amounts as are determined at trial, or the 

value of thereof, and as otherwise detailed in the amounts set forth herein, plus pre-judgment 

interest from the date of the transfers and post-judgment interest, and costs of suit, all pursuant to 

11 U.S.C. § 550; (c) disallowing any claim that each respective Defendant may have against the 

Debtor, including without limitation, pursuant to and as provided in 11 U.S.C. § 502(d); and (d) 

for such other and further relief as the Court deems just and proper.

COUNTS 90-92

ACTION FOR CONSTRUCTIVE TRUST

The Trustee sues Defendants and alleges: 

167. The Trustee restates and realleges paragraphs 1 through 110 as if fully set forth 

herein. 

168. The Trustee is the legal title holder to all property of the Debtor and its Related 

Defendants. 

169. The following transfers were fraudulently effected by the Debtor or its Related 

Defendant(s) or alternatively, without fraud but retained by the transferees set forth below under 

inequitable circumstances. 

Count

Debtor/

Related Defendant 

Transferor

Transferee / 

Defendant Property Transferred

90

Sovereign Zokaites Properties

Encumbrance of 

Tatarow Mortgage 

transferred to 

Defendant Zokaites 

Properties

91 Sovereign Gibson Gibson Transfer

92 Chance Wellington Santa Barbara 

Foreclosure Transfer

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 51 of 103
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170. As the beneficiary of the transfers set forth herein, each Defendant knew or 

should have known that transfers at issue in each Count set forth herein were improper.

171. The recipients of each transfer set forth herein have been unjustly enriched to the 

detriment of the Debtor and its alter egos, and as a result, a constructive trust should be 

established against the transfers at issue and all proceeds, products and replacements of each of 

the subject transfers.

WHEREFORE, the Plaintiff, Robert C. Furr, as Chapter 7 Trustee of the Debtor, 

Chance & Anthem, LLC, respectfully requests this Court to enter a judgment against e each 

respective Defendant, for imposition of a constructive trust lien to be established against the 

transfers identified herein and all proceeds, products or replacements of the transfers set forth 

herein, for damages and all such other relief as this court deems just and appropriate.

COUNT 93-95

ACTION FOR EQUITABLE LIEN

The Trustee sues Defendants and alleges: 

172. The Trustee restates and realleges paragraphs 1 through 110 as if fully set forth 

herein.

173. The Trustee is the legal title holder to all property of the Debtor and its Related 

Defendants. 

174. The following transfers were fraudulently effected by the Debtor or its Related 

Defendants or egregiously, or alternatively, without fraud but retained by the transferees set 

forth below under inequitable circumstances. 

Count

Debtor/

Related Defendant 

Transferor

Transferee / 

Defendant Property Transferred

93 Sovereign Zokaites Properties Encumbrance of 

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53

Tatarow Mortgage 

transferred to 

Defendant Zokaites 

Properties

94 Sovereign Gibson Gibson Transfer

95 Chance Wellington Santa Barbara 

Foreclosure Transfer

175. As the beneficiary of the transfers set forth herein, each Defendant knew or 

should have known that transfers at issue in each Count set forth herein were improper.

176. The recipients of each transfer set forth herein have been unjustly enriched to the 

detriment of the Debtor and its alter egos, and as a result, a constructive trust should be 

established against the transfers at issue and all proceeds, products and replacements of each of 

the subject transfers.

WHEREFORE, the Plaintiff, Robert C. Furr, as Chapter 7 Trustee of the Debtor, 

Chance & Anthem, LLC, respectfully requests this Court to enter a judgment against each 

respective Defendant, for imposition of an equitable lien to be established against all realty and 

personalty directly traceable from the transfers at issue herein and all proceeds of the their 

products, proceeds or replacements, for damages and all such other relief as this Court deems 

just and appropriate.

