Filing # 154720038 E-Filed 08/04/2022 04:39:01 PM

IN THE CIRCUIT COURT OF THE 15th

JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA

CIRCUIT CIVIL DIVISION: AH

CASE NO. 50-2016-CA-009292-XXXX-MB

FIRST AMERICAN BANK, as successor

by merger to Bank of Coral Gables, LLC,

Plaintiff,

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vs.

LAURENCE S. SCHNEIDER,

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STEPHANIE L. SCHNEIDER, et al.,

Defendants.
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FIRST AMERICAN BANK, as successor
by merger to Bank of Coral Gables, LLC,

Plaintiff,
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vs.
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LAURENCE S. SCHNEIDER, STEPHANIE

L. SCHNEIDER, 1ST FIDELITY LOAN
SERVICING, LLC, S & A CAPITAL
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PARTNERS, INC., REAL ESTATE

& FINANCE, INC., BRAD AXEL and
PAIGE AXEL
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Third Party Defendants.

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VERIFIED EMERGENCY MOTION FOR THE APPOINTMENT OF A RECEIVER

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Based on the facts as set forth herein, on information and belief, Judgment
Debtor Laurence Schneider is actively dissipating and hiding assets to avoid
and defraud his creditors, in particular First American to avoid payment of
the Judgment. Accordingly, First American requests that the Court treat this
Motion as an Emergency Motion, and pursuant to Administrative Order
3.206, schedule a hearing, enter an ex parte order, or take any other
appropriate action the Court deems necessary.

Plaintiff in Execution, First American Bank (“First American”), moves for the

appointment of a Receiver pursuant to Florida Statutes § 56.29 and § 726.108(1)(c)(2) with

FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 08/04/2022 04:39:01 PM



 
  


respect to Defendant Laurence S. Schneider (“Schneider”), and with respect to the entities and

properties that he controls as set forth herein. The Court’s entry of an order appointing a

Receiver is: (i) in accordance with law; (ii) necessary to prevent Schneider’s evasion of

compliance with the Court’s orders and Judgment; and (iii) necessary to prevent further

dissipation of Schneider’s assets.

INTRODUCTION

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Schneider believes he is above the law. Schneider is a professional purchaser of

consumer debt and litigious individual with an extensive history in both the collection of debt

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and in unsuccessful lawsuits against banks. This experience makes Schneider knowledgeable and

adept at techniques to delay and avoid paying debts, which he is utilizing in these post-judgment

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proceedings. Prior to and since the entry of the Judgment, Schneider has engaged in a continuous
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and improper course of conduct in an effort to shield his assets from creditors, including First
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American, and to evade payment on the Judgment. Schneider made misrepresentations and
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engaged in numerous machinations in an effort to conceal his true worth and assets, including

refusing to truthfully complete his Judgment Debtor Fact Information Sheet and sit for a
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deposition, causing First American to incur substantial expenses.

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First American has evidence that Schneider has actively made extensive

misrepresentations and engaged in numerous machinations, including the use of family members
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as shills, in an effort to conceal his assets. In fact, Schneider has engaged in dozens of transfers
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of cash and property and engaged in numerous other activities in an evident effort to divest

himself of individual ownership of any and all assets that otherwise would be subject to the

payment of the Judgment owed by him to First American, all despite the fact that Schneider,

individually, remains in full control of these assets or the people who hold them.

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Moreover, Schneider’s transfers and suspicious activities includes the use of entities he

owns and controls, including 1st Fidelity Loan Servicing, LLC (“1st Fidelity”), S & A Capital

Partners, Inc. (“S&A”), and Real Estate & Finance, Inc. (“REF”), which act as his personal

piggy banks that are used to pay his personal expenses.

Millions of dollars go through Schneider’s hands, paying for expensive automobiles and

residences along with other personal expenses of him and his family yet to date, he has not paid a

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single dollar to First American against the Judgment.1

Accordingly, First American seeks an order appointing a Receiver over Schneider, 1st

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Fidelity, S&A and REF and entering a temporary injunction in aid of the receivership.

FACTUAL BACKGROUND

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A. General Background
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On August 17, 2016, First American filed suit against Schneider. On September 22, 2020,
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this Court entered a Final Judgment (“Judgment”) in favor of First American and ordered
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Schneider to pay First American $1,547,391.54 with interest at the rate of 6.03% per year.2 The

Judgment against Schneider remains due and unsatisfied.

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B. Schneider’s Money Commingling and Assistance from Others

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Schneider has been using 1st Fidelity, S&A and REF as his personal piggy bank. On

February 17, 2021, from approximately 12:39 p.m. to 1:25 p.m., one or both of the Schneiders
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First American’s recoveries have been limited to recovery of proceeds from liquidation of real
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estate, which secured Schneider’s commercial loan, and recovery of a bond Schneider posted in an appeal
Schneider filed and lost.
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The Judgment was also entered against Schneider’s wife, Stephanie Schneider (“Stephanie” and
together with Schneider, “Schneiders”). On March 9, 2022, the Fourth District Court of Appeal entered
an order reversing the Judgment against Stephanie in Case No. 4D21-571 (the “Appeal”). On March 22,
2022, First American filed a Motion for Rehearing and Motion or Rehearing En Banc in the Appeal,
which was denied on April 28, 2022. On May 31, 2022, First American filed a Notice to Invoke
Discretionary Jurisdiction of Supreme Court in the Florida Supreme Court, and on June 6, 2022, filed its
Jurisdictional Brief. On July 14, 2022, Stephanie filed her Amended Answer to First American’s
Jurisdictional Brief. The matter remains pending before the Florida Supreme Court as of the date of this
Motion.
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were at 6312 NW 26th Terrace, Boca Raton, FL 33413 (the “Boca Raton Property”). After

leaving the Boca Raton Property, Schneider and/or Stephanie traveled to a Northern Trust bank

branch located at 3100 N. Military Trail, Boca Raton, FL 33431, and at 2:31 p.m. withdrew

$17,500 in cash by check #7177 drawn on their personal account (ending 913) (the “Personal

Account”). After this withdrawal, Schneider and/or Stephanie traveled back to the Boca Raton

Property and remained there from 2:48 p.m. to 3:14 p.m.

