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EXPERT REPORT 

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UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

CASE NO.: 19-01298-MAM 

In re: 

CHANCE & ANTHEM, LLC, 

 Debtor. 

______________________________________/ 

ROBERT FURR, as Chapter 7 Trustee of the Debtor, 

CHANCE & ANTHEM, LLC, 

 

EXPERT REPORT OF ALAN R. BARBEE, CPA/ABV 

GLASSRATNER ADVISORY & CAPITAL GROUP, LLC

APRIL 20, 2020 

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Contents

I. Introduction and Summary of Conclusion .......................................................................... 1

II. About the Litigation ............................................................................................................ 3

III. Scope of Review and Limiting Conditions .......................................................................... 4

IV. Relevant History of the Debtor ........................................................................................... 4

V. The National, State, and Local Economy ........................................................................... 9

VI. Financial Analysis of Chance & the Related Entities .......................................................... 9

VII. Financial Tracing Analysis and Evaluation of Corporate Formalities .................................16

VIII. Valuation Analysis ............................................................................................................21

IX. Solvency Analysis of Chance & the Related Entities ........................................................28

X. Summary Conclusion .......................................................................................................31

XI. Alan Barbee Professional Background .............................................................................31

Appendix 1 ................................................................................................................................33

Documents Considered .............................................................................................................33

Appendix 2 ................................................................................................................................34

Barbee CV and Prior Testimony ................................................................................................34

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I. INTRODUCTION AND SUMMARY OF CONCLUSION

Introduction 

1. GlassRatner Advisory & Capital Group, LLC (“GlassRatner”) was retained on July 20, 2018 

by Robert Furr (the “Trustee”), the Chapter 7 Trustee of Chance & Anthem, LLC (“Chance” 

or the “Debtor”), to provide forensic accounting and litigation support services in connection 

with the Debtors Bankruptcy Case. 

2. In connection with the litigation described below in Section II, the Trustee requested that 

we evaluate the financial condition of the Debtor during the four-year period preceding the 

bankruptcy filing date of January 29, 2018 (the “Petition Date”). We therefore evaluated the 

financial condition of the Debtor as of December 31 each year from 2014 through 2017 (the 

“Valuation Dates”) and opine on whether the Debtor was solvent or insolvent as of each of 

the Valuation Dates. 

3. Additionally, in connection with the litigation described below in Section II, the Trustee 

requested that we evaluate the consolidated financial condition of Chance combined with 

the following related entities during the four year period preceding the Petition Date: 

Florida’s Association of Community Banks and Credit Unions, Inc. (“FLACC”), Siskind Legal 

Services, LLC (“Siskind Legal”), Sovereign Gaming & Entertainment, LLC (“Sovereign”), 

and Sympatico Equine Rescue, Inc. (“Sympatico”) (collectively referred to as the “Related 

Entities”). We therefore evaluated the consolidated financial condition of Chance and the 

Related Entities as of the Valuation Dates and opine on whether the they were collectively 

solvent or insolvent as of each of the Valuation Dates. 

4. In order to perform this engagement, I relied on other GlassRatner professionals with 

extensive experience in financial analysis, solvency analysis, economic damages, business 

valuation and forensic accounting, all of whom worked under my direct supervision and 

control. I have relied on the work of this team to support my analysis of information related 

to this matter, and references to “our” and “we” recognize this reliance. Any differences in 

the amounts calculated or referenced in this report to the underlying supporting 

documentation are due to rounding. 

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5. GlassRatner’s fees for professional services provided are based on hours actually 

expended by each assigned staff member extended by the standard hourly billing rate for 

that individual. The hourly billing rates for professional staff working on this matter range 

from $150 to $515 for staff and my time has been billed at $450 per hour. 

6. Our analysis was performed solely for the purpose stated above. This analysis is not 

intended for general circulation or publication, nor is it to be referred to or used for any 

purpose other than that outlined above, or without our prior written consent in each specific 

instance. 

Summary of Conclusions 

7. Regarding the Debtor as a stand-alone entity, it is my opinion that: 

 The Debtor was insolvent based on the balance sheet test as of December 31, 2014 and 

remained insolvent as of each Valuation Date through the Petition Date, and 

 The Debtor was not adequately capitalized as of December 31, 2014 and remained 

inadequately capitalized as of each Valuation Date through the Petition Date, and 

 The Debtor was not able to meet its debt obligations as they became due, beginning no 

later than December 31, 2014 and continued to not be able to meet its debt obligations as 

they became due as of each of the Valuation Dates and through the Petition Date. 

8. Regarding the consolidated financial condition of Chance and the Related Entities, it is my 

opinion that: 

 Chance and the Related Entities were insolvent based on the balance sheet test as of 

December 31, 2014 and remained insolvent as of each of the Valuation Dates and through 

the Petition Date, and 

 Chance and the Related Entities were not adequately capitalized as of December 31, 2014 

and remained inadequately capitalized as of each of the Valuation Dates and through the 

Petition Date, 

 Chance and the Related entities generally did not follow corporate formalities as 

summarized at paragraph 59, and 

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 Chance and the Related Entities were not able to meet their debt obligations as they 

became due, beginning no later than December 31, 2014 and continued to not be able to 

meet their debt obligations as they became due as of each of the Valuation Dates and 

through the Petition Date. 

II. ABOUT THE LITIGATION

9. This report has been prepared in connection with the amended adversary complaint filed by 

the Trustee, which is generally described below. 

10. On August 6, 2019, the Trustee filed an Adversary Complaint To Avoid and To Recover 

Fraudulent Transfers, For Turnover, For An Accounting, Alter-Ego, Substantive 

Consolidation, Injunctive Relief and For Other Relief (Case No.: 18-16248-BKC-MAM). On 

November 1, 2019, the Trustee filed the First Amended Adversary Complaint to Avoid and 

to Recover Fraudulent Transfers, For Turnover, For An Accounting, Substantive 

Consolidation, Injunctive Relief and for Other Relief (the “Amended Complaint” or “Amended 

Adversary Complaint”). 

11. The Amended Complaint was filed against the following Defendants: 

 Jeffrey Siskind – Individually 

 Jeffrey Siskind doing business as Siskind Legal Services 

 Tanya Siskind – Individually 

 Jeffrey Siskind as Trustee of the Second Siskind Family Trust 

 CannaMED Pharmaceuticals, LLC 

 OB Real Estate Holdings 1732, LLC 

 Siskind Legal Services, LLC 

 Sovereign Gaming & Entertainment, LLC 

 Florida’s Association of Community Banks and Credit Unions, Inc. 

 Sympatico Equine Rescue, Inc. 

 Wellington 3445, LP 

 Zokaites Properties, LP 

 Robert Gibson – Individually 

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12. Additionally, the Trustee filed a four separate Adversary Complaints To Avoid And Recover 

Avoidable Transfers And For Other Relief in connection with fraudulent transfers disbursed 

to: 1) Advanced Avionics, LLC (the “Advanced Avionics Complaint”), 2) Air Center, Inc. (the 

“Air Center Complaint”), 3) New Country Motor Cars of Palm Beach, LLC d/b/a Mercedes 

Benz of Palm Beach (the “New Country Complaint”), and 4) Ocean Reef Club, Inc. (the 

“Ocean Reef Complaint”). 

III. SCOPE OF REVIEW AND LIMITING CONDITIONS

Scope and Limiting Conditions 

13. My analysis was based on documents and information enumerated in Appendix 1 of this 

report and discussed throughout the report and attachments. 

14. Part of my analysis included the preparation of various valuation analysis, calculations and 

conclusions. All of the valuation work performed in this engagement has been prepared in 

accordance with the business valuation standards of the American Institute of Certified 

Public Accountants (“AICPA”) Statement of Standards for Valuation Services No. 1 

(“SSVS”). Furthermore, all of the valuation analyses and methodologies applied herein are 

consistent with the generally accepted body of knowledge in the area of business valuation. 

IV. RELEVANT HISTORY OF THE DEBTOR

15. On February 11, 2013, Jeffery Siskind (“Siskind”) filed personal Chapter 11 bankruptcy with 

the U.S. Bankruptcy Court in the Southern District of Florida – West Palm Beach Division 

under Case No.: 13-13096-MAM (the “Siskind Chapter 11”). Siskind’s Plan of 

Reorganization was approved on October 22, 2014 and the Siskind Chapter 11 was 

dismissed on June 11, 2018 for failure to comply with required payment of US Trustee fees 

and reporting requirements. During the pendency of the Siskind Chapter 11, Siskind was 

involved in significant business transactions that ultimately led up to the filing of the Debtor’s 

bankruptcy. 

16. Below is an overview of the Debtor’s business, operations and relevant key events leading 

up to the Petition Date. 

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Chance & Anthem, LLC

17. Chance was formed as a Limited Liability Company in the State of Florida on October 9, 

2014. Siskind was the sole member and control person. Siskind also served as the primary 

attorney for the Debtor. 

18. According to Siskind1, the Debtor’s two primary business purposes were to: 1) fund the startup and operation of CannaMED Pharmaceuticals, LLC (“CannaMED”), a medical cannabis 

growing venture located in Hebron, Maryland in which the Debtor held a 70% membership 

interest, described by Siskind as a non-controlling interest, and 2) to renovate a large 

mansion-type home located at 3445 Santa Barbara Drive, Wellington, FL 33144 (the 

“Wellington Home”). 

CannaMED Pharmaceuticals, LLC 

19. CannaMED was formed on October 27, 2015 by Siskind, per Maryland corporate search 

records. According to the CannaMED Operating Agreement dated same, Siskind is listed 

as the Managing Member and Managing Director. The Operating Agreement reflects 

ultimate power and authority on all corporate matters resided with the Managing Member. 

20. CannaMED planned to operate a growing facility in Hebron, Maryland, that included 7.4 

acres of land and a 47,000 sq. ft. production warehouse (the “Hebron Property”). Initially, 

in June 2015, related entity Sovereign entered into an Improved Commercial Sales Contract 

with Machining Technologies Inc. (“Machining Technologies”) to purchase the Hebron 

Property for the sum of $950,000. Sovereign did not close under the terms of the contract, 

but instead entered into a Purchase Option Agreement with Machining Technologies dated 

August 28, 2015. Per section 5.4.4 (Site Financing) of CannaMED’s company business 

plan, CannaMED was the third-party beneficiary of the Purchase Option Contract. Lastly, 

on March 31, 2016, Chance entered into a Commercial Lease with Option to Purchase with 

27120 Ocean Gateway LLC for the use of the Hebron Property. 

1 Source: First Amended Adversary Complaint to Avoid and to Recover Fraudulent Transfers, For Turnover, For An Accounting, 

Substantive Consolidation, Injunctive Relief and for Other Relief – Filed November 1, 2019 (the “Amended Complaint” or Amended 

Adversary Complaint”)

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21. In order to operate as a medical cannabis growing company in the state of Maryland, 

CannaMED needed to obtain a grower’s license from the Maryland Medical Cannabis 

Commission (the ”MMCC”). According to the MMCC website, the process of obtaining a 

license requires a potential grower to apply with the MMCC and then go through a twophase approval process. During phase one of the approval process, the potential grower’s 

business plan is evaluated and if preliminarily approved the potential grower moves onto 

phase two, which requires a physical site visit from state officials and approval of growing 

facilities. Upon approval of both phase one and two by MMCC, the potential grower 

becomes a pre-approved grower with the MMCC and the State of Maryland. 

