Filing 53783431 E-Filed 03/15/2017 04:00:46 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA DAVID FIORE et al., Plaintiff, v. Case No. JEFFREY M. SISKIN D, et al., Defendants. EMERGENCY VERIFIED MOTION FOR PROTECTIVE ORDER TO PROHIBIT DIS- CLOSURE OF BANKING RECORDS AND INCORPORATED MEMORANDUM OF LAW Nature of Emergency: Plaintiffs have short-noticed a Deposition Duces ecam which impermissibly requires production by three separate ?nancial institutions of all of Defendants private business and personal banking records, including the IOTA account records of Defendant Je??rey M. Siskind, Esq. which contains private and con?dential client transactional information. COMES NOW Defendants Jeffrey M. Siskind, William Siskind, Florida?s Association of Community Banks and Credit Unions, Inc., Sympatico Equine Rescue, Inc. and Sovereign Gaming Entertainment, LLC, by and through their undersigned counsel, and move for issuance of a Protective Order to prohibit disclosure of Defendants? banking records, to require Plaintiff?s counsel to forward said Protective Order to each of the ?nancial institutions which were served with Plaintiffs? Notice of Depositions Duces Tecum and ?le proof of service of same with the Court, and to keep con?dential and immediately destroy any such records which may be inappropriately provided as a result of Plaintiffs? Notice of Taking Depositions Duces Tecum. and state: 1. On March 8, 2017, Counsel for Plaintiffs issued a Notice of Taking Depositions Duces Tecum of records custodians of Wells Fargo Bank, Chase Bank and Suntrust Bank. See ?Exhibit attached. Pursuant to said notice, the records custodian of each of the three named FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 03/15/2017 04:00:46 PM institutions was requested to bring all documents pertaining to banking records belonging to each of the named defendants, and including the IOTA account records for attorney Jeffrey M. Siskind, from YR 2013 to the present. 2. The Notice of Taking Depositions Duces Tecum, which requested that documents be produced on March 28, 2017, is defective ab initio for Plaintiffs? failure to provide thirty (30) days to respond as required by F1. Rule of Civil Procedure and Fl. Rule of Civil Procedure 1.3 50(b). Plaintiff?s counsel?s ill~timed notice instead provided only twenty (20) days. 3. The private ?nancial information requested to be produced is sought by Plaintiffs to shore up Plaintiffs? improperly ?led amended complaint, which lacks presentation of sufficient facts on which to base Plaintiffs? allegations, constitutes an attempt to cast an impermissibly wide net, and amounts to an improper ??shing expedition.? Florida courts do not allow fishing expeditions disguised as discovery requests. Walter v. Page, 638 So. 2d 1030 (Fla. 2d DCA 1994). 4. Essential issues presented by Plaintiff in the case essentially concern whether Jeffrey M. Siskind imprOperly used $2,000,000 which was allegedly provided by Dianna George and $800,000 which was allegedly provided by Carl Stone and David Fiore, and whether Sovereign?s interest in real property known as 3485 Lago De Talavera was improperly obtained by the ?ling of a foreclosure suit and receipt of a deed in lieu of foreclosure. 5. In Plaintiffs? original complaint, David iore alleged that he possessed assignments of the interests of Dianna George and Carl Stone, but subsequently sought to amend by adding Dianna George, Carl Stone and 3485 Lago De Talavera Trust as co-Plaintiffs after Defendants showed that said claims were not assignable to Fiore. Although Dianna George purports to assert standing because she allegedly advanced funds to one or more Defendants, she really only did so on behalf of her ex-husband, Christopher George, who was at the time and remains in prison, pursuant to loan transactions evidenced by two promissory notes which bear Christopher George?s initials in the upper right-hand corners. See ?Exhibit attached. 6. David iore (the original Plaintiff) presumably still asserts standing by virtue of purported assignments from Dianna George, Carl Stone and Lago De Talavera Trust (copies of which were never provided by iore) or a partnership arrangement with Carl Stone involving $800,000 in funding for a residential house remodel and ?ip project, which use of funds is re?ected by Jeffrey M. Siskind?s ?3445? trust account ledger card. See ?Exhibit attached. However, David Fiore?s total lack of standing is evidenced by his signed release which Defendants attached to their response to Plaintiffs? original complaint. See ?Exhibit attached. 7. In addition to questions about standing, the Plaintiffs? amended complaint fails to allege facts suf?cient to base any of the allegations made against any Defendants. Instead, Plaintiffs posed their bare allegations with the obvious hope of later obtaining suf?cient facts to back them up. This strategy amounts to an improper method of discovery under the rules and relevant case law. At the same time, Plaintiffs simply refuse to recognize the validity of certain evidence which is readily available by means of public record, including the Deed in Lieu of Foreclosure which conveyed the property the propeity located at 3485 Lago De Talavera, Lake Worth, Florida to Defendant Sovereign Gaming Entertainment, LLC, attached hereto as ?Exhibit choosing instead to seek less probative evidence. 8. Additionally, Plaintiffs? demand for production of Defendants? private personal business ?nancial records and Plaintiffs? wholesale demand for over six years of Jeffrey M. Siskind?s IOTA account records is not reasonably calculated to lead to any probative evidence relevant to Plaintiffs? claims, especially when considering the true nature of the transactions alleged to be improper upon the substantial evidence of same attached to this motion. An attorney?s IOTA records, to a greater extent than private personal and business records, contain a great deal of privileged and irrelevant information. Sensitive information attendant to an attomey?s IOTA account records belongs to legal clients who have an expectation of privacy, which expectation clearly outweighs release of same absent some overwhelming demonstration of relevancy. 9. Responses to Plaintiffs? Notice of Depositions Duces Tecum should be prohibited because it improperly seeks production of private ?nancial information without any relevant or compelling reason for doing so. ?Article 1, Section 23 of the Florida Constitution protects the ?nancial information of persons if there is no relevant or compelling reason to compel disclosure.? Rowe v. Rodriguez-Schmidt, 89 So. 3d 1101, 1103 (Fla. DCA 2012) (citing Borck v. Borck, 906 So. 2d 1209, 1211 (Fla. 4th DCA 2005)). ?This is because ?personal ?nances are among those private matters kept secret by most people.?? Id. (citing Woodward v. Berkery, 714 So.2d 1027, 1035 (Fla. 4th DCA 1998)). 