UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

www.flsb.uscourts.gov

In re: 

CHANCE & ANTHEM, LLC, CASE NO. 18-16248-BKC-MAM 

Debtor. Chapter 7 

____________________________________/

ROBERT FURR,

Plaintiff,

v. ADV. NO. 19-01298-MAM

ROBERT GIBSON, et al.,

Defendants.

____________________________________/

 

MOTION TO COMPEL THE CHAPTER 7 TRUSTEE TO PROVIDE

SUFFICIENT REPONSES TO INTERROGATORIES AND FOR SANCTIONS

COMES NOW Jeffrey M. Siskind, by and through undersigned counsel, and files this Motion 

to Compel the Chapter 7 Trustee to Provide Sufficient Responses to Interrogatories [propounded by 

Defendant] and for Sanctions, and states:

1. On September 17, 2019, Defendant served twenty-five (25) interrogatories upon the 

Chapter 7 Trustee, Robert Furr (hereinafter “Creditor’s Representative”).

2. On October 17, 2019 (the deadline date for responses), the Creditor’s Representative 

requested a two-week extension of time to file responses, which Movant approved, and the Creditors’

Representative uploaded an “agreed motion” that same day.

3. On November 1, 2019, the Creditor’s Representative provided its responses after the

two-week agreed deadline expired. See attached “Exhibit A.” Said responses, consisting mostly of

impertinent objections, are wholly insufficient and were provided purely for purposes of delay.

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4. All but the following two responses were blanket objections; (1) the Creditors’ 

Representative withdrew its fraudulent claim that Tanya Siskind served as trustee of the Second 

Siskind Family Trust, and (2) corrected its claim as to its purported ownership of nonvoting units of 

CannaMED Pharmaceuticals, LLC.1 The Creditors Representative’s false claim as to Tanya was 

without any basis in fact and was made and fed to local media solely to attempt to embarrass her.

5. The Creditors’ Representative’s withdrawn claim as to Tanya, although necessary and

appropriate, is particularly disturbing because its immediate withdrawal demonstrates that it was of 

whole cloth to begin with and was alleged without sufficient basis. The undersigned submits that the 

Creditors’ Representative’s false claim against Tanya was also nothing other than a ‘bullying’ tactic 

which is routinely used by this particular Creditors’ Representative and its counsel in other cases to 

intimidate stakeholders and to attempt to obtain more favorable settlements used chiefly to pay the 

Creditors’ Representative’s own fees, and that current and future defendants in this case should be 

alerted to the likelihood that the Creditors’ Representative will continue to make similar unfounded 

and bad faith assertions for said purposes.

6. The failure to respond substantively to each of the other interrogatories demonstrates

that the Creditors’ Representative is either unable or unwilling to provide a factual basis for its false 

allegations concerning any alleged “alter ego” and/or “scheme” orchestrated by the Debtor, and that 

these two phrases were only utilized by the Creditors’ Representative in an effort to discredit and 

attack the credibility and integrity of Defendants.

7. While its failure to sufficiently respond to the undersigned’s interrogatories, each of 

which was designed to ‘flesh out’ whatever support that the Creditors’ Representative believes it has 

1 The bankruptcy estate’s interest in CannaMED Pharmaceuticals, LLC (“CannaMED”) was forfeited as a result of the 

Creditors’ Representative’s violation of disparagement protections contained within CannaMED’s governing documents. 

The forfeiture was for zero consideration as a result of the Creditors’ Representative’s own published valuation but may 

have actually caused substantial losses to creditors.

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to defend its false and outrageous allegations, the Creditor’s Representative has already employed 

other similar tactics obviously meant to wrongfully influence the factfinder, other defendants and the 

media; to wit, its attempt to circumvent evidentiary proof by seeking the use of ‘summaries’ to obtain

preliminary injunctive relief and its continuing “discovery is still ongoing” disclosure (that in essence 

means that its newest amended complaint is disingenuous, because it may yet need to file another 

one) are two such transparent measures. For these reasons, current and future defendants in this and 

any related case(s) must always regard this Creditors’ Representative’s statements and claims as 

suspect.