22. During the initial round of grower license application2, CannaMED was one of 146 potential 

growers to successfully submit an application and supporting business plan (the 

“CannaMED Business Plan”) by the November 6, 2015 deadline3. Per the MMCC, only 15 

grower licenses would be awarded during the inaugural application period. 

23. The CannaMED Business Plan stated their mission was to” provide medical cannabis 

processors and dispensaries with safe, affordable medical cannabis of consist and 

pharmaceutical-grade.” Their first year objectives were as follows:4

 Complete and open the facility consistent with representations made to the 

Commission, and by first utilizing a preliminary ‘fast start’ which will permit bringing the 

product to harvest within 5.5 months of licensure; 

 Obtain and train employees who can work in a regulatory environment, and are happy 

and motivated;

 Develop and launch a distribution program which permits ample feedback from 

licensed medical cannabis processors and dispensaries, and based upon 

recommendations from a Business Board of Advisors; and

 Devote 5,000 sq. ft. of the facility (on the second floor) and adequate funding to initiate 

a medical science component, including collaboration with a Scientific Board of 

Advisors.

2 Debtor applied during inaugural application period. Subsequent application periods have re-opened for new growers to apply. 

3 MMCC Announcement dated December 21, 2015 re: Revised Scoring Timeline for Grower and Processor License Applications

4 CannaMED Pharmaceuticals, LLC – Company Business Plan

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24. The CannaMED Business Plan contemplated three separate stages of build-out projections 

for the Hebron Property. Based on the CannMED Business Plan, the first stage of the build 

out, referred to as the ‘Fast Start’ phase, required capital of approximately $424,000 and 

would take about two and a half months to complete. The second stage required capital of 

approximately $985,000 and would take about six and a half months to complete. The third 

and final stage, referred to as the “full build-out”, required capital of approximately $1.6MM 

and would take about eight and a half months to complete. The CannaMED Business Plan 

indicated that the capital required for the business would be funded by Chance through the 

profits from the Wellington House. 

25. Included in the CannaMED Business Plan were three separate Profit & Loss projections 

related to each stage of the build out of the Hebron Property. During the first stage, 

CannaMED projected annual revenue of approximately $1.925MM and net profit of 

approximately $87,000. During the second stage, CannaMED projected annual revenue of 

approximately $9.625MM and net profit of approximately $4MM. For the last stage 3, the full 

build-out, CannaMED projected annual revenue of approximately $19.25MM and net profit 

of approximately $9.5MM. 

26. One December 9, 2016, the MMCC announced 10 growers that were granted Phase One 

license pre-approval and CannaMED was not listed and therefore failed to receive Phase 

one approval. 

27. On August 15, 2017, CannaMED filed a Complaint for Damages and Injunctive Relief 

against the MMCC with the Circuit Court for Baltimore City (Case No.: 24-C-17-004230) 

claiming damages associated with MMCC’s decision to not grant a license to CannaMED. 

On January 30, 2018, the court granted the Defendant’s Motion to Dismiss, stating there 

was no contractual relationship between the parties and the Complaint failed to state a claim 

upon which relief could be granted. On February 19, 2018, CannMED filed a Motion for 

Reconsideration, which was denied by the court on April 2, 2018. On May 2, 2018, 

CannaMED filed a Notice of Appeal, which was denied by the court on January 9, 2019. 

CannaMED again filed a Motion for Reconsideration on January 22, 2019, but the motion 

was again denied by the court on February 6, 2019. We have not been provided any 

information that CannaMED submitted subsequent applications. We believe that from the 

date CannaMED learned it was not granted the growers license up until the Petition Date, 

CannaMED did not attempt to re-apply for the grower’s license. 

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 The Wellington Home 

28. Pursuant to a deed dated August 25, 2015, the Debtor purchased the Wellington Home for 

$1.25MM. The purchase of the Wellington Home was funded by loans from investors. The 

purpose of this real estate purchase by the Debtor was to renovate the home to sell it for a 

profit. Our financial reconstruction indicate that after purchasing the Wellington Home, the 

Debtor did little renovations, never sold the property as a renovated home and in June of 

2017 the lender foreclosed on the Wellington Home. 

29. According to an appraisal prepared by Greg Eidson, MAI, CCIM (the “Real Estate 

Appraiser”) of GlassRatner dated February 27, 2020, the Wellington Home had an 

approximate value between $1.2MM and $1.5MM as of December 31, 2015 and December 

31, 2016 (the “Appraisal”). 

30. The Real Estate Appraiser reviewed the building permits issued to the Debtor in connection 

with the Wellington Home. The Appraisal reflects that the only permit the Debtor ever 

obtained in connection with the Wellington House was a permit to demolish the detached 

garage. As discussed above the Debtor’s business purpose for purchasing the Wellington 

House was to renovate the property and sell the property for a profit but from acquisition 

until the foreclosure sale in June 2017 the Debtor was only permitted to demolish the 

garage. 

The Bankruptcy Filing 

31. On January 29, 2018, the Debtor filed for voluntary Chapter 7 bankruptcy with the U.S. 

Bankruptcy Court for the District of Maryland. That same day, George W. Liebman was 

appointed as the Chapter 7 Trustee. On March 17, 2018, the 341 Meeting of Creditors was 

held and the Debtor failed to appear. 

32. On May 24, 2018, an order was approved transferring the venue to the Bankruptcy Court 

for the Southern District of Florida – West Palm Beach Division (Case No.: 18-16248-MAM). 

The next day, on May 25, Robert C. Furr was appoint as the new Chapter 7 Trustee (the 

“Trustee”). 

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33. Pursuant to the Debtor’s amended bankruptcy schedules A & B [ECF 59], the Debtor listed 

CannaMED with a value of $14MM. The Debtor omitted the Wellington Home from assets 

on its bankruptcy schedules, due to the foreclosure (discussed below in paragraph 94), 

however the Debtor included the debts associated with the Wellington House as liabilities 

on the bankruptcy schedules. According to the Claims Register, eight claims have been 

filed against the Debtor in the total amount of $4,114,896.17, of which $42,500 is claimed 

secured. 

V. THE NATIONAL, STATE, AND LOCAL ECONOMY

34. In preparation of this report, we reviewed and considered the Economic Outlook Update for 

the 4th Quarter of 2016 prepared by Business Valuation Resources, LLC. This report 

provides an overall look at the national economy, summarizing both past performance and 

future predictions. 

35. The appraisal includes a discussion regarding local Palm Beach County economy. 

VI. FINANCIAL ANALYSIS OF CHANCE & THE RELATED ENTITIES

36. The analysis of any business includes performing a detailed financial analysis. Financial 

analysis is the process of summarizing, synthesizing, comparing and interpreting financial 

data and other relevant information in order to assess a company’s present performance 

and future prospects. 

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37. To our knowledge, the Debtor and the Related Entities did not prepare any financial 

statements and did not maintain a financial accounting system or ledgers of their financial 

activity for any period. For purposes of this Expert Report, we prepared a reconstruction of 

the Debtors cash activity that was used as the primary basis of our evaluation of assets, 

liabilities, income and expenses. The categorization of the Debtors and Related Entities 

financial activity was based upon the information available to us, including the bankruptcy 

schedules of the Debtor and Jeffrey Siskind, documents turned over to the Trustee, filed 

claims, pleadings, 2004 examinations, etc. The categorization of the financial activity 

including the amounts Due To (payables) and Due From (receivables) was for the purpose 

of evaluating solvency or insolvency only and for no other purpose. Payments made to third 

parties in exchange for no value (or less than equivalent value) may not represent actual 

amounts due from Siskind or others. Additionally, we utilized the claims filed against the 

Debtor and public records for purposes of evaluating assets, liabilities, income and 

expenses for the period of 2014 through 2017 (the “Analyzed Period”). 

38. Below at Tables 6-1 and 6-2 are the summaries of assets & liabilities and income & 

expenses of the Debtor as a stand-alone entity and Tables 6-3 and 6-4 are the summaries 

of assets & liabilities and income & expenses of the Debtor consolidated with the Related 

Entities. 

Summaries of Assets, Liabilities, Income, and Expenses – Chance & Anthem, LLC 

39. Table 6-1 summarizes the summary of assets and liabilities prepared for Chance for the 

calendar years 2014 through 2017. 

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Table 6-1

40. With regard to the Debtor’s assets and liabilities summarized in Table 6-1 I noted the 

following: 

a. The Debtor was over leveraged; 

b. The Debtor’s liabilities exceed its assets every year; 

Description

ASSETS

Cash 735,179.97 $ 54,725.05 $ 125.48 $ 770.15 $ 

3445 Santa Barbara - 1,405,000.00 1,300,000.00 - 3445 Santa Barbara - Refi - - 1,815.63 - Due to/from David Merrill - 22,618.37 - - Due to/from Fiore - 43,500.00 43,500.00 43,500.00 Due to/from FLACC 100,000.00 272,350.00 320,685.95 321,035.95 Due to/from George Maler - - - - Due to/from Gibson - - - 500.00 Due to/from Jeffrey Siskind 13,233.88 296,953.51 297,794.91 293,748.91 Due to/from Jeffrey Siskind - Aircraft - 117,000.00 117,091.00 117,091.00

Due to/from Jeffrey Siskind - Auto - 26,500.00 - - Due to/from OB Real Estate 15,000.00 22,500.00 37,125.00 37,125.00 Due to/from Siskind Legal - - 62,395.00 55,810.20

Due to/from Siskind Iota 100,000.00 110,000.00 - - Due to/from Sovereign Gaming 1,000.00 56,000.00 60,581.00 60,581.00 Due to/from Sympatico - - 5,132.50 9,442.50 Due to/from Tanya Siskind - - 16,500.00 16,500.00 Due to/from Unknown - Santa Barbara Refi. - - 400,000.00 Due to/from Volkwein 193,109.92 - - - Due to/from Wendy Buckingham - - 16,200.00 16,200.00 Due to/from Zokaites - 62,506.00 47,506.00 47,506.00

In the Weeds - - 290.00 290.00 New Wave Loan - - 32,125.00 32,125.00 Transfers between Chance accounts - - 9,720.00 9,720.00 Total Assets $ 1,157,523.77 $ 2,489,652.93 $ 2,768,587.47 $ 1,061,945.71

LIABILITIES

3445 Santa Barbara - $ 739,445.74 $ 739,445.74 $ - $ 

3445 Santa Barbara - Refi - - 500,000.00 - Due to/from Carl Sone & David Fiore - 770,000.00 770,000.00 770,000.00 Due to/from George Maler - 190,950.00 199,200.00 204,300.00

Due to/from M&T Bank - - 60,000.00 60,000.00 Due to/from Richard Neff - 500,000.00 500,000.00 500,000.00 Due to/from Siskind Iota - - 142,850.00 159,666.00

Due to/from Sympatico - - - 2,441.00 Due to/from Volkwein 1,157,623.77 539,606.25 539,606.25 539,606.25 Due to/from Zokaites - - - 1,560.00 

In the Weeds - - 50,000.00 50,000.00 Sharp Energy - - 1,250.00 2,500.00 Transfers between Chance accounts - - 9,720.00 9,720.00

Total Liabilities 1,157,623.77 2,740,001.99 3,512,071.99 2,299,793.25

Solvency/Insolvency $ (100.00) $ (250,349.06) $ (743,484.52) $ (1,237,847.54)

12/31/2014 12/31/2015 12/31/2016 12/31/2017

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c. The Debtor’s assets consisted of the Wellington home, an interest in CannaMED, 

and transfers to or for the benefit of Jeffrey Siskind and Related Entities which, as 

discussed herein, may be uncollectible; 

d. The Debtors bank activity included numerous indiscriminate transfers to and from 

Related Entities, which we have been categorized for evaluating solvency/ 

insolvency as amounts Due to/Due from the Related Entities in the summary of 

assets and liabilities; and 

e. The Debtor made significant transfers to or for the benefit of Jeffrey Siskind, which 

we have categorized for evaluating solvency/ insolvency as amounts Due to/Due 

from Siskind. 