10. Furthermore, the actions of several of the Plaintiffs and related family members as described herein raise additional concerns and make the Plaintiffs? disclosure request especially troubling. The danger demonstratedly unique to this case of public disclosure of Defendants? private personal and business banking records, especially those which pertain to IOTA account transactions involving clients of attorney Jeffrey M. Siskind, is discernable because of Plaintiffs? recent harassing actions and those undertaken by John George (Plaintiff Dianna George?s ex- father-in-law), as follows: 11. On February 22, 2017, John George left a voicemail message on the Wellington Village Council, in which he defamed Defendant Jeffrey M. Siskind (Councilwoman Tanya Siskind?s husband) and accused him of committing illegal acts. An accurate transcript of said voicemail message is attached as ?Exhibit Also on February 22, 2017, Dianna George utilized social media to defame Defendant Jeffrey M. Siskind by ?check[ing] in? with Facebook posts accusing him of wrongdoing, and encouraged the ?sharing? of said posts. She alleged that she was at various times during that day ?ling reports at the City of West Palm Beach Police Department and local FBI Of?ce. See Facebook post attached as ?Exhibit That afternoon, John George telephoned Defendant Jeffrey M. Siskind from the FBI of?ce where he stated he was together with Dianna George and David Fiore, and urged him to ?turn [him]self in.? 12. On or about February 27, 2017, John George sent a diSparaging letter to persons related to entities which are tied to Defendant Jeffrey M. Siskind as identi?ed by SunBiz listings. A copy of this letter is attached as ?Exhibit 13. On Friday, March 10, 2017, John George sent a letter to the of?ces of the Village of Wellington by facsimile which evidenced the tender of a $2,000,000 wire by Christopher Paul George to Defendant Jeffrey M. Siskind which contained more outrageous allegations of wrongdoing. The wire was pursuant to a wire order signed by Dianna George on behalf of Christopher George from Christopher George?s bank account pursuant to a power of attorney. See ?Exhibit attached. 14. Several actions by Plaintiff David Fiore included improperly ?ling a Lis Pendens against real property located outside of Palm Beach County, which action was undertaken by iore pro se and, upon information and belief, without his counsel?s knowledge. A copy of the recorded Lis Pendens is attached as ?Exhibit In recent weeks, David Fiore also boasted that he had made numerous disparaging telephone calls to Maryland of?cials in order to derail a business undertaking belonging in part to Defendant Jeffrey M. Siskind, including a confirmed telephone call to the company?s CEO/President, and further stated that his several calls succeeded in preventing Jeffrey M. Siskind from obtaining a license to engage in a valuable business opportunity. 15. There is no reason to believe that this behavior will cease without Court intervention. These Plaintiffs? and related parties? actions indicate how any ?nancial information disclosed to Plaintiffs is likely to be utilized to disparage one or more Defendants and how the privacy of third party clients of attorney Jeffrey M. Siskind may be adversely affected if disclosure of Defendants? financial information is not prohibited. MEMORANDUM OF LAW Florida?s Rules of Civil Procedure govern the manner in which Plaintiff may seek to obtain discovery and the extent of matters discoverable. Florida Rule Civ. Pro. sets forth general provisions governing discovery and states that ?Parties may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter of the pending action, whether it relates to the claim or defense of the party seeking discovery or the claim or defense of any other party, including the existence, description, nature, custody, condition, and location of any books, documents, or other tangible things and the identity and location of persons having knowledge of any discoverable matter.? Florida Rule Civ. Pro 1.280(c) addresses use of protective orders, and states that ?Upon motion by a party or by the person from whom discovery is sought, and for good cause shown, the court in which the action is pending may make any order to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense that justice requires, including one or more of the following: (1) that the discovery not be had; (2) that the discovery may be had only on speci?ed terms and conditions, including a designation of the time or place; (3) that the discovery may be had only by a method of discovery other than that selected by the party seeking discovery; (4) that certain matters not be inquired into, or that the scope of the discovery be limited to certain matters; (5) that discovery be conducted with no one present except persons designated by the court; (6) that a deposition after being sealed be opened only by order of the court; (7) that a trade secret or other con?dential research, development, or commercial information not be disclosed or be disclosed only in a designated way; and (8) that the parties simultaneously ?le speci?ed documents or information enclosed in sealed envelopes to be opened as directed by the court.? Florida Rule Civ. Pro. 1.310 and 1.350 address the issue of adequate notice. Deponents cannot be compelled by subpoena to produce documents or items for inspection within less than 30 days after service. This is true even when the document production is sought in conjunction with a proposed deposition at the same time pursuant to the subpoena. See Ohio Casualty Insurance Company v. Jackman, 621 So.2d 531 (Fla. 2d DCA 1993) at footnote 1. Florida?s Constitution, in Article I, Sectiojn 23. guarantees a right to informational privacy. One of the principal concerns of the drafters of the amendment to the Florida Constitution that became Article 1, Section 23 was the right to informational privacy. The constitutionally protected right to privacy ?ensures that individuals are able ?to determine for themselves when, how and to what extent information about them is communicated to others? Shakman v. State, 553 So.2d 148, 150 (Fla. 1989) (quoting A. Westin, Privacy and Freedom 7 (1967)). Plaintiffs have a burden to prove that Plaintiffs need the otherwise private ?nancial information which Plaintiffs are attempting to discover, and that the Plaintiffs? chosen method of discovery is the least intrusive means of obtaining it. As the Florida Supreme Court noted, ?Although the general concept of privacy encompasses an enormously broad and diverse ?eld of personal action and belief, there can be no doubt that the Florida amendment was intended to protect the right to determine whether or not sensitive information about oneself will be disclosed to others, including a person?s social security number. See Rasmussen v. South Florida Blood Service, 500 So. 2d 533, at 536. See also Thomas v. Smith, 882 So.2d 1037 (2004). It is thus obvious that private, sensitive, and con?dential information regarding individuals is protected by the privacy clause in the Florida Constitution. No less intrusive methods of obtaining relevant information has been properlv explored by Plaintiffs. The Second DCA in Thomas went on to state that if a person has a legitimate expectation of privacy in the information at issue then the burden is on the party requesting otherwise private information to show that there is a compelling interest warranting the intrusion into the individual?s privacy and the intrusion is accomplished by the least intrusive means. 