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Upon further investigation, First American learned that the Boca Raton Property is

located in the Grand Oaks of Arvida Country Club, Boca Raton Rentals. An online search of this

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residence revealed that it was renting for $9,500 per month. This activity took place

approximately one month before the Schneiders moved into the luxury townhouse located at 628

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SE 5th St., Unit 2, Delray Beach, FL 33483 (the “Delray Beach Property”), which was rented
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from Michelle Figueras beginning on March 29, 2021 for a period of eight months. The
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Schneiders moved out of the Delray Beach Property on or about November 29, 2021.
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As noted above, Schneider owns and controls 1st Fidelity. Public records in Sunbiz do not

list anyone affiliated with 1st Fidelity other than Schneider. Based on the bank records for the
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Personal Account, 1st Fidelity is Schneider’s primary, but not only, source of income. When the
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Schneiders need money, it is often wired in from 1st Fidelity. The millions of dollars in transfers

did not occur on predictable dates or in predictable amounts as would be expected for transfers
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related to employment – instead, they occurred at irregular intervals and in varying amounts,
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from $15,000 to $500,000, and whenever the Schneiders needed larger sums of money for

personal expenses.

For example, when the Schneiders needed money in February 2021 to pay the $17,500

presumed deposit or rent for the Boca Raton Property, money was wired into their Personal

Account from 1st Fidelity. See Exhibit A.

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In March 2021, Stephanie needed money to pay the deposit and prepay rent to Michelle

Figueras for the Delray Beach Property pursuant to a lease between Stephanie and Michelle

Figueras (the “Lease”). Pursuant to the Lease, which was in Stephanie’s name only, rent was not

paid monthly; it was all due upon execution of the Lease, along with an $11,500 security deposit

for a total of $103,500 upon signing. On March 19, 2021, 1st Fidelity transferred $25,000 to the

Personal Account. The Lease was signed only by Stephanie on March 25, 2021. On March 26,

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2021, Schneider ordered a cashier’s check drawn on the Personal Account for $11,500. See

Exhibit B.

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On March 29, 2021, 1st Fidelity transferred $100,000 to the Personal Account. The next

day, Schneider transferred $94,300 from the Personal Account to Michelle Figueras’s UBS

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account, relating to the Lease. See Exhibit C. On June 11, 2021, 1st Fidelity sent Ms. Figueras

another $5,000 relating to the Lease.

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1st Fidelity also transferred money to an account jointly titled in the names of the
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Schneiders and their adult daughter, Jordyn Schneider, including a $9,500 transfer to Jordyn on

September 21, 2020. Upon information and belief, Jordyn provided no value to 1st Fidelity in
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exchange for this transfer, as she does not receive regular transfers from 1st Fidelity that would
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indicate employment by 1st Fidelity. Jordyn spent the money deposited into her account on

jewelry and clothing retailers, beauty retailers, restaurants, and Starbucks. See Exhibit D.
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Commingling among the Schneiders’ entities, including 1st Fidelity, S&A, and REF, and
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the Schneiders and their immediate family members as a way to avoid and frustrate creditors and

fund the Schneiders lifestyle is evident in other ways as well. For example, on information and

belief, between 2016 and 2022, Schneider’s son, Zachary Schneider, received transfers from 1st

Fidelity totaling approximately $116,000 for which he provided no value. Zachary is a college

student.

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In addition to the $9,500 transfer discussed above, on information and belief, Jordyn

received other transfers from 1st Fidelity between 2016 and 2022 totaling approximately

$196,184 for which she provided no value, and transfers from S&A between 2018 and 2020

totaling approximately $2,760 for which she provided no value. On information and belief,

Schneider then uses some of the funds transferred to Jordyn to pay his own expenses. For

example, Schneider had a term life insurance policy with Prudential that lapsed on or about June

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8, 2021 for nonpayment. On or about December 17, 2021, Jordyn used funds she received from

1st Fidelity to purchase a cashier’s check from Region’s Bank in the amount of $1,585. The

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check was payable to Prudential and referenced Schneider and Schneider’s Prudential policy

number.

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Schneider transferred money between and among S&A, REF and the Schneiders in other
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ways. On information and belief, between 2016 and 2021, S&A directly transferred the
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Schneiders approximately $520,023. On information and belief, S&A is REF’s primary and
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possibly sole source of funding. Between 2016 and 2021, S&A transferred REF $568,966. On

information and belief, REF provided no or less than reasonably equivalent value for these
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transfers and instead, this was simply another way to move money to Schneider without
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transferring it to him directly in order to avoid his creditors. In that same time period, between

2016 and 2021, REF in turn transferred the Schneiders approximately $398,361.
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This movement of money and the loans appear simply to be modes of moving money
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around so that Schneider’s creditors could not access the funds, but so that he could. In addition,

the fact that Schneider is using 1st Fidelity, S&A and REF to fund his day-to-day living expenses

shows that those entities’ bank accounts are merely his own personal piggy bank that he uses as

he desires.

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1st Fidelity, S&A and REF are dominated and controlled by Schneider in such a way that

they are mere alter egos of Schneider, and 1st Fidelity, S&A and REF are used solely for

Schneider’s personal benefit to shield assets from his creditors. As to S&A, the only entity

involving anyone other than Schneider, Brad Axel, Paige Axel, and Stephanie are shareholders,

and Brad is its vice president and is a signer on its bank account. On information and belief,

while Schneider is the controlling shareholder of S&A, Brad, Paige and Stephanie are aware of

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S&A’s financial activities and exercise at least some minimal control or oversight over S&A,

though on information and belief, there is currently little or no management alignment among the

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Schneiders and the Axels.

On information and belief, Brad, Paige, and Stephanie knew or were willfully blind to the

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fact that Schneider was using S&A to funnel money to at least one of his children and REF as a
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means to avoid his creditors, including First American. By acquiescing to these transactions with
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knowledge of Schneider’s fraudulent intent to structure transactions to frustrate his creditors,
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Brad, Paige, and Stephanie substantially assisted Schneider in his scheme to use S&A for his

own personal benefit. What’s more, on information and belief, S&A’s sole business purposes is
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to buy and outsource mortgages for servicing, hence it only sits with its hand out for payments
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form its service provider. These handouts are then funneled to Brad and Schneider, along with

other investors, though on information and belief, no other investor is currently owed any
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money, hence it all belongs to Brad and Schneider. However, on information and belief,
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following the garnishment, Schneider may be preventing Brad from accessing his share of

distributions by not agreeing to open a new bank account into which S&A’s loan servicer may

deposit proceeds from the servicing of S&A’s loan portfolio.

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C. Schneider’s Other Suspicious Financial Activity

The Schneiders have a safety deposit box at Northern Trust. It is unknown specifically

what assets the Schneiders are keeping in the safety deposit box and away from Schneider’s

creditors. On July 2, 2021, the Schneiders arrived at the Northern Trust bank branch. Schneider

carried a backpack and duffle bag into the bank, while Stephanie remained in the car for

approximately 25 minutes. Given the need for a backpack and duffle bag, presumably more than

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paperwork is being kept in the box. Given the large amounts of cash being withdrawn, as

discussed below, First American believes that large amounts of cash are being kept in the safety

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deposit box.