41. Table 6-2 summarizes the income and expenses for Chance for the calendar years 2014 

through 2017. 

Table 6-2 

42. With regard to the Debtor’s income and expenses as shown in Table 6-2 I noted the 

following: 

Description Total

Income

Income Received - $ - $ - $ - $ - $ 

Expenses

Auto Insurance - - 508.69 - 508.69 Bank Fees 100.00 389.00 2,026.58 1,560.50 4,076.08 Cash & Withdrawals 1

 79,500.00 - (46,646.50) (30,703.20) 2,150.30 Client Expenses - 41,250.00 (3,500.00) - 37,750.00 Closing Costs - - 73,054.26 - 73,054.26 Commisions - 17,812.50 18,050.00 - 35,862.50 Donations - - 1,000.00 - 1,000.00 Employee Related - - 59,660.65 100.00 59,760.65 Gas & auto - 52.23 1,884.99 2,017.07 3,954.29 Maintenance - 378.28 21,135.70 3,001.61 24,515.59 Meals - 357.85 3,666.65 3,049.24 7,073.74 Miscellaneous - 40.00 3,957.64 8,186.51 12,184.15 Office Rent/Mortgage - 3,796.72 185,290.83 22,255.37 211,342.92 Property Expense - 8,771.90 7,899.82 16,671.72 Travel and Entertainment - 1,979.74 7,236.93 4,266.40 13,483.07 Utilities - 639.21 2,911.01 159.81 3,710.03 Total Expenses 100.00 154,967.43 330,237.43 21,793.13 507,097.99 Net Income/(Loss) $ (100.00) $ (154,967.43) $ (330,237.43) $ (21,793.13) $ (507,097.99)

FOOTNOTES: 1

 Although Chance & Anthem reflects net cash deposits in years 2016 & 2017, when reviewing the consolidated Related Entities, including 1

 Siskind IOTA, they reflect net checks to cash and withdrawals of approximately $168K over the four year period.

12/31/2014 12/31/2015 12/31/2016 12/31/2017

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a. The Debtor had no income from business operations; 

b. The Debtors cash activity reflected significant withdrawals and deposits of cash; 

and 

c. The Debtor incurred a net loss every year since it had no income and incurred 

expenses. 

Summaries of Assets, Liabilities, Income, and Expenses – Debtor Consolidated with 

Related Entities 

43. Table 6-3 summarizes the consolidated summary of assets and liabilities for the Debtor 

combined with the Related Entities for the fiscal years 2014 through 2017. 

Table 6-3 

Description

December 31, 

2014

December 31, 

2015

December 31, 

2016

December 31, 

2017

ASSETS

Cash 735,595.09 $ 59,734.74 $ 896.33 $ 1,308.29 $ 

3445 Santa Barbara - 1,405,000.00 1,300,000.00 - Due to/from David Merrill - 22,618.37 - - Due to/from Fiore 76,000.00 119,500.00 299,542.65 299,542.65 Due to/from Gibson 2,500.00 2,700.00 2,700.00 3,800.00 Due to/from Jeffrey Siskind 380,306.34 1,070,555.28 1,285,669.13 1,285,375.18 Due to/from Jeffrey Siskind - Aircraft 50,462.00 241,128.41 245,150.92 245,150.92 Due to/from Jeffrey Siskind - Auto - 26,500.00 - - Due to/from OB Real Estate 1,015,086.25 1,000,000.00 1,000,000.00 1,000,000.00 Due to/from Tanya Siskind - 4,000.00 20,500.00 22,700.00 Due to/from Unknown - Santa Barb. Refi. - - 400,000.00 - Due to/from Wendy Buckingham - - 16,200.00 16,200.00 Due to/from William Siskind 15,192.77 15,325.50 15,325.50 15,325.50

Due to/from Zokaites 25,000.00 117,506.00 102,506.00 61,448.40

Total Assets $ 2,300,142.45 $ 4,084,568.30 $ 4,690,306.16 $ 2,950,850.94

LIABILITIES

3445 Santa Barbara Mortgages - $ 739,445.74 $ 739,445.74 $ - $ 

3445 Santa Barbara - Mortgage Refi - - 500,000.00 - 3485 Lago de Talavera - - 271,586.55 271,586.55 Due to/from Carl Sone & David Fiore - 770,000.00 770,000.00 770,000.00

Due to/from Christopher George 1,911,000.00 1,911,000.00 1,911,000.00 1,911,000.00 Due to/from George Maler 76,954.33 271,249.81 288,421.09 292,221.09 Due to/from M&T Bank - - 60,000.00 60,000.00 Due to/from OB Real Estate - 70,986.78 33,071.78 33,071.78

Due to/from Richard Neff - 500,000.00 500,000.00 500,000.00 Due to/from Siskind Iota 72,500.00 544,330.00 133,280.00 161,541.00

Due to/from Volkwein 904,513.85 479,606.25 479,606.25 479,606.25

Due to/from William Siskind 266.40 266.40 266.40 766.40 

In the Weeds - - 99,710.00 99,710.00 Sharp Energy - - 1,250.00 3,750.00 Transfers between Chance accounts - - 9,720.00 - Total Liabilities $ 2,965,234.58 $ 5,286,884.98 $ 5,797,357.81 $ 4,583,253.07

Solvency/Insolvency $ (665,092.13) $ (1,202,316.68) $ (1,107,051.65) $ (1,632,402.13)

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44. With regard to the consolidated summary of assets and liabilities as shown in Table 6-3 I 

noted the following: 

a. Similar to the Debtor, the consolidated entities were overleveraged; 

b. The consolidated entities had liabilities that greatly exceed assets every year; and 

c. The largest asset consists of amounts Due from Siskind that are likely 

uncollectable (as discussed in paragraph 87). 

 

45. Table 6-4 summarizes the consolidated summary of income and expenses for the Debtor 

combined with the Related Entities for the fiscal years 2014 through 2017. 

Table 6-4 

46. With regard to the consolidated income statement as shown in Table 6-4, I noted the 

following: 

a. The cash activity of the consolidated entities reflect no income from operations; 

Description

December 31, 

2014

December 31, 

2015

December 31, 

2016

December 31, 

2017 Total 

Income

Income Received - $ - $ - $ - $ - $ 

Expenses

Auto Insurance - - 508.69 570.77 1,079.46 Bank Fees 1,278.50 918.00 3,114.88 2,900.50 8,211.88 Cash & Withdrawals 1

 29,123.47 (16,405.92) (55,170.00) (27,808.33) (70,260.78) Client Expenses 1,234.75 40,640.29 (3,500.00) 1,793.76 40,168.80 Closing Costs - - 73,054.26 73,054.26

Credit Card 400.00 - - - 400.00 Commisions 377.98 18,030.50 23,550.00 - 41,958.48 Donations 2,997.83 6,423.59 3,288.86 - 12,710.28 Employee Related 4,116.97 6,439.57 61,673.29 100.00 72,329.83 Gas & auto 6,294.38 16,710.97 5,748.53 2,297.90 31,051.78 

Insurance 2,508.24 10.62 - - 2,518.86 

Investment in CannaMED - - - - - Maintenance 14,201.72 27,461.59 29,690.48 4,830.66 76,184.45 Meals 9,925.27 7,066.55 7,224.22 4,126.77 28,342.81 Miscellaneous 45,811.42 21,303.48 19,518.27 34,074.12 120,707.29 Office Rent/Mortgage 104,244.41 99,357.07 180,403.63 23,790.54 407,795.65 Property Expense 16,370.63 10,294.85 95,651.35 17,878.52 140,195.35 Taxes (9,320.43) 363.50 - - (8,956.93) Travel and Entertainment 13,732.54 25,179.42 16,052.86 4,872.97 59,837.79 Utilities 1,391.85 3,512.73 6,115.21 977.21 11,997.00 Total Expenses 199,160.14 312,836.20 466,924.53 70,405.39 1,049,326.26 Net Income/(Loss) $ (199,160.14) $ (312,836.20) $ (466,924.53) $ (70,405.39) $ (1,049,326.26)

FOOTNOTES: 1

 Related entity Siskind IOTA reflected an additional approximate $238K of net checks to cash and withdrawals that are not included in this consolidation.

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b. The consolidated activity reflects significant cash activity in the form of cash 

withdrawals and cash deposits; and 

c. The consolidated entities incurred a net loss every year since they had no income 

and incurred expenses. 

47. In connection with our evaluation of the assets and liabilities we identified and analyzed 

significant indiscriminate transfers between the Debtor, Related Entities and Siskind. 

Although we found no evidence that these transfers were loans and/or were documented 

by promissory notes with stated terms, we assumed that the net amount of the transfers 

between the Debtor, Related Entities and Siskind resulted in the amounts we categorized 

as due to or from asset or liability, for purposes of evaluating solvency/ insolvency. As 

indicated above in Table 6-3, net transfers to or for the benefit of Siskind totaled over 

$430,000 as of December 31, 2014, $1.3 million as of December 31, 2015 and over $1.5 

million as of December 31, 2016 through 2017 and made up approximately 65% of the total 

assets of the Debtor and Related Entities as of December 31, 2017. The majority of net 

transfers to or for the benefit of Siskind were made during the period when Siskind’s 

personal bankruptcy was pending. 

Summary of Financial Analysis – Chance & Anthem, LLC 

48. Overall, the financial analysis of the Debtor summarized in Tables 6-1 and 6-2 reflect a 

company with no income, expenses primarily related to the Wellington Property and 

CannaMED with net losses, no capital, no earnings, over leveraged, and significant 

indiscriminate transfers between Related Entities and Siskind. 

Summary of Financial Analysis – Debtor Consolidated with Related Entities 

49. Similar to Chance, the financial analysis of the consolidated companies summarized in 

Tables 6-3 and 6-4 reflect no income, expenses primarily related to the Wellington Property, 

CannaMED and payroll and net losses, no capital, lack of retained earnings, over leveraged 

and significant indiscriminate transfers between the Debtor, Related Entities, and Siskind. 

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VII. FINANCIAL TRACING ANALYSIS AND EVALUATION OF CORPORATE FORMALITIES

Christopher George 

50. As discussed in the Amended Adversary Complaint, Christopher George, a Siskind client 

and incarcerated individual, transferred $2MM and his homestead (located at 3485 Lago de 

Talavera, Lake Worth, FL 33467 (“Talavera House”)). The Talavera House was transferred 

via quitclaim deed to the Talavera Trust on or around May 8, 2013 while the $2MM was 

transferred later that same year to the Siskind IOTA account, on or around December 24, 

2013. 