882 So. 2d at 1044. See Young v. Santos, 61] So. 2d 586 (Fla. 4th DCA 1993). Also see Rasmussen v. South Florida Blood Service, Inc, 500 So. 2d 533 (Fla. 1987), regarding the trial court's broad discretion to limit or prohibit discovery to protect the privacy of a witness or party. Plaintiffs? Notice of Depositions Duces Tecum seeks documents that are irrelevant and call for disclosure of protected financial information. Plaintiffs? Notice of Depositions Duces Tecum seeks irrelevant documents, (ii) impermissibly seeks discovery of private ?nancial information and likely constitute impermissible and premature discovery in aid of execution, and are exceedingly overbroad. Documents are relevant if they relate to a claim or defense of a party. See Fla.R.Civ.P. While the permissible scope of discovery is indeed broad, it is not unlimited. See East Colonial Refuse Serv., Inc. v. Velocci, 416 So. 2d 1276, 1277 (Fla. 5th DCA 1982); see also Fla. R. Civ. P. To be discoverable, the information sought must be relevant to the proceeding and admissible or reasonably calculated to lead to the discovery of admissible evidence. Allstate Ins. Corp. v. Langston, 655 So. 2d 91, 94 (Fla. 1995). See also Velocci, 416 So. 2d at 1277; see also McCarty v. Estate of Schultz, 372 So. 2d 210, 212 (Fla. 3d DCA 1979) (party may not utilize the discovery process for a ?mere ?shing expedition or general inquisitorial examination of papers with a view to ascertaining whether something of value may or may not show And even if this relevance standard is met, ?the particular items or information sought to be discovered may be privileged and therefore beyond permissible discovery.? See Velocci, 416 So. 2d at 1278-78, n.2 (citing Central Florida Skates, Inc. v. Thomas, 393 So. 2d 1200 (Fla. 5th DCA), rev. denied, 402 So. 2d 608 (Fla. 1981)). Thus, the trial court has broad discretion to refuse discovery of irrelevant information, deny requests that are unreasonable and oppressive, and protect privileged information. See also Travelers Indem. Co. v. Salido, 354 So. 2d 963, 964 (Fla. 3d DCA 1978) (trial court erred in not quashing subpoena that requested irrelevant information because discovery ?cannot be utilized to explore all the minute details of a controversy or delve into immaterial or inconsequential matters?). Judges must ensure that parties are not manipulating the discovery system for unauthorized or unseemly purposes. Discovery must be prohibited if the requests are essentially premature discovery in aid of execution. Florida courts are unequivocal in holding that a party may be irreparably harmed if forced to reveal ?nancial information where no judgment has yet been entered. See Friedman v. Heart Inst. ofPort St. Lucie, Inc, 863 So.2d 189, 194 (Fla.2003) (general rule is that ?nancial information is ordinarily discoverable only in aid of execution after judgment). Much like ordering discovery of protected ?nancial information without a compelling reason, were the trial court to prematurely allow discovery in aid of a non-existentjudgment, it would be not just revisable error, but would amount to a departure from the essential requirements of law. See Delmonico v. Crespo, 59 So. 3d 337 (Fla. Dist. Ct. App. 201 1). Moreover, ?the burden to prove the information is relevant or reasonably calculated to lead to the discovery of admissible evidence is on the party seeking the information.? Id. (citing Spry v. Prof] Emp?r Plans, 985 So.2d 1187, 1188?89 (Fla. DCA 2008)). This determination can be made only after an evidentiary hearing. Id. It is a departure from the essential requirements of law for a court to order production of personal ?nancial information without ?rst conducting an evidentiary inquiry into its relevance. Rowe, 89 So. 2d at 1103. The assertions or arguments of a party?s attorney are not suf?cient evidence of relevance. See DiSarrio v. Mills, 711 So. 2d 1355, 1357 (Fla. 2d DCA 1998). Plaintiffs? need to obtain various Defendants? banking records is an improper attempt to shore up claims which Plaintiffs made in the amended complaint with facts which Plaintiff was required to ascertain prior to filing the complaint, and thus constitutes an improper ??shing expedition.? As expressed in DB Real Estate Holdings 1732, recently ?led motion to dismiss, Plaintiffs? amended complaint alleges essentially the same claims as the original complaint and is de?cient for the same reasons that the original Complaint was de?cient; it fails to state a cause of action, as there are no ultimate facts in support of any of the purported causes of action. Rule 1.140(b) of Florida?s Rules of Civil Procedure requires that Plaintiffs? complaint be dismissed because it fails to state a cause of action. Florida?s Rules of Civil Procedure require fact 10 pleading. See Louie?s Oyster, Inc. v. Villaggio Di Las Olas, Inc., 915 So. 2d 220, 221-22 (Fla. 4th DCA 2005). ?In order to state a cause of action, a complaint must allege suf?cient ultimate facts to show that the pleader is entitled to relief.? See Meba Medical Bene?ts Plan v. Lago, 867 So. 2d 1184, 1186 (Fla. 4th DCA 2004). The pleading rules require recognition of the elements of a cause of action and presentation of facts necessary to support it. See Barrett v. City of Margate, 743 So. 2d 1160, 1162 (Fla. 4th DCA 1999) (a complaint must set out the elements and the facts that support them so that the court and the defendant can clearly determine what is being alleged). Plaintiffs fail to state a cause of action because only general and conclusory allegations are set forth in the amended complaint without any speci?c facts in support of any alleged cause of action. See American Seafood, Inc. v. Clawson, 598 So. 2d 273, 274 (Fla. 3d DCA 1992); Beckler v. Hoffman, 550 So. 2d 68, 70 (Fla. 5th DCA 1989) (?general? and ?vague and conclusory? allegations are insuf?cient); Barrett, 743 So. 2d at 1160 (alleging merely opinions, theories, legal conclusions or arguments is insuf?cient). See also Bliss v. Cannona, 418 So. 2d 1017, 1019 (Fla. 3d DCA 1982) (?Certainty is required when pleading defenses and claims alike, and pleading conclusions of law unsupported by allegations of ultimate facts is legally insuf?cient?). ?Mere legal conclusions inserted in a complaint are insuf?cient to state a cause of action unless substantiated by allegations of ultimate fact.? See Doyle v. Flex, 210 So. 2d 493, 494 (Fla. 4th DCA 1968). Plaintiffs? amended complaint improperly ?lumps? all ?Defendants? together, and does not suf?ciently factually support any appropriate cause of action. Paragraphs 22 and 23 state that M. SISKIND and WILLIAM SISKIND have conspired together and used andfor formed SOVEREIGN, CHANCE, 0BRE, SISKIND LEGAL SERVICES, LLC, FACB, 11 Amalgamated Asset Trust and Sympatico as their alter egos and used them improperly, fraudulently and not for lawful purposes, in order to obtain money and assets from people like the Plaintiffs . . . Defendants maliciously, wantonly and without cause in bad faith mislead and misrepresented to Plaintiffs in order to wrongfully obtain, use and retain their moneys and real property, and interfere with their rights to certain real property. Further, Plaintiffs used duress, threats and misinformation in making Plaintiffs execute unconscionable documents in favor of Defendants and not in the best interest of Plaintiffs. However, Plaintiff failed to include any speci?c factual allegations, and Plaintiffs? amended complaint therefore does not state any valid cause of action. Moreover, when a plaintiff seeks to allege theories of alter-ego, it is entirely improper to conclusorily allege that one of the defendants is an alter-ego of another in an attempt to prove that the alleged ?factual support? applies to all defendants in an amorphous manner. Stansell v. BGP, lnc., 2010 WL 2791850, *1 (MD. Fla. 2010) (?nding that single conclusory allegation of alter ego with no supporting facts was improperly pled) (internal citations omitted). Each claim