Filing 60871664 E-Filed 08/24/2017 03:29:00 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA DAIVID FIORE et a1., Plaintiffs, v. Case No. JEFFREY SISKIND, et al., Defendants. MOTION TO DISMISS FOR FRAUD ON THE COURT AND LACK OF STANDING COMES NOW Defendants Jeffrey Siskind, William Siskind, Chance Anthem, LLC, Siskind Legal Services, LLC, Sovereign Gaming Entertainment, LLC, and all other Defendants against which Plaintiffs have brought claims but whose interests are not otherwise represented, by and through undersigned counsel, and move to dismiss Plaintiff?s Second Amended Complaint for fraud on the court and lack of standing at the inception of bringing suit, and state: 1. Plaintiff David Fiore iore?) originally brought this action on the premise that he had been assigned causes of action by Dianna George, Carl Stone, Lago De Talavera Trust. 2. When it became apparent to Flore that said causes of action were unassignable, which resulted from Defendants? ?ling of a motion for sanctions, Plaintiff revised his claims to state that he only partially possessed said causes of action, and the Court permitted Fiore to add three additional Plaintiffs. 3. Fiore?s amended and second amended complaints demonstrate that Fiore lacked standing which he alleged when the original complaint was filed, and this matter should therefore be dismissed. FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 08/24/2017 03:29:00 PM 4. The matter should also be dismissed for fraud on the court because Fiore?s initial false claims that he was assigned others? causes of action, at least one of which he had expressly released, and the addition of one or more new plaintiffs who also lack standing, constitutes a scheme sentiently set in motion and calculated to interfere with administration of justice by Fiore at the outset, and then with the knowledgeable participation of Dianna George, Carl Stone and Michael Haggerty on behalf of the Lago De Talavera Trust 5. One such false Plaintiff, Dianna George (?Dianna?), provided proof to the Court that funds which she alleges belonged to her and were misappropriated by Siskind Legal Services, LLC and/or other defendants actually belonged to her estranged husband who is currently serving a sentence in Federal Prison. 6. Dianna, herself an eX-felon who participated in the same ?pill mill? conspiracy which landed brothers Christopher George (?Chris?) and Jeffrey George in prison, has provided no proof whatsoever that she is a legitimate plaintiff in this action. 7. Dianna, who was taped saying to Chris that ?she would take the wrap? for his illegal drug dealing activity, was convicted for lying to federal prosecutors. 8. Plaintiff Lago De Talavera Trust which has alleged wrongdoing on the part of one or more defendants, but which gave defendant Sovereign Gaming Entertainment, LLC a deed in lieu of foreclosure to the real property located at 3485 Lago De Talavera, Wellington, Florida, is overseen by Michael Haggerty (?Haggerty?) 9. Haggerty is married to Dianna?s eX-mother-in-law (who also went to prison for her complicity in the pill mill scheme), and it was in Haggerty?s attic that federal investigators discovered millions of dollars in hidden ill-gotten gains from the George brothers? pill mill operations. 10. Fiore, who serves as ringleader of the ?replacement plaintiffs,? is no angel either. It was in Fiore?s West Palm Beach strip club that an automatic weapon recently ?fell of the shelf? in an of?ce, discharged and killed a maintenance worker working on an air conditioner in the next room. 11. Fiore, a co-owner of Tobacco World, a West Palm Beach paraphernalia store, suffered a civil forfeiture and narrowly escaped prosecution for drug crimes by service as a con?dential informant for the Palm Beach County Sheriff?s Department. 12. Defendants provided the Court with initialed promissory notes which prove that the $2 million which Dianna claims she lost was actually loaned by Chris to Sovereign; she thus has no valid claim against any defendant. 13. Haggerty voluntarily assigned his trust?s interest in the Lago De Talavera property to Sovereign in order to avoid a foreclosure sale which would likely result in a de?ciency judgment against the trust, and therefore does not possess a valid claim against any defendant. 14. Fiore, who currently alleges that he and Carl Stone are partners, signed a written release which bars any claim to the original $800,000 which was provided for his bene?t by Carl Stone and used to acquire the property located at 3445 Santa Barbara Drive, Wellington, Florida. Moreover, Fiore actively planned and facilitated the scheme to wrongfully assert claims against all defendants by ?rst bringing claims which he knew to be false individually as a purported assignee and then, with assistance of his counsel, assembling the replacement Plaintiffs to further the scheme. 15. Florida law provides that when a plaintiff lies to the court on matters central to the claim, which impede the ability to defend or undermine the truth-seeking function of the court, dismissal of the claim may be appropriate. See, e. Ramey v. Haverty Furniture Cos, 993 So. 2d 1014, 1018 (Fla. 2d DCA 2008) trial court has the inherent authority to dismiss an action as a sanction when the plaintiff has perpetrated a fraud on the court. ?Such power is indispensable to the proper administration of justice, because no litigant has a right to tri?e with the 16. The basis for keeping clearly fraudulent claims entirely out of court is that ?a party who has been guilty of fraud or misconduct in the prosecution or defense of a civil proceeding should not be permitted to continue to employ the very institution it has subverted. See Andrews v. Palmas De Majorca Condo, 898 So. 2d 1066, 1069 (Fla. 5th DCA 2005).? WHEREFORE, Defendants Jeffrey Siskind, William Siskind, Chance Anthem, LLC, Siskind Legal Services, LLC, Sovereign Gaming Entertainment, LLC, and all other Defendants against which Plaintiffs have brought claims but whose interests are not otherwise represented request dismissal of this matter for lack of standing at the time suit was filed and for fraud on the court, and for such other and further relief as appropriate in the circumstances. SISKIND LEGAL Jeffrey Siskind Jeffrey M. Siskind, Esquire FBN 138746 525 S. Flagler Drive, Ste. 500 West Palm Beach, FL 33401 TEL (561) 791-9565 FAX (561) 791-9581 Email: ieffsiskind@msn.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing motion was served upon all appropriate parties this 24th day of August, 2017 by Florida?s E-service Portal. Jeffrey Siskind Jeffrey M. Siskind, Esquire FBN 1 3 8746