The Northern Trust records have also revealed that the Schneiders may be paying

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expenses largely in cash and withdrawing that cash in transactions that are just under the $10,000
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trigger for a cash transaction report to the Financial Crimes Enforcement Network of the U.S.
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Department of Treasury. Many of these cash transactions are not standard cash withdrawals –
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they are accomplished by writing checks to cash, endorsed by the same person with the same

signature as the person who wrote the check. See Exhibit E. In some instances, multiple smaller
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checks are made to cash within a short time period to withdraw $10,000 in total without
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triggering a cash transaction report. See Exhibit F.

The Schneiders then use the cash they systematically withdraw to pay their expenses. For
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example, on September 30, 2021 at 9:36 p.m., the Schneiders and their adult children were at the
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Island Vibes Kava Bar in Delray Beach. Just prior to leaving, Schneider gave his adult son cash,

who then placed the cash on the bar to settle the tab.

Schneider also made a number of fraudulent transfers from the Personal Account to

Muriel Schneider, his mother. Between December 13, 2016 and August 9, 2019, Muriel received

$105,899 in transfers from Schneider. The transfers were paid by check from the Personal

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Account, either made directly to Muriel or made to “cash” and endorsed by Muriel. Upon

information and belief, Muriel provided no value in exchange for these transfers.

D. Additional Transfers

Schneider is a controlling person for not only 1st Fidelity, but also S&A and REF. The

Personal Account records alone have made clear that Schneider uses at least one of his corporate

entities (1st Fidelity) to fund the Schneider’s personal expenses on an as-needed basis, making

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that corporate entity account effectively his. But there are other accounts making sizeable,

private transfers into the Personal Account at irregular intervals and in varying amounts, from

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$552 to $79,000. See Exhibit G. Upon information and belief, some or all of those transfers are

from S&A and/or REF. Some of these private transfers are in repeating amounts of $552, which

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might indicate employment income. On information and belief, some or all of these $552

transfers are from S&A.

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In August 2017 and February 2019, private transfers were sent to the Personal Account
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from an account ending 411 – one in the amount of $17,000 and the other $4,275.55. The 411

account is Jordyn Schneider’s account, which is jointly titled in the Schneider’s names. Sizeable
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transfers from their adult daughter’s account, which is controlled by the Schneiders, further
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evidences commingling of funds.

In response to a writ of garnishment pertaining to Schneider, Northern Trust froze

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accounts titled in the names of S&A and REF. Schneider is the only authorized signer on the
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REF account, which gives him total control over the account. Despite being titled in the name of

S&A, the S&A account is designated as a Joint Account with rights of survivorship, not a

corporate account, and the joint tenants are Schneider and Brad Axel. Only one signature is

required for withdrawal, which gives Schneider the ability to withdraw all of the funds in the

account at any time.

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Based upon bank records from BankUnited and Northern Trust, from 2016 to 2019, both

1st Fidelity and S&A made a number of transfers to Foster, Walker & DiMarco, P.C., a law firm

in Massachusetts where notably, Schneider’s sister is an attorney. These transfers from 1st

Fidelity and S&A totaled in the hundreds of thousands of dollars. On information and belief,

while some of these transfers funded unsuccessful litigation against Chase Bank to which 1st

Fidelity and S&A were parties (litigation which, on information and belief, non-Schneider

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shareholders had no say or control over), it may have also funded other litigation or real estate

ventures not involving these entities and benefitting only Schneider.

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E. Schneider’s Misrepresentations and Failures To Cooperate

In addition to the above, Schneider has engaged in numerous lies and has failed to

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cooperate with First American’s counsel, all in an effort to evade paying the Judgment.
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Schneider has actively obstructed First American’s post-judgment discovery and
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collection efforts. For example, Schneider has not been forthcoming in post-judgment discovery
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about income and transfers from any source. His first Fact Information Sheet was woefully

incomplete and contained false information (including a knowingly outdated residence address).
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His second Fact Information Sheet was still incomplete and failed to attach required documents.
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Stephanie objected to every document subpoena that First American notified parties that it

intended to serve, forcing substantial delay in obtaining necessary post-judgment discovery that
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First American was clearly entitled to.

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More recently, Schneider evaded his scheduled deposition. Through his counsel,

Schneider had agreed to sit for his deposition on June 28, 2022. First American had prepared for

the deposition including by reserving and paying for a court reporter, compiling documents into

binders, attorney preparation time and attorney travel time for First American’s lead counsel

from Chicago to Miami.

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However, at 3 a.m. on the morning of the deposition, Schneider’s counsel e-mailed First

American’s counsel to seek to postpone the deposition slightly due to needing time to prepare for

the deposition. First American agreed to a two-hour delay of the deposition, which was

communicated to Schneider and confirmed by him shortly after 9 a.m. on June 28, 2022. Later

that morning, Schneider and his counsel indicated that they were running late but would arrive

for the deposition within twenty minutes. However, miraculously, within those twenty minutes,

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Schneider was suddenly exposed to someone with COVID and had become “severely ill” to the

point where he could not even join a brief zoom conference to confirm his sudden-onset “severe”

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illness and testify that he believed he had COVID and the circumstances of his supposed

exposure. Emails attached as Exhibit H.

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First American finds it unbelievable that Schneider would have been well enough at 3
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a.m. and 9 a.m. and 12 p.m. on June 28, 2022, but all of a sudden exposed to COVID and
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“severely ill” mere minutes later. This scheme smacks of being simply a ploy to avoid having his
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deposition taken. Not surprisingly, the undersigned has not heard from Schneider or his counsel

about re-scheduling the exam, even after First American filed a Motion to Compel and for
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Sanctions on July 18, 2022, relating to Schneider’s failure to appear.

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In addition, though Schneider’s adult children were properly served with deposition

subpoenas weeks ago via substitute service on Stephanie (see Proof of Service, Exhibit I) to
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have their depositions taken the following day (June 29, 2022), without filing and obtaining an
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order granting a motion for protective order or motion to quash the subpoenas as required under

the Florida Rules of Civil Procedure to excuse their appearance, they too refused to appear as

scheduled, causing First American to incur additional substantial costs related to the reserved

court reporter, attorney preparation time and travel time for First American’s lead counsel from

Chicago to Miami.

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Schneider’s fraud and refusals to cooperate are further attempts to avoid Schneider

satisfying his obligations under the Court’s orders and Judgment and keep First American from

discovering the depth of his schemes to transfer all of his assets away from himself and

otherwise commingle his assets with his entities to maintain control over his assets while

appearing to own none.