alleging theories of alter ego must be supported by facts against each defendant. Grew v. Hopper, 207CV-550-FTM-34SPC, 2008 WL 114915, *2 (MD. Fla. 2008) Plaintiffs? claims must fail because they set forth conclusory allegations that have absolutely no factual support, and Plaintiffs? amended complaint also fails because it alleges claims against multiple Defendants within each discrete ?Count? and thus confuses the applicability and relevancy of the underlying ?facts.? Plaintiffs? causes of action do not ?describe in suf?cient detail the factual basis for each of [their] claims and how each defendant is responsible.? Grew, 2008 WL 114915 at Without a clear delineation that sets forth the 12 factual basis for each count against each Defendant, it is impossible to know what each Defendant is being accused of by Plaintiffs. Plaintiffs? vague references to all Defendants in a general manner and failure to allege speci?c improper actions that each Defendant committed subjects Plaintiffs? amended complaint to dismissal. Peavey v. Black, 2010 WL 4680850, *1 (MD. Fla. 2010) (?It remains unclear what claims are alleged against each defendant. Though Plaintiffs attempt to lay out distinct counts, claims are intermingled and the facts alleged are unintelligible?); In re All Am. Semiconductor, Inc., 490 BR. 418, 423 (Bankr. S.D. Fla. 2013) (dismissing complaint due to plaintiff 3 failure to specify which operative facts and claims were asserted against which defendants). Plaintiffs also failed to properly allege a basis for misrepresentation. While most pleading standards do not require detailed factual allegations, certain causes of action must be pled with speci?city and particularity. Rule 1.120(b) of the Florida Rules of Civil Procedure provides, in pertinent part, that: all averments of fraud or mistake, the circumstances constituting fraud or mistake shall be stated with such particularin as the circumstances may permit.? Fla. R. Civ. P. ?Particularity? requires that a party asserting a claim for fraud not only speci?cally identify the ?misrepresentations? but also the ?time, place or manner in which they were made, and how the misrepresentations were false or misleading.? Robertson v. P. H. F. Life Ins. Co., 702 So. 2d 555, 556 (Fla. DCA 1997) (emphasis added). The plaintiff is also required to allege those facts ?tending to show why the statements were false.? Gordon v. Etue, Wardlaw Co., P.A., 511 So. 2d 384, 388 (Fla. Ist DCA 1987). lorida?s rule regarding particularity serves a vital role in actions predicated upon a fraud. ?Pleading fraud with particularity is necessary in order to: (1) provide the defendants with 13 suf?cient notice of the facts in which the plaintiff complains to enable them to frame a response, (2) prevent ?shing expeditions to uncover moral wrongs, and (3) protect defendants from unfounded accusations of immoral and otherwise wrongful conduct. The ?clear intent of [the] Rule . . . is to eliminate fraud actions in which all the facts are learned through discovery after the complaint is ?led.? Butler v. Magellan Health Servs., Inc., 74 F. Supp. 2d 1201, 1215 (MD. Fla. 1999) [emphasis added]. Fair notice underlies Rule 1.120(b) of the Florida Rules of Civil Procedure. A plaintiff who pleads fraud must ?reasonably notify the defendants of their purported role in the scheme.? Brooks v. Blue Cross Blue Shield of Fla., Inc., 116 F.3d 1364, 1381 (11th Cir. 1997) (citations omitted). In actions ?involving multiple defendants the complaint should inform each defendant of the nature of his alleged participation in the fraud.? Id. (citations omitted). Rule 1.120(b) ?is not satis?ed where the complaint vaguely attributes the alleged fraudulent statements to [the] defendants.? Id. Movant is entitled to an award of attorney?s fees. Rule 1.280 Fla. R. Civ. P. incorporates Rule Fla. R. Civ. P. for the purpose of authorizing an award of attorneys fees and reasonable expenses to the person who has obtained a protective order. Those attomey?s fees and reasonable expenses shall be paid by the party whose conduct necessitated the motion for protective order or such party?s attorney who advised the party. WHEREF ORE, Defendants Jeffrey M. Siskind, William Siskind, Sovereign Gaming Entertainment, LLC, Florida?s Association of Community Banks Credit Unions, Inc. and 14 Sympatlco Equine Rescue Inc request that the Court?issue '1 Protectlve Order 1mmed1ately . . . . disclosure of any and all of Defendants? banking records to requ1re Plaintiffs counsel to forward sald Protective Order to each of the ?nancial 111st1tutlons were served with Plaintiffs Not1ce of Deposmons Duces Tecum and file proof of serv1ce of same With the Court and to keep con?dential and immediately destroy any such records may be inappropriately piov1ded as a result of Plaintiffs? Notice of Taking Deposrtlons Duces Tecum and to reserve as to Movants entitlement to attorney?s fees related to the ?ling of Emergency Motion. VERIFICATION The attests to the truthfulness of facts, including herem set f01th and as attached. Jeffra M. Siskind, Esquire State of Florida County'of Palm Beach BEFORE M13 this 151h day of March, 2017 appeared Jeffrey W110 lS personally known to me or provided voluntarlly af?xed his signature hereto in my presence (SEAL) 09994. new Notary Public? State of Florid My Commission Expires: 9/96) 9 as identi?cation, and-who Notary Public State at Florida 23$: Linda Moss My Commission FF 239154 Expires 0611912019 . inf-3 gilrorrt? Emergency Motion ?/Iovauts counsel cer If es that it undertook a good faith e?ort to resolve the Issues contoured or this Emergency Veri?er! Motion with opposmg counsel prior to [mg fins 15 SISKIND LEGAL GROUP Jeffrey M. Siskind Jeffrey M. Siskind, Esquire FBN 138746 525 S. lagler Drive, Ste. 500 West Palm Beach, FL 33401 TEL (561) 832-7720 FAX (561) 832-7668 Email: iefl?siskinda?i?msn.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing Emergency Motion was served upon all appropriate parties this 15?h day of March, 2017 by Florida?s E-?ling Portal. 16 Jeffrey M. Siskind Jeffrey M. Siskind, Esquire FBN 138746 Filing 53471753 E-Filed 03/08/2017 04:09:32 PM IN THE CIRCUIT COURT OF THE FIFT EENT JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA DAVID FIORE, an individual; CARL STONE, an individual, 3485 LAGO DE TALAVERA TRUST, a Florida Trust; and, DIANNA GEORGE, an individual, Plaintiff, CASE NO: 2016CA008765 vs. JEFFREY M. SISKIND, an individual; WILLIAM SISKIND, an individual; SOVEREIGN GAMING ENTERTAINMENT LLC, a Florida limited liability company; CHANCE ANTHEM LLC, a Florida limited liability company; OB REAL ESTATE HOLDINGS 1732, LLC, a Florida limited liability company; SISKIND LEGAL SERVICES, LLC, a Florida limited liability company; and, ASSOCIATION OF COMMUNITY BANKS AND CREDIT UNIONS, INCORPORATED, a Florida not for pro?t corporation, Defendants. NOTICE OF TAKING DEPOSITIONS DUCES TECUM PLEASE TAKE NOTICE, that Plaintiffs will take the depositions of: NAME DATE AND TIME PLACE Records Custodian for Wells March 28, 2017 at 11:00 A.M. Florida Court Reporting Fargo Bank NA EST 2161 Palm Beach Lakes Blvd. Suite 302 West Palm Beach FL 33409 Phone: 561-689-0999 Records Custodian for IP March 28, 2017 at 1:00 PM. Florida Court Reporting Morgan Chase Bank NA EST 2161 Palm Beach Lakes Blvd. Suite 302 West Palm Beach FL 33409 Phone: 561-689-0999 Records Custodian for March 28, 2017 at 3:00 P.M. Florida Court Reporting Suntrust Bank EST 2161 Palm Beach Lakes