Ex. 29 Verified Mot. Set Aside Judgement, 2019

Filing # 83842970 E-Filed 01/24/2019 01:17~59 PM
IN THE CIRCUIT COURT OF THE 1511-!

JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO. 50-2016-CA-009292
FIRST AMERICAN BANK,
Plaintiff,
vs.
LAURENCE S. SCHNEIDER
and STEPHANIE L. SCHNEIDE~
etal.
Defendants.
------------I
DEFENDANTS' VERIFIED MOTION TO STAY (1) THE EXECUTION OF THE
AMENDED JUDGMENT OF FORECLOSURE DATED OCTOBER 12, 2018,
AND (2) THE SEVERAL MOTIONS FOR ATTORNEYS' FEES, COSTS, AND
EXPENSES PENDING RESOLUTION OF COMPLAINT TO SET
ASIDE JUDGMENT PURSUANT TO FL. R. CIV. P. J.S40
The plaintiffs, Laurence S. Schneider and Stephanie L. Schneider (collectively, ''the
Schneiders''), by and through their undersigned attorneys, respectfully move this Court to stay ( 1)
the execution of or any proceedings to enforce the Amended Final Judgment of Foreclosure
entered in this action on October 12, 2018 (the "Amended Judgment"); and (ii) the plaintiff, First
American Bank's, motions for assessment of attorneys' fees, costs, and expenses pursuant to Fla
R. Civ. P. 1.550(b), pending the resolution of the Schneiders' Verified Complaint to Set Aside
Judgment (filed and docketed with this Court on January 22, 2019).
Introduction
In an independent action, the Schneiders have filed a Verified Complaint to Set Aside
Judgment (the "Verified Complaint'') under Fla R Civ. P. l.540(b), seeking redress for the
Exhibit "29"
misrepresentations made by First American Bank ("First American") and its counsel, Henry H.
Bolz, III ("Bolz"), prior to and at the time of the summary judgment hearing in this case. (A true
and accurate copy of the Verified Complaint is attached to this motion as Ex. 1; All references to
Ex. I, Verified Complaint shall be in the form "Compl., f'). In the Verified Complaint, the
Schneiders outline the precise manner in which First American and Bolz fraudulently and
deceptively orchestrated events, while the Schneiders represented themselves pro se, to set up an
unopposed summary judgment hearing in this case, which resulted in a $1.625 million-plus
judgment in favor of First American. Specifically, the Schneiders allege that:
(i) Bolz unilaterally scheduled a hearing on First American's motion for summary
judgment for June 26, 2017, a date on which the Schneiders, after they were
subsequently consulted, told Bolz they were unavailable;
(ii) after the Schneiders told Bolz they were unavailable, Bolz told the Schneiders that
this precluded First American from scheduling it on that date and promised to
pursue alternate dates, but First American then made no effort to change the date
of the hearing from June 26, 2017;
(iii) in a May 26, 2017 e-mail purportedly to confer on the scheduling of the hearing -
despite Bolz having unilaterally scheduled the hearing two days prior - Bolz told
the Schneiders that the "earliest possible" hearing date on which the Court could
hear First American's motion for summary judgment was June 26, 2017. After the
Schneiders told him that they were unavailable from June 19, 2017 to July 5, 2017,
Bolz circulated a letter to them that purported to request that the Court schedule the
hearing on dates earlier than June 26, 2017 but no later than the start of the Court's
June 28, 2017 trial calendar period (knowing that this meant the Court would
2
schedule the hearing for June 26 or 27, 2017, both of which are days that Bolz knew
the Schneiders were across the country and unavailable). Regardless, there is no
record on the docket of Court's receipt of this May 26, 2017 letter that Bolz claims
to have sent. The absence of this record - coupled with the fact that it would have
been standard procedure to enter the letter on the docket and maintain it in the file
had it been received - infers that Bolz never sent the letter to the Court;
(iv) after the Schneiders filed a Notice of Removal with the U.S. District Court,
Southern District of Florida, First American and Bolz submitted a document that
they purported was signed by the Schneiders (but which the Schneiders did not
actually sign) to the District Court on June 22, 2017 in a successful attempt to get
the case remanded back to state court and the motion for summary judgment heard
while the Schneiders were out of state and unavailable; and
(v) at the June 26, 2017 hearing on the motion for summary judgment, Bolz failed to
inform.Judge Susan R. Lubitz: that the Schneiders had told him a month before that
they would not be available for a hearing on June 26, 2017; that he had told Mr.
Schneider that this precluded First American from scheduling a hearing on that
date, which it still did; and that he had promised Mr. Schneider that First American
would pursue alternate dates for the hearing, which it did not.
For the reasons set forth herein, the Schneiders respectfully request that this Court allow
the motion to stay.
Procedural Background
3
1. On June 30, 2017, this Court entered an Amended Final Judgement in the above-
refenced matter, awarding First American Bank ("First American") the sum of$1,625,072.21 plus
interest at the rate of 5.05% per year. The monetary judgment was entered against Laurence
Schneider only. The Court retained jurisdiction to determine the total amounts of attorneys' fees,
costs, and expenses to which First American is entitled.
2. On September 7, 2018, First American filed a motion to tax appellate costs to
Laurence Schneider in the amount of$1,797.35.
3. On October 12, 2018, this Court issued an Amended Final Judgment of Foreclosure.
This Amended Final Judgment of Foreclosure mistakenly indicates that the monetary judgment is
against Laurence Schneider, Stephanie Schneider, and The Oaks at Boca Raton Property Owners'
Association, Inc.
4. On October 23, 2018, First American filed a motion seeking assessment of its
attorneys' fees, costs, and expenses in this case in the amount of$451,602.19, and a motion seeking
the assessment of its appellate attorney's fees in the amount of $119,892.50 (collectively, these
two motions and the motion to tax appellate costs will be referred to as the "Fee Motions").
5. On December 12, 2018, the Court set the Fee Motions for hearing on the Court's
trial docket sometime between March 4, 2019 and March 28, 2019.
Allegations in the Other Action
On August 17, 2016, First American filed this foreclosure action against the Schneiders,
and others, seeking to foreclose on a mortgage on residential property located at 17685 Circle Pond
Court, Boca Raton, Florida. (Compl., 17). On November 16, 2016, the Schneiders, through their
4
then-counsel, Kenneth Trent, Esquire {"Trent"), filed an Answer and Affirmative Defenses.
(Compl. ,r 8).
On November 21, 2016, Trent, a solo practitioner, filed a ''Notice of Absence" with the
Court. (Compl. ,r 9). The Notice of Absence indicated that Trent was suspended from the practice
of law from December 12, 2016 through January 11, 2017 "due to a consent judgment upon a Bar
grievance" and asked that the notice be "construed as a motion to continue any events scheduled,
and toll any time periods set to elapse, during the 30-day suspension." (Id.). During this period,
Trent could not represent the Schneiders. (Id.). Trent's bar suspension elapsed on January 11,
2017 and he was allowed to reengage in the practice of law on January 12, 2017. (Compl. ,r 10).
Upon Trent's return, and upon Fir~t American unilaterally setting hearings for a dispositive motion
and carpet bombing Trent with document requests, Trent's communications with the Schneiders
was dismal and virtually non-existent, and his representation of the Schneiders was at the same
level. (Id.).
On March 22, 2017, without the Schneiders' knowledge or consent, Trent filed a motion
to withdraw as counsel, stating in the motion:
This request is necessary because the undersigned does not have sufficient
time to properly represent the interests of the Defendants in this Action.
(Compl. ,r 11). On May 1, 2017, the Court heard-and allowed-the motion to withdraw. (Compl.
,r 12). As a result, the Schneiders became pro se litigants in the Foreclosure Action. (Id.).
Immediately thereafter, First American began its naked attempts to take advantage of the
Schneiders' unrepresented status. (Compl. ,r 13). On May 9, 2017, Bolz quickly, and unilaterally,
noticed the depositions of Mr. Schneider for June 13, 2017 and Mrs. Schneider for June 14, 2017.
(Compl. ,r 14). Later that same day, Bolz unilaterally filed a Notice for Trial, claiming that his
April 17, 2017 communication with Trent - who, at the time of the communication, had a motion
5
to withdraw pending, and who, at the time Bolz filed his notices, had, in fact, withdrawn - satisfied
the confer requirement (despite acknowledging in the communication his keen awareness that
Trent was not "in touch" with the Schneiders). {Id.).
On May 24, 2017, the Schneiders served written discovery on First American. At the time
of the summary judgment hearing, First American had still not responded to the discovery requests.
(Compl. ,r 15). On May 25, 2017, only three weeks after Trent withdrew, and despite having not
raised it as being on the horizon at the motion to withdraw hearing, First American filed a motion
for summary judgment. (Compl. ,r 16). At that time, the Schneiders had still not been successful
in retaining new counsel. (Id.). On May 26, 2017, at 9:53 a.m., Bolz sent an e-mail to the
Schneiders asking if they could attend a hearing on June 26, 2017 on the just-filed motion for
summary judgment. (Compl. ,r 17). Bolz wrote:
In accordance with the Court's procedures, we are attempting to coordinate