COUNT 96

AVOIDANCE OF POST-PETITION TRANSFERS UNDER 11 U.S.C. §549

The Trustee sues Defendants Siskind and CannaMed and alleges: 

177. The allegations contained in paragraphs 1 through 110 are restated in their 

entirety. 

178. The Post-Petition Forfeiture was executed on October 29, 2010, well after the 

Petition Date and, therefore, is ineffective and void as an improper and unauthorized postCase 19-01298-MAM Doc 95 Filed 11/01/19 Page 53 of 103
54

petition transfer of an interest of the Debtor in property of the estate under 11 U.S.C. §541 of the 

Bankruptcy Code. 

179. 11 U.S.C. §549 provides in pertinent part, as follows:

(a) Except as provided in subsection (b) or (c) of this section, the 

Trustee may avoid a transfer of property of the estate -

(1) that occurs after the commencement of the case; and 

(2) (A) that is authorized only under §303(t) or 542(c) of this 

title; or 

(B) that is not authorized under this title or by the Court. 

180. For the reasons stated above, the Trustee may avoid and recover post-petition 

transactions pursuant to 11 U.S.C. §549 and §550, such that any claims, rights or interests 

asserted by Siskind of CannaMEd in the Debtor’s interest in CannaMed pursuant to the PostPetition Forfeiture are ineffective and avoidable based upon the statutory prohibition on postpetition transfers. 

181. Accordingly, the Trustee seeks the entry of an order avoiding any improper postpetition transfer arising from the Post-Petition Forfeiture, preserving the avoided transfer or the 

value thereof for the benefit of the estate. 

WHEREFORE, the Plaintiff, Robert C. Furr, as Chapter 7 Trustee of the Debtor, 

Chance & Anthem, LLC, respectfully requests this Court to enter a judgment against each 

respective Defendant (i) determining and declaring that the Post-Petition Forfeiture is ineffective 

and/or avoidable as an unauthorized post-petition transfer; (ii) avoiding the Post-Petition 

Forfeiture, thus preserving the avoided transfer or the value thereof for the benefit of the 

bankruptcy estate pursuant to under 11 U.S.C. §549, §550 and §551 of the Bankruptcy Code; 

(iii) awarding to the Trustee the amount or value of Post-Petition Forfeiture, plus pre-judgment 

and post-judgment interest and costs ;and (iv) for such other further relief as the Court deems 

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 54 of 103
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necessary and appropriate. 

COUNT 97

ACTION SEEKING A PERMANENT

INJUNCTION AGAINST ALL DEFENDANTS

The Trustee sues all Defendants and alleges: 

182. The Trustee realleges Counts 1-96 above.

183. This is an action requesting the entry of a permanent injunction against 

Defendants and others pursuant to Fed. R. Civ. P. 65 as incorporated by Fed. R. Bankr. P. 7065.

184. Given the nature of the transfers and transactions at issue in this Complaint and 

the facts and circumstances surrounding such transfers as alleged above, it is necessary and 

appropriate for a permanent injunction to be issued against the Defendants, and all others in 

custody, possession or control of funds or other property that is the subject of the transfers and 

transactions at issue in this complaint, in order to fully protect the interests of the estate in regard

to recovering such transfers.

WHEREFORE, the Plaintiff, Robert C. Furr, as Chapter 7 Trustee of the Debtor, 

Chance & Anthem, LLC, demands the entry of an order and/or judgment against Defendants (i) 

imposing a permanent injunction against each Defendant, and all others in custody, possession or 

control of funds or other property that are the subject of the transfers at issue in this Complaint; 

and (ii) for any other relief the Court deems appropriate.

G. Reservation of Rights

185. The Trustee reserves his right to amend this Complaint to assert any additional 

claims for relief against the Defendants as may be warranted under the circumstances and as 

otherwise allowed by law.

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 55 of 103
56

Respectfully submitted this 1st day of November, 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

John H. Genovese, Esq.

Florida Bar No. 280852

jgenovese@gjb-law.com

Jesus M. Suarez, Esq.