Blvd. Suite 302 West Palm Beach FL 33409 Phone: 561-689-0999 The depositions will be taken upon oral examination, before a court reporter or any other Notary Public or of?cer authorized to take depositions in and for the State of Florida. The oral examination will continue from day to day until completed. The deponents are to have the documents listed in the attached exhibit list at the time and place of the deposition. CC: CERTIFICATE OF SERVICE I certify that a copy hereof has been furnished on March 8, 2017 by e?ling/email to all parties listed on the eservice list. Florida Court Reporting Respectfully submitted, SOFIYE WILLIAMS, RA. 5/ Solive Williams WILLIAMS, ESQ. Florida Bar No.: 191507 sotiye@comcast.net 500 E. Broward Blvd. Suite 1710 Fort Lauderdale, Florida 33394 Telephone: (954) 397-5739 Attorney for Plaintiffs AMERICANS WITH DISABILITIES ACT ?If you are a person with disability needing special accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Florida Court Reporting, 2161 Palm Beach Lakes Blvd., Suite 302, West Palm Beach FL 33409, Phone: 56l~689-0999 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711.? ?Si usted es una persona minusvalida que necesita algv?m acomodamiento para poder participar en este procedimiento, usted tiene derecho, sin tener gastos propios, a que se le provea cierta ayuda. Tenga la amabilidad de ponerse en contacto con, Florida Court Reporting, 2161 Palm Beach Lakes Blvd., Suite 302, West Palm Beach FL 33409, Phone: 561-689-0999, por lo menos 7 dias antes de la cita fijada para su comparecencia en los tribunales, inmediatamente despu?s de recibir esta notificaci?n si el tiempo antes de la comparecencia que se ha programado es menos de 7 dias; si usted tiene discapacitaci?n del oido 0 de la voz, llame al 711.? ?Si on se yon moun ki enl?im ki bezwen akomodasyon pou ka patisipe nan pwosedi sa, ou kalifye san ou pa gen okenn lajan pou peye, gen pwovizyon pou jwen k?k Tanpri kontakte, koodonat? pwogram Lwa pou ameriken ki Enfim yo nan Florida Court Reporting, 2161 Palm Beach Lakes Blvd., Suite 302, West Palm Beach FL 33409, Phone: 561-689-0999 nan 7 jou anvan dat ou gen randevou pou par?t nan tribinal la, oubyen imedyatman apre ou fin resevwa konvokasyon an si ou gen pou paret nan tribinal la mwens ke 7 jou; si on gen pwobl?m pou tande oubyen pale, rele 711.? id i?u b?l 12. 13. 14. 15. WELLS FARGO DOCUMENTS TO BE PRODUCED: Any and all of the following records from 2013 to the present for the Jeffrey Siskind attorney trust account ending in - account ending in - andlor any other accounts for the following persons/entities: Jeffrey M. Siskind, Siskind Legal Services, William Siskind; Sovereign Gaming Entertainment Chance Anthem OB Real Estate Holdings 1732, Florida?s Association of Community Banks and Credit Unions, Incorporated; Sympatico Equine Rescue, Inc. andlor Amalgamated Asset Trust. Account Statements, Canceled Checks, Ledgers, Correspondence, Deposit Tickets, Items Deposited, Debit And Credit Memos, IRS Forms/Schedules, Signature Cards, Financial Statements, Audit Records, All documents pertaining to wire transfers sent or received by any of the named Defendants andlor entities in which any of the Defendants have an interest, including but not limited to: a. Fed Wire, CHIPS, SWIFT, or other money transfer of message documents b. Documents (checks, debit memos, cash in tickets, wires in, etc.,) re?ecting the source of the funds wired out c. Documents (bank checks, credit memos, cash out tickets, wires out, etc.,) re?ecting the ultimate disposition within the bank of the funds wired in (1. Notes, memoranda or other writings pertaining to the sending or receipt of wire transfers All documents pertaining to current or expired safe deposit box rentals by or under the signatory authority of any of the named Defendants, including but not limited to: a. Contracts b. Entry records All CTRs (Forms 4789) and CMIRs (Form 4790) ?led with the Department of Treasury, Internal Revenue Service or the United States Customs Service by Wells Fargo between 2013 and the present concerning currency transactions conducted by or on behalf of the Defendants All pertaining to open or closed accounts of the Defendants and/or any other entity dba, pertaining to, andlor controlled by Jeffrey Siskind andlor William Siskind. 10. 11. 12. l3. 14. 15. 16. 17. CHASE DOCUMENTS TO BE PRODUCED: Any and ali of the following records from 2013 to the present for Jeffrey M. Siskind dba Siskind Legal account ending in -andlor any other accounts for the following persons/entities: Jeffrey M. Siskind, Siskind Legal Services, William Siskind; Sovereign Gaming Entertainment Chance Anthem 0B Real Estate Holdings 1732, Florida?s Association of Community Banks and Credit Unions, Incorporated; Sympatico Equine Rescue, Inc. and/or Amalgamated Asset Trust. Account Statements, Canceled Checks, Ledgers, Correspondence, Deposit Tickets, Items Deposited, Debit And Credit Memos, IRS Forms/Schedules, Signature Cards, Financial Statements, Audit Records, All documents pertaining to wire transfers sent or received by any of the named Defendants and/or entities in which any of the Defendants have an interest, including but not limited to: a. Fed Wire, CHIPS, SWIFT, or other money transfer of message documents b. Documents (checks, debit memos, cash in tickets, wires in, etc.,) reflecting the source of the funds wired out c. Documents (bank checks, credit memos, cash out tickets, wires out, etc.,) re?ecting the ultimate disposition within the bank of the funds wired in d. Notes, memoranda or other writings pertaining to the sending or receipt of wire transfers All documents pertaining to current or expired safe deposit box rentals by or under the signatory authority of any of the named Defendants, including but not limited to: Contracts Entry records All CTRs (Forms 4789) and CMIRs (Form 4790) filed with the Department of Treasury, Internal Revenue Service or the United States Customs Service by Wells Fargo between 2013 and the present concerning currency transactions conducted by or on behalf of the Defendants All documents/records pertaining to open or closed accounts of the Defendants and/or any other entity dba, pertaining to, and/or controlled by Jeffrey Siskind andlor William Siskind. b?Ii?Ii?I Nude 13. 14. 15. 16. 17. SUNTRUST DOCUMENTS TO BE PRODUCED: Any and all of the following records from 2013 to the present for Jeffrey M. Siskind account andlor any other accounts for the following persons/entities: Siskind Legal Services, William Siskind; Sovereign Gaming Entertainment Chance Anthem OB Real Estate Holdings 1732, Florida?s Association of Community Banks and Credit Unions, Incorporated; Sympatico Equine Rescue, Inc. and/or Amalgamated Asset Trust. Account Statements, Canceled Checks, Ledgers, Correspondence, Deposit Tickets, Items Deposited, Debit And Credit Memos, IRS Forms/Schedules, Signature Cards, . Financial Statements, . Audit Records, . All documents pertaining to wire transfers sent or received by any of the named Defendants and/or entities in which any of the Defendants have an interest, including but not limited to: a. Fed Wire, CHIPS, SWIFT, or other money transfer of message documents b. Documents (checks, debit memos, cash in tickets, wires in, etc.,) reflecting the source of the funds wired out c. Documents (bank checks, credit memos, cash out tickets, wires out, etc.,) reflecting the ultimate disposition within the bank of the funds wired in (1. Notes, memoranda or other writings pertaining to the sending or receipt of wire transfers All documents pertaining to current or expired safe deposit box rentals by or under the signatory authority of any of the named Defendants, including but not limited to: Contracts Entry records All CTRs (Forms 4789) and CMIRs (Form 4790) filed with the Department of Treasury, Internal Revenue Service or the United States Customs Service by Wells Fargo between 2013 and the present concerning currency transactions conducted by or on behalf of the Defendants All documents/records pertaining to open or closed accounts of the Defendants andlor any other entity dba, pertaining to, and/or controlled by Jeffrey Siskind and/or William Siskind. 