a hearing on the Motion for Summary Judgment (filed yesterday). The
earliest possible hearing date that we can now get is 1:30 p.m. or 2:30 p.m.
on Monday, June 26, 2017. Please let us know (by noon) if you can attend
the hearing on June 26, 2016 [sic] and at what time.
(Id.; Ex. 2). On May 26, 2017, at 11 :12 a.m., Mr. Schneider responded to the e-mail:
I am unavailable from between June 26, 2017 and July S, 2017.
[Emphasis added]. (Compl. ,r 18; Ex. 2).
In response, Bolz wrote:
Your advices [sic] that you are "unavailable from between June 26, 2017 to
July 5, 2017" precludes our ability to set the Motion for Summary
Judgment down for hearing on June 26, 2017. We will pursue alternate
dates for the hearing.
[Emphasis added]. (Compl. ,r 19; Ex. 2).
Despite this communication, sometime between May 25, 2017 and June 2, 2017, without the
Schneiders knowledge or consent, Bolz unilaterally scheduled a hearing on First American's soon-
6
to-be served motion for summary judgment for June 26, 2017. (Compl. ,r 20; Affidavit of Zebb
Duffany). Over the telephone, Mr. Schneider also told Bolz that he would not be available the
week prior to June 26, 2017, specifically informing Bolz that he would be in Phoenix, Arizona on
Thursday, June 22 and 23, 2017 attending depositions in another matter. (Compl. ,r 21).
On the afternoon of May 26, 2017, despite knowing the dates on which the Schneiders
would be unavailable, Bolz addressed a letter to Judge James Ferrara requesting that the hearing
occur before June 26, 2017 and recommended dates that Mr. Schneider had told him the Schneiders
would be out of town and unavailable. (Compl. ,r 22; Ex. 3). Regardless, Bolz already knew the
Court would not be able to accommodate a request for a date earlier than June 26, 2017 because
he had already communicated to Mr. Schneider that the earliest possible hearing date available
was June 26, 2017. (Id.; Ex. 3). Bolz also requested in his letter that the motion for summary
judgment be heard before the start of the Court's June 28, 2017 trial calendar period-meaning, in
effect, that he was requesting that the hearing be held on June 26 or 27, 2017, both dates on which
the Schneiders were not available and across the country at depositions in an unrelated matter.
(Compl. ,r 23; Ex. 3). Despite his promise ''to pursue alternate dates for the hearing", which,
interpreted reasonably, meant dates on which the Schneiders would actually be available, Bolz
requested only dates on which he knew either the Court or the Schneiders would be unavailable.
(Compl. ,r 24; Ex. 3). First American and Bolz's actions were in bad faith. (Compl. ,r 25).
In the purported letter, Bolz also misrepresented that "the Schneiders refuse[d] to agree to
a hearing date." (Compl. ,r 26; Ex. 3). The Schneiders never refused to agree on a hearing date,
and, in fact, fully informed Bolz about the dates on which they were not available so that the
hearing could be scheduled on a date they were available. (Compl. ,r 27). The Schneiders recently
7
learned that the Court does not have a record of the May 26, 2017 letter on the docket. (Compl. 1
28; Duffany Aff. ). The Schneiders suspect that Bolz never submitted the letter to the Court. (Id.).
On June 2, 2017, despite the Schneiders' unavailability - and likely because Bolz
unilaterally scheduled the hearing on the Court's online system and then did not change it or inform
the Court about the Schneiders' unavailability - the Court issued an order setting the special
hearing for June 26, 2017. (Compl. 129; Ex. 4). On June 9, 2017, the Schneiders filed a Notice
of Removal of the Foreclosure Action to the U.S. District Court for the Southern District of Florida
(the "District Court"). (Compl. 1 30). On June 12, 2017, the District Court issued an order
requiring the Schneiders to respond by showing good cause why the matter should not be remanded
to state court. (Compl. 131).
On.June 22, 2017, without the Schneiders' knowledge or consent, First American filed a
document titled "Defendants' Response to Court's Order to Show Cause" (the "Response") with
the District Court and this Circuit Court. Bolz alleges to have received it in the mail from the
Schneiders - but neither Mr. Schneider nor Mrs. Schneider ever drafted, reviewed, signed, or
mailed it. (Compl. 1 32; Ex. 5). The Response provides, in relevant part:
Defendants indicate their consent to this remand, and will pursue their
remedies to prevent the sale of the subject property in the separate filed
action before this Court, Schneider v. First American Bank, Case No. 9:l 7-
cv-80728-DMM. 1
(Compl. 133; Schneider Aff., Ex. 5). The Response purports to have been signed by either Mr. or
Mrs. Schneider, but, again, at no point in time did the Schneiders sign, or permit First American
to sign, the Response. (Compl. 134; Ex. 5). The notice was filed by Bolz after he purportedly
1 The document claims that the Schneiders intend to "pursue their remedies to prevent the sale of the subject property"
through a separate action that was already pending in the federal court. Such a reasoning is illogical on its face since
the "agreement to remand" would effective give the Circuit Court unfettered ability to determine the future actions as
to the subject property. There is no rationale that would support an action such as this by the Schneiders.
8
received the document in the U.S. postal mail from Schneiders purportedly mailed while they were
in Arizona. The Response is dated June 21, 2017 and was filed by Bolz on June 22, 2017. (Compl.
,r 35). The envelope in which it allegedly arrived at Bolz's has never been produced by FAB or
Bolz. (Id.).
The "scrawl" purporting to be the signature of only one of the Schneiders - despite both
being pro se and parties to the case - is not similar in any respect to either of their signatures, as
can be seen in any of the several documents executed by the Schneiders in this matter. (Compl. ,r
36). On information and belief, First American and Bolz submitted the document in an attempt to
push the action back to state court before June 26, 2017, so that First American could move forward
with the unilaterally set hearing on the motion for summary judgment while the Schneiders were
still out of town. (Compl. ,r 37).
On June 22, 2017, upon receipt of the Response from Bolz, the District Court issued an
order remanding the Foreclosure Action back to state court. (Compl. ,r 38). It is unclear when the
District Court actually notified this Circuit Court about the remand, as opposed to Bolz notifying
the Circuit Court about the remand in his quest to have the motion heard while the Schneiders were
still out of town. (Id.).
On Friday, June 23, 2017, Bolz sent an e-mail to Mr. Schneider:
Although you may have already seen it, we attach a copy of United States
District Court Judge Donald Middlebrooks' June 22, 2017 Order remanding
the Foreclosure Litigation back to Circuit Court.
We are advised by the Circuit Court that First American Bank's Motion for
Summary Judgment ... remains scheduled to be heard by the Circuit Court
at 2:30 p.m. on Monday, June 26, 2017.
(Compl. ,r 39; Ex. 6). Stunned by the e-mail - as a result of both his lack of awareness about the
remand and his repeated communications with Bolz about his unavailability on that date and
9
Bolz's assurances that the hearing would not be scheduled for that date - Mr. Schneider
responded:
As I had explained to you, I am in Phoenix doing depositions and will not