Fla. Bar No. 60086

jsuarez@gjb-law.com

Barry P. Gruher, Esq. 

Florida Bar No. 960993

bgruher@gjb-law.com

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 1st day of 

November, 2019.

By: /s/ Jesus M. Suarez

 Jesus M. Suarez, Esq.

SERVICE LIST

Notice was served via CM/ECF upon:

Nancy B Colman on behalf of Defendant Robert Gibson

ncolman@baritzcolman.com, mizzo@baritzcolman.com

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

jf@womenatlawfl.com, way@womenatlawfl.com

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 56 of 103
57

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

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:

Jeffrey M. Siskind 

3465 Santa Barbara Drive

Wellington, Florida 33414 

CannaMed Pharmaceuticals, LLC

c/o Siskind Legal 

3465 Santa Barbara Dr 

Wellington, FL 33414 

Florida's Association of Community Banks and Credit Unions, Incorporated

c/o Jeffrey M Siskind, President 

3465 Santa Barbara Dr 

Wellington, FL 33414 

Second Siskind Family Trust

c/o Jeffrey Siskind, Trustee 

3465 Santa Barbara Dr 

Wellington, FL 33414 

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 57 of 103
58

Tanya Siskind

3465 Santa Barbara Dr 

Wellington, FL 33414 

Siskind Legal Services

c/o Jeffrey M Siskind, Managing Member 

3465 Santa Barbara Dr 

Wellington, FL 33414

Sovereign Gaming and Entertainment, LLC

c/o Jeffrey M Siskind 

3465 Santa Barbara Dr 

Wellington, FL 33414 

Sovereign Gaming and Entertainment, LLC

c/o Secretary of State

500 S. Bronough Street

Tallahassee, Florida 32399

Sovereign Gaming and Entertainment, LLC

c/o Secretary of State

2661 Executive Center Circle

Tallahassee, Florida 32301

Sympatico Equine Rescue, Inc.

c/o Jeffrey M Siskind, President 

3465 Santa Barbara Dr 

Wellington, FL 33414 

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 58 of 103
59

EXHIBIT “A”

(Periodic Reports)

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 59 of 103
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 60 of 103 Case 13-13096-MAM Doc 34 Filed 03/14/13 Page 1 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 61 of 103 Case 13-13096-MAM Doc 34 Filed 03/14/13 Page 2 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 62 of 103 Case 13-13096-MAM Doc 34 Filed 03/14/13 Page 3 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 63 of 103 Case 13-13096-MAM Doc 34 Filed 03/14/13 Page 4 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 64 of 103 Case 13-13096-MAM Doc 34 Filed 03/14/13 Page 5 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 65 of 103 Case 13-13096-MAM Doc 34 Filed 03/14/13 Page 6 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 66 of 103 Case 13-13096-MAM Doc 34 Filed 03/14/13 Page 7 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 67 of 103 Case 13-13096-MAM Doc 34 Filed 03/14/13 Page 8 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 68 of 103 Case 13-13096-MAM Doc 34 Filed 03/14/13 Page 9 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 69 of 103 Case 13-13096-MAM Doc 150 Filed 12/18/13 Page 1 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 70 of 103 Case 13-13096-MAM Doc 150 Filed 12/18/13 Page 2 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 71 of 103 Case 13-13096-MAM Doc 150 Filed 12/18/13 Page 3 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 72 of 103 Case 13-13096-MAM Doc 150 Filed 12/18/13 Page 4 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 73 of 103 Case 13-13096-MAM Doc 150 Filed 12/18/13 Page 5 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 74 of 103 Case 13-13096-MAM Doc 150 Filed 12/18/13 Page 6 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 75 of 103 Case 13-13096-MAM Doc 150 Filed 12/18/13 Page 7 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 76 of 103 Case 13-13096-MAM Doc 150 Filed 12/18/13 Page 8 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 77 of 103 Case 13-13096-MAM Doc 150 Filed 12/18/13 Page 9 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 78 of 103 Case 13-13096-MAM Doc 265 Filed 09/16/14 Page 1 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 79 of 103 Case 13-13096-MAM Doc 265 Filed 09/16/14 Page 2 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 80 of 103 Case 13-13096-MAM Doc 265 Filed 09/16/14 Page 3 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 81 of 103 Case 13-13096-MAM Doc 265 Filed 09/16/14 Page 4 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 82 of 103 Case 13-13096-MAM Doc 265 Filed 09/16/14 Page 5 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 83 of 103 Case 13-13096-MAM Doc 265 Filed 09/16/14 Page 6 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 84 of 103 Case 13-13096-MAM Doc 265 Filed 09/16/14 Page 7 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 85 of 103 Case 13-13096-MAM Doc 265 Filed 09/16/14 Page 8 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 86 of 103 Case 13-13096-MAM Doc 265 Filed 09/16/14 Page 9 of 9
B26 (Official Form 26) (12/08)