ARGUMENT & MEMORANDUM OF LAW

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The Court’s appointment of a receiver will help ensure Schneider’s compliance with the

Court’s orders and Judgment and reduce the chance of Schneider further dissipating his assets. In

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First American Banks’ Second Amended Supplemental Complaint for Reverse Piercing the

Corporate Veil, Permanent Injunctive Relief, Avoidance and Recovery of Fraudulent Transfers,

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and Other Related Relief, filed on July 6, 2022, First American sought to avoid the following

transfers:
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x On March 19, 2021, 1st Fidelity (Schneider’s alter ego) transferred $25,000 to the
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Personal Account, of which, $11,500 was used for Stephanie’s benefit relating to
the Lease;

x On March 29, 2021, 1st Fidelity transferred $100,000 to the Personal Account, of
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which, $94,300 was used for Stephanie’s benefit and subsequently transferred to
Michelle Figueras pursuant to the Lease; and

On June 11, 2021, 1st Fidelity transferred $5,000 to Michelle Figueras for
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x
Stephanie’s benefit, relating to the Lease.
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As set forth more fully therein, and as is, in relevant part, incorporated herein by
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reference, before and/or after the transfers by Schneider set forth more fully herein, First
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American held a right to payment against Schneider (and his alter ego, 1st Fidelity) and was a

creditor of Schneider (and his alter ego, 1st Fidelity). Schneider/1st Fidelity made the transfers in

order to delay, hinder or defraud First American and/or were made with the actual intent to

hinder, delay or defraud First American.

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Furthermore, First American held a right to payment against Schneider (and his alter ego

1st Fidelity) before or after the transfers. 1st Fidelity made the transfers without receiving any

value in exchange for the transfer or receiving less than the reasonably equivalent value.

Moreover, at the time of the transfers: 1) 1st Fidelity was engaged in or was about to engage in a

business or transaction for which the remaining assets of 1st Fidelity were unreasonably small in

relation to the business or transaction; and/or 2) 1st Fidelity intended to incur or believed or

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reasonably should have believed that it would incur, debts beyond its ability to pay.

Based upon Schneider’s nefarious activity and extensive machinations to shield his

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assets, as detailed in this Motion, First American is entitled to the appointment of a receiver

pursuant to Fla. Stat. § 726.108(1)(c)(2) (entitling First American to the appointment of a

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receiver “to take charge of the asset transferred or of other property of the transferee”); see also
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Friedman v. Heart Inst. of Port St. Lucie, Inc., 863 So. 2d 189, 192 (Fla. 2003) (“A creditor who
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possesses a claim may seek a number of remedies to prevent the fraudulent transfer of assets.
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Among the remedies are avoidance of the transfer, attachment, an injunction, appointment of a

receiver, and any other relief the circumstances may require.”) (internal citations and quotation
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marks omitted); Sallah ex rel. MRT LLC v. Worldwide Clearing LLC, 860 F. Supp. 2d 1329
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(S.D. Fla. 2011) (receiver authorized to avoid fraudulent transfers).

In addition to statutory authority for appointment of a receiver, “[t]he power to appoint a

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receiver has long been recognized as one that is inherent in a court of equity, which ‘lies in the
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sound discretion of the chancellor to be granted or withheld according to the facts and

circumstances of the particular case.’” Granada Lakes Villas Condominium Ass’n, Inc. v. Metro-

Dade Investments Co., 125 So.3d 756, 758-59 (Fla. 2013), citing Ins. Mgmt., Inc. v. McLeod, 194

So.2d 16, 17 (Fla. 3d DCA 1966), Lehman v. Trust Co. of Am., 49 So. 502, 503-04 (Fla. 1909)

(acknowledging that the power to appoint a receiver lies in the court’s discretion and listing

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certain principles that a court should consider when exercising its equitable power to appoint a

receiver), and Edenfield v. Crisp, 186 So.2d 545, 549 (Fla. 2d DCA 1966 (“The power to appoint

a receiver is always one that is inherent in a [court of equity].”).

Here, equitable considerations support appointment of a receiver to, among other things,

protect against and remedy misappropriation and maintain the status quo. The appointment of a

receiver is a recognized method to preserve the status quo. See, e.g., Romay v. Caribevision

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Holdings, Inc., 173 So.3d 1055 (Fla. 3d DCA 2015); Arison Shipping Co. v. Klosters Rederi A/S,

259 So. 2d 784, 785 (Fla. 3d DCA 1972); DeSilva v. First Cmty. Bank of Am., 42 So. 3d 285,

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290 (Fla. 2d DCA 2010) (internal citations omitted).

Accordingly, First American seeks the Court’s order appointing a receiver over the

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following assets pending resolution of this matter:

x All assets of Schneider;

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x All assets of Stephanie (based on her conspiring with Schneider to fraudulently
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transfer Schneider’s assets);

x All assets of 1st Fidelity (the alter ego of Schneider);

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x All assets of S&A (the alter ego of Schneider); and

x All assets of REF (the alter ego of Schneider).

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First American further requests the entry of a limited, temporary injunction in support of
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the receivership and to allow the receiver to exercise his or her duties and powers without the
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interference of Schneider or third parties.

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Courts have discretion to enter injunctive relief that furthers the purposes of a court-

ordered receivership. See Ins. Mgmt., Inc., v. McLeod, 194 So. 2d 16 (Fla. 3d DCA 1966)

(affirming appointment of receiver over corporate property and injunction in relation to

unauthorized withdrawals of corporate funds from corporate accounts by the president); Dixie

Music Co., Inc., v. Pike, 185 So. 441 (Fla. 1938) (affirming ex parte injunction preventing
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defendant’s principals, servants, agents, and employees from interfering with the receiver, and

the assets and business in receivership); cf. Puma Enter. Corp. v. Vitale, 566 So. 2d 1343, 1345

(“[T]he court making the appointment [of a receiver] may, at its discretion, during the pendency

of the action much such further orders as are necessary and proper for the protection of the

property and interests concerned.”) (citing Abramson v. Brant, 141 So. 2d 777, 778 (Fla. 3d

DCA 1962)).

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Accordingly, First American requests the entry of a limited injunction requiring

Schneider to:

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x turn over all financial statements, books, and records as may be needed for the
receiver to carry out its powers and duties with respect to the receivership;

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x cooperate with the receiver in the conduct of the receivership; and

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the receiver’s powers and duties.
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otherwise refrain from interfering with the receivership or delaying the exercise of
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As demonstrated in the Motion and by the protracted pre and post Judgment litigation,
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Schneider acts as though he is above the law. Absent the appointment of a receiver, he will
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continue to act that way improperly prolong these proceedings.