be back in town until Thursday of next week.
(Compl. ,I 40; Ex. 6).
Based on the Schneiders' unavailability, Mr. Schneider reasonably believed that Bolz
would inform the Court and request another date for the hearing on his motion. (Compl. ,I 41 ).
Instead, Bolz did nothing to change the date of the hearing from June 26, 2017 - which he
unilaterally scheduled and kept despite knowing the Schneiders' unavailability - and then, after
the issuance of the remand order, pressed hard for the Court to hear the motion for summary
judgment on that date, while the Schneiders were still out of town. (Id.).
Mr. Schneider's June 23, 2017 e-mail, and almost all of his prior communications with
Bolz, Mr. Schneider made clear that the Schneiders intended to oppose the motion for summary
judgment- but, in light of the truncated timeframe resulting from the remand after two weeks in
federal court, and the calendar requirements of Rule 1.5102, it would have been impossible for the
Schneiders to submit evidence in opposition prior to the Monday, June 26, 2017 hearing. (Compl.
,I 42).
On June 26, 2017, Bolz attended the hearing and Judge Susan R. Lubitz presided over it.
Judge Lubitz had not scheduled the hearing and was not the addressee of Bolz's alleged May 26,
2017 letter. (Compl. ,I 43). During the hearing, Bolz did not inform Judge Lubitz about the May
26, 2017 e-mail exchange between him and Mr. Schneider in which he was advised of the
2 Rule 1.510 of the Florida Rules of Civil Procedure provides that ''the adverse party shall identify, by notice mailed
to the movant's attorney at least 5 days prior to the day of the hearing, or delivered no later than 5:00 p.m. 2 business
days prior to the day of the hearing, any summary judgment evidence on which the adverse party relies."
Schneiders' unavailability and in which he promised to pursue hearing dates other than June 26,
2017. On information and belief, Judge Lubitz did not have any independent knowledge of this
exchange. (Compl. ,r 44). During the hearing, Judge Lubitz had the following preliminary
exchange with Bolz:
THE COURT: Okay. He [Laurence Schneider] hasn't filed any notice on

