UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

 Case No.: 18-16248-BKC-MAM 

IN RE: Chapter 7

CHANCE & ANTHEM, LLC,

Debtor.

____________________________________/

ROBERT C. FURR, not individually but 

as Chapter 7 Trustee of the estate of the 

Debtor, Chance & Anthem, LLC,

Plaintiff.

v. Adv. Proc. No.: 19-01298-BKC-MAM

JEFFREY SISKIND, et al.,

Defendant/Counter-Plaintiff,

v.

ROBERT C. FURR, individually and not as

Chapter 7 Trustee, JESUS SUAREZ and

GENOVESE JOBLOVE AND BATTISTA, P.A.

Counter-Defendants.

____________________________________/

DEFENDANT JEFFREY M. SISKIND’S INITIAL DISCLOSURES PURSUANT

TO FEDERAL RULE OF BANKRUPTCY PROCEDURE 26(A)(1)

JEFFREY M. SISKIND (“Defendant/Counter-Plaintiff”) hereby files its Initial 

Disclosures Pursuant to Federal Rule of Bankruptcy Procedure 26(a)(1), and states:

I. Witnesses:

At the present time, subject to amendment, Defendant/Counter-Plaintiff hereby adopts

and incorporates the disclosures of the names and, if known, the addresses and telephone 

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numbers of each individual likely to have discoverable information that the disclosing party may 

use to support its claims or defenses, unless the use would be solely for impeachment, as is stated 

in the disclosures provided by the related defendants in this matter and those already provided by 

the Chapter 7 Trustee, and hereby adds thereto the following: Robert C. Furr in his individual

capacity and not as Chapter 7 Trustee, Jesus Suarez, Esq. and the corporate representative of 

Genovese Joblove & Battista, P.A., whose addresses are c/o Genovese Joblove & Battista, P.A., 

100 S.E. Second Street, 44th Floor, Miami, Florida 33131; Telephone: (305) 349-2300. These 

witnesses shall testify as to the Capter 7 Trustee’s role, transactions related to the Chapter 7 

Trustee and its counsel, as well as their own business affairs, and shall further testify as to other 

transactions referenced within the Defendant/Counter-Plaintiff’s Counterclaims. In addition 

thereto, any additional witnesses later disclosed by Plaintiff and/or Counter-Defendants, any 

witnesses necessary for rebuttal or impeachment, any and all additional witnesses which may be 

relied upon by the Plaintiff and/or Counter-Defendants and any and all rebuttal witnesses as may 

be deemed necessary.

II. Documents:

Pursuant to Federal Rule of Bankruptcy Procedure 26(a)(1)(B), Defendant/CounterPlaintiff will provide a copy of, or description by category, all documents, data compilations, and 

tangible things that are in his possession, custody or control and that it may use to support its 

claims, unless solely for impeachment, including: 

(a) Copies of Debtor’s Petition, Schedules, Statement of Financial Affairs and 

all amendments thereto, as filed in the case style, In Re: Chance & Anthem, LLC, 18-16248-

BKC-MAM (“Main Case).

(b) All hearing and Rule 2004 examination transcripts, including exhibits in 

the Main Case, In Re: Chance & Anthem, LLC, 18-16248-BKC-MAM.

(c) Copies of any and all deposition transcripts taken within this adversary 

proceeding, of all persons, including all attachments and exhibits to same, no matter the party 

who initially conducted said deposition.

(d) Any and all documentation produced by the Plaintiff pursuant to discovery 

requests served upon him by Defendant/Counter-Plaintiff or any of the co-defendants in this 

matter.

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(e) Any and all documents produced by third parties pursuant to Subpoenas 

issued in the Main Case.

(f) Any and all attachments to the Plaintiff’s complaint.

(g) Any and all documents relied upon by the Plaintiff.

(h) Any and all rebuttal documents as may be deemed necessary.

III. Status of Discovery.

Contrary to the Chapter 7 Trustee’s (“Trustee”) disclosure, Defendant/Counter-Plaintiff is 

not in the possession of any documents which the Trustee intends to rely upon at trial and 

requests that the Trustee supply these to Defendant forthwith. The Trustee continues to prevent 

Defendant from obtaining discovery. Defendant/Counter-Plaintiff is continuing to conduct 

discovery related to this matter and reserves the right to supplement its Initial Disclosures as 

required by Federal Rule of Bankruptcy Procedure 26(e). Defendant/Counter-Plaintiff further 

reserves the right to object to the admission of any of the aforementioned documents, witnesses, 

and/or computations. Defendant/Counter-Plaintiff hereby demands that the Trustee immediately 

produce any and all records upon which the Trustee intends to rely upon at trial. 

Defendant/Counter-Plaintiff’s objections will include motions to prevent the Trustee form using 

information that the Trustee has failed to disclose to Defendant/Counter-Plaintiff. The case is 

therefore not at issue.

IV. Damages

Defendant/Counter-Plaintiff requests that the Court enter judgment against the Trustee 

and Counter-Defendants in accordance with Defendant/Counter-Plaintiff’s responses to 

Plaintiff’s allegations in its First Amended Adversary Complaint, as well as Defendant/CounterPlaintiff’s amended affirmative Defenses and Counterclaims, including but not limited to 

rejection of the Trustee’s ability to represent creditors of the estate and to recover transfers for

the benefit of the estate, including any amount or value of transfers at issue, including interest 

and costs, and permits creditors to negotiate voluntary repayment arrangements with third parties 

independent of the Trustee.

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V. Insurance

Upon information and belief, the Trustee and Counter-Defendants are covered by one or 

more insurance policies which may provide for payment of any damages which may be assessed 

in favor of Defendant/Counter-Plaintiff and against the Trustee and Counter-Defendants. No 

disclosure of insurance coverage(s) has been obtained by Defendant/Counter-Plaintiff, and

demand is hereby made for all pertinent information pertaining to said coverage(s).

Dated April 10, 2020.

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

_______/s/ Jeffrey M. Siskind_______

Jeffrey M. Siskind, Esq. FBN 138746

1629 K Street, Ste. 300, NW Washington, DC 20006

113 N. Monroe Street, 1st Floor Tallassee, Florida 32301

3465 Santa Barbara Drive Wellington, Florida 33414

TELEPHONE (561) 791-9565 FACSIMILE (561) 791-9581

Email: jeffsiskind@msn.com

CERTIFICATE OF SERVICE

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

April 10, 2020 upon all parties in interest registered to receive electronic notification on this 

case via the Court’s Case Management/Electronic Case Filing System and/or email as 

reflected on the Service List below. 

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

_______/s/ Jeffrey M. Siskind_______

Jeffrey M. Siskind, Esq. FBN 138746

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