UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION

www.flsb.uscourts.gov

In re: Case No. 18-16248-BKC-MAM

Chapter 7

CHANCE & ANTHEM, LLC,

Debtor.

/

ROBERT C. FURR not individually but ADV. NO. 19-01298-BKC-MAM-A 

as Chapter 7 Trustee of the estate of the

Debtor, Chance & Anthem, LLC, 

Plaintiff,

v.

JEFFREY M. SISKIND, individually and 

d/b/a SISKIND LEGAL SERVICES,

TANYA SISKIND, individually and as Trustee of the, 

SECOND SISKIND FAMILY TRUST,

FRANK ZOKAITES, individually,

ORDERED in the Southern District of Florida on September 10, 2019.

Mindy A. Mora, Judge

United States Bankruptcy Court

_____________________________________________________________________________

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CANNAMED PHARMACEUTICALS, LLC,

a Maryland Limited Liability Company, 

OB Real Estate 1732, LLC, a

Florida Limited Liability Company, 

SISKIND LEGAL SERVICES, LLC,

a Florida Limited Liability Company,

SOVEREIGN GAMING & ENTERTAINMENT, LLC,

a Florida Limited Liability Company 

FLORIDA'S ASSOCIATION OFCOMMUNITY

BANKS AND CREDIT UNIONS, INC. a Florida Corporation, 

SYMPATICO EQUINE RESCUE, INC, a Florida Corporation, 

WELLINGTON 3445, LP, a Florida Limited Partnership, 

ZOKAITES PROPERTIES, LP, a Pennsylvania Limited Partnership, 

and ROBERT GIBSON, individually.,

Defendants.

/

AGREED ORDER GRANTING IN PART

CHAPTER 7 TRUSTEE ROBERT C. FURR’S EXPEDITED 

MOTION FOR PRELIMINARY INJUNCTION AND OTHER 

RELIEF AND SCHEDULING STATUS CONFERENCE ON

OCTOBER 16, 2019 AT 2:30 P.M.

THIS MATTER came before the Court on August 9, 2019 at 10:30 a.m. (the “Hearing”) 

upon the Expedited Motion for Preliminary Injunction and Other Relief (the “Motion”) filed by 

Plaintiff Robert C. Furr (the “Trustee”) in his capacity as chapter 7 Trustee of estate of the Debtor, 

Chance & Anthem, LLC (the “Debtor” or “C&A”). The Court, having (A) heard the argument and 

Trustee’s proffer of evidence; (B) noted the agreement of (i) Jeffrey Siskind (“Siskind”); (ii) Tanya 

Siskind (“T. Siskind”); (iii) Second Siskind Family Trust (“Family Trust”); (iii) CannaMED 

Pharmaceuticals, LLC (“CannaMED”); (iv) Siskind Legal Services, LLC (“Siskind Legal”), (v) 

Sympatico Equine Rescue, Inc. (“Sympatico”); (vi) Florida’s Association of Community Banks & 

Credit Unions, Inc. (“FLACC”); (vii) and Robert Gibson, and (C) further noted the agreement 

between the Trustee and (i) Frank Zokaites, (ii) Zokaites Properties, LP, OB Real Estate 1732, 

LLC and (iii) Wellington 3445, LP (the “Zokaites Parties”), and being otherwise duly advised in 

the premises, hereby finds good cause for the relief sought for the reasons stated on the record. 

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Accordingly, the Court, FINDS as follows:

A. In the Motion, the Trustee sought the entry of a preliminary injunction with notice 

to the Defendants.1

B. Prior to the Hearing, the Trustee and the Zokaites Parties reached an agreement on 

the Court’s entry of a preliminary injunction consistent with the terms of this Order, which 

agreement was announced on the record and is incorporated in Paragraph 2 of this Order.

C. On August 8, 2019, Defendant Siskind filed his Response to the Trustee’s Motion 

for Preliminary Injunction [ECF No. 9] (the “Response”) wherein Defendant Siskind “join[ed] in 

the Trustee’s request for preliminary injunction” as to SLS, Sympatico, FLACC, the Family Trust, 

and CannaMED. Furthermore, at the Hearing, the Court, without objection, noted the agreement 

among the parties that a preliminary injunction would issue with respect to SLS, Sympatico, 

FLACC, the Family Trust, and Cannamed.

D. At the Hearing, Defendant Siskind stipulated that he is not in possession of any of 

the Protected Transfers (defined in Paragraph 3(b) of this Order), or the proceeds, products, or 

replacements of such Protected Transfers.2 Defendant Siskind also stipulated and agreed to the 

entry of a preliminary injunction with respect to the Protected Transfers, and the proceeds, 

products, or replacements of such Protected Transfers as of the date of the Hearing.3

E. In light of the agreements of the Zokaites Parties, SLS, Sympatico, FLACC, the 

Family Trust, CannaMED and Siskind, the Court notes that the parties have agreed that a 

preliminary injunction which would serve to maintain the status quo in order to preserve this

1 Defendant SOVEREIGN GAMING & ENTERTAINMENT, LLC (“Sovereign”) did not appear at the Hearing and

the Trustee advised the Court that service may not have been perfected upon Sovereign. Accordingly, the Trustee 

abated his request as to Sovereign at the Hearing. Siskind, T. Siskind, Family Trust, Cannamed, Sympatico and 

FLACC shall be referred to as the (“Consenting Defendants”). 2 See Transcript of August 9, 2019 Hearing, ECF No. 11, 42:2 – 43:8.

3 Id.

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Court’s ability to award legal equitable relief and provide for distribution to the Debtor’s creditors.