unavailability, nor has he filed a motion to continue the case?
MR. BOLZ: Neither.
THE COURT: Okay. Let's proceed.
(Compl. ,r 45; Ex. 7).
Despite having had the opportunity to do so, and despite having an obligation of candor to the
Court, Bolz did not reveal to Judge Lubitz that the Schneiders had told him a month prior that they
would not be available for a hearing on June 26, 2017; that Bolz had informed Mr. Schneider that
this precluded First American from scheduling a hearing on that date; and that Bolz had promised
Mr. Schneider that First American would pursue alternate dates for the hearing (meaningfeasible
dates other than June 26, 2016). (Compl. ,r 46).

During the hearing, Bolz also did not inform the Court that First American's responses to
the Schneiders' discovery requests - which were served before First American served its motion
for summary judgment-were still outstanding. (Compl. ,r 47). On information and belief, Bolz's
actions were an intentional attempt to thwart the well-settled law that a trial court should not
entertain a motion for summary judgment until discovery is concluded. ( Compl.). As a result of
First American and Bolz's fraudulent, deceptive, and bad faith conduct, the Court went forward
with the hearing, and, at its conclusion, granted the motion for summary judgment. (Compl. ,r 48).
On June 27, 2017, the Court issued a Final Judgment for monetary damages against Mr.
Schneider only, and a Final Judgment for Foreclosure against Mr. Schneider, Mrs. Schneider, and
11
The Oaks at Boca Raton Property Owners' Association, Inc. (Compl. ,I 49). On June 30, 2017,
the Court issued an Amended Final Judgment against Mr. Schneider. The Schneiders did not
receive any notification of the hearing or its results until they received an email from Bolz at 2:30
p.m. on June 30, 2017 attaching the Amended Final Judgment. (Compl. ,r 50). On October 12,
2018, the Court issued an Amended Final Judgment for Foreclosure against Mr. Schneider, Mrs.
Schneider, and The Oaks at Boca Raton Property Owners' Association, Inc. (Compl. ,I 51 ).
Discussion
As a result of First American and Bolz's fraud on the court (as detailed above and in the
attached Verified Complaint) - which resulted in the Schneiders being unable to participate in the
summary judgment proceeding - the Schneiders seek to stay the execution of the judgments, as
well as any proceedings to enforce the above-referenced judgments, pursuant to Rule l .550(b) of
the Florida Rules of Civil Procedure (the "Rules). Pursuant to Rule 1.5 50(b),
[the] court before which an execution or other process based on a final

judgment is returnable may stay such execution or other process and
suspend proceedings thereon for good cause on motion and notice to all
adverse parties.
[Emphasis added]. "The definition of'good cause' must develop to some extent on a case-by-case
basis." Almodovar v. Gonzalez, 573 So. 2d. 380,382 (Fla. 3rd DCA 1991).
The Schneiders have alleged that First American and Bolz have perpetrated a fraud on the
court. The Florida Supreme Court defines "fraud on the court" as:
[The] prevention of an unsuccessful party [from] presenting his case, by

fraud or deception practiced by his adversary; keeping the opponent away
from the court; falsely promising a compromise; ignorance of the adversary
about the existence of the suit or the acts of the plaintiff; fraudulent
representation of a party without his consent and connivance in his defeat;
and so on. In other words, extrinsic fraud occurs where a defendant has
somehow been prevented from participating in a cause.
12
DeClaire v. Yohanan, 453 So. 2d 375, 377 (Fla. 1984). superseded by rule on other grounds; see
also Lefler v. Lefler, 776 So. 2d 319, n. 1 (Fla. 4th DCA 2001}. The primary objective in "fraud
on the court" cases is to ensure that the adverse party did not somehow prevent the complaining
party from participating in a cause of action and thereby taint the judgment entered by the Court
(which would make it no longer equitable for the trial court to enforce the judgment). See
Schindler v. Schiavo (In re Schiavo) .. 792 So. 2d 551, 559-560 (Fla. 2d DCA 2001).
In this instance, the Schneiders have filed a Verified Complaint alleging the precise manner
in which First American and its attorney, Henry Bolz, manipulated the Schneiders and the Court
system to orchestrate an unopposed summary judgment hearing which resulted in a $1.625 million
plus judgment in favor of First American. This Court should permit the Schneiders the opportunity
to present their "fraud on the court" claim in the other action before continuing to permit First
American to execute on its judgments.
Finally, with respect to the Fee Motions, the interests of justice call for such motions to
likewise be held in abeyance pending the Court's disposition of the Rule l.540(b) proceeding.
Conclusion
Given (1) the potential for significant and adverse prejudice if execution of or proceedings
to enforce judgment were allowed before disposition of the other action; (2) the benefit of
promoting judicial efficiency; and (3) the modest length of any potential stay of execution of
judgment, this Court should await resolution of the other action before allowing
13
exe cuti on of or proceedings to enfo rce
the judg men ts, and stay the hea ring and
resolution of the
Fee Motions.
VERIFICATION
Under penalties of perjury, I declare that

l have read the foregoing Verified Com
Set Aside Judgment, and that the facts plaint to
stated in it are true to the best of my kno
belief. wledge and
STEPHANIE L. SCHNEIDER
Dated: January..22, 2019.
RESPECTFU LLY SUBMITTED .

ROD MAN EMP LOY MEN T LAW
181 WEL LS AVE NUE , SUIT E 20 l
NEWTON, MA 02459
P: (617) 820-5250
BY: Isl Charles F. Rodman. Esq.