1' t" I .I PROMISSORY NOTE AMOUNT: $200,000.00 West Palm Beach, Florida December 24, 2013 FOR VALUE RECEIVED the undersigned promises to pay to the order of Christopher George (?Payee?) the principal sum of TWO HUNDRED THOUSAND DOLLARS together with interest thereon at the rate of FIFTEEN PERCENT per annum from the date of execution hereof until maturity on December 23, 2016, both principal and interest being payable in lawful money of the United States. Interest and principal shall be payable upon maturity and compounded annually. There shall be no pre?payment penalty. If any payment due hereunder is paid more than ten (10) days late, Borrower shall pay a late fee equal to ?ve percent of the total payment due, together with the payment. The makers and endorsers of this note further agree to waive demand, notice of non-payment. and protest, and in the event suit shall be brought for the collection hereof, or the same has to be collected upon demand of an attorney, to pay reasonable attorney?s fees for making such collection. Payable at such place as shall be designated by the holder of this note in writing. THIS IS A BALLOON NOTE. OUTSTANDING PRINCIPAL IN THE AMOUNT OF $200,000.00 SHALL BE DUE AND PAYABLE ON OR BEFORE DECEMBER 23. 2016, TOGETHER WITH UNPAID LATE CHARGES AND FEES, IF APPLICABLE. Borrower: Sovereign Gaming Entertainment By: William L. y/ a PROMISSORY NOTE AMOUNT: $1.800.000.00 West Palm Beach. Florida January 9. 2014 FOR VALUE RECEIVED the undersigned promises to pay to the order of Christopher George (?Payee?) the principal sum of ONE MILLION EIGHT HUNDRED THOUSAND DOLLARS (51.800.000.00) together with interest thereon at the rate of FIFTEEN PERCENT per annum from the date of execution hereof until maturity on January 8, 2017, both principal and interest being payable in lawful money of the United States. Interest and principal shall be payable upon maturity and compounded annually. There shall be no pie-payment penalty. If any payment due hereunder is paid more than ten (10) days late, Borrower shall pay a late fee equal to five percent of the total payment due, together with the payment. The makers and endorsers of this note further agree to waive demand, notice of non?payment and protest, and in the event suit shall be brought for the collection hereof, or the same has to be collected upon demand of an attorney. to pay reasonable attorney's fees for making such collection. Payable at such place as shall be designated by the holder of this note in writing. THIS IS A BALLOON NOTE. OUTSTANDING PRINCIPAL IN THE AMOUNT OF 31.800.000.00 SHALL BE DUE AND PAYABLE ON OR BEFORE JANUARY 8, 2017. TOGETHER WITH UNPAID LATE CHARGES AND FEES, IF APPLICABLE. Borrower: Sovereign Gaming Entertainment 7, By: ?ax/R William L. Siskind. President SISKIND LEGAL GROUP CHentLedger Client/Matter: 3445 Start: October 5, 2015 End: May 31, 2016 Date Amount Description Ledger Balance 10-05-2015 800,000.00 Wire In from Carl Stone 800,000.00 10-06-2015 750,000.00 to Chance Anthem, LLC 50,000.00 10-06-2015 42,631.57 - 3325 2321 Kentucky Street 7,368.43 10-16-2015 1,000.00 - Withdrawa ~ pay Steve Wilkins 6,368.43 12-07-2015 4,000.00 - Withdrawal- pay Steve Wilkins 2,368.43 01-07-2016 1,000.00 Withdrawal? pay Steve Wilkins 1,368.43 01-25-2016 1,000.00 - Withdrawal- pay Steve Wilkins 368.43 05-31-2016 31.57 Transfer from Misc. Ledger 400.00 05-31-2016 400.00 - 3391 to Chance 8: Anthem, LLC - 0 - RE: Wellington Development DA: March 2, 2016 T0 WHOM IT MAY CONCERN: in consideration of the sum of $65,000, which Chance 8: Anthem, LLC agrees to cause to be wired to David W. Fiore,1r., Account No. at Bank of America, ABA.- no. the undersigned hereby assigns his entire interest In the remodeling wait ,3 located at 3445 Santa Barbara Drive, Wellington, FL 33414 to Chance 8: Anthem?ug We Florida limited liability company. 991/ Wt ess CFN 20150008658 OR EH 27267 PG 0.122 Prepared by and Return To: RECORDED 01l3912615 11 :51 :33 .le?'rey M. Siskind, Esquire Palm Beach County. Florida 525 S. Flagler Drive. Suite 500 MST 10. 39 We aim Beach, FL 3340l Doc Steep 9, 76 Sharon it. Back. CLERK 8 coup-rams 2-44- I 9-000-0290 P9 8122; ?pg! 0 Deed in Lieu of Foreclosure This Ciide :11;ng day of January, 2015 between Michael Haggerty, Trustee of the 3485 Lago De vcra Trust (?Grantor?) and Sovereign Gaming Entertainment, LLC, 525 South lagler Brights 500. West Palm Beach, FL 33401 (Whenever @111 the terms ?Grantor" and ?Grantee? include all the parties to this instrument and heirs, legal representatives, and assigns of individuals, and the successors and assigns of corpora@, trusts and trustees.) that sai DOLLARS ($10.00) Grantee, the receipt who remise, release, convey an forever, all the right, title, i described land, situate, lying tor, for and in consideration of the sum TEN AND or good valuable consideration to said Grantor in hand paid by said hereby acknowledged, does hereby grant, bargain, sell, alienate, (firm unto the said Grantee, and Grantee? heirs and assigns [aim and demand which Grantor has in and to the following ing in Palm Beach County, Florida to-wit: Lot 29, of the Plat of P.U.D., according to the Plat thereof, as recorded in Plat Book I05, Page 44, 0% public records of Palm Beach County, Florida. To Have and to Hold. the same toget ith all and singular the appurtenances thereto belonging or in anywise appertaining, the estate, right, title, interest, lien, equity and claim whatsoever of Grantor, either in [@quity. for the use, bene?t and pro?t of the said Grantee forever. Subject to zoning, restrictions, prohibitions and other requirements imposed by govenunental authority, restrictions and matters appearing on the Plat or otherwise common to the subdivision, easements of record, taxes for the current year and all subsequent years, and all items of record, which are not intended to be re-imposed hereby. In Witness Whercof, Grantor has signed and granted these presents the day and year ?rst above Written. 3485 Logo De Talavera Trust {gaze/ma" 133nm Michael Haggerty, TrusteV/ Wi ess Print: 30 l?m State of Florida County of Palm Beach Before me this _day of January, 2015, appeared Michael Haggerty, who produced ['7le 9/.va as identi?cation, or who is personally known to me and who voluntarily affixed their signatures hereto in my presence, and did/did not take an oath. (SEAL) NOTARYPUBLIC MKWI Print Name' Wan er. . "also Public wisdom in - ?17.:in Comm. EXP- 40/1] 7 Omaha 0 "0604 Book27267/Page122 Page 1 of 1 Transcript of John George Voicemail Message to Village of Wellington Hi Gloria [this is] John George, we?re calling about Tanya Siskind?s husband Jeffrey. We are sitting in the FBI office right now. He embezzled several million dollars from several different people. We are doing a Ponzi Scheme affidavit on Jeffrey Siskind who?s also in bankruptcy at this very minute. My phone number is 561?722?7971, 561-722?7971. We have also given this case to the Palm Beach Post. John at the Palm Beach Post, also [his] name is John. So please give us a call. This is about the councilwoman?s embezzling husband. It will get messy. Thank you. Date Recorded: February 22, 2017 jeffsiskind@msn.com It? From: thecarpenter@yahoo com Sent: Wednesday, February 22,2017 3: 21 PM To: Gloria Kelly Subject: embezzlement Dianna Lovebug checked in to West Palm Beach Police Dept.. 5 - West Palm Beach, FL - Hey Jeffrey Siskind it only gets worse from here 5-3 .you my friend will not get away with what you have done. That's a The FBI and the city of WPB now have knowledge of your embezzlement of over 2. 