WHEREFORE, First American respectfully requests this Court: (i) appoint a receiver
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over Schneider, 1st Fidelity, S&A, REF and the transferred assets as set forth in this Motion; (ii)

enter a temporary injunction in aid of the receivership as set forth in this Motion; and (iii) grant
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any and all other relief this Court deems appropriate.

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VERIFICATION

Pursuant to 28 U.S.C. § 1746 and § 92.525, Fla. Stat., under penalties of perjury, I

declare that I have read the foregoing Verified Emergency Motion for the Appointment of a

Receiver and that the facts stated in it are true.

__________________________
Joseph Resler

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Senior Vice President
First American Bank




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Dated: August __, 2022.

Respectfully submitted,

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/s/Meaghan E. Murphy /s/ Neal H. Levin
Meaghan E. Murphy, Esquire Neal H. Levin, Esquire
Florida Bar No. 102770
[email protected]
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Admitted Pro Hac Vice
[email protected]
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MELAND BUDWICK, P.A. FREEBORN & PETERS LLP
3200 Southeast Financial Center 311 South Wacker Drive
200 South Biscayne Boulevard Suite 3000
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Miami, Florida 33131 Chicago, Illinois 60606-6677

Telephone: (305) 358-6363 Telephone: (312) 360-6000
Facsimile: (305) 358-1221 Facsimile: (312) 360-6520
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Co-Counsel for First American Bank Co-Counsel for First American Bank
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CERTIFICATE OF SERVICE
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I HEREBY CERTIFY that a true and correct copy of the foregoing was served on August
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/s/ Meaghan E. Murphy

Meaghan E. Murphy, Esquire

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EXHIBIT H

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From: Martin McCarthy
To: Meaghan Murphy
Cc: Emre Yersel; Kaitlyn Bunnell
Subject: Re: Deposition of Larry Schneider
Date: Tuesday, June 28, 2022 2:52:08 AM
Attachments: 6.28.22 Larry Notice of Taking Depositions.pdf

EXTERNAL EMAIL:
Dear Ms. Murphy:

My apologies for the after-hours email. Both myself and Mr. Schneider had an unrelated
appellate deadline yesterday, Monday, June 27, 2022, which ran into the evening. Due to this

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unforeseen but unavoidable delay we could not speak until this evening. Mr. Schneider has
requested that I reach out to determine whether you would be willing to postpone his
deposition to Wednesday, June 29, 2022 (to my understanding neither Zack or Jordyn have
been served) beginning and ending at your convenience, push back tomorrow's start time to

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1pm, and continue into either the morning or afternoon of Wednesday, June 29, 2022, or at the
minimum push back today's starting time to noon on Tuesday, June 28, 2022. Thank you for
your consideration of these requests. I cannot imagine the Court Reporter will have any
objection due to the likelihood that Mr. Schneider's deposition will be protracted due to the

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nature of the Parties and their history. 
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I have a 830am Family motion calendar hearing, but I will reach out to you at its conclusion. 
IF
Sincerely Yours,
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Martin G. McCarthy, Esq.

MCCARTHY & YERSEL, PLLC
4929 SW 74th CT, Ste 5
CE

Miami, Florida 33155

(305) 407-8006 office
(866) 676-4671 facsimile
(305)522-6224 cellular
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email: [email protected]

Our Address Changed!  Please note effective February 22, 2021, our new Office Address is
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4929 SW 74th CT, Ste 5, Miami, FL 33155

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Confidentiality Notice: This e-mail transmission, and any documents, files or previous e-mail

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messages attached to it may contain confidential information that is legally privileged. If you
are not the intended recipient, or a person responsible for delivering it to the intended
recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you
have received this transmission in error, please immediately notify us by reply e-mail, or by
telephone at the direct dial number above and destroy the original transmission and its
attachments without reading or saving in any manner. Thank you.
From: Meaghan Murphy
To: Martin McCarthy
Cc: Emre Yersel; Kaitlyn Bunnell; Neal H. Levin
Subject: Re: Deposition of Larry Schneider
Date: Tuesday, June 28, 2022 6:59:46 AM
Attachments: 6.28.22 Larry Notice of Taking Depositions.pdf

Good morning,

We can move the start time today to noon to accommodate you and Mr. Schneider. 

As for Jordyn and Zachary, it is our opinion that that were properly serviced by substitute
service on June 14 and expect them to appear tomorrow. 

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Meaghan Murphy
Meland Budwick, P.A.

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From: Kaitlyn Bunnell
To: Meaghan Murphy; Martin McCarthy
Cc: Emre Yersel; Neal H. Levin
Subject: Re: Deposition of Larry Schneider
Date: Tuesday, June 28, 2022 9:12:10 AM

EXTERNAL EMAIL:
We have advised our client, Mr. Schneider, of the new start time.  Please provide us with the
Return of Service for the Zachary and Jordyn Schneider.

Thank you, 

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Kaitlyn Bunnell, Paralegal
MCCARTHY & YERSEL, PLLC
4929 SW 74th CT

CO
Miami, FL 33155
Telephone: (305) 407-8006
Cell: (305) 335-5543
Fax: (866) 676-4671

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CONFIDENTIALITY NOTE: The information contained in this transmission is privileged and
confidential intended only for the use of the individual or entity named above.  If the reader of this
message is not the intended recipient, you are hereby notified that any dissemination, distribution or
IF
copying of this communication is strictly prohibited.  If you have received this transmission in error,
do not read it.  Please immediately reply to the sender that you have received this communication in
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error and then delete it. Thank you.

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From: Kaitlyn Bunnell
To: Meaghan Murphy; Martin McCarthy
Cc: Emre Yersel; Neal H. Levin
Subject: Re: Deposition of Larry Schneider
Date: Tuesday, June 28, 2022 11:43:33 AM

EXTERNAL EMAIL:
Good afternoon Ms. Murphy,

Mr. McCarthy is on his way; however, has advised that he may be approximately 20 minutes
late. 

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Thank you, 

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Kaitlyn Bunnell, Paralegal
MCCARTHY & YERSEL, PLLC
4929 SW 74th CT
Miami, FL 33155
Telephone: (305) 407-8006

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Cell: (305) 335-5543
Fax: (866) 676-4671 IE
 
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CONFIDENTIALITY NOTE: The information contained in this transmission is privileged and
confidential intended only for the use of the individual or entity named above.  If the reader of this
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message is not the intended recipient, you are hereby notified that any dissemination, distribution or
copying of this communication is strictly prohibited.  If you have received this transmission in error,
do not read it.  Please immediately reply to the sender that you have received this communication in
error and then delete it. Thank you.
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From: Kaitlyn Bunnell
To: Meaghan Murphy; Martin McCarthy
Cc: Emre Yersel; Neal H. Levin
Subject: Re: Deposition of Larry Schneider
Date: Tuesday, June 28, 2022 12:04:40 PM
Importance: High

EXTERNAL EMAIL:
Good afternoon Ms. Murphy,

I attempted to call your office; however, the call was disconnected and I was unable to get

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through.  Mr. Schneider has reached out to us to advise that he was exposed to someone with
covid, and is now feeling ill.  Mr. McCarthy asked that you provide us with the invoice for the
court reporter, and we will pay such. 