CI-JARLES F. RODMAN, ESQ .
14
FLORIDA STATE BAR NO.: 0147737
chuck.rodman@rodmanemploymentlaw.com
ATTORNEY FOR DEFENDANTS
LAURENCE S. SCHNEI DER AND
STEP HANIE L. SCHNEIDER
RESPECTFULLY SUBM ITTED,

WYMAN LEGAL SOLUTIONS
955 NW 17TH AVENUE, SUITE C
DELRAY BEACH, FL 33445
P: (561) 361-8700
F: (561) 361-8899
BY: Isl Andrew D. Wyman. Esq.

ANDREW D. WYMAN, ESQ.
FLORJDA STATE BAR No.: 326010
ANDY@WYMANLEGALSOLUTIONS.COM
ATTORNEY FOR DEFENDA NTS
LAURENCE S. SCHNEIDER AND
STEPHANIB L. SCHNEIDER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been served via the Florida Court's
E-Portal Automatic Email service, pursuant to Florida Rule of Judicial Administration 2.5 16, on
all counsel and pro se parties identified on the attached Service List on this 24th day of January
2019.
RESPECTFULLY SUBMITTED,
955 NW l 7n 1 A VENUE SUITE C
P: (56 1) 36 1-8700
F: (561) 361-8899
BY: Isl Andrew D. Wyman, Esq.

ANDREW D. WYMAN, ESQ.
15
FLORJDA STATE BAR No.: 326010
ATTORNEY FOR D EFENDANTS
SERVICE LIST
HENRY H. BOLZ, Ill, Esq.

JOHN W. KELLER, III, Esq.
Attorney for First American Bank
KELLER & BOLZ, LLP
121 Majorca A venue, #200
Coral Gables, FL 33134
hbolz@kel lerbo lz.com
jke1ler/'@kellerbolz.com
ahart@kellerbolz.com
ALEKSANDRA NOVAKOVICH GONZALEZ, Esq.

Attorney for The Oaks at Boca Raton POA, inc.
SACHS, SAX, CAPLAN
6111 Broken Sound Parkway, NW, #200
Boca Raton, FL 33487
foreclosures@ssclawfirrn.com
CHARLES F. RODMAN, Esq.

Co-counsel for Schneider Defendants
RODMAN EMPLOYMENT LAW
181 Wells Avenue, Suite 201
Newton, MA 02459
Chuck.rodman@rodmanemploymentlaw.com
Zebb. Duffany@rodmanemploymentlaw.com
16
EXHIBIT 1
Filing # 83837222 E-Filed 01/24/2019 12:17:25 PM
IN THE CIRCUIT COURT OF THE I 5nt

JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLOR.IDA
CASE NO.
and STEPHANIE L. SCHNEIDER,
Plaintiffs,
vs.
FIRST AMERICAN BANK
HENRY H. BOLZ, Ill,
and KELLER & BOLZ, LLP,
Defendants.
____________...,!
VERIFIED COMPLAINT TO SET ASIDE JUDGMENT
The plaintiffs, Laurence S. Schneider and Stephanie L. Schneider (collectively, ''the
Schneiders''), by and through their undersigned attorneys, hereby sue the defendants, First
American Bank, Henry H. Bolz, ill, and Keller & Bolz, LLP, and state as follows:
Parties
1. The plaintiff, Laurence S. Schneider ("Mr. Schneider"). is a resident of Palm Beach
County, Florida.
2. The plaintiff; Stephanie L. Schneider (''Mrs. Schneider"), is a resident of Palm
Beach County, Florida.
3. The defendant, First American Bank ("First American"), is an lllinois banking
corporation with a principal place of business in Elk Grove Village, Illinois.
4. The defendant Keller & Bolz, LLP, is a limited liability partnership, which practices
law and whose address is 121 Majorca Avenue, Suite 200, Coral Gables, Florida.
1
5. The defendant, Henry H. Bolz, III ("Bolz"), is an individual with a principal place
of business at Keller & Bolz, LLP, 121 Majorca Avenue, Suite 200, Coral Gables, Florida. Bolz
represented First American in a foreclosure action (the "Foreclosure Action") against the
Schneiders. The Foreclosure Action was filed with this Court and is docketed as Case No. 502016-
CA-009292.
Jurisdiction
6. This action is brought pursuant to Rule 1.540 of the Florida Rules of Civil
Procedure. Rule 1.540 pennits the Court ''to entertain an independent action to relieve a party
from a judgment, decree, order or proceeding or to set aside a judgment or decree for fraud upon
the court."
Background
7. On August 17, 2016, First American filed the Foreclosure Action against the
Schneiders, and others, seeking to foreclose on a mortgage on residential property located at 17685
Circle Pond Court, Boca Raton, Florida.
8. On November 16, 2016, the Schneiders, through their then-counsel, Kenneth Trent,
Esquire ("Trent"), filed an Answer and Affirmative Defenses.
9. On November 21, 2016, Trent, a solo practitioner, filed a "Notice of Absence" with
the Court. The Notice of Absence indicated that Trent was suspended from the practice of law
from December 12, 2016 through January 11, 2017 "due to a consent judgment upon a Bar
grievance" and asked that the notice be "construed as a motion to continue any events scheduled,
and toll any time periods set to elapse, during the 30-day suspension." During this period, Trent
could not represent the Schneiders.
2
10. Trent's bar suspension elapsed on January 11, 2017 and he was allowed to reengage
in the practice of law on January 12, 2017. Upon Trent's return, and upon First American
unilaterally setting hearings for a dispositive motion and carpet bombing Trent with document
requests, Trent's communications with the Schneiders was dismal and virtually non-existent, and
his representation of the Schneiders was at the same level.
11. On March 22, 2017, without the Schneiders' knowledge or consent, Trent filed a
motion to withdraw as counsel, stating in the motion:
This request is necessary because the undersigned does not have sufficient
time to properly represent the interests of the Defendants in this Action.
12. On May 1, 2017, the Court heard - and allowed - the motion to withdraw. As a
result, the Schneiders became pro se litigants in the Foreclosure Action.
13. Immediately thereafter, First American began its naked attempts to take advantage
of the Schneiders' unrepresented status.
14. On May 9, 2017, Bolz quickly, and unilaterally, noticed the depositions of Mr.
Schneider for June 13, 2017 and Mrs. Schneider for June 14, 2017. Later that same day, Bolz
unilaterally filed a Notice for Trial, claiming that his April 17, 2017 communication with Trent -
who, at the time of the communication, had a motion to withdraw pending, and who, at the time
Bolz filed his notices, had, in fact, withdrawn - satisfied the confer requirement (despite
acknowledging in the communication his keen awareness that Trent was not "in touch" with the
Schneiders).
15. On May 24, 2017, the Schneiders served written discovery on First American. At
the time of the summary judgment hearing, First American had still not responded to the discovery
requests.
3
16. On May 25, 2017, only three weeks after Trent withdrew, and despite having not
raised it as being on the horizon at the motion to withdraw hearing, First American filed a motion
for summary judgment. At that time, the Schneiders had still not been successful in retaining new
counsel.
17. On May 26, 2017, at 9:53 a.m., Bolz sent an e-mail to the Schneiders asking ifthey
could attend a hearing on June 26, 2017 on the just-filed motion for summary judgment. Bolz
wrote:
In accordance with the Court's procedures, we are attempting to coordinate