2 million dollars and my home Did you really think that you Sir would get away with Lol you tried I guess. Your poor wife Tanya Lee Siskind she? 13 going to see what kind of person you are now. How embarrassingParI. . I. t. A .. B?lnl?al?vd 1 ll Wear Palm j. i i? 8 each Station .it, West?Palm 3 I - ,1 Beach Amtrak I 1: i - . West Palm Beach Police Dept. Police Station - West Palm Beach. FL William Roger Cummings and 2 others have been here Sent from Yahoo Mail. Get the app JOHN P. GEORGE . 2442 BAY VILLAGE COURT - PALM BEACH GARDENS, FL 33410 - - 91113 '3 0101.53W14 ,4ng 17 x4151 {2 45* anagg .ou- autumn?mGEORGE 2442 BAY VILLAGE COURT 3H . BEACH GARDENS, FL 33410 PC NAM EL 1 7* 1% $sz2 3/73 Leo/L4 2/ ?208?- 11?308? 4 SCFEBE RECEIVED MAR t-z 201? JOHN GEORGE 2442 BAY VILLAGE CT PALM BEACH GARDENS, FL 33410 551-722-7971 RE: SISKIND, JEFFREY ATTORNEY WE ARE INVESTIGATING SISKIND AND HIS MANY ASSOCIATED ENTITIES FOR A POSSIBLE PONZI OR EMBAZZEMENT FOR CLIENTS FUNDS. I HAVE PERSONALLY BEEN TO THE LELAND THE CITY OF WEST PALM BEACH POLICE THEY WERE BOTH GIVEN DOCUMENTS SHOWING MILLIONS OF DOLLARS WERE WIRED INTO HIS ANYONE REQUESTING THIS DOCUMENT WILL BE SEND A COPY). I HAVE ALSO MEET WITH THE FOLLOWING- 1. PALM BEACH POST NEWSPAPER 2. WELLINGTON TOWN CRIER NEWSPAPER 3. WELLINGTON CITY MANAGER WHERE SISKIND WIFE IS ON THE COUNCIL. I DO FIND IT IRONIC THAT HIS WIFE IS ON THE CITY COUNCIL WHEN SISKIND IS IN BANKRUPTCY, HOW DO THEY AFFORD THAT WE WILL NEXT GO THE THE CRIMINAL DIVISION OF THEE WE HAVE DELIVERED DOCUMENTS THAT WE BELIEVE HE STOLE MORE THAN $2,000,000 AND FROM ANOTHER $800,000, AND SOME REAL ESTATE OVER 60 ENTITIES HE WAS OR IS ASSOCIATED WITH PLUS ANOTHER BUNCH FOR DAD WE ALSO HAVE 2 FLORIDA BAR COMPLIANTS FILED WE BELIEVE WE ARE NOT UNIQUE, AND YOU MAY HAVE HAD SIMILAR DEALINGS THE FBI WANTS AS MANY PEOPLE AS POSSIBLE TO BE ASSIST IN THE INVESTIGATION PLEASE DO NOT FEEL EMBARRASSED IF YOU WERE ALSO A VICTIM, WE CAN UNITE I UNDERSTAND SOME OF THE ENTITIES HAVE BEEN DISSOLVED, WE ARE TRYING TO FIND OUT HOW LONG THIS PRACTICE WAS GOING ON. CONTACT ME ASAP SP LLY {a OHN GEORGE 561-722-7971 Search Corporations, Limited Liability Compames, Lumtea arm rug: 1 u; 1. Florida Desartman: of State ox: Coapcamcus . ?ag-mu-?prw ,1 ..51:} ll) 21.5 - (:Ji 'iJim: ?rah.- hr .Jr . . - Deganmen: cf Siate I Division Corccra??c-ns I Search Records I Search bv Of?ceror Registered MenPravitms List Next Us: Of?cerIRA Name SESKIND. HARRY J. SISKIND HARRY SISKIND. HARRY JAY SISKIND. HEATHER SISKIND JEFFERY BRUCE JEFFREY SISKIND. JEFFREY SISKIND. JEFFREY SISKIND JEFFREY SISKIND. JEFFREY SISKIND JEFFREY SISKEND. JEFFREY SISKIND JEFFREY SISKINE). JEFFREY SISKIND, JEFFREY SISKIND JEFFREY SISKIND JEFFREY SISKIND. JEFFREY SISKIND. JEFFREY SISKIND JEFFREY .. - . a 4.. Previous List Nex'z List Cf?c?rlRegistered Agent Name List RADIUS PHI. Entity Name COOPERATIVE TARGET MARKETING. INC. SISKIND AND MARTIN. INC. SISKIND PRODUCTIONS. INC. JACK AND JILL CENTER. INC. JEFFERY BRUCE SISKIND. PH.D., PA. NEPTUNE FURNISHINGS. LLC STARS AND STRIPES FOUNDATION FOR PRO BONO LEGAL SUPPORT. INC. my - --.. . an . (rm .. .-.. .. M. ?4 .. .. .7 . PALM BEACH JEWELRY 8: ANTIQUE CENTER. INC. 1-800-SERVE-EM. INC. WELLINGTON 3445. LP HAILEY ACQUISITIONS. LLC SISKIND LEGAL SERVICES. LLC SISKIND LEGAL SERVICES. LLC PC ALAN NASH. LLC PC SURFSIDE BEACH. LLC PC BALTO SAG. LLC PC CARLYLE DECO. LLC PC FOUR ELEVEN. LLC RADIUS TWELVE ZERO THREE. LLC 1W0. LLC .- amm? nwvn' vu- .-.. V. .. - --., .. - . iO?I?cerlRA Name Search] Of?cerIRA Name Search . . Entity Number {338890 352710 550038 ?(33062 822793 1.14000147569 N06000007217 P05000046992 P10000094700 L02000027952 L04000093133 L04000093133 L05000003805 LOSOODOOSGSD L05000004169 L05000005023 LOSOODDOSOZS L05000005030 . V?s: . Hausa Genera-nan: of State. Emsmn of Cameraman 2/25/2017 Search Corporations, Limited Liability Companies, Limited Partnerships, and Page 1 of Florada Degartmen: cf State Dmsmu as: Conpoamnons . .. -. ll-ql?1w?4?' Previws Us: Next List .. .. .. . a by. ..-. Of?cerlRegistered Agent Name List Of?cerlRA Name Entity Name SISKIND. JEFFREY PC THREE ZERO THREE. LLC JEFFREY PC EIGHT SIXTEEN LLC JEFFREY OPERA PLACE RESIDENTIAL HOLDINGS, LLC SISKIND. JEFFREY 1831 N. DIXIE. LLC SISKIND LEGAL SOLUTIONS OF SOUTH FLORIDA. SISKIND, JEFFREY LLC I A 0L I SISKIND. JEFFREY if: LEG UT 0N5 OF SOUTH FLORIDA. LEGACY HOLDINGS - MI. LLC BOCA BAY DEVELOPMENT GROUP LLC FIORE 7102. LLC INTELLIGENT TITLE SOLUTIONS OF SOUTH JEFFREY SISKIND JEFFREY JEFFREY SISKIND. JEFFREY FLORIDA. LLC SISKIND. JEFFREY DUVAL. LLC JEFFBEY JURISMORTGAGE PRACTICE RESOURCES. LLC SISKIND, JEFFREY TP5, LLC COLLECTIVE MANAGEMENT ASSOCIATES. LLC COLLECTIVE MANAGEMENT CONSULTANTS. LLC CASTLE ASSETS. LLC PANGA PROPERTIES. LLC IN THE WEEDS PRODUCTIONS. LLC IN THE WEEDS PRODUCTIONS. LLC DOWNTOWN BIKE TAXI. LLC .-. SISKIND. JEFFREY SISKIND JEFFREY SISKIND. JEFFREY SISKIND. JEFFREY SISKIND. JEFFREY SISKIND. JEFFREY SISKIND JEFFREY .- Previous List Next List . -- [Of?cer/RA Name Search! mm?. w. rm?: Entity Number L05000009930 L05000009979 L05000085288 L05000108191 L05000122295 L050001 22295 L06000012715 L0600001271B 1.0600001 6954 136000031963 L06000047915 L06000085150 L07000032384 L09000054906 L09000063550 L11000127872 L11000127883 L12000150860 L12000150860 L12000155586 [Of?cerfRA Name Search] earch' -. . ..I 1-. For-c.) :epanmerz 5 Sum. amaze: 2/25/2017 Search Corporations, Limited Liability Companies, Lumted and rage 1 o; .1. DMSION OF CORPORATIONS I Divigion cf Corscrazions I Search Records I Search by Oi?ceronggIstered Ageng I Previous Next Of?cer/RA Name SISKIND. JEFFREY SISKIND. JEFFREY SISKIND. JEFFREY SISKIND, JEFFREY SISKIND. JEFFREY JEFFREY SISKIND. JEFFREY SISKIND. JEFFREY SISKIND JEFFREY SISKIND. JEFFREY SISKIND. JEFFREY SISKIND. JEFFREY JEFFREY JEFFREY JEFFREY SISKIND JEFFREY SISKIND. JEFFREY SISKIND JEFFBEY SISKIND. JEFFREY SISKIND. JEFFREY -. Previous LIsr Next List OfficerlRegistered Agent Name List Entity Name Entity Number 08 REAL ESTATE HOLDINGS 1732. LLC L13000029596 AVIATAT. LLC L13000078442 AVIATAT. LLC L1 3000078442 JURISMORTGAGE, LLC L14000059808 OCEANS 704 INVESTMENTS. LLC L14000152760 CHANCE 8; ANTHEM. LLC L140001 58320 FOUNDATION FOR THE STUDY AND TREATMENT OF BLOOD-BORNE VIRAL AND BACTERIAL N02000005063 DISEASES. INCORPORATED STARS AND STRIPES FOUNDATION FOR PRO BONO LEGAL SUPPORT. INC- ?06000007217 ASSOCIATION OF COMMUNITY BANKS AND CREDIT UNIONS, INCORPORATED ?12000010159 ASSOCIATION OF COMMUNITY BANKS N12000010159 AND CREDIT UNIONS, INCORPORATED SYMPATICO EQUINE RESCUE. INC. N13000001179 SYMPATICO EQUINE RESCUE. INC. N13000001179 LAKE VIEW HEIGHTS I PINE CREST CEMETERY NEIGHBORHOOD ASSOCIATION, INC ?13000006887 MIAMI FIRST FRIDAYS. INC. P01000033514 POINCIANA TITLE COMPANY P01000095472 POINCIANA TITLE COMPANY P01000095472 PORTFOLIO INVESTMENT PROPERTIES. INC. P01000115996 MY 1031 EXCHANGE. INC. P03000004337 FINN DISTRIBUTING. INC. P03000077369 CONSOLIDATED ENGINEERING OF FLORIDA. INC. P03000123474 .. 