51. The $2 million from George was deposited into the Siskind IOTA Trust account and then 

approximately $1.9MM was transferred to related entity Sovereign. The flow of funds after 

the $1.9MM transfer to Sovereign is outlined below: 

 Two transfers totaling $70,000 to a private membership club; 

 Transfer of $1.15MM to FLACC that would be subsequently used to purchase an office 

condominium; 

 Withdrawal of $100,000 in cash; 

 Acquisition of a mortgage on the Talavera House; 

 Purchasing real estate located at 114000 Torchwood Court, Wellington, FL in the name of 

David Fiore and Beacon Acquisition; and 

 Transfer of $25,000 in cash to Siskind Legal and a transfer $25,000 in cash to Siskind. 

52. Table 7-1 below shows a summary flowchart of all the transfers: 

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Table 7-1 

Carl Stone & Richard Neff 

53. On or around August 9, 2015, Carl Stone and his associate David Fiore transferred 

$800,000 to Siskind’s trust account. According to Siskind5, the transfer was for investment 

purposes to renovate and improve the Wellington Home. Siskind allegedly told Stone he 

would record the proper instruments to protect Stone’s security interest in the property, but 

we have seen no such instrument recorded.

54. Instead, below is a summary of the flow of funds: 

 Transfer $35,000 to related entity FLACC, then FLACC subsequently transferred $30,000 

to Siskind, individually;

 Transfer $750,000 to FLACC and subsequently $725,000 was transferred by FLACC back 

to the Debtor; and

 The remainder of the proceeds totaling $1.121MM were used to purchase the Wellington 

Home.

5 Source: Amended Adversary Complaint

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55. On or around October 6, 2015, Richard Neff transferred $500,000 to Siskind for the same 

purpose of renovating and improving the Wellington Home. Again, Siskind allegedly did not 

record any kind of instrument to protect Neff’s interest. Instead, Siskind transferred $59,000 

from the Debtor to purchase a Mercedes Benz in the name of the Second Siskind Family 

Trust, which he testified that his wife (Tanya Siskind) drove and the remaining balance was 

used to fund the purchase of the Wellington Home. 

56. Table 7-2 below shows a summary flowchart of all the transfers: 

Table 7-2 

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Fredrick Volkwein 

57. According to Siskind6, on or around November 17, 2014, Fredwick Volkwein transferred 

$1,157,623 to the Debtor to be used for investment purposes, the actual flow of funds 

follows: 

 Transfer $230,000 to related entity FLACC, then FLACC subsequently transferred 

$188,000 to Siskind, individually and $15,000 to related entity Siskind Legal;

 Transfer $101,500 to Siskind through a series of six separate disbursements;

 Transfer $100,000 to the IOTA Trust account;

 Transfer $58,000 to an entity named “Fenderhooks,” which appears to be Volkwein;

 Transfer $45,000 to George Maler satisfy Maler’s previous debt;

 Transfer $43,500 to Crystal Title and Equity regarding “Fiore” (from the Carl Stone & David 

Fiore transfers discussed above);

 Transfer $26,000 to related entity Sovereign; and

 Utilized $535,109 of Volkwein’s own funds to repay Volkwein for a prior investment.

58. Table 7-3 below shows a summary flowchart of all the transfers: 

Table 7-3 

6 Source: Amended Adversary Complaint and Continued 2004 Examination of Jeffrey M. Siskind – December 19, 2019

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Corporate Formalities 

59. In connection our analysis of Chance & the Related Entities, we noted the below issues 

which summarize our analysis regarding the observance of corporate formalities: 

a. Each Related Entities was a separate legal entity and other than CannaMED each 

had its own bank account 

b. The banking activity of FLACC, Siskind Legal and Sympatico do not reflect activity 

consistent with their stated corporate purposes 

c. Siskind was a signatory to the bank accounts of the Chance and the Related 

Entities and substantially all of the available documents evidencing banking 

transactions were signed by Siskind 

d. A substantial portion of the banking activity of Chance and the Related Entities is 

activity on behalf of Siskind, his family and transfers between the Related Entities 

and other entities controlled by Siskind 

e. The banking activity of Chance, the Related Entities and other accounts controlled 

by Siskind reflect checks made payable to cash, deposits of cash and withdrawals 

in the total amount of hundreds of thousands of dollars and no registers, ledgers 

or receipts have been provided that document the use of the funds and purpose 

or nature of the transactions 

f. The banking activity of FLACC reflect numerous debit card transactions that 

appear to be consumer purchases, presumably on behalf of Siskind or his family 

g. There are numerous indiscriminate banking transfers between Chance and the 

Related Entities and also among the Related Entities and we have not been 

provided any notes, agreements or other documents evidencing the business 

purpose or terms of the transactions 

h. Chance and the Related Entities conducted financial transactions on behalf of 

each other without agreements, ledgers or other documents evidencing the nature 

and terms of the transactions 

i. Chance and the Related Entities did not maintain ledgers or registers of the 

amounts due to/ due from each entity 

j. Siskind maintained what he describes as an “online check register” for Chance, 

however the check register did not cover the whole time period of Chance’s 

existence, was not complete, was not accurate, and did not record deposits. 

k. Other than the “online check register” for Chance, we have not been provided any 

registers, accounting ledgers or other documents evidencing the nature and 

business purposes of the financial transactions of Chance and the Related Entities 

l. Siskind advised that income tax returns were not filed on behalf of Chance and we 

have not been provided income tax returns for the Related Entities 

m. GlassRatner has incurred hundreds of hours to reconstruct the banking activity 

and analyze the available information in an attempt to understand the financial 

affairs of Chance and the Related Entities 

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VIII. VALUATION ANALYSIS

60. As part of the assignment, I performed a valuation of Chance as of the Valuation Dates, 

which included: 

a. An analysis of the transfers to/ from the Related Entities and Siskind; 

b. an analysis of CannaMED, the efforts and failure to obtain a grower’s license from 

the MMCC; and 

c. the review of an appraisal of the Wellington Home. 

Valuation Parameters (Standard of Value and Premise of Value) 

61. The Standard of Value typically applied in a valuation assignment is “Fair Market Value,” 

which is defined as: 

The price, expressed in terms of cash equivalents, at which the property 

would change hands between a hypothetical willing and able buyer and a 

hypothetical willing and able seller, acting at arm’s length in an open and 

unrestricted market, when neither is under compulsion to buy or sell and 

when both have reasonable knowledge of the relevant facts. 7

62. The Premise of Value is the overall assumption regarding the most likely future business 

circumstances for the company being valued; for example, going concern or in liquidation.8

63. I performed this valuation analysis based on the going concern premise of value because 

Chance, as a stand-alone entity, was a going concern operating company as of the 

Valuation Dates. 

 Related Entities and other involved entities 

64. In connection with the evaluation of solvency/ insolvency of Chance and Related Entities 

combined we also evaluated the value of the Related Entities. 

7

 International Glossary of Business Valuation Terms adopted by the ASA, AICPA and other standard setting business valuation 

professional associations. 

8

 Shannon P. Pratt “Valuing A Business: The Analysis and Appraisal of Closely Held Companies” Fifth Edition, p. 41. 

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65. According to Florida’s Division of Corporations9 (“Sunbiz”), Florida’s Association of 

Community Banks and Credit Unions, Inc. (“FLACC”) was formed on October 25, 2012 as 

a not for profit and filed for Administrative Dissolution on September 22, 2017. Siskind is 

reflected as the Registered Agent and Director. According to Siskind, this entity provided 

services to community banks and credit unions. Based on the bank cash activity, FLACC 

did not receive income for performing services to customers and in fact the majority of the 

cash activity related to significant transfers to and from other Siskind controlled companies. 

66. According to Sunbiz, Siskind Legal Services, LLC (“Siskind Legal”) was formed on 

December 23, 2004 and filed for Administrative Dissolution on September 22, 2017. Siskind 

is listed as the Registered Agent and Manager. According to Siskind, this entity was 

occasionally used as a vehicle for Siskind to practice law. Based on the banking activity 

this entity had significant transfers to and from other Siskind controlled companies. 

Additionally, much of the banking activity seems to be to or for the benefit of Siskind 

personally. 

67. According Sunbiz, Sympatico Equine Rescue, Inc. (“Sympatico”) was formed on February 

6, 2013 and filed for Administrative Dissolution on September 27, 2019. Siskind is reflected 

as the Registered Agent and President. According to Siskind, this entity is a charity in West 

Palm Beach, Florida. Based on the banking activity there do not appear to be donations or 

charity related expenses. The majority of the banking activity is related to significant 

transfers to and from other Siskind controlled companies. Additionally, much of the banking 

activity seems to be to or for the benefit of Siskind personally. The banking activity reflect 

debit card transactions that appear to be consumer purchases for the benefit of Siskind or 

Siskind’s family members. 

9

 www.sunbiz.org 

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68. According to Sunbiz, Sovereign Gaming & Entertainment, LLC (“Sovereign”) was formed on 

February 3, 2014 and is currently listed as “Inactive” and “Pending Reinstatement” as of 

February 21, 2020. William Siskind, Siskind’s deceased father, is reflected as the 

Registered Agent and Manager. The Amended Complaint alleges that Siskind controls this 

entity as a nominee of his father. It is unclear as to what goods or services this entity was 

to provide. In reviewing the reconstructed bank activity, it appears Sovereign did not provide 

goods or service but reflects extensive intercompany activity with other Siskind controlled 

companies. Additionally, much of the banking activity seems to be to or for the benefit of 

Siskind personally or his family. 

69. Additionally, as mentioned in Section IV, Sovereign entered into a Purchase Option 

Agreement for the Hebron Property that was to be used in the CannaMED venture. 

CannaMED was to be the third-party beneficiary of Chance & Anthem’s assignment of this 

Purchase Option Contract entered into by Sovereign.10 We have found no records reflecting 

that Sovereign had any interest in CannaMED or has a business purpose related to 

CannaMED. 

70. In conclusion, in regards to the Related Entities, we assumed these were going concern 

entities for valuation purposes, but many of them seem to lack a legitimate business purpose 

or do not seem to operate consistent their stated business purpose. 

Valuation Approaches 

71. There are numerous techniques and approaches to determine the value of an ongoing 

business enterprise. Generally, there are three traditional approaches to value a business 

interest or asset: 

a. The Asset Approach, 

b. The Income Approach, and 

c. The Market Approach. 

10 CannaMED Pharmaceuticals, LLC – Company Business Plan – Section 5.4.4 (Site Financing)

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72. Within these approaches, valuation analysts will use one or more methods when valuing a 

business and/or its ownership interests. The objective of using more than one approach or 

method (if applicable) allows the appraiser to view the target company from different 

perspectives to form an opinion as to the value conclusion. The method or methods 

selected for each valuation will depend upon the appraiser’s judgment and experience with 

similar valuations and upon the quantity and quality of available financial, operational and 

industry data. 

73. The generally accepted business valuation approaches and accompanying methodologies 

we considered are discussed briefly below. 

The Asset Approach 

74. The underlying Asset or Cost Approach establishes value by netting the fair market value of 

assets and liabilities to determine the net asset value or net worth of the business. The 

value of all of the target company’s assets are discretely determined and accumulated. 

Therefore, this valuation approach requires a discrete valuation of all of the assets of a 

company, where the appraiser examines the current cost to purchase or replace each asset. 