a hearing on the Motion for Summary Judgment (filed yesterday). The
earliest possible hearing date that we can now get is 1:30 p.m. or 2:30 p.m.
on Monday, June 26, 2017. Please let us know (by noon) if you can attend
the hearing on June 26, 2016 [sic] and at what time.
18. On May 26, 2017, at 11 :12 a.m., Mr. Schneider responded to the e-mail:
I am unavailable from between June 26, 2017 and July 5, 2017.
[Emphasis added].
19. In response, Bolz wrote:
Your advices [sic] that you are "unavailable from between June 26, 2017 to
July 5, 2017" precludes our ability to set the Motion for Summary
Judgment down for hearing on June 26, 2017. We will pursue alternate
dates for the hearing.
[Emphasis added].
20. Despite this communication, sometime between May 25, 2017 and June 2, 2017,
without the Schneiders knowledge or consent, Bolz unilaterally scheduled a hearing on First
American's soon-to-be served motion for summary judgment for June 26, 2017.
21. Over the telephone, Mr. Schneider also told Bolz that he would not be available the
week prior to June 26, 2017, specifically informing Bolz that he would be in Phoenix, Arizona on
Thursday, June 22 and 23, 2017 attending depositions in another matter.
4
22.. On the afternoon of May 26, 2017, despite knowing the dates on which the
Schneiders would be unavailable, Bolz addressed a letter to Judge James Ferrara requesting that
the hearing occur before June 26, 2017 and recommended dates that Mr. Schneider had told him
the Schneiders would be out of town and unavailable. Regardless, Bolz already knew the Court
would not be able to accommodate a request for a date earlier than June 26, 2017 because he had
already communicated to Mr. Schneider that the earliest possible hearing date available was June
26, 2017.
23. Bolz also requested in his letter that the motion for summary judgment be heard
before the start of the Court's June 28, 2017 trial calendar period- meaning, in effect, that he was
requesting that the hearing be held on June 26 or 27, 2017, both dates on which the Schneiders
were not available and across the country at depositions in an unrelated matter.
24. Despite his promise ''to pursue alternate dates for the hearing", which, interpreted
reasonably, meant dates on which the Schneiders would actually be available, Bolz requested only
dates on which he knew either the Court or the Schneiders would be unavailable.
25. First American and Bolz' s actions were in bad faith.
26. In the purported letter, Bolz also misrepresented that ''the Schneiders refuse[d] to
agree to a hearing date."
27. The Schneiders never refused to agree on a hearing date, and, in fact, fully informed
Bolz about the dates on which they were not available so that the hearing could be scheduled on a
date they were available.
28. The Schneiders recently learned that the Court does not have a record of the May
26, 2017 letter on the docket. The Schneiders suspect that Bolz never submitted the letter to the
Court.
5
29. On June 2, 2017, despite the Schneiders' unavailability- and likely because Bolz
unilaterally scheduled the hearing on the Court's online system and then did not change it or inform
the Court about the Schneiders' unavailability - the Court issued an order setting the special
hearing for June 26, 2017.
30. On June 9, 2017, the Schneiders filed a Notice of Removal of the Foreclosure
Action to the U.S. District Court for the Southern District of Florida (the "District Court").
31. On June 12, 2017, the District Court issued an order requiring the Schneiders to
respond by showing good cause why the matter should not be remanded to state court.
32. On June 22, 2017, without the Schneiders' knowledge or consent, First American
filed a document titled "Defendants' Response to Court's Order to Show Cause" (the "Response")
with the District Court and this Circuit Court. Bolz alleges to have received it in the mail from the
Schneiders - but neither Mr. Schneider nor Mrs. Schneider ever drafted, reviewed, signed, or
mailed it.
33. The Response provides, in relevant part:
remedies to prevent the sale of the subject property in the separate filed
action before this Court, Schneider v. First American Bank, Case No. 9: l 7-
cv-80728-DMM.1
34. The Response purports to have been signed by either Mr. or Mrs. Schneider, but,
again, at no point in time did the Schneiders sign, or permit First American to sign, the Response.
35. The notice was filed by Bolz after he purportedly received the document in the U.S.
postal mail from Schneiders purportedly mailed while they were in Arizona. The Response is
1 The document claims that the Schneiders intend to "pursue their remedies to prevent the sale of the subject property''
through a separate action that was already pending in the federal court. Such a reasoning is illogical on its face since
the "agreement to remand" would effective give the Circuit Court unfettered ability to detennine the future actions as
to the subject property. There is no rationale that would support an action such as this by the Schneiders.
6
dated June 21, 2017 and was filed by Bolz on June 22, 2017. The envelope in which it allegedly
arrived at Bolz's has never been produced by FAB or Bolz.
36. The "scrawl" purporting to be the signature of only one of the Schneiders - despite
both being prose and parties to the case - is not similar in any respect to either of their signatures,
as can be seen in any of the several documents executed by the Schneiders in this matter.
37. On information and belief, First American and Bolz submitted the document in an
attempt to push the action back to state court before June 26, 2017, so that First American could
move forward with the unilaterally set hearing on the motion for summary judgment while the
Schneiders were still out of town.
38. On June 22, 2017, upon receipt of the Response from Bolz, the District Court issued
an order remanding the Foreclosure Action back to state court. It is unclear when the District
Court actually notified this Circuit Court about the remand, as opposed to Bolz notifying the
Circuit Court about the remand in his quest to have the motion heard while the Schneiders were
still out of town.
39. On Friday, June 23, 2017, Bolz sent an e-mail to Mr. Schneider:
Although you may have already seen it, we attach a copy of United States
District Court Judge Donald Middlebrooks' June 22, 2017 Order remanding
the Foreclosure Litigation back to Circuit Court.
We are advised by the Circuit Court that First American Bank's Motion for
Summary Judgment ... remains scheduled to be heard by the Circuit Court
at 2:30 p.m. on Monday, June 26, 2017.
40. Stunned by thee-mail-as a result of both his lack of awareness about the remand
and his repeated communications with Bolz about his unavailability on that date and Bolz's
assurances that the hearing would not be scheduled for that date - Mr. Schneider responded:
7
As I had explained to you, I am in Phoenix doing depositions and will not
be back in town until Thursday of next week.
41. Based on the Schneiders' unavailability, Mr. Schneider reasonably believed that
Bolz would inform the Court and request another date for the hearing on his motion. Instead, Bolz
did nothing to change the date of the hearing from June 26, 2017 -which he unilaterally scheduled
and kept despite knowing the Schneiders' unavailability - and then, after the issuance of the
remand order, pressed hard for the Court to hear the motion for summary judgment on that date,
while the Schneiders were still out of town.
42. Mr. Schneider's June 23, 2017 e-mail, and almost all of his prior communications
with Bolz, Mr. Schneider made clear that the Schneiders intended to oppose the motion for
summary judgment - but, in light of the truncated timeframe resulting from the remand after two
weeks in federal court, and the calendar requirements of Rule 1.51 <>2, it would have been
impossible for the Schneiders to submit evidence in opposition prior to the Monday, June 26, 2017
hearing.
43. On June 26, 2017, Bolz attended the hearing and Judge Susan R. Lubitz presided
over it. Judge Lubitz had not scheduled the hearing and was not the addressee of Bolz's alleged
May 26, 2017 letter.
44. During the hearing, Bolz did not inform Judge Lubitz about the May 26, 2017 e-
mail exchange between him and Mr. Schneider in which he was advised of the Schneiders'
unavailability and in which he promised to pursue hearing dates other than June 26, 2017. On
information and belief, Judge Lubitz did not have any independent knowledge of this exchange.
2 Rule 1.510 of the Florida Rules of Civil Procedure provides that ''the adverse party shall identify, by notice mailed
to the movant's attorney at least 5 days prior to the day of the hearing, or delivered no later than 5:00 p.m. 2 business
days prior to the day of the hearing, any summary judgment evidence on which the adverse party relies."
8
45. During the hearing, Judge Lubitz had the following preliminary exchange with
Bolz:
THE COURT: Okay. He [Laurence Schneider] hasn't filed any notice on