United States Bankruptcy Court

Southern District of Florida

In re Jeffrey Marc Siskind Case No. 13-13096

Debtor Chapter 11

PERIODIC REPORT REGARDING VALUE, OPERATIONS AND PROFITABILITY OF

ENTITIES IN WHICH THE ESTATE OF JEFFREY MARC SISKIND

HOLDS A SUBSTANTIAL OR CONTROLLING INTEREST

This is the report as of June 1, 2015 on the value, operations and profitability of those 

entities in which the estate holds a substantial or controlling interest, as required by Bankruptcy 

Rule 2015.3. The estate of Jeffrey Marc Siskind holds a substantial or controlling interest in the 

following entities:

Name of Entity Interest of the Estate Tab #

Consolidated Engineering Co., Inc. 80% 1

JurisMortgage, LLC 100% 2

Aviatat, LLC 100% 3

This periodic report (the "Periodic Report") contains separate reports ("Entity Reports") on the 

value, operations, and profitability of each entity listed above.

Each Entity Report shall consist of three exhibits. Exhibit A contains a valuation estimate 

for the entity as of a date not more than two years prior to the date of this report. It also contains 

a description of the valuation method used. Exhibit B contains a balance sheet, a statement of 

income (loss), a statement of cash flows, and a statement of changes in shareholders' or partners' 

equity (deficit) for the period covered by the Entity Report, along with summarized footnotes. 

Exhibit C contains a description of the entity's business operations.

THIS REPORT MUST BE SIGNED BY A REPRESENTATIVE OF THE TRUSTEE OR 

DEBTOR IN POSSESSION.

The undersigned, having reviewed the above listing of entities in which the estate of [Debtor] 

holds a substantial or controlling interest, and being familiar with the Debtor's financial affairs, 

verifies under the penalty of perjury that the listing is complete, accurate and truthful to the best 

of his/her knowledge.

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 87 of 103 Case 13-13096-PGH Doc 406 Filed 06/02/15 Page 1 of 9
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 88 of 103 Case 13-13096-PGH Doc 406 Filed 06/02/15 Page 2 of 9
B26 (Official Form 26) (12/08) - Cont. 3

Exhibit A

Valuation Estimate

Consolidated Engineering Co., Inc., JurisMortgage, LLC and Aviatat, LLC

[Provide a statement of the entity's value and the value of the estate's interest in the entity, 

including a description of the basis for the valuation, the date of the valuation and the valuation 

method used. This valuation must be no more than two years old. Indicate the source of this 

information.]