75. This valuation approach is typically applied for asset heavy or capital intensive businesses, 

real estate or security holding companies. Asset value also constitutes the price 

determinant of corporate worth where operations have historically been unprofitable, 

unstable, or earnings are marginal in relation to invested capital. In the case of a company 

that does not possess sufficient earnings potential or cash flow to warrant treatment as a 

going concern, assets can be stated at their liquidation values less a provision for disposal 

costs and taxes that might arise from their liquidation. On the other hand, in situations where 

there are earnings or potential earnings, the business should be considered a going concern 

and its value should be calculated with reference to its earnings or earnings potential as 

opposed to the value of the assets. 

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The Income Approach 

76. The application of the Income Approach establishes value by means that capitalize or 

discount future anticipated benefits, such as cash flows or earnings, by a discount or 

capitalization rate.11 Capitalization and discount rates are developed to reflect market rate 

of return expectations, as well as the relative risk of the investment. This approach is often 

used to determine the value of a going-concern business whose value is aligned with its 

ability to generate future earnings and/or cash flows. Valuations under this approach are 

typically performed through the use of the Discounted Cash Flow (“DCF”) Method or a 

Capitalization of earnings method. 

77. Capitalization of earnings method is most appropriate for mature businesses with level 

income streams versus the discounting which is more appropriate for businesses with 

varying levels of income in the future. 

78. The Capitalized Earnings Method normalizes current after-tax cash flows to represent 

expected future earnings and divides that by a capitalization rate to arrive at a value 

indication. 

79. The Excess Earnings Method is a hybrid of the Asset Approach and Income Approach in 

that it considers the value of the assets as well as the expected future cash flows. The 

process of valuing a business utilizing the Excess Earnings Method involves estimating the 

company’s net tangible asset values and applying a reasonable rate of return to identify the 

earning related to the net tangible assets. Once the earnings attributable to the net tangible 

assets are identified they are subtracted from the earnings to arrive at the “excess” earnings 

to be capitalized to determine the amount of “goodwill.” The goodwill is added to the net 

tangible assets to arrive at the value of the assets. 

The Market Approach 

80. The Market Approach is a relative valuation approach that assesses a company’s value by 

comparing the company being valued to the market price of similar companies at the 

valuation date or the historical sales price of similar companies that have been sold. There 

are two primary methods to apply the Market Approach: 

11 Typically, a capitalization rate is a rate of return used to convert a single period income into a value, and a discount rate is a rate 

applied to a series of future income amounts to convert them into one value. The inverse of the capitalization rate is a multiple of 

cash flow. 

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a. The “Guideline Public Company Method” where the value of a business enterprise 

is determined by comparing the target company to publicly-traded guideline 

companies in the same or similar lines of business. The guideline firms are also 

referred to as peers or peer companies (“Peers” or “Peer Companies”). 

b. The “Mergers and Acquisitions (“M&A”) Transaction Method” or “Transactions 

Method” where the value of a business is determined by comparing the target 

company to actual M&A sales transactions involving both publicly-traded and 

privately-held companies in the same industry sector as that target company. 

Valuation Approach – Chance & Anthem, LLC 

81. The only assets of the Debtor, other than the transfers we categorized as amounts Due to/ 

Due from Siskind, Related Entities and third parties, were the interest in CannaMED and 

the Wellington Home. For the Wellington Home and the amounts we categorized as Due 

to/Due from, we utilized the Net Asset Approach. We obtained an appraisal prepared by 

Greg Eidson, MAI, CCIM that estimated the value of the Wellington Home between $1.2MM 

and $1.5MM. For the Debtor’s interest in CannaMED, we also evaluated the income 

approach combined with a probability analysis, as discussed below in paragraphs 81 to 86. 

Income Approach – Capitalization of Earnings (CannaMED) 

82. As previously discussed in Section IV, CannaMED prepared a business plan that contained 

three stages of build-out projections and corresponding three stages of profit & loss 

projections. Their initial build-out phase, named ‘Fast Start’, would provide CannaMED with 

their initial ramp-up period. The CannaMED Business Plan estimates capital requirements 

of approximately $424,000 and a time period of about two and half months to complete. 

Additionally, after the initial build out, CannaMED would continue with Phases 1, 2, and 3 

(Phase 3 being the final phase), which would require an additional $2.585MM in capital and 

take about 15 months to complete. The CannaMED Business Plan indicated that the capital 

required to fund the build out would come from the profit related to the Wellington House. 

As discussed above in Section IV, the Debtor did little renovations to the Wellington House 

and also refinanced the property in 2016, and then the property was foreclosed upon in June 

of 2017. 

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83. The CannaMED Business Plan profit & loss projections for each phase of the build-out 

indicate an estimated annual revenue of approximately $1.925MM and net profit of 

approximately $87,000 during the Fast Start. After Phases 1, 2, & 3 and the Full build-out 

was completed, they projected an annual revenue of approximately $19.25MM and net profit 

of approximately $9.5MM. 

84. The CannaMED Business Plan assumes that CannaMED would obtain the license 

necessary to operate as a grower in Maryland, which assumption is the key to the entire 

business plan. Obtaining a grower’s license from MMCC is not guaranteed and was 

contingent upon the scoring by the MMCC of the business plan submitted as compared to 

the other business plans submitted by the additional 146 applicants who were all trying to 

obtain one of the fifteen grower licenses available. 

85. In connection with evaluating the value of the Debtor’s interest in CannaMED we evaluated 

the probability of CannaMED obtaining one of the fifteen grower licenses from MMC, which 

licenses were being sought by 146 other applicants. In evaluating the probability, we 

considered the CannaMED Business Plan that required capital in the amount of $3MM to 

do a buildout, which capital was expected to come from a house in Wellington Florida. 

Additionally, we considered that the managing member of CannaMED was an individual in 

his own Chapter 11 Bankruptcy. Based on our evaluation, it is our opinion that the 

probability of CannaMED obtaining one of the fifteen grower licenses was very low given 

the fact that there were 145 other applicants, the source of the capital indicated in the 

CannaMED Business Plan, and that the managing member of the applicant was an 

individual Chapter 11 Debtor. 

86. In connection with evaluating the Debtor’s interest in CannaMED, we also considered the 

probability that the Debtor had sufficient capital and would overcome the business and 

litigation risks to be able fund the build out to allow CannaMED to realize operations and the 

projected revenue and earnings. Given the limited available capital, risk of litigation from 

investors & Chris George, Chapter 11 bankruptcy of Siskind and other business risks, it is 

our opinion is that is very unlikely that Chance would be awarded a license, fulfill the 

requirements of the build out, become operational and operate profitability as outlined in the 

business plan given all the risks facing Chance and Siskind. 

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87. We also considered that although the Debtor held a 70% ownership interest in CannaMED, 

according to Siskind, the Debtor had no voting or control rights. In our opinion, a hypothetical 

willing buyer would place a significant discount on this 70% ownership interest due to the 

lack of voting rights and control, particularly for such a large interest. 

Valuation Approach – Debtor Consolidated with Related Entities

88. Similar to the Debtor, as evidenced in the banking cash activity, the Debtor and the Related 

Entities have no income and the only assets were the Wellington Home, interest in 

CannaMED, and amounts we characterized as due from Siskind, a Chapter 11 Debtor. As 

discussed earlier in Section VII, most of the Related Entities were not active operating 

companies. Additionally, in regards to the multitude of significant indiscriminate transfers 

between the Debtor and the Related Entities, we have found no records evidencing the 

terms of the transfers between the entities such as promissory notes with stated repayment 

terms, interest rate, security agreements and maturity date. As discussed previously in 

Section VII, Siskind utilized a portion of the loans and investor proceeds of these entities to 

fund his personal lifestyle. Further we evaluated the monthly operating reports and periodic 

reports regarding value, operations and profitability of entities in Siskind’s Chapter 11. 

In evaluating the collectability of the $1M amount Due from OB Real Estate, we reviewed 

the equity in the Trump Office Suite property. We found it was encumbered with 

indebtedness to George Maler and others in the amount of $350,000 as of December 31, 

2014 and then the debt increased to $750,000 as of December 31, 2015. 

Based on our analysis we have determined that it is likely that the amounts we categorized 

as Due to the Debtor and Due from Siskind and Related Entities are uncollectible. Due to 

the lack of income and earnings of the Related Entities, we utilized the Net Asset Approach 

in connection with valuing Chance and the Related Entities. For Chance, see the above 

discussion in paragraph 80. 

IX. SOLVENCY ANALYSIS OF CHANCE & THE RELATED ENTITIES

89. In connection with the adversary proceedings in this matter, I was asked to determine 

whether the Debtor (and the Debtor consolidated with the Related Entities) was solvent or 

insolvent during the four year prior to the bankruptcy filing date. Solvency is analyzed by 

determining if, among other factors, the Debtor: 

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a. 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; 

b. 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 represented 

an unreasonably small capital; or 

c. Incurred, 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. 

90. In order to determine whether Chance was solvent or insolvent, I performed three tests 

related to the factors described in the previous paragraph: the Balance Sheet Test, the 

Capital Adequacy Test, and the Cash Flow Test.12

Balance Sheet Test 

91. A company's solvency or insolvency can be measured by performing an analysis commonly 

referred to as the Balance Sheet Test, pursuant to which a debtor is insolvent when the sum 

of its debts is greater than all of its property “at a fair valuation.” It is generally accepted that 

“at a fair valuation” for the purpose of a Balance Sheet Test means Fair Market Value. My 

valuation analysis presented in Section VII above calculated the Fair Market Value of the 

Company. I therefore utilized this valuation analysis in performing the Balance Sheet Test. 

92. As indicated above, it is my opinion that beginning as of December 31, 2014, Chance was 

insolvent, and continued to be insolvent at each Valuation Date and through the bankruptcy 

filing date under the Balance Sheet Test. 

93. Additionally, it is my opinion that beginning as of the December 31, 2014, Chance 

consolidated with the Related entities was also insolvent, and continued to be insolvent at 

each Valuation Date and through the bankruptcy filing date under the Balance Sheet Test. 

12 Based on Latham & Watkins presentation “Insolvency” by Christopher Harris dated 5/10/12, there are generally three tests used to 

determine whether an entity is insolvent, Balance Sheet Test, Cash Flow Test, and Adequate Capital Test. 

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 35 of 58
GlassRatner Advisory & Capital Group LLC Page 30 

Cash Flow Test13

94. The Cash Flow Test assesses whether a company can meet its operating and debt service 

obligations as they come due. Sources of cash include (a) cash flow generated by 

operations and (b) additional borrowing capacity, if any. In addition to operating expenses, 

cash needs include (a) capital expenditures required for the future operations of the 

business, (b) interest on outstanding debt, and (c) repayment of debt principal. The Cash 

Flow Test should also consider whether the subject company will be able to repay or 

refinance existing debt upon maturity. 

95. The Debtor had no income. The sources of receipt were loans, deposits from investors, 

deposit from Chris George and refinancing or mortgages taken on properties. In regards to 

the Debtor’s primary asset the Wellington Home, New Wave lenders filed a Complaint for 

Mortgage Foreclosure and Damages on November 8, 2016 in the Circuit Court of Palm 

Beach County (Case No.: 2016-CA-012543). On June 12, 2017, the Wellington Home was 

foreclosed upon. Had CannaMED obtained a license, it would have required substantial 

capital to fund the build out. 