unavailability, nor has he filed a motion to continue the case?
MR. BOLZ: Neither.
THE COURT: Okay. Let's proceed.
46. Despite having had the opportunity to do so, and despite having an obligation of
candor to the Court, Bolz did not reveal to Judge Lubitz that the Schneiders had told him a month
prior that they would not be available for a hearing on June 26, 2017; that Bolz had informed Mr.
Schneider that this precluded First American from scheduling a hearing on that date; and that Bolz
had promised Mr. Schneider that First American would pursue alternate dates for the hearing
(meaningfeasible dates other than June 26, 2016).
47. During the hearing, Bolz also did not inform the Court that First American's
responses to the Schneiders' discovery requests - which were served before First American served
its motion for summary judgment - were still outstanding. On information and belief, Bolz' s
actions were an intentional attempt to thwart the well-settled law that a trial court should not
entertain a motion for summary judgment until discovery is concluded.
48. As a result of First American and Bolz's fraudulent, deceptive, and bad faith
conduct, the Court went forward with the hearing, and, at its conclusion, granted the motion for
summary judgment.
49. On June 27, 2017, the Court issued a Final Judgment for monetary damages against
Mr. Schneider only (Bk.29187/Pg.733), and a Final Judgment for Foreclosure against Mr.
9
Schneider, Mrs. Schneider, and The Oaks at Boca Raton Property Owners' Association, Inc.
(29187/ 15 l 5).
50. On June 30, 2017, the Court issued an Amended Final Judgment against Mr.
Schneider (29205/1606; 29207/353). The Schneiders did not receive any notification of the
hearing or its results until they received an email from Bolz at 2:30 p.m. on June 30, 2017 attaching
the Amended Final Judgment.
51. On October 12, 2018, the Court issued an Amended Final Judgment for Foreclosure
against Mr. Schneider, Mrs. Schneider, and The Oaks at Boca Raton Property Owners'
Association, Inc. (30184/1587; 30186/720). The Judgments and Amended Judgments referenced
herein are attached as Composite Exhibit "A" hereto.
Count I
Fraud on the Court
52. The Schneiders repeat and reallege the allegations contained in paragraphs 1 to 51
of the Verified Complaint.
53. First American and Bolz's misrepresentations and deception prevented the
Schneiders from presenting an opposition to the motion for summary judgment and participating
in the hearing on the motion for summary judgment.
54. First American and Bolz's actions caused harm to the Schneiders and resulted in
the entry of the Judgments and Amended Judgments against the Schneiders in the Foreclosure
Action.
WHE REF ORE , the defendants, Laurence and
Step hani e Schn eide r, respectfully requ est
that this Cou rt ente r an Orde r (1) setti ng aside
the judg men t ente red in the Foreclosure Action,
and (2) gran ting such othe r and further relie f as
the Cour t deem s just and proper.
VERIFICATION
Under penalties of perjury, I decl are that I have

read the foreg oing Verified Com plain t to
Set Asid e Judgment, and that the facts stated
in it are true to the best of my know ledg e and
belief.
~,,.---
~
Dated: Jan uary ~ 20 19.
RESPECTFULLY SUBMITTED,
ROD MAN EMP LOY MEN T LAW
181 WEL LS AVEN UE, SUITE 201
NEW TON , MA 0245 9
P: (617) 820-5250
BY: Isl Charles F. Rodman, Esq.