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My apologies for any inconveniences this may cause.

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When possible, please provide us dates to reschedule.

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Further, please provide me with the Returns of Service for Jordyn and Zachary Schneider.
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Thank you, 
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Kaitlyn Bunnell, Paralegal

MCCARTHY & YERSEL, PLLC
4929 SW 74th CT
Miami, FL 33155
CE

Telephone: (305) 407-8006

Cell: (305) 335-5543
Fax: (866) 676-4671
A

 
CONFIDENTIALITY NOTE: The information contained in this transmission is privileged and
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confidential intended only for the use of the individual or entity named above.  If the reader of this
message is not the intended recipient, you are hereby notified that any dissemination, distribution or
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copying of this communication is strictly prohibited.  If you have received this transmission in error,
do not read it.  Please immediately reply to the sender that you have received this communication in
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error and then delete it. Thank you.

From: Levin, Neal H.
To: Kaitlyn Bunnell; Martin McCarthy
Cc: Meaghan Murphy; Emre Yersel; Isenberg, Shira R.; [email protected]
Subject: Re: Deposition of Larry Schneider
Date: Tuesday, June 28, 2022 12:15:08 PM
Importance: High

EXTERNAL EMAIL:
Here are the steps that need to be taken:

1. Larry will join the Zoom call immediately to swear under oath as to his exposure, complete with name of
the party to whom he was exposed for independent verification;
2. We will then set a date for the continued exam.
3. The fees and costs that we will seek include:

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Court Reporter, including Zoom charges
1 hour of non-prep counsel time for Meaghan
My travel time and expenses from Chicago

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Zoom instructions:

Join Zoom Meeting

https://melandbudwick.zoom.us/j/87003876883?pwd=SXN6NjdRYy9oM0pyVFA4ZHJORCtmdz09

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Meeting ID: 870 0387 6883
Passcode: 157518
One tap mobile
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+19292056099,,87003876883#,,,,*157518# US (New York) 
+13017158592,,87003876883#,,,,*157518# US (Washington DC)
 
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We look forward to Martin’s agreement to the foregoing and Laurence and Martin joining the call shortly.
We will wait until 12:30.

Neal
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From: Kaitlyn Bunnell
To: Levin, Neal H.; Martin McCarthy
Cc: Meaghan Murphy; Emre Yersel; Isenberg, Shira R.; [email protected]
Subject: Re: Deposition of Larry Schneider
Date: Tuesday, June 28, 2022 12:22:24 PM

EXTERNAL EMAIL:
I have spoken with Mr. McCarthy, and it is our impression that Mr. Schneider is severely ill; however, he is
attempting to call him now and will advise thereafter. 

Thank you, 

Kaitlyn Bunnell, Paralegal

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MCCARTHY & YERSEL, PLLC
4929 SW 74th CT
Miami, FL 33155
Telephone: (305) 407-8006

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Cell: (305) 335-5543
Fax: (866) 676-4671

 
CONFIDENTIALITY NOTE: The information contained in this transmission is privileged and confidential

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intended only for the use of the individual or entity named above.  If the reader of this message is not the intended
recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly
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prohibited.  If you have received this transmission in error, do not read it.  Please immediately reply to the sender
that you have received this communication in error and then delete it. Thank you.
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From: Kaitlyn Bunnell
To: Meaghan Murphy
Cc: Martin McCarthy; Emre Yersel; Melissa Ramos
Subject: Re: Deposition of Larry Schneider
Date: Tuesday, June 28, 2022 12:45:18 PM

EXTERNAL EMAIL:
Dear Ms. Murphy:

As this your deposition, I am kindly writing to you to readvise that Mr. Schneider is ill and is unable to attend nor testify
per Mr. McCarthy's last communication with him.  Mr. McCarthy was not able to get a hold of him after the zoom
instructions were provided.

Thank you, 

PY
Kaitlyn Bunnell, Paralegal
MCCARTHY & YERSEL, PLLC
4929 SW 74th CT

CO
Miami, FL 33155
Telephone: (305) 407-8006
Cell: (305) 335-5543
Fax: (866) 676-4671

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CONFIDENTIALITY NOTE: The information contained in this transmission is privileged and confidential intended only for
the use of the individual or entity named above.  If the reader of this message is not the intended recipient, you are hereby notified
IE
that any dissemination, distribution or copying of this communication is strictly prohibited.  If you have received this
transmission in error, do not read it.  Please immediately reply to the sender that you have received this communication in error
and then delete it. Thank you.
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EXHIBIT I

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 RETURN OF SERVICE

State of Florida County of Palm Beach Circuit Court

Case Number: 50-2016-CA-009292-XXXX-MB Court Date: 6/29/2022 9:30 am

Plaintiff:
FIRST AMERICAN BANK, as successor by merger to Bank of Coral
Gables, LLC
vs.
Defendant:

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LAURENCE S. SCHNEIDER, STEPHANIE L. SCHNEIDER, et al.,

For:
Meaghan Murphy

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MELAND & BUDWICK, P.A.
200 South Biscayne Blvd., Suite 3200
Miami, FL 33131

Received by Brickell Courier Services on the 14th day of June, 2022 at 10:05 am to be served on Jordyn

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Schneider, 2000 Island Blvd., Unit 2001, Aventura, FL 33160.

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I, Wilfredo Gonzalez, do hereby affirm that on the 14th day of June, 2022 at 2:15 pm, I:

SUBSTITUTE served by delivering a true copy of the Subpoena for Deposition and Notice of Taking
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Deposition with the date and hour of service endorsed thereon by me, to: Stephanie Schneider as
Mother Co-Resident at the address of: 2000 Island Blvd., Unit 2001, Aventura, FL 33160, the within
named person's usual place of Abode, who resides therein, who is fifteen ( 15) years of age or older and
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informed said person of the contents therein, in compliance with state statutes.