Capital Adequacy Test14

96. In addition, I analyzed the adequacy of Chance’s capital as of the Valuation Dates. Chance 

did not have sufficient cash flow to meet its obligations as they became due. The Capital 

Adequacy Test assesses solvency by evaluating an entities ability to meet its obligations as 

they become due while staying within its financial covenants. 

97. As discussed above, we evaluated the Balance Sheet Test and Cash Flow Test, which 

indicated Chance’s liabilities exceeded its assets and it did not have sufficient cash flow to 

meet its obligations as they became due. 

13 Based on Willamette Management Associates, Proving or Contesting Debtor Insolvency Under the Balance Sheet Test, by Robert 

F. Reilly, evidence used to determine insolvency includes, among other things, capital adequacy test documents and data including, 

cash balance restrictive covenants, details of all working capital account balances, operating budgets, prior year operating budgets, 

short term capital expenditure commitments. 

14 Based on Willamette Management Associates, Proving or Contesting Debtor Insolvency Under the Balance Sheet Test, by Robert 

F. Reilly, evidence used to determine insolvency includes, among other things, cash flow test documents and data, including cash 

balance restrictive covenants, lease repayment schedules, debt repayment schedule, debt covenants and restrictions, debt capacity 

available, capital expenditures and other uses of cash, asset sales and other sources of cash and intercompany debt obligations. 

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 36 of 58
GlassRatner Advisory & Capital Group LLC Page 31 

Solvency Test Conclusion 

98. Based on the solvency analyses discussed above, it is my opinion that Chance was 

insolvent as of the Valuation Dates because (a) the Company’s assets were worth less than 

its liabilities, (b) the Company was inadequately capitalized, and (c) the Company would not 

be able to meet its debt obligations as they matured. 

99. Additionally, based on the solvency analysis discussed above, it is my opinion that the 

Debtor consolidated with the Related Entities was insolvent for the same reasons stated in 

the above paragraph. 

X. SUMMARY CONCLUSION

100. Based on my detailed analysis of the financial and other information cited in this report, my 

past experience and my training, it is my opinion that both Chance, as a stand-alone entity, 

and Chance consolidated with the Related Entities was insolvent, inadequately capitalized, 

was not able to meet its debt obligations, and was unable to manage the various business 

challenges that it faced by December of 2014 and beyond and through the Petition Date. 

XI. ALAN BARBEE PROFESSIONAL BACKGROUND 

101. I am a Principal with GlassRatner Advisory & Capital Group LLC. I am a Certified Public 

Accountant (“CPA”) licensed in the State of Florida. In addition, I am Accredited in Business 

Valuation (“ABV”) by the American Institute of Certified Public Accountants (AICPA). I have 

consistently equaled, or exceeded, the continuing professional education requirements for 

my areas of specialty and related professional designations. 

102. I have over twenty-five years of experience in financial advisory services in the areas of 

forensic and general accounting, including investigation of financial and accounting matters, 

corporate investigations, calculating economic damages, valuation, financial fraud 

investigations, financial consulting, insolvency matters, and litigation support. 

103. I have testified as an expert at trial, mediation, arbitration and depositions on numerous 

occasions on behalf of plaintiffs and defendants. 

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 37 of 58
Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 38 of 58
GlassRatner Advisory & Capital Group LLC Page 33 

APPENDIX 1 

DOCUMENTS CONSIDERED

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 39 of 58
Appendix 1 - Docs Considered

Chance & Anthem, LLC (Case No.: 18-16248-MAM)

Documents Considered

Appendix 1

Item 

No. Documents Considered

1 Chance & Anthem, LLC - Monthly Bank Statements & Check Copies - Chase xx1866 - October 2015 to June 2018

2 Siskind Legal - Monthly Bank Statements & Check Copies - Chase xx0683 - September 2013 to August 2018

3 Jeffrey Siskind Personal DIP - Monthly Bank Statements & Check Copies - Chase xx2061 - September 2013 to August 2018

4 Sympatico Equine Rescue, Inc. - Monthly Bank Statements & Check Copies - Chase xx3506 - February 2013 to August 2018

5 Florida Association of Community Banks - Monthly Bank Statements & Check Copies - Chase xx6890 - January 2013 to July 2018

6 Chance & Anthem, LLC - Monthly Bank Statements & Check Copies - Suntrust xx6688 - November 2014 to February 2017

7 Sovereign Gaming & Entertainment LLC - Monthly Bank Statements & Check Copies - Suntrust xx1472 - January 2013 to January 2017

8 Siskind Legal Services- Check Copies - PNC Bank xx7373 - July 2017 to July 2018

9 OB Real Estate Holdings 1732, LLC - Monthly Bank Statements & Check Copies - Suntrust xx1451 - April 2014 to June 2017

10 Siskind Legal Services, LLC - Monthly Bank Statements & Check Copies - Suntrust xx9840 - January 2013 to March 2013

11 Siskind Legal Services, LLC (Escrow) - Monthly Bank Statements & Check Copies - Suntrust xx3254 - January 2013 to March 2013

12 Tanya Siskind - Monthly Bank Statements - Suntrust xx1505 - March 2015 to June 2018

13 Tanya Siskind - Monthly Bank Statements & Check Copies - Suntrust xx7764 - February 2013 to August 2018

14 William & Jeffrey Siskind - Monthly Bank Statements & Check Copies - Wells Fargo xx1063 - May 2018 to July 2018

15 Samantha & Tanya Siskind - Monthly Bank Statements - Wells Fargo xx1549 - November 2015 to July 2018

16 Jack & Tanya Siskind - Monthly Bank Statements - Wells Fargo xx4415 - July 2018

17 Samantha & Tanya Siskind - Monthly Bank Statements - Wells Fargo xx7382 - November 2015 to March 2016

18 Jack & Tanya Siskind - Monthly Bank Statements - Wells Fargo xx7516 - December 2015 to June 2016

19 Tanya Siskind - Monthly Bank Statements & Check Copies - Wells Fargo xx8067 - February 2013 to July 2018

20 Jack & Tanya Siskind - Monthly Bank Statements - Wells Fargo xx8423 - December 2015 to April 2017

21 Tanya Siskind - Monthly Bank Statements - Wells Fargo xx8850 - January 2013 to July 2018

22 Tanya Siskind Campaign Account - Monthly Bank Statements & Check Copies - Wells Fargo xx9229 - August 2017 to June 2018

23 Siskind IOTA Attorney Trust Account - Monthly Bank Statements & Check Copies - Wells Fargo xx9721 - January 2013 to July 2018

24 Chapter 11 Monthly Operating Reports - Jeffrey Siskind - February 2013 to December 2017

25 Warranty Deed - 11400 Torchwood Acquisition by Beacon & Fiore - February 25, 2014

26 Warranty Deed - 11400 Torchwood Sale by Beacon & Fiore - June 24, 2014

27 Assignment of Mortgage - Talavera property - August 23, 2017

28 Late Rent Letters to J. Siskind re: rent at Hebron, MD property

29 Rental Agreement for Hebron, MD property dated March 31, 2016

30 Complaint for Damages filed by CannaMED against Maryland Medical Cannabis Commission - August 15, 2017

31 Motion to Dismiss Compaint against MMCC - October 30, 2017

32 Order dismissing Complaint against MMCC - January 30, 2018

33 Motion for Reconsideration of Complaint against MMCC - February 19, 2018

34 Order Denying Motion for Reconsideration of Complaint against MMCC - April 2, 2018

35 Notice of Appeal filed by CannaMED - May 1, 2018

36 Cross Creek- Assignment of Mortgage from Maler - December 2, 2015

37 Cross Creek- Assignment of Mortgage to Zokaites - October 12, 2017

38 Cross Creek- Mohammed foreclosure complaint

39 Cross Creek- Notice of Lis Pendens

40 Deed between Sovereign and Talavera Trust - January 9, 2015

41 Indemnity Mortgage - Talavera Trust - February 6, 2014

42 Lis Pendens - Talavera trust - November 14, 2014

43 Assignment of Second Mortgage - Talavera property - July 19, 2016

44 Santa Barbara- ABK Mortgage

45 Santa Barbara deed from Chase - August 25, 2015

46 Santa Barbara- Foreclosure Deed - June 12, 2017

47 Santa Barbara- New Wave foreclosure complaint

48 Santa Barbara- New Wave Mortgage - November 12, 2015

49 Siskind resignation from OB Real Estate

50 Talavera Assignment of Mortgage - February 6, 2014

51 Talavera QuitClaim Deed - May 8, 2013

52 Tatarow Complaint for Foreclosure

53 Tatarow mortgage - February 25, 2016

54 Trump- Certificate of Title to OB Holdings

55 Trump- Mortgage Deed to Maler

56 Trump- Mortgage Modification Agreement with Maler Lenders - November 28, 2014

57 Trump- Sale of property by Zokaites - January 31, 2018

58 Trump- Second Mtge Modification Agreement with Maler Lenders - March 20, 2015

59 Trump- Third Mtge Modification Agreement with Maler Lenders - September 20, 2015

60 Trump- TP5 Deed - May 17, 2013

61 CannaMED Operating Agreement

62 CannaMED Company Business Plan prepared for MMCC

63 2004 Examination of Jeffrey Siskind with corresponding exhibits - December 19, 2019

64 Purchase Option Agreement with Machining Technologies dated 08.28.2015 - Hebron Property

65 Purchase Option Agreement with 27120 Ocean Gateway dated 03.31.2016 - Hebron Property

66 Case Information Listing from Circuit Court for Baltimore City-Civil System - CannaMED v. MMCC

67 Appraisal of 3445 Wellington property prepared by Greg Eidson

GlassRatner Advisory & Capital Group, LLC Page 1 of 2

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 40 of 58
Appendix 1 - Docs Considered

Chance & Anthem, LLC (Case No.: 18-16248-MAM)

Documents Considered

Appendix 1

Item 

No. Documents Considered

68 Economic Outlook Update - Q4 2016 - Business Valuation Resources, LLC

69 Maryland.gov Business Search - Cucanna Pharamacueticals (CannaMED Pharmacueticals, LLC)

70 Maryland Medical Cannabis Commission (MMCC) - Announcement December 21, 2015 - Revised Scoring Timeline for Applications

71 Maryland Medical Cannabis Commission (MMCC) - Announcement December 9, 2016 - License Pre-Approvals

72 Maryland Medical Cannabis Commission (MMCC) - FAQ as of February 21 ,2020 - How will growers be licensed?

73 Florida Division of Corporations (Sunbiz.org) - Company Search - Florida's Association of Community Banks and Credit Unions, Inc. (FLACC)

74 Florida Division of Corporations (Sunbiz.org) - Company Search - OB Real Estate Holdings 1732, LLC

75 Florida Division of Corporations (Sunbiz.org) - Company Search - Siskind Legal Services, LLC

76 Florida Division of Corporations (Sunbiz.org) - Company Search - Sovereign Gaming & Entertainment, LLC

77 Florida Division of Corporations (Sunbiz.org) - Company Search - Sympatico Equine Rescue, Inc.

78 Florida Division of Corporations (Sunbiz.org) - Company Search - Wellington 3445, LP

79 Washington Post article dated September 8, 2019 - A bigger crop: Why Maryland's medical pot growers are adding more plants

80 Palm Beach Post article dated August 7, 2019 - Wellington attorney Siskind defrauded investors of millions, bankruptcy trustee claims

GlassRatner Advisory & Capital Group, LLC Page 2 of 2

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 41 of 58
GlassRatner Advisory & Capital Group LLC Page 34 

APPENDIX 2

BARBEE CV AND PRIOR TESTIMONY

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 42 of 58
Alan Barbee is a Principal of GlassRatner and part of the Florida leadership team. 