Accordingly, the Court ORDERS as follows:

1. The Motion is granted in part as set forth herein, on and effective as of the 9th day 

of August, 2019, at 10:30 a.m. The Court will hold a status conference regarding this Order on

October 16, 2019 at 2:30 p.m.

2. Pending further Order of the Court and except as otherwise provided herein, and in 

accordance with the agreement by and among the Trustee and the Zokaites Parties, the Zokaites 

Parties are enjoined from selling, transferring, further hypothecating, collateralizing, or 

encumbering the mortgage on the Talavera House4. Subject to and without limiting the foregoing 

injunctive relief, the Trustee will withdraw all other requests for injunctive relief sought in the 

Motion by the Trustee against the Zokaites Parties.

3. Pending further order of the Court and except as otherwise provided herein, and in 

accordance with the agreements and/or stipulations noted in Paragraphs D and E of this Order, a 

preliminary injunction shall be and is hereby entered against the Consenting Defendants, and each 

of their third party counterparties or creditors, attorneys, agents, employees and all persons and 

entities having actual knowledge of the preliminary injunction as follows:

a. The Consenting Defendants, their third party counterparties or creditors, 

attorneys, agents, employees and all persons and entities having actual knowledge of the 

preliminary injunction upon having been served with notice of this Order, are enjoined 

from (i) directly or indirectly, transferring, selling, assigning, pledging, hypothecating, 

encumbering, or disposing of any proceeds, products, or replacements of the Protected 

Transfers, in any manner; (ii) causing the Protected Transfers, or the proceeds, products,

4 All capitalized terms not otherwise defined in this Order shall have the meaning ascribed to them in the Motion.

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or replacements of the Protected Transfers, to be transferred, sold, assigned, pledged, 

hypothecated, encumbered, disposed of in any manner; or (iii) taking, or causing to be 

taken, any action that would have the effect of depreciating, damaging, or in any way 

diminishing the value of the Protected Transfers, or the proceeds, products, or replacements 

of the Protected Transfers, except as provided herein.

b. The Protected Transfers are defined as the following transfers of cash as well 

as their products, proceeds and replacements:

1. Transfers between 02/13/14 and 6/23/14 from Sovereign in the

total amount of $1.15 million to FLACC, of which (i) $25,000 was transferred to 

Siskind Legal on 02/27/14 and $25,000 was transferred to Siskind on 3/31/14.

2. Transfer of $35,000 from Debtor to FLACC on 10/7/15 and thereafter 

to Siskind on 10/9/15. Transfer of $59,500 from Debtor on 10/9/15 to purchase 

Mercedes titled in the name of Family Trust, however this order shall not restrict the 

use of the subject vehicle. Transfer of $750,000 from the Debtor to FLACC on 

10/21/15.

3. Transfers of $230,000 from Debtor to FLACC between 11/13/14 and 

5/11/15, of which (i) $188,000 was transferred to Siskind between 11/14/14 and 

5/12/15; and (ii) $15,000 to Siskind Legal on 11/14/14. Transfers of $101,500 from 

Debtor to Siskind between 11/12/14 and 11/9/15. Transfers totaling $100,000 from 

Debtor to Siskind’s IOTA between 11/25/14 and 06/19/15.

4. Two transfers totaling $29,000 to Siskind Legal from refinance of 

Talavera House on 05/13/16 and 05/26/16, and the transfer of $15,000 to FLACC 

from the Debtor on 05/16/16. The interests of the Consenting Defendants in the 

Talavera House, including Zokaites Properties, LLC by consent in the Talavera 

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House.

5. Transfers of $107,500 from Debtor to Siskind from 11/9/15 to 

12/15/15. Thirteen cash withdrawals from Debtor totaling $82,000 from 11/9/15 to 

01/04/16. Two Transfers totaling $60,000 from Debtor to Siskind’s IOTA. Four 

transfers totaling $30,000 from Debtor to Sovereign between 11/10/15 and 12/28/15. 

Six transfers totaling from Debtor $48,625 to FLACC between 03/24/16 and 

03/28/16. $10,000 transferred from the Debtor on 03/26/16 to Siskind Legal.

6. Transfers of $100,000 to FLACC in part from refinance of Office 

Space owned by OB Real Estate on 12/4/14 & 12/17/14. Two transfers of $35,000 

to Jeffrey Siskind on 4/2/15 and 4/21/15 from six deposits totaling $110,000 from 

OB Real Estate and FLACC.

7. The transfers to Jeffery and Tanya Siskind from the Debtor identified 

in Exhibit A and B of the Complaint, which are further attached to this order.

c. All counterparties, creditors or claimants of the Consenting Defendants, or 

any person acting on their behalf, that have received notice of this Order are enjoined from 

taking any action to interfere with the control, possession, or management of the Protected 

Transfers, except as provided herein.

d. Notwithstanding anything herein to the contrary, all lawful defenses as may 

be raised by counterparties, creditors or claimants of the Consenting Defendants shall be 

unimpaired by this Order.

4. The Trustee’s request for expedited discovery is withdrawn without prejudice and 

therefore moot.

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5. The Court reserves jurisdiction to enforce, effectuate or modify the terms of this 

Order as may be lawful and just.

# # #

Submitted by:

Jesus M. Suarez, Esq.

GENOVESE JOBLOVE & BATTISTA, P.A.

100 Southeast Second Street, Suite 4400

Miami, Florida 33131

Telephone: (305) 349-2300

Facsimile: (305) 349-2310 

Email: jsuarez@gjb-law.com

Copy furnished to:

Jesus M. Suarez, Esq., who shall serve a copy of this Order 

upon the Defendants, and to the extent applicable, their counsel)

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