Tab 1 Value Estate Interest

$800,000 $640,000

Valuation basis is most recent sale of 5% for $40,000

Tab 2 Value Estate Interest

$50,000 $50,000

Valuation basis is Debtor in Possession’s assessment of value

Tab 3 Value Estate Interest

$20,000 $20,000

Valuation basis is Debtor in Possession’s assessment of value

Source: Debtor in Possession

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 89 of 103 Case 13-13096-PGH Doc 406 Filed 06/02/15 Page 3 of 9
B26 (Official Form 26) (12/08) - Cont. 4

Exhibit B

Financial Statements

Consolidated Engineering Co., Inc., JurisMortgage, LLC and Aviatat, LLC

Tab 1 No income or expenses during this reporting period

Tab 2 No separate records are maintained; income and expenses appear on Debtor’s 

monthly reports

Tab 3 No income or expenses during this reporting period

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 90 of 103 Case 13-13096-PGH Doc 406 Filed 06/02/15 Page 4 of 9
B26 (Official Form 26) (12/08) - Cont. 5

Exhibit B-1

Balance Sheet

Consolidated Engineering Co., Inc., JurisMortgage, LLC and Aviatat, LLC

As of June 2, 2015

[Provide a balance sheet dated as of the end of the most recent six-month period of the current 

fiscal year and as of the end of the preceding fiscal year. Indicate the source of this information.]

Tab 1 Assets Liabilities

Tab 2 - 0 - - 0 -

Tab 3 $50,000 - 0 –

Source: Debtor in Possession

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B26 (Official Form 26) (12/08) - Cont. 6

Exhibit B-2

Statement of Income (Loss)

Consolidated Engineering Co., Inc., JurisMortgage, LLC and Aviatat, LLC

Period ending June 1, 2015

[Provide a statement of income (loss) for the following periods:

(i) For the initial report:

a. the period between the end of the preceding fiscal year and the end of the most 

recent six-month period of the current fiscal year; and

b. the prior fiscal year.

(ii) For subsequent reports, since the closing date of the last report.

Indicate the source of this information.]

Tab 1 No income or operating expenses during current period

Tab 2 Advertising costs appear on Debtor’s monthly reports

Tab 3 No income or operating expenses during current period

Source: Debtor in Possession

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B26 (Official Form 26) (12/08) - Cont. 7

Exhibit B-3

Statement of Cash Flows

Consolidated Engineering Co., Inc., JurisMortgage, LLC and Aviatat, LLC

For the period ending June 1, 2015

[Provide a statement of changes in cash flows for the following periods:

(i) For the initial report:

a. the period between the end of the preceding fiscal year and the end of the most 

recent six-month period of the current fiscal year; and

b. the prior fiscal year.

(ii) For subsequent reports, since the closing date of the last report.

Indicate the source of this information.]

Tab 1 No income or operating expenses during current period

Tab 2 Advertising costs appear on Debtor’s monthly reports

Tab 3 No income or operating expenses during current period

Source: Debtor in Possession

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 93 of 103 Case 13-13096-PGH Doc 406 Filed 06/02/15 Page 7 of 9
B26 (Official Form 26) (12/08) - Cont. 8

Exhibit B-4

Statement of Changes in Shareholders'/Partners' Equity (Deficit)

Consolidated Engineering Co., Inc., JurisMortgage, LLC and Aviatat, LLC

Period ending June 1, 2015

[Provide a statement of changes in shareholders'/partners equity (deficit) for the following 

periods:

(i) For the initial report:

a. the period between the end of the preceding fiscal year and the end of the most 

recent six-month period of the current fiscal year; and

b. the prior fiscal year.

(ii) For subsequent reports, since the closing date of the last report.

Indicate the source of this information.]

Tab 1 No changes during this period

Tab 2 No changes during this period

Tab 3 No changes during this period

Source: Debtor in Possession

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 94 of 103 Case 13-13096-PGH Doc 406 Filed 06/02/15 Page 8 of 9
B26 (Official Form 26) (12/08) - Cont. 9

Exhibit C

Description of Operations

Consolidated Engineering Co., Inc., JurisMortgage, LLC and Aviatat, LLC

[Describe the nature and extent of the estate's interest in the entity.