Prior to joining GlassRatner in 2014, he was the partner in charge of Marcum, LLP’s 

Florida Advisory Services Division; prior to that from 1991 to 2007 he worked at 

Barbee & Associates, Inc a well respected boutique Insolvency and Forensic 

Accounting Practice in Florida. He led Barbee & Associates from 2000 to 2007. 

Mr. Barbee has over 25 years experience providing forensic accounting and litigation 

support services primarily concentrated in the areas of fraud investigation, 

quantification of economic damages, bankruptcy and insolvency consulting and 

business valuation. Additionally, Mr. Barbee has extensive experience providing 

business management and advisory services related to businesses in a wide range 

of different industries.

Mr. Barbee has been retained by numerous attorneys, secured lenders, business

organizations, Bankruptcy Trustees, court appointed Receivers and other fiduciaries to 

provide services that include forensic review and reconstruction of books and records, 

investigation of investment fraud and Ponzi schemes, identification of concealed assets 

and complex asset tracing, analysis of avoidable transfers, evaluation of technical tax 

issues and business valuation in connection with litigation, estate/gift taxation and 

financial statement audits.

Alan has extensive litigation support experience that includes both expert witness 

and consulting assignments. Mr. Barbee has rendered numerous expert opinions in 

connection with commercial economic damage calculations, determination of solvency/

insolvency and valuation issues. Mr. Barbee has also provided expert witness consulting 

services for numerous mediations and settlement conferences. Alan has also served 

as a court appointed fiduciary relating to matters involving administration of assets, 

resolution of litigation and claims adjudication.

Mr. Barbee has performed consulting and valuation services for Nations Credit, 

SunTrust Bank, Colonial Bank, and Bank of America related to distressed properties 

and troubled loans. He has also performed engagements for the Securities and Exchange 

Commission and Commodity Futures Trade Commission to name a few of his clients.

Mr. Barbee is a licensed Certified Public Accountant (CPA) in the State of Florida, is

Accredited in Business Valuations (ABV) by the AICPA and graduated from the 

University of Central Florida with a Bachelor degree in Business Administration. 

Alan Co-authored “Following Electronic Trails to Evidence of Fraud”, published in The 

Journal of Corporate Renewal, August 2007 and has presented at the Region 21 U.S. 

Trustee training event for panel Trustees, the Turnaround Management Association and 

other professional associations. Mr. Barbee has also been named Top CPA’s in Litigation 

Support from 2006 to 2016 by South Florida Legal Guide.

Biography: 

Name, Designations

Title

©2019 GlassRatner Advisory & Capital Group LLC. All rights reserved. www.GlassRatner.com

Biography: 

ALAN R. BARBEE - CPA, ABV

PRINCIPAL

Contact:

561.657.4891

abarbee@glassratner.com

vCard

Industries

Automotive

Healthcare

Real Estate

Restaurant

Specialties

Bankruptcy Proceedings

Damages/Lost Profit Analysis

Expert Witness

Fiduciary Services

Forensic Accounting

Fraud Investigation

Litigation Support

Ponzi Schemes

Solvency Opinions

Valuation

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 43 of 58
Alan R. Barbee, CPA/ABV 

Principal 

Direct: 561.657-4891 

Cell: 561.398.2025 

Email: abarbee@glassratner.com

Fiduciary Roles – Assignments for the Benefit of Creditors, Receiver, Plan Administrator, 

Chief Restructuring Officer 

All Southern Rehabilitation Services, LLC 

Frank Investment, Inc. (Florida) 

Frank Investment, Inc. (New Jersey) 

K2 Builders, Inc. 

Luna Development Group 

Pilates by Geri, LLC 

P&S Cigar, Inc. 

Tradewinds Engine Services 

Vitreo Retinal Consultants of the Palm Beaches, Inc. 

Also appointed as financial advisor to fiduciaries in numerous cases. A list of 

cases will be provided upon request. 

Deposition or Trial Testimony Experience 

Autotech Leasing Services LLC et al 

United States Bankruptcy Court, Southern District of New York 

Case No. 00-12084-BKC-SMB 

Evidence by Deposition 

Retained by: Ian J, Gazes, Trustee 

Counsel: Ian J. Gazes, Esq. 

Opposing Counsel: Timothy O'Neill, Esq. 

Issue: Forensic Accounting, Avoidable Transfers and Valuation

Atlas Environmental, Inc. 

United States Bankruptcy Court, Southern District of Florida 

Case No. 97-20203-BKC-RBR 

Evidence at Trial 

Retained by: Defendants

Counsel: Keith Grumer, Esq. 

Opposing Client: Soneet Kapila, Trustee 

Opposing Counsel: Jeffrey Bast, Esq. 

Issue: Forensic accounting, Avoidable Transfers, 

Solvency/Insolvency and Valuation 

Blue Marlin Motors of Stuart, LLC 

United States Bankruptcy Court, Southern District of Florida 

Case No. 15-28093-BKC-PGH 

Evidence at Deposition and Trial 

Retained by: Deborah Menotte, Trustee 

Counsel: Kenneth Robinson, Esq. 

Opposing Counsel: Gary Goldstein, Esq, 

Issue: Avoidable Transfers and Solvency 

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 44 of 58
Alan R. Barbee, CPA/ABV 

Principal 

Direct: 561.657-4891 

Cell: 561.398.2025 

Email: abarbee@glassratner.com

GlassRatner Advisory & Capital Group LLC 2

 

Center for Child Development, Inc. 

United States Bankruptcy Court, Southern District of Florida 

Case No. 07-15574-BKC-PGH 

Evidence at Trial 

Retained by: Michael Bakst, Trustee 

Counsel: Nadine White-Boyd, Esq. 

Opposing Counsel: Tina Talarchyk, Esq, 

Issue: Avoidable Transfers and Solvency 

Center for Child Development, Inc. 

United States Bankruptcy Court, Southern District of Florida 

Case No. 07-15574-BKC-PGH 

Evidence by Deposition 

Retained by: Michael Bakst, Trustee 

Counsel: David Cimo, Esq 

Opposing Counsel: Jose Rojas, Esq 

Issue: Economic Damages, Forensic accounting, Avoidable 

Transfers, Solvency and Valuation 

Cascade International, Inc. 

United States Bankruptcy Court, Southern District of Florida 

Case No. 91-33703-BKC-RAM 

Evidence at Trial and Deposition 

Retained by: Kenneth A. Welt, Trustee 

Counsel: David Cimo, Esq. 

Issue: Claims Objections, Constructive Trust Tracing, and 

Economic Damages 

Corporate Communications Group, Inc. 

United States Bankruptcy Court, Southern District of Florida 

Case No. 97-10486-BKC-AJC 

Evidence by Deposition 

Retained by: Jeffrey H. Beck, Trustee 

Counsel: Lance Baker, Esq., Andrew Zaron, Esq. 

Opposing Counsel: Gary Freedman, Esq. 

Issue: Forensic accounting, Avoidable Transfers, Solvency, 

Substantive Consolidation and Valuation 

Custom Contractors, Inc. 

United States Bankruptcy Court, Southern District of Florida 

Case No. 09-24404-BKC-PGH 

Evidence at Trial and Deposition 

Retained by: Deborah Menotte, Trustee

Counsel: Steven Fender, Esq. 

Opposing Counsel: Phillip Doyle, US Attorney Trial Attorney 

Issue: Forensic Accounting, Solvency, Capital Adequacy and 

Valuation 

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 45 of 58
Alan R. Barbee, CPA/ABV 

Principal 

Direct: 561.657-4891 

Cell: 561.398.2025 

Email: abarbee@glassratner.com

GlassRatner Advisory & Capital Group LLC 3

 

Thomas D'Agostino, Sr. vs. Frederick J. Keitel, III, et.al. 

Circuit Court of the Fifteenth Judicial Circuit in and for Palm Beach County, 

Florida 

Case No. 502013CA004692XXXXMBAI 

Evidence at Trial 

Retained by: Plaintiff

Counsel: Eric Christu, Esq., Jonathan Hart, Esq. 

Opposing Counsel: Robert Stone, Esq. 

Issue: Forensic accounting and Economic Damages 

Evolution Imports, Inc. 

United States Bankruptcy Court, Southern District of Florida 

Case No. 96-21853-BKC-RBR 

Evidence at Trial 

Retained by: Kenneth A. Welt, Trustee

Counsel: Arthur Rice, Esq. 

Opposing Counsel: Patrick Scott, Esq. 

Issue: Forensic accounting, Claims Objections; Constructive 

Trust Tracing; Establishing Indebtedness; Equitable 

Subordination 

Genesis Press, Inc. vs. Hartford Casualty 

United States District Court, District of South Carolina 

Case No. 6:08-CV-2115-HMH 

Evidence at Jury Trial and Deposition 

Retained by: Plaintiff

Counsel: Dick Harpootlian, Esq. 

Opposing Counsel: Martin Disiere, Esq., Frankie Marion, Esq. 

Issue: Business Interruption Claim and Economic Damages 

Greenwood Partners 

United States Bankruptcy Court, Southern District of Florida 

00-33098-BKC-PGH 

Evidence by Deposition 

Retained by: Deborah Menotte, Trustee

Counsel: Michael Bakst, Esq. 

Opposing Counsel: Stephen Mayans, Esq. 

Issue: Forensic accounting, Avoidable Transfers, Valuation and 

Insolvency 

Bankruptcy Estate of Dr. James Alan Harrison, D.D. S. 

United States Bankruptcy Court, Southern District of Florida 

96-35373-PGH 

Evidence by Deposition 

Retained by: Patricia Dzikowski, Trustee

Counsel: Patricia Dzikowski, Esq. 

Issue: Business Valuation 

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 46 of 58
Alan R. Barbee, CPA/ABV 

Principal 

Direct: 561.657-4891 

Cell: 561.398.2025 

Email: abarbee@glassratner.com

GlassRatner Advisory & Capital Group LLC 4

 

Bankruptcy Estate of Ronald Hyman vs. Deon Burton 

United States Bankruptcy Court, Southern District of Florida 

09-14669-BKC-EPK 

Evidence at Trial 

Retained by: Robert Furr, Trustee 

Counsel: Robert C. Furr, Esq., Marc Barmat, Esq. 

Opposing Counsel: Pro-se 

Issue: Forensic Accounting, Tax Issues and Tax Refunds 

KB Aircraft Acquisition, LLC vs. BerryAir, LLC, Jack M. Berry Jr., J&H Grove 

Holdings, L.C. and Southern Air Systems, Inc. 

Circuit Court of the Thirteenth Judicial Circuit in and for Hillsboro County, Florida 

10-CA-22168-DIV-G 

Evidence at Trial 

Retained by: Plaintiff 

Counsel: Riley Cirulnick, Esq. 

Opposing Counsel: Patrick Lennon, Esq. 

Issue: Accounting and Forensic Accounting 

Kipu Systems, LLC vs. ZenCharts, LLC, Solutions Recovery, LLC, et.al. 

United States District Court, Southern District of Florida 

1:17-cv-24733-KMW-EGT 

Evidence at Jury Trial 

Retained by: Defendant

Counsel: Walter H. Boone, Esq. andAdam K. Israel, Esq. 