2/25/2017 Search Corporations, Limited Liability Companies, Limited Partnerships, and Page 1 of 1 Florida Deganmen: of State DIVISION as CORPORATIONS . .. .. ?.1de a. I. .3 J.- . . 531'? Ema? Degartmeniof State I Division chorgoraticns I Search Records I Search bv Of?cercr Rgistered Agenj Previous List WI ear Of?cerIRegistered Agent Name List Of?cerIRA Name Entity Name Entity Number SISKIND. JEFFREY CONSOLIDATED ENGINEERING OF FLORIDA, INC. P03000123474 SISKIND, JEFFREY WATERI-IOUSE REAL ESTATE BROKERS. INC. P05000152501 SISEIND. JEFFREY WATERHOUSE REAL ESTATE BROKERS. INC. SISKIND. JEFFREY POINCIANA PROCESSING. INC. P06000053970 SISKIND JEFFREY POINCIANA PROCESSING. INC. P060000539m INTERNATIONAL MARKETING MANAGEMENT CORPORATION P09000007511 SISKIND. JEFFREY VIRGIN OLIVE RESTAURANTS, INC. SISKIND JEFFREY TALAVERA REMODELING. INC. P14000005199 SISKIND JEFFREY CANNAMED FARMS. INC. P14000043933 JEFFREY TAMI. INCORPORATED P98000066525 SISKIND, Misg, JEFFREY REZZA PROPERTIES. INC. F00000008212 SISKIND. MESO. JEFFREY TP3. LLC L05000077693 SISKIND. MESO JEFFREY TP3. LLC L05000077693 SISKIND. M. JEFFREY TP5. LLC L07000032384 SISKIND. MESQ. JEFFREY COLLECTIVE MANAGEMENT ASSOCIATES. LLC L09000054906 SISKINDJMESQ- JEFFREY LIOUIDATION AUTO. LLC L11000098610 SISKIND. JEFFREY ESQ. ZOKAITES CONTRACTING FL. LLC L17000034189 SISKIND. MESO. JEFFREY JXL INTERNATIONAL. INC. N01000001927 FOUNDATION FOR THE STUDY AND TREATMENT SISKIND. MESO. JEFFREY OF BLOOD-BORNE VIRAL AND BACTERIAL N02000005053 DISEASES. INCORPORATED SISKINDLMESOLJEFFREY JXL COMMUNICATIONS CORP. P01000028111 Previous List Next List ,Of?cerIRA Name Seatch ea.- a~ -., '9?122 ?2 LC- 2/25/2017 Search Corporations, Limited Liability Companies, LImIted and rage 1 UI .I. Ficnda Eeoartmen: of Iate DIVISION or- CORPORATIONS Deaanment of I 0 rezions I Search Records I Search bv Of?cer or Reaistered Aoent I Frewous List Next List Of?cerIRegistered Agent Name List Of?cerIRA Name Entity Name Entity Number SISKIND. MESO. JEFFREY LAW CENTER OF THE PALM BEACHES, INC. P01000115951 SISKIND. MESO. JEFFREY LAW CENTER OF THE PALM BEACHES. INC. P01000115951 PORTFOLIO INVESTMENT PROPERTIES. INC. P01000115996 PATRIOT RESIDENTIAL PROPERTIES. INC. P02000000592 PATRIOT RESIDENTIAL PROPERTIES, INC. P02000000592 SI KIND MESQ JEFFREY jg? MOORER KEVIN P03000157241 SISKIND, JEFFREY KANARIS CORP. P1000007774a JESSICA GALLERY AT TURNBERRY, INC. 661293 JESSICA GALLERY AT TURNBERRY. INC. 661293 SISKIND JESSICA ADVENTURES IN ART. INC. J99654 SISKIND. JESSICA TURNBERRY ART GALLERY. INC. L68373 SISKINO. JESSICA SWEET SOCIETY, INC. P97000051936 SISKIND. JESSICA SWEET SOCIETY. INC. P97000061936 SISKIND. JESSICA ART VISIONS. INC. 311746 SISKIND. JESSICA ART VISIONS. INC. 311745 SISKIND. JOEL GLOBAL TRADING SPECIALTIES. INC P11000001349 SISKIND. JOEL GLOBAL TRADING SPECIALTIES. INC P11000001349 SISKIND JOEL CITY CELLULAR PLUS INC. P94000086173 SISKINO. JOEL I SELL IT STORE. INC. P08000110405 SISKIND. JOEL SELL IT STORE. INC. P08000110405 Previws Lisa- NexI L?Ist ear Canaan: a! 5:33. Swiss: 2/25/2017 Search Corporations, Limited Liability Companies, Limited Partnerships, and Page 1 of I Flo?ca Department of State Dame-3n OF Coapomnoxs 9f State I Divisign of Corgorations Search Records I Search by Of?ce: or Reoistered Aoent I Previoug Lis; Next List OfficerlRA Name SISKIND. WILLIAM ?asxwo WILLIAM L. WILLIAM SISKIND WILLIAM SISKIND WILLIAM WILLIAM SISKIND. WILLIAM SISKIND. WILLIAM SISKIND. WILLIAM SISKIND. WILLIAM SISKIND WILLIAM SISKIN, ELIZABETH SISKIN ENID SISKIN FLORENCE SISKING W. SISKIN. JOANNA WE SISKIN. LEAH SISKIN LEAH . . .. Previous List Next List Of?cerlRegistered Agent Name List .. louu?lu?aIIr-t h- . .H -. ,m Entity Name TRANSDOM. SA. OF THE DOMINICAN REPUBLIC STANDARD DREDGING CORPORATION CONSOLIDATED ENGINEERING COMPANY. INCORPORATED MIAMI VILLAGE CORPORATION UPLANDS. INC. ADAMS MORTGAGE COMPANY, INC. SOVEREIGN GAMING ENTERTAINMENT. LLC SOVEREIGN GAMING 8: ENTERTAINMENT. LLC CHANCE 8: ANTHEM. LLC FOUNDATION FOR THE STUDY AND TREATMENT OF BLOOD-BORNE VIRAL AND BACTERIAL DISEASES. INCORPORATED CONSOLIDATED ENGINEERING OF FLORIDA. INC. 1. LAUNDRIES. INC. FRIENDS OF SANTA ROSA COUNTY. INC. CARIGEM. INC. TRANSDOM. SA. OF THE DOMINICAN REPUBLIC NEIGHBORS. INC. NEIGHBORS. INC. COMMUNITY ADVOCATES FOR NEIGHBORS INC LISCHER LAUNDRY. INC. LISCHER LAUNDRY. INC. . . n. .. 77-- ?a . ..-- ma- - . .-.. um..-.. .Name Search O'F?oerfRA Name Search Search: Entity Number P33480 807595 808627 825511 825532 F99000002750 L14000018186 1.140000181 86 L14000158320 N02000005063 P03000123474 505585 N07000000442 P03 0001 0491 4 P38480 N08000002852 N08000002852 N1600001 1637 50361 9 50351 9 Searc? o~ - mum? . vii-rice Sesa??e?z o9 Stat-z, Cum-Int n'far??u'dsrs 2/25/2017 0 . ?515.04 p? 54149?9. wit 2.3M?z6?? \hs 6(5615? 5:61PALM BCH FL 33400-4193 3cm: . GEORGE - Accoumus . . Tb 5H - - m? 2048.171; 74 22? BAL - . 2048171.74 PREVIOUS: - 0.00 AVAILABLE: 0.00 - F0N65.AVAILABLE on: 10 DEC 13 200.00 24 mac: .13 004793.24 EHECKS: - 2048171.?4 50K AMT HOLD AMT - 2031.71. 74 204817134 . CH CK HOLD 1.1m, HOLD - CHECK HOLD RE z~ Lf-n Date: 3? :V?aj - "we, I - 3, JOSEPHE . SMITH. CLERK OF THE CIRCUIT COURT - ?Inna Filing 45932725 E?Filed 08/31/2016 03:39:30 PM I IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT IN AND FOR ST. LUCIE DAVID FIORE. individually and as assignee for Carl Stone, 3485 Lego de Taliveia Trust and Dianna George Plaintiff case V5. JEFFREY M. SISKIND, an individual; William SISKIND, an individual; SOVEREIGN GAMING 8: ENTERTAINMENT LLC, a Florida limited liability company; CHANCE 8: ANTHEM. LLC. a Florida limited liability company; 08 REAL ESTATE HOLDINGS 1732, a Florida limited liability company: SISKIND LEGAL SERVICES . LLC, a Florida limited liability company: and, ASSOCIATION OF COMMUNITY BANKS AND CREDIT UNIONS, INCORPORATED. a Florida for pro?t corporation. 910 SW DALTON TRUST Defendants. NOTICE or us ?egg TO: NAMED ABOVE AND ALI. omens WHOM rr MAY CONCERN: YOU ARE NOTIFIED OF THE FOLLOWING: 9. The Plaintiff named above has instituted this action against you based on ire; I I. raking to partition, tranSI?er of title, and/Dr money damages with respect to the prom; ?Ies. .Ded below. {bjThe piaintif?s) in this action islare DAVID FIORE, individually and as assignee for Carl Stone, 3485 L330 de Tallvera Trust and Dianna George (cmis action is instituted in the Circuit Court oi the 15in, ?icl "3"th in and for PALM BEACH County. Florida. The property that is subject matter of this axiom ?53 [Cl? County. Florida. and is described below as follows: he lDescri tlo .Locx 1595 PORT semen: SECTION 23 A SUBDIVISION occonoms to THE MAP on PLAT THEREOF DESCRIBED IN PLAT BOOK 13 PAGES 29 29A THOUGH 290, 9 PORT s?r 23- Elk 1595 LOT 13 44/075) (on 3310-2323 .SWDALTON AVE LUCIE 34953 BLOCK 1.595 SECTION 23 441075 Parcel ?timber anti-6109022341001 Subdivision?? Of?cial Records Book 1145 938? 2209 as of public records of PALM BEACH County. Florida Date this _25 of August, 2016 .. av DAVID FIORE, individually and as assignee for Carl Stone. 3485 Lego do Tailvera Trust and Dianne George MailingAddress 9727 U5 uss?k? emca 33w: FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 08/31/2016 03:39:30 PM