Describe the business conducted and intended to be conducted by the entity, focusing on the 

entity's dominant business segment(s). Indicate the source of this information.]

Tab 1 80% owned by Debtor in Possession

Commercial construction company founded 1911

Dormant

Tab 2 100% owned by Debtor in Possession

Law office support services consisting of mortgage loan training program

Tab 3 100% owned by Debtor in Possession

Entity possesses lien interests in aircraft

Source: Debtor in Possession

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 95 of 103 Case 13-13096-PGH Doc 406 Filed 06/02/15 Page 9 of 9
60

EXHIBIT “B”

(Correspondence dated 10/29/2019)

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 96 of 103
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 97 of 103
Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 98 of 103
61

EXHIBIT “C”

(Siskind Cash Transfers)

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 99 of 103
Detail

Chance & Anthem, LLC

Detailed of Disbursements - Cash & Withdrawals

Bank Entity Type Date Received From/ Payee

Disbursement/ 

Debit

Chase 1866 Chance & Anthem ATM Withdrawal 10/13/15 Cash 500.00

Chase 1866 Chance & Anthem ATM Withdrawal 10/30/15 Cash 500.00

SunTrust 6688 Chance & Anthem Withdrawal 11/09/15 Cash 2,500.00

SunTrust 6688 Chance & Anthem Withdrawal 11/13/15 Cash 5,000.00

SunTrust 6688 Chance & Anthem Withdrawal 11/23/15 Cash 5,000.00

Chase 1866 Chance & Anthem ATM Withdrawal 11/25/15 Cash 500.00

SunTrust 6688 Chance & Anthem Withdrawal 11/27/15 Cash 40,000.00

SunTrust 6688 Chance & Anthem Withdrawal 12/02/15 Cash 2,000.00

SunTrust 6688 Chance & Anthem Withdrawal 12/02/15 Cash 5,000.00

SunTrust 6688 Chance & Anthem Withdrawal 12/07/15 Cash 1,000.00

Chase 1866 Chance & Anthem ATM Withdrawal 12/11/15 Cash 100.00

SunTrust 6688 Chance & Anthem Withdrawal 12/11/15 Cash 5,000.00

SunTrust 6688 Chance & Anthem Withdrawal 12/14/15 Cash 2,000.00

SunTrust 6688 Chance & Anthem Withdrawal 12/16/15 Cash 5,000.00

SunTrust 6688 Chance & Anthem Withdrawal 12/21/15 Cash 2,000.00

SunTrust 6688 Chance & Anthem Withdrawal 12/31/15 Cash 5,000.00

SunTrust 6688 Chance & Anthem Withdrawal 01/04/16 Cash 2,500.00

SunTrust 6688 Chance & Anthem Withdrawal 01/19/16 Cash 2,000.00

Chase 1866 Chance & Anthem ATM Withdrawal 03/07/16 Cash 300.00

Chase 1866 Chance & Anthem ATM Withdrawal 03/22/16 Cash 2,500.00

Chase 1866 Chance & Anthem ATM Withdrawal 03/23/16 Cash 63.50

Chase 1866 Chance & Anthem ATM Withdrawal 03/24/16 Cash 200.00

Chase 1866 Chance & Anthem Withdrawal 03/25/16 Other Withdrawal 2,000.00

Chase 1866 Chance & Anthem Withdrawal 04/04/16 Other Withdrawal 500.00

Chase 1866 Chance & Anthem ATM Withdrawal 04/21/16 Cash 20.00

SunTrust 6688 Chance & Anthem Withdrawal 04/22/16 Cash 1,100.00

Chase 1866 Chance & Anthem Withdrawal 06/01/16 Other Withdrawal 200.00