Additional Information pertaining to this Service:

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The mother opened the door and stated that her children are out of state, then she asked me how I got into
the unit and I replied that I'm a process server and the concierge let me go upstairs. The mother was angry
with me and refused to accept the documents for her daughter Jordyn Schneirder and she closed the door
on my face. I left the documents at the door and I told her that she was served.
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Description of Person Served: Age: 55, Sex: F, Race/Skin Color: White, Height: 5'5", Weight: 140, Hair:
Blonde, Glasses: N
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 RETURN OF SERVICE For 50-2016-CA-009292-XXXX-MB

I certify that I am over the age of 18, have no interest in the above action, and am a Certified Process
Server, in good standing, in the judicial circuit in which the process was served. Under penalty of perjury, I
declare that I have read the forgoing return of service and that the facts stated in it true per F.S. 92.535(2).
Notary not required

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Wilfredo G
CPS# 1863

Brickell Courier Services

P.O Box 01-1310
Miami, FL 33101
(305) 350-3224

Our Job Serial Number: BKS-2022000634

Copyright© 1992-2022 Database Services. Inc. -Process Server's ToolboxV8.1c

 IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR
·PALM BEACH COUNTY, FLORIDA

CIRCUIT CIVIL DIVISION: AH

CASE NO. 50-2016-CA-009292-XXXX-MB

FIRST AMERICAN BANK, as successor

by merger to Bank of Coral Gables, LLC,

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Plaintiff,

vs.

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LAURENCE S. SCHNEIDER,
STEPHANIE L. SCHNEIDER, et al.,

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Defendants.
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---------------
SUBPOENA FOR DEPOSITION
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THE STATE OF FLORIDA:
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TO: Jordyn Schneider

2000 Island Blvd.
Unit 2001
CE

Aventura, FL 33160

YOU ARE HEREBY COMMAND ED to appear before a person authorized by law to

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take deposition at Meland Budwick, P.A., 3200 Southeast Financial Center, 200 South
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Biscayne Blvd., Miami, Florida 33131 on Wednesday, June 29, 2022 at 9:30 a.m. EST, for
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the taking of your deposition in this action.

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The deposition will be upon oral examination before Veritext Legal Solutions, Notary

Public in and for the State of Florida at large, or some other officer duly authorized by law to

take depositions. The deposition will be recorded stenographically. This deposition is being

taken for discovery and/or any other purpose permitted under the Rules of Civil Procedure and
Rules of Evidence. The deposition will continue from hour to hour and from day to day until

completed.

You are subpoenaed to appear by the following attorney, and unless excused from this

Subpoena by said attorney or the Court, you shall respond to this Subpoena as directed. Please

contact the undersigned attorney upon your receipt of this Subpoena. If you fail to appear, you

may be in contempt of Court.

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DATED June 8, 2022.

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s/Meaghan E. Murphy
Meaghan E. Murphy
For the Court

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Meaghan E. Murphy, Esq.
Florida Bar No. 102770
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[email protected]
Meland Budwick, P.A.
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Co-Counsel for First American Bank

3200 Southeast Financial Center
200 South Biscayne Boulevard
CE

Miami, FL 33131
Telephone: (305) 358-6363
Facsimile: (305) 358-1221
A

In accordance with the Americans with Disabilities Act of 1990, persons needing a special
accommodation to participate in this proceeding should contact Meaghan E. Murphy, Esquire at
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Meland Budwick, telephone number (305) 358-6363, no later than three (3) days prior to the
proceeding. If hearing impaired, please call telephone Florida Relay Service at 1-800-955-8771 for
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assistance.
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2
 IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA

CIRCUIT CIVIL DIVISION: AH

CASE NO. 50-2016-CA-009292-XXXX-MB

FIRST AMERICAN BANK, as successor

by merger to Bank of Coral Gables, LLC,

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Plaintiff,
vs.

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LAURENCE S. SCHNEIDER,
STEPHANIE L. SCHNEIDER, et al.,

Defendants.

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NOTICE OF TAKING DEPOSITION
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PLEASE TAKE NOTICE that pursuant to Florida Rule of Civil Procedure 1.310 and
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1.560, First American Bank will take the deposition of the below-named persons on the dates and

times indicated below:

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Name Date and Time Place

Jordyn Schneider Wednesday, June 29, 2022 Meland Budwick, P.A.
at 9:30 a.m. EDT 200 S. Biscayne Blvd.
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Suite 3200
Miami, FL 33131
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Regarding the matters described in the subpoena attached hereto. The deposition will be taken
upon oral examination before a court reporter Veritext Court Reporter, Notary Public, in and for
the State of Florida at Large, or some other officer duly authorized by law to take deposition. This
deposition is being taken for discovery, use at trial, or any other purpose permitted under the Rules
of Civil Procedure and Rules of Evidence. The deposition will continue from hour to hour and
from day to day until completed.

MELAND l BUDWICK
3200 SOUTHEAST FINANCIAL CENTER I 200 SOUTH BISCAYNE BOULEVARD I MIAMI, FL 33131 IT 305-358-6363
In accordance with the Americans with Disabilities Act of 1990, persons needing a special
accommodation to participate in this proceeding should contact Meaghan E. Murphy, Esquire
at Meland Budwick, P.A. telephone number (305) 358-6363, no later than seven (7) days prior
to the proceeding. If hearing impaired, telephone Florida Relay Service at 1-800-955-8771 for
assistance.

CERTIFICATE OF SERVICE

I CERTIFY that the foregoing document has been furnished to all registered users via the

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Florida Courts e-Filing Portal on June 8, 2022.

s/ Meaghan E. Murphy

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Meaghan E. Murphy, Esquire
Florida Bar No. 102770
[email protected]
MELAND BUDWICK, P.A.

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200 South Biscayne Boulevard, Suite 3200
Miami, Florida 3313 1
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Telephone: (305) 358-6363
Facsimile: (305) 358-1221
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Counsel for Plaintiff
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Email Designation per Fla. R. Jud.

Admin 2.516
[email protected]
[email protected]
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[email protected]
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MELAND ! BUDWICK
3200 SOUTHEAST FINANCIAL CENTER I 200 SOUTH BISCAYNE BOUL.EVARD I MIAMI, FL 33131 IT 305-358-6363
 RETURN OF SERVICE

State of Florida County of Palm Beach Circuit Court

Case Number: 50-2016-CA-009292-XXXX-MB Court Date: 6/29/2022 2:00 pm

Plaintiff:
FIRST AMERICAN BANK, as successor by merger to Bank of Coral
Gables, LLC
vs.
Defendant:

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LAURENCE S. SCHNEIDER, STEPHANIE L. SCHNEIDER, et al.,

For:
Meaghan Murphy

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MELAND & BUDWICK, P.A.
200 South Biscayne Blvd., Suite 3200
Miami, FL 33131

Received by Brickell Courier Services on the 14th day of June, 2022 at 10:05 am to be served on Zachary

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Schneider, 2000 Island Blvd., Unit 2001, Aventura, FL 33160.