CHARLES F. RODMAN , ESQ.
FLORIDA STAT E BAR No.: 0147 737
chuckrodman@rodmanemploymentlaw.com
lI
ATTORNEY FOR PLArNTIFFS
R.ESPECTFULL Y SUBMITTED,
955 NW 17TH AVENUE, SUITE C
P: (561) 361-8700
F: (561) 36 1-8899
BY : Isl Andrew D. Wvman. Esq.

ANDREW 0. WYMAN, ESQ.
FLORIDA STATE BAR No.: 326010
ATTORNEY FOR PLArNTIFFS
12
COMPOSITE
EXHIBIT A
CFN 20170234342
OR BK 29187 PG 733
RECORDED 06/28/20 1715:54: 56
Palm Beach County, Florida
AMT
Sharon R. Bock
IN THE CIRCUIT COURT OF CLERK & COMPTROLLER
THE FIFTEENTH JUDICIAL CIRCUIT Pgs 0733-0734; (2Pgs)
IN AND FOR PALM BEACH COUNTY, FLORIDA
io ~ 0
CASE NO.: 502016-CA-009292
DIVISION AW
FIRST ~RIC AN BANK, as

succes sor~m erger to Bank of
Coral Gab~ LC,
~tiff ,
V. ~
LAURENCE S. SC
STEPHANIE L. SCHtlE I)
~INA L JUDGMENT
THIS CAUSE came on ~ e this Court upon the Motion for Summary Judgment
ly set
filed by First American Bank whi~ s heard by the Court at a 45-minute special
~)). -o~ ......,
i~ ~
hearing on Monday, June 26, 2 ~ n d the Court, having heard and cons
~:o _,
na,o '- .,,
argument from First American Bank, it is ~Mz
nl>:o
c:n•
-::ca,
§2
_,
•._
-.I
r_
ORDERED AND ADJUDGED THAT: ~gg .-o m
<CA :JC
1. Judgment is GRANTED in favor of Plaintiff, FIRST AMERICAN BANK, andPcl @st 9'?
. ,..,., 0
0
~::o
.~
°'
Defendant, LAURENCE S. SCHNEIDER.
2. Plaintiff, Fl RST AMERICAN BANK, 2295 Galiano Street, Coral Gables, Florida
33134, is due $1,625,072.71 which shall bear interest at the rate of 5.05% per year.
ble
3. The Court finds that Plaintiff, FIRST AMERICAN BANK, is entitled to reasona
Court
attorneys' fees, costs and expenses incurred in connection with this action. The
CFN 20170234342
BOOK 29187 PAGE 734
20F2
will retain jurisdiction to determine the total amounts of attorneys' fees, costs and
ex~ nses to which Plaintiff is entitled.
ONE AND ORDERED in Chambers in Palm Beach County, Florida on this ~ l,
ilw,u....
w 0
,2017.
~
~~
Copies furnishe~
Henry H. Bolz, 111, ~

Keller & Bolz, LLP ~
Attorneys for First A n Bank
121 Majorca Avenue, o
Coral Gables, FL 33134 ~
Laurence S. Schneider @
360 E Coconut Palm Road iQ:!>
Boca Raton, FL 33432 ~
@
~
Stephanie L. Schneider
360 E Coconut Palm Road
Jay S. Levin, Esq.

Sachs, Sax, Caplan
Attorneys for The Oaks at Boca Raton Property Owners' Association, Inc.
6111 Broken Sound Parkway, N.W., #200,
Page 2 of 2
CFN 20170234535
OR BK 29187 PG 1515
RECORDED 06/28/201716:31:38
AMT
Sharon R. Bock
THE FIFTEENTH JUDICIAL CIRCUIT Pgs 151 5-1518: (4 Pgs)
1°
CASE NO.: 502016-CA-009292
DIVISION AW
~ 0
FIRST ~ICAN BANK, as

successor~rger to Bank of
Coral Gab C,
a
~tiff,
v. ~
LAURENCE S. SC ER,
STEPHANIE L. SCH~i\ER. et al.,
0
0
. --- Defendant ~
1
~INAL JUDGMENT
THIS CAUSE came on b~this Court upon the Motion for Summary Judgment
filed by First American Bank whic~ heard by the Court at a 45-minute specially set
hearing on Monday, June 26, 20~d the Court, having heard and consid~ :
-r
nmo '-
:i:f'T1Z C:
argument from First American Bank, it is n > :o :z:
en• N
-:c:n -..I
ORDERED AND ADJUDGED THAT: ~gg -v
<c::~ X
m
1. Judgment is GRANTED in favor of Plaintiff, FIRST AMERICAN BANK, and dg~t W
-Zn .. C
-,,:o 0
r-:,.: 0'\
Defendants, LAURENCE S. SCHNEIDER, STEPHANIE L. SCHNEIDER and THE OAKS
AT BOCA RATON PROPERTY OWNERS' ASSOCIATION, INC.
2. Amounts Due. Plaintiff, FIRST AMERICAN BANK, 2295 Galiano Street, Coral
Gables, Florida 33134, is due:
Principal ............. ........ .. ...................... .............. .. ... ............................ . $1,488,554.76

CFN 20170234535
BOOK 29187 PAGE 1516
20F4
Interest from March 16, 2016 to date of this Judgment ..................... $69,646.52
lorida Ad Valorem/real property taxes for 2014, 2015 and 2016 ..... $66,870.93
I •