8. As to the Creditors’ Representative’s willful failure to respond substantively to the 

undersigned’s interrogatories, Defendants are unable to defend against its allegations unless the 

interrogatories are answered in good faith, and are thus entitled to full and complete responses.

9. Defendants reached out to the Creditors’ Representative’s counsel in an effort to 

obtain compliance in meeting condition(s) precedent to filing this motion, but were unsuccessful

absent meeting to confer which Defendant is willing to do if the Creditors’ Representative will do so 

in good faith, but Defendant doubts that any meaningful resolution will be forthcoming therefrom.

10. It should be noted that this behavior on the part of the Creditors’ Representative is in 

addition to the questionable manner in which it became involved in the Debtor’s bankruptcy case.

11. The Creditors’ Representative’s late objections should be disallowed, not only 

because they are disingenuous, but also as a sanction because they were not timely provided.

WHEREFORE, Defendant requests that the Court furnish an order compelling the Creditors’ 

Representative to respond fully to its interrogatories and for imposition of sanctions disallowing the

Creditors’ Representative’s objections, and for such other and further relief as appropriate.

Dated this 4

th

day of November, 2019

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

_______/s/ Jeffrey M. Siskind_______

Jeffrey M. Siskind, Esq. FBN 138746

- Offices -

113 N. Monroe Street, 1st Floor

Tallassee, Florida 32301

- And -

3465 Santa Barbara Drive

Wellington, Florida 33414

TELEPHONE (561) 791-9565

FACSIMILE (561) 791-9581

Email: jeffsiskind@msn.com

CERTIFICATE OF SERVICE

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

November 4, 2019 upon all creditors and parties in interest registered to receive electronic 

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

U.S. Mail or Personal Service of Process as reflected on the Service List below. 

_______/s/ Jeffrey M. Siskind_______

Jeffrey M. Siskind, Esq. FBN 138746

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SERVICE LIST:

19-01298-MAM Notice will be electronically mailed to:

Samantha T Haimo on behalf of Defendant Wellington 3445, LP

sth@womenatlawfl.com, way@swlawyers.law

Jeffrey M Siskind on behalf of Defendant CannaMed Pharmaceuticals, LLC

jeffsiskind@msn.com, jmsesq500@gmail.com

Jeffrey M Siskind on behalf of Defendant Florida's Association of Community Banks and Credit 

Unions, Incorporated

jeffsiskind@msn.com, jmsesq500@gmail.com

Jeffrey M Siskind on behalf of Defendant OB Real Estate Holdings 1732, LLC

jeffsiskind@msn.com, jmsesq500@gmail.com

Jeffrey M Siskind on behalf of Defendant Siskind Legal Services

jeffsiskind@msn.com, jmsesq500@gmail.com

Jeffrey M Siskind on behalf of Defendant Sympatico Equine Rescue, Inc.

jeffsiskind@msn.com, jmsesq500@gmail.com

Jeffrey M Siskind on behalf of Defendant Jeffrey M Siskind

jeffsiskind@msn.com, jmsesq500@gmail.com

Jeffrey M Siskind on behalf of Defendant Tanya Siskind

jeffsiskind@msn.com, jmsesq500@gmail.com

Jesus M Suarez on behalf of Plaintiff Robert C Furr

jsuarez@gjb-law.com, gjbecf@gjb-law.com;chopkins@gjb-law.com;jzamora@gjblaw.com;ecastellanos@gjb-law.com;gjbecf@ecf.courtdrive.com

Nancy Coleman on behalf of Robert Gibson

ncoleman@bartizcolman.com

Robert Gibson, intelexigent@gmail.com

19-01298-MAM Notice was sent by U.S. Mail to:

Robert Gibson

1709 22nd Avenue North

Lake Worth, FL 33460

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EXHIBIT A

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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished 

via E-mail 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 E-Mail upon: 

Jeffrey M Siskind jeffsiskind@msn.com, jmsesq500@gmail.com

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 

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 

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 

Notice will be served via U.S. Mail upon:

Jeffrey M. Siskind 

3465 Santa Barbara Drive 

Wellington, Florida 33414 

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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 

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 

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