Chase 1866 Chance & Anthem Withdrawal 06/15/16 Other Withdrawal 750.00

Chase 1866 Chance & Anthem Withdrawal 06/24/16 Other Withdrawal 750.00

Chase 1866 Chance & Anthem ATM Withdrawal 07/08/16 Cash 20.00

Chase 1866 Chance & Anthem Withdrawal 07/29/16 Other Withdrawal 600.00

Chase 1866 Chance & Anthem Withdrawal 08/08/16 Other Withdrawal 300.00

Chase 1866 Chance & Anthem Withdrawal 08/26/16 Other Withdrawal 3,300.00

SunTrust 6688 Chance & Anthem Withdrawal 08/26/16 Cash 900.00

SunTrust 6688 Chance & Anthem Withdrawal 08/30/16 Cash 300.00

Chase 1866 Chance & Anthem Withdrawal 09/02/16 Other Withdrawal 40.00

Chase 1866 Chance & Anthem Withdrawal 09/06/16 Other Withdrawal 3,265.00

Chase 1866 Chance & Anthem Withdrawal 09/06/16 Other Withdrawal 500.00

Chase 1866 Chance & Anthem Withdrawal 09/09/16 Other Withdrawal 300.00

Chase 1866 Chance & Anthem Withdrawal 09/09/16 Other Withdrawal 4,000.00

Chase 1866 Chance & Anthem Withdrawal 09/12/16 Other Withdrawal 40.00

Chase 1866 Chance & Anthem Withdrawal 09/14/16 Other Withdrawal 250.00

Chase 1866 Chance & Anthem ATM Withdrawal 09/16/16 Cash 200.00

Chase 1866 Chance & Anthem ATM Withdrawal 10/21/16 Cash 400.00

Chase 1866 Chance & Anthem ATM Withdrawal 10/24/16 Cash 500.00

Chase 1866 Chance & Anthem Withdrawal 11/01/16 Other Withdrawal 200.00

Chase 1866 Chance & Anthem ATM Withdrawal 11/28/16 Cash 50.00

Chase 1866 Chance & Anthem ATM Withdrawal 01/27/17 Cash 20.00

Chase 1866 Chance & Anthem ATM Withdrawal 01/30/17 Cash 100.00

Chase 1866 Chance & Anthem ATM Withdrawal 02/27/17 Cash 100.00

Chase 1866 Chance & Anthem Withdrawal 03/07/17 Other Withdrawal 75.00

GlassRatner Advisory & Capital Group, LLC Page 1 of 2

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 100 of 103
Detail

Bank Entity Type Date Received From/ Payee

Disbursement/ 

Debit

Chase 1866 Chance & Anthem ATM Withdrawal 03/30/17 Cash 40.00

Chase 1866 Chance & Anthem ATM Withdrawal 05/01/17 Cash 200.00

Chase 1866 Chance & Anthem ATM Withdrawal 05/04/17 Cash 60.00

Chase 1866 Chance & Anthem Withdrawal 05/15/17 Other Withdrawal 20.00

Chase 1866 Chance & Anthem ATM Withdrawal 05/24/17 Cash 180.00

Chase 1866 Chance & Anthem ATM Withdrawal 06/19/17 Cash 100.00

Chase 1866 Chance & Anthem ATM Withdrawal 07/26/17 Cash 100.00

Chase 1866 Chance & Anthem ATM Withdrawal 07/28/17 Cash 20.00

Chase 1866 Chance & Anthem ATM Withdrawal 08/04/17 Cash 500.00

Chase 1866 Chance & Anthem Withdrawal 10/03/17 Other Withdrawal 80.00

Chase 1866 Chance & Anthem ATM Withdrawal 10/04/17 Cash 100.00

Chase 1866 Chance & Anthem Withdrawal 10/05/17 Other Withdrawal 400.00

Chase 1866 Chance & Anthem Card Purchase 10/10/17 Walmart 102.68

Chase 1866 Chance & Anthem Card Purchase 10/10/17 Walmart 112.05

Chase 1866 Chance & Anthem Card Purchase 10/10/17 Walmart 102.98