Opposing Counsel: Christopher B. Spuches, Esq., Mark Stein, Esq. and 

 Javier J. Rodriguez, Esq. 

Issue: Economic Damages 

Landmark at Sky Towers Suites, LLC and Fountainhead Sky Tower Suites 

Investors, LLC vs. Krandon International Management Group, LLC 

Circuit Court of the Thirteenth Judicial Circuit in and for Hillsboro County, Florida 

11-001922 

Evidence by Deposition 

Retained by: Defendant and Counter Plaintiff - Krandon 

International Management Group 

Counsel: Phillip Schwartz, Esq., Richard Martin, Esq., Christopher 

Carver, Esq., Stacy Rodriguez, Esq. 

Opposing Counsel: Robert L. Olsen, Esq., Joshua Smith, Esq. 

Issue: Economic Damages 

Label & Co. Developments, Inc. vs. DeBuys Property Investment Group, Ltd., 

et al. 

Circuit Court of the Fifteenth Judicial Circuit in and for Palm Beach County, 

Florida 

2011 CA-013872 XXXX MB 

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 47 of 58
Alan R. Barbee, CPA/ABV 

Principal 

Direct: 561.657-4891 

Cell: 561.398.2025 

Email: abarbee@glassratner.com

GlassRatner Advisory & Capital Group LLC 5

 

Evidence by Deposition 

Retained by: Plaintiff, Label & Co, Developments, Inc.

Counsel: Michael Joblove, Esq. 

Opposing Counsel: William J. Cornwell, Esq., David K. Freidman, Esq. 

Issue: Economic damages 

Michael Chow et.al. vs. Chak Yam Chua et.al. 

United States District Court, Southern District of Florida 

Case No. 09-21893-CIC-Hoeveler/ Garber 

Evidence at Jury Trial and Deposition 

Retained by: Defendants

Counsel: Anthony Accetta, Esq. 

Opposing Counsel: Curtis Miner, Esq. 

Issue: Economic damages 

Wells Fargo Bank, NA as Trustee for the Registered Holders of JP Morgan 

Chase Commercial Mortgage Securities Corp,, Commercial Mortgage PassThrough Certificates, L.T. Series 2003-PM1, by its special servicer, Orix Capital 

Markets, LLC vs. Palm Beach Mall, LLC, Simon Property Group, L.P. et.al. 

Circuit Court of the Fifteenth Judicial Circuit in and for Palm Beach County, 

Florida 

Case No. 502009CA013088XX 

Evidence by Deposition 

Retained By: Plaintiff, Orix Capital Markets, LLC as Special Servicer

Counsel: Matthew Chait, Esq. 

Opposing Counsel: David P. Ackerman, Esq., Paul Vizcarrondo, Esq., Ben 

Germana, Esq. 

Issue: Prevailing rates of expert witnesses 

Bankruptcy Estate of Jeffrey Prosser 

United States Bankruptcy Court, District of Virgin Islands 

Case No. 06-30009-BKC-JKF 

Evidence at Trial and Deposition 

Retained by: James Carroll, Trustee 

Counsel: Yann Geron, Esq., William Stassen, Esq. 

Opposing Counsel: Dustin McFaul, Esq. 

Issue: Forensic Accounting and Characterization of transactions 

Bankruptcy Estate of Jeffrey Prosser 

United States District Court, District of Virgin Islands 

Case No. 06-30009-BKC-JKF 

Evidence at Jury Trial 

Retained by: James Carroll, Trustee

Counsel: William Stassen, Esq. 

Opposing Counsel: Jeffrey Moorhead, Esq. 

Issue: Economic damages, Avoidable Transfers, Characterization 

of transactions, Forensic Accounting and Valuation 

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 48 of 58
Alan R. Barbee, CPA/ABV 

Principal 

Direct: 561.657-4891 

Cell: 561.398.2025 

Email: abarbee@glassratner.com

GlassRatner Advisory & Capital Group LLC 6

 

PSN USA, Inc. 

United States Bankruptcy Court, Southern District of Florida 

Case No. 02-11913-BKC-AJC 

Evidence at Trial 

Retained by: PSN USA, Inc. (Debtor)

Counsel: Robert Charbonneau, Esq. 

Opposing Counsel: Michael Seese, Esq. 

Issue: Forensic accounting, Avoidable Transfers, Valuation and 

Plan of Reorganization Confirmation 

R&J Roofing, Inc. 

United States Bankruptcy Court, Southern District of Florida 

Case No. 98-32072-BKC-SHF 

Evidence by Deposition 

Retained by: Patricia Dzikowski, Trustee

Opposing Counsel: John Walsh, Esq. 

Issue: Forensic accounting and Avoidable Transfers 

Rollaguard Security, LLC vs. Shamrock Jewelers, Inc., Anthony Simpson, et.al. 

United States Bankruptcy Court, Southern District of Florida 

Case No. 14-38071-BKC-EPK 

Evidence at Trial 

Retained by: Robert C. Furr, Trustee

Counsel: John Genovese, Esq. and Jesus Suarez, Esq. 

Issue: Forensic accounting 

S.E.C. vs. Victor Incendy, et al 

United State District Court, Southern District of Florida 

Case No. 95-8149-CIV-NESBITT 

Evidence by Deposition 

Retained by: Securities and Exchange Commission

Counsel: Glenn Harris, Esq. 

Issue: Forensic accounting, Damages and Disgorgement of 

Insider Trading Profits 

State of Florida vs. Craig Burton Danzig 

Circuit Court for the Nineteenth Circuit of the State of Florida, Martin County 

Case No. 43-2015-CF-001397-A 

Evidence at Jury Trial 

Counsel for State: Lev Evans, Esq. and Anastasia Norman, Esq. 

Opposing Counsel: Menachem Mayberg, Esq. 

Issue: Forensic Accounting, Tracing of Sources and Uses of 

Proceeds, Insolvency 

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 49 of 58
Alan R. Barbee, CPA/ABV 

Principal 

Direct: 561.657-4891 

Cell: 561.398.2025 

Email: abarbee@glassratner.com

GlassRatner Advisory & Capital Group LLC 7

 

Mohammed Saeme v. Philip Levine and Baron Wellness LLC. 

United States District Court, Southern District of Florida 

Case No. 11-civ-21913-UU 

Evidence by Deposition 

Retained by: Defendants

Counsel: Robert B. Miller, Esq., Alaina B. Siminovsky, Esq. 

Opposing Counsel: Larry A. Stumpf, Esq., Roy E. Black, Esq., 

Jared M. Lopez, Esq. 

Issue: Economic damages 

Seacoast 5151 Condominium Association, Inc. 

United States Bankruptcy Court, Southern District of Florida 

Case No. 99-11096-BKC-AJC 

Evidence at Trial 

Retained by: Seacoast 5151 Condominium Association, Inc. 

(Debtor) 

Counsel: Kenneth Robinson Esq., Kendall Coffey, Esq. 

Opposing Counsel: Peter Russin, Esq. 

Issue: Forensic accounting, Avoidable Transfers, Internal 

Controls, Solvency and Valuation 

Teligent Services, Inc. 

United States Bankruptcy Court, Southern District of New York 

01-12974-BKC-SMB 

Evidence at Trial and Numerous Depositions 

Retained by: Denise Savage, Litigation Trustee 

Counsel: Denise Savage, Esq. 

Opposing Counsel: Numerous 

Issue: Forensic accounting, Avoidable Transfers, Solvency and 

Valuation 

Tuttles Design Build, Inc. 

United States Bankruptcy Court, Southern District of Florida 

Case No. 98-33662-BKC-SHF 

Evidence by Deposition 

Retained by: Patricia Dzikowski, Trustee

Counsel: John Walsh, Esq. 

Issue: Forensic accounting, Avoidable Transfers and Valuation

Lawrence Weinstein MD. vs. Tenet Florida Physician Services, LLC 

Arbitration Hearing 

Case No. 71-166-00409-12 

Evidence at Arbitration Hearing 

Retained by: Plaintiff

Counsel: Robert B. Miller, Esq. 

Opposing Counsel: Martin Goldberg, Esq., Alan Lash, Esq. 

Issue: Economic Damages 

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 50 of 58
Alan R. Barbee, CPA/ABV 

Principal 

Direct: 561.657-4891 

Cell: 561.398.2025 

Email: abarbee@glassratner.com

GlassRatner Advisory & Capital Group LLC 8

 

XTEC, Incorporated vs. Hembree Consulting Services, Inc. and Larry Hembree 

United States District Court, Southern District of Florida 

Case No. 14-21029-CIV-Altonaga/ O'Sullivan 

Evidence at Jury Trial 

Retained by: Defendants 

Counsel: Thomas J. Meeks, Esq., Gregory M.Cesarano, Esq. 

Opposing Counsel: Eduardo I. Rasco, Esq., Steve Bimston, Esq. 

Issue: Economic Damages 

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 51 of 58
EXHIBIT A 

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 52 of 58
EXHIBIT A Adv. Avionics - $100K Payment

Chance & Anthem, LLC (Case No.: 18-16248-MAM)

Detail - Payments to Advanced Avionics

Four Year Period

Bank Entity Type

Check 

No. Date Memo

 Deposit/ 

Credit 

 Disbursement/ 

Debit 

SunTrust 6688 Chance & Anthem Check 1026 11/13/15 Panel Equipment & Initial Labor Deposit $ 100,000.00

Total $ - $ 100,000.00

GlassRatner Advisory & Capital Group, LLC Page 1 of 1

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 53 of 58
EXHIBIT A

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 54 of 58
EXHIBIT A

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 55 of 58
EXHIBIT A

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 56 of 58
EXHIBIT B 

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 57 of 58
EXHIBIT B Santa Barbara Flowchart

Chance & Anthem, LLC (Case No.: 18-16248-MAM)

Flowchart Tracing Referenced Funds

Santa Barbara House 11/6/15 Deposit of refinance 

proceeds to 

$704,974.57 into Chance & Anthem

11/9/15 - 1/4/16

13 cash withdrawals 

totaling $82,000

11/9/15 - 12/10/15 Five payments totaling

$107,500 to Jeffrey Siskind

12/7/15 Payment of $62,506 to 

Zokaites Property re: 

Loan Payoff 11/9/15 & 12/2/15 Two payments totaling 

$145,950 to George Maler 11/13/15 & 11/17/15 Two payments totaling 

$117,000 for aircraft 

related expenses 12/10/15 & 1/4/16 Two transfers totaling 

$60,000 to Siskind 

IOTA

11/10/15 - 12/28/15 Four transfers totaling 

$30,000 to Sovereign 

Gaming See detail for remaining $56,929.85

3/24/16 Deposit of refinance 

proceeds ot $100,00 

into Chance & Anthem

3/24/16 - 3/28/16 Six transfers totaling 

$48,625 to FLACC

3/29/16 Payment of $53,715.56 to 

Long Badger & Sheller LLP 

re: 27120 Gateway

($30,231.23 applies to 

$100,000) 3/25/16 Transfer of $10,000 to 

Siskind Legal See Detail for remaining $11,143.77

11/13/15 Payment of $61,719.63

to K Title Company 

LLC fbo Jeffrey Siskind

GlassRatner Advisory & Capital Group, LLC Page 1 of 1

Case 19-01298-MAM Doc 477-20 Filed 10/22/20 Page 58 of 58