UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

www.flsb.uscourts.gov 

In re: 

CHANCE & ANTHEM, LLC, 

Debtor. 

------------~/ 

ROBERT C. FURR not individually 

but 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 and as Trustee of the, 

SECOND SISKIND FAMILY TRUST, FRANK 

ZOKAITES, individually, 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, 

SYMPA TICO EQUINE RESCUE, INC, a 

Florida Corporation, WELLINGTON 3445, LP, a 

Florida Limited Partnership, ZOKAITES 

PROPERTIES, LP, a Pennsylvania Limited 

Partnership, and ROBERT GIBSON, individually 

Defendants 

_______________ ___,/ 

Case No. 18-16248-BKC-MAM Chapter 7 

ADV. NO. 19-01298-MAM 

~LED-USBC,FLS--tl!'B '19 SEP 23 PM3:04 

RELIEF DEFENDANT'S MOTION FOR PROTECTIVE ORDER 

Robert Gibson, pro se, a Relief Defendant in this matter hereby files this Motion for 

Protective Order seeking relief from three (3) notices of taking deposition, none of which is 

served pursuant to the rules and which make untimely and unauthorized demands, and in support 
" 

thereof states as follows: 

1. By this Motion, Relief Defendant Robert Gibson ("Movant") requests the entry of an Order 

protecting Relief Defendant from unauthorized, untimely and improperly served notices of taking 

deposition from co-defendants in this adversary proceeding concerning the estate of the Debtor, 

Chance & Anthem, LLC. 

2. On January 29, 2018 (the "Petition Date"), Debtor filed a voluntary petition for relief under 

Chapter 7, Title 11 of the United States Code (the "Bankruptcy Code"). [Main Case, ECF No. 1]. 

Shortly thereafter, the Trustee was appointed as the duly acting Chapter 7 trustee for the Debtor's 

bankruptcy estate. 

3. On August 06, 2019, the Trustee filed an adversary complaint (the "Complaint") against 

numerous Defendants, including Movant, to among other things, avoid and recover certain 

fraudulent transfers made by the Debtors to Defendants pursuant to Sections 544, 548 and 550 of 

Title 11 of the United States Code and Section 726 of the Florida Statutes. 

4. Movant is, as of yet, unrepresented but intends to retain counsel and Plaintiff has agreed to 

extend until Monday September 30, 2019 the time in which Relief Defendant is to retain counsel 

and/or file a response to the Complaint. 

5. As contemplated by Local Rule Number 9076-1 Movant is not a Registered User of 

CM/ECF and has not otherwise waived his right to receive notice by first class mail nor consented 

to receive notice electronically via the CM/ECF generated NEF, as otherwise allowed by Local 

Rule Number 9076-l(A). 

6. Further, Movant has already been subjected to four and one-half (4 1⁄2) hours of 

interrogation during deposition in addition to being examined by the parties during a plenary two 

(2) day circuit court trial concerning the only subject matter for which Movant could reasonably be 

informative. 

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7. Additionally, in post-trial discovery requests by the parties, the circuit court found that 

Movant' s additional testimony could only be elicited by the parties with same day agreement for 

depositions of the parties to be taken by Movant. 

WHEREFORE, Relief Defendant Robert Gibson requests entry of an Order protecting or 

limiting the extent of interrogation to which Movant may be subjected and requiring the parties to 

obey the rules concerning reasonable notice by US Mail in their attempts to seek testimony of 

Movant and further ordering the coordinated appearance of the parties to be interrogated by 

movant, and granting such other and further relief as the Court deems just and proper 

Respectfully submitted this 23rd day of September.2019 

(~--

Robert Gibson 

1709 22nd Ave North 

Lake Worth Beach, FL 33460 

561-868-2100 

intelexigent@gmail.com 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on this 23th day of September 2019, a copy of the foregoing 

was served upon all parties registered to receive electronic notification in this case via email 

and/or via U.S. Mail as indicated on the Service List below. 

Robert Gibson 

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SERVICE LIST 

Nonce will be served via email u,pon; 

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, jmsesg500@gmail.com 

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

Unions, Incorporated 

jeffsiskind@msn.com, jmsesg500@gmail.com 

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

jeffsiskind@msn.com, jmsesg500@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, jmsesg500@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, jmsesg500@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 

Notice will be served via u.s. Mail H11Qn; 

Second Siskind Family Trust 

c/o Tanya Siskind, Trustee 

3465 Santa Barbara Drive 

Wellington, Florida 33414 

Frank Zokaites 

375 Golfside Drive 

Wexford, PA 15090 

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Sovereign Gaming and Entertainment, LLC 

c/o Jeffrey M. Siskind, on behalf of William Siskind, deceased 

3465 Santa Barbara Drive 

Wellington, Florida 33414 

Zokaites Properties, LP 

c/o Frank Zokaites, for General Partner, Zokaites Contracting, Inc. 

375 Golfside Drive 

Wexford, PA 15090 

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