Chase 1866 Chance & Anthem Card Purchase 10/10/17 Walmart 103.57

Chase 1866 Chance & Anthem Card Purchase 10/10/17 Walmart 107.46

Chase 1866 Chance & Anthem Card Purchase 10/10/17 Walmart 103.74

Chase 1866 Chance & Anthem Card Purchase 10/11/17 Walmart 101.80

Chase 1866 Chance & Anthem Withdrawal 11/30/17 Other Withdrawal 50.00

Chase 1866 Chance & Anthem Card Purchase 12/05/17 Walmart 110.57

Chase 1866 Chance & Anthem ATM Withdrawal 12/05/17 Cash 500.00

Chase 1866 Chance & Anthem ATM Withdrawal 12/14/17 Cash 500.00

Chase 1866 Chance & Anthem ATM Withdrawal 12/15/17 Cash 500.00

Chase 1866 Chance & Anthem Withdrawal 12/16/17 Other Withdrawal 250.00

Chase 1866 Chance & Anthem Card Purchase 12/18/17 Walmart 100.98

Chase 1866 Chance & Anthem Card Purchase 12/18/17 Walmart 104.97

Chase 1866 Chance & Anthem Withdrawal 12/23/17 Other Withdrawal 300.00

Chase 1866 Chance & Anthem Card Purchase 01/02/18 Walmart 141.77

Chase 1866 Chance & Anthem ATM Withdrawal 01/02/18 Cash 200.00

Chase 1866 Chance & Anthem ATM Withdrawal 01/02/18 Cash 300.00

Chase 1866 Chance & Anthem ATM Withdrawal 01/04/18 Cash 200.00

Chase 1866 Chance & Anthem Card Purchase 01/16/18 Walmart 135.94

Chase 1866 Chance & Anthem Card Purchase 01/16/18 Walmart 115.40

Chase 1866 Chance & Anthem ATM Withdrawal 01/16/18 Cash 220.00

Chase 1866 Chance & Anthem ATM Withdrawal 01/22/18 Cash 100.00

Chase 1866 Chance & Anthem ATM Withdrawal 01/22/18 Cash 200.00

Chase 1866 Chance & Anthem Card Purchase 02/26/18 Walmart 101.05

Chase 1866 Chance & Anthem Withdrawal 03/06/18 Other Withdrawal 20.00

Chase 1866 Chance & Anthem Withdrawal 03/14/18 Other Withdrawal 200.00

Chase 1866 Chance & Anthem Withdrawal 03/22/18 Other Withdrawal 2,000.00

Chase 1866 Chance & Anthem Card Purchase 03/27/18 Walmart 140.97

Chase 1866 Chance & Anthem ATM Withdrawal 05/12/16 Cash 500.00

Chase 1866 Chance & Anthem ATM Withdrawal 05/13/16 Cash 600.00

Chase 1866 Chance & Anthem Withdrawal 05/31/16 Other Withdrawal 200.00

Cash & Withdrawal Total $ 119,769.43

GlassRatner Advisory & Capital Group, LLC Page 2 of 2

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 101 of 103
62

EXHIBIT “D”

(Tanya Siskind Cash Transfers)

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 102 of 103
Chance & Anthem, LLC

Summary of Transfers to Tanya Siskind

Source: Bank Statements, deposit detail and canceled checks

Bank Entity Type Date Check No. Received From/ Payee

 D

Chase 1866 Chance & Anthem Check 03/01/16 1127 Tanya Siskind 

Chase 1866 Chance & Anthem Check 04/04/16 1151 Tanya Siskind 

Chase 1866 Chance & Anthem Check 06/29/16 1210 Tanya Siskind 

Chase 1866 Chance & Anthem Check 11/01/16 1315 Tanya L. Siskind Chase 1866 Chance & Anthem Check 03/29/18 1361 Tanya Siskind 

TOTAL $ 

GlassRatner Advisory & Capital Group, LLC 

Case 19-01298-MAM Doc 95 Filed 11/01/19 Page 103 of 103