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I, Wilfredo Gonzalez, do hereby affirm that on the 14th day of June, 2022 at 2:15 pm, I:

SUBSTITUTE served by delivering a true copy of the Subpoena for Deposition and Notice of Taking
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Deposition with the date and hour of service endorsed thereon by me, to: Stephanie Schneider as
Mother at the address of: 2000 Island Blvd., Unit 2001, Aventura, FL 33160, the within named person's
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usual place of Abode, who resides therein, who is fifteen (15) years of age or older and informed said
person of the contents therein, in compliance with state statutes.

Additional Information pertaining to this Service:

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The mother opened the door and stated that her children are out of state, then she asked me how I got into
the unit and I replied that I'm a process server and the concierge let me go upstairs. The mother was angry
with me and refused to accept the documents for her son Zachary Schneirder and she closed the door on
my face. I left the documents at the door and told her that she was served.
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Description of Person Served: Age: 55, Sex: F, Race/Skin Color: White, Height: 5'5", Weight: 140, Hair:
Blonde, Glasses: N
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 RETURN OF SERVICE For 50-2016-CA-009292-XXXX-MB

I certify that I am over the age of 18, have no interest in the above action, and am a Certified Process
Server, in good standing, in the judicial circuit in which the process was served. Under penalty of perjury, I
declare that I have read the forgoing return of service and that the facts stated in it true per F.S. 92.535(2).
Notary not required

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Brickell Courier Services

P.O Box 01-1310
Miami, FL 33101
(305) 350-3224

Our Job Serial Number: BKS-2022000635

Copyright© 1992-2022 Database Services. Inc. - Process Server"s Toolbox V8.1c

 IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA

CIRCUIT CIVIL DIVISION: AH

CASE NO. 50-2016-CA-009292-XXXX-MB

FIRST AMERICAN BANK, as successor

by merger to Bank of Coral Gables, LLC,

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Plaintiff,

vs.

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LAURENCE S. SCHNEIDER,
STEPHANIE L. SCHNEIDER, et al.,

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Defendants.
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SUBPOENA FOR DEPOSITION
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THE STATE OF FLORIDA:
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TO: Zachary Schneider

2000 Island Blvd.
Unit 2001
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Aventura, FL 33160

YOU ARE HEREBY COMMANDED to appear before a person authorized by law to

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take deposition at Meland Budwick, P.A., 3200 Southeast Financial Center, 200 South
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Biscayne Blvd., Miami, Florida 33131 on Wednesday, June 29, 2022 at 2:00 p.m. EST, for
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the taking of your deposition in this action.

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The deposition will be upon oral examination before Veritext Legal Solutions, Notary

Public in and for the State of Florida at large, or some other officer duly authorized by law to

take depositions. The deposition will be recorded stenographically. This deposition is being

taken for discovery and/or any other purpose permitted under the Rules of Civil Procedure and
Rules of Evidence. The deposition will continue from hour to hour and from day to day until

completed.

You are subpoenaed to appear by the following attorney, and unless excused from this

Subpoena by said attorney or the Court, you shall respond to this Subpoena as directed. Please

contact the undersigned attorney upon your receipt of this Subpoena. If you fail to appear, you

may be in contempt of Court.

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DATED June 8, 2022.

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s/Meaghan E. Murphy
Meaghan E. Murphy
For the Court

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Meaghan E. Murphy, Esq.
Florida Bar No. 102770
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[email protected]
Meland Budwick, P.A.
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Co-Counsel.for First American Bank

3200 Southeast Financial Center
200 South Biscayne Boulevard
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Miami, FL 33131
Telephone: (305) 358-6363
Facsimile: (305) 358-1221
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In accordance with the Americans with Disabilities Act of 1990, persons needing a special
accommodation to participate in this proceeding should contact Meaghan E. Murphy, Esquire at
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Meland Budwick, telephone number (305) 358-6363, no later than three (3) days prior to the
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proceeding. If hearing impaired, please call telephone Florida Relay Service at 1-800-955-8771 for
assistance.
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 IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA

CIRCUIT CIVIL DIVISION: AH

CASE NO. 50-2016-CA-009292-XXXX-MB

FIRST AMERICAN BANK, as successor

by merger to Bank of Coral Gables, LLC,

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Plaintiff,
vs.

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LAURENCE S. SCHNEIDER,
STEPHANIE L. SCHNEIDER, et al.,

Defendants.

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NOTICE OF TAKING DEPOSITION
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PLEASE TAKE NOTICE that pursuant to Florida Rule of Civil Procedure 1.310 and
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1.560, First American Bank will take the deposition of the below-named persons on the dates and

times indicated below:

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Name Date and Time Place

Zachary Schneider Wednesday, June 29, 2022 Meland Budwick, P.A.
at 2:00 p.m. EDT 200 S. Biscayne Blvd.
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Suite 3200
Miami, FL 33131
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Regarding the matters described in the subpoena attached hereto. The deposition will be taken
upon oral examination before a court reporter Veritext Court Reporter, Notary Public, in and for
the State of Florida at Large, or some other officer duly authorized by law to take deposition. This
deposition is being taken for discovery, use at trial, or any other purpose permitted under the Rules
of Civil Procedure and Rules of Evidence. The deposition will continue from hour to hour and
from day to day until completed.

MELAND i BUDWICK
3200 SOUTHEAST FINANCIAL CENTER I 200 SOUTH BISCAYNE BOULEVARD I MIAMI, FL 33131 IT 305-358-6363
In accordance with the Americans with Disabilities Act of 1990, persons needing a special
accommodation to participate in this proceeding should contact Meaghan E. Murphy, Esquire
at Meland Budwick, P.A. telephone number (305) 358-6363, no later than seven (7) days prior
to the proceeding. If hearing impaired, telephone Florida Relay Service at 1-800-955-8771 for
assistance.

CERTIFICATE OF SERVICE

I CERTIFY that the foregoing document has been furnished to all registered users via the

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Florida Courts e-Filing Portal on June 8, 2022.

s/ Meaghan E. Murphy

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Meaghan E. Murphy, Esquire
Florida Bar No. 102770
mmurphy0 )melandbu dwick.com
MELAND BUDWICK , P.A.

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200 South Biscayne Boulevard, Suite 3200
Miami, Florida 33131
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Telephone: (305) 358-6363
Facsimile: (305) 358-1221
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Counsel for Plaintiff
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Email Designatio n per Fla. R. Jud.

Admin 2.516
[email protected]
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mramos@m elandbudw ick.com

mrbstate@ yahoo.com
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MELAND I BUDWICK
3200 SOUTHEAST FINANCIAL CENTER I 200 SOUTH BISCAYNE BOULEVARD I MIAMI, FL 33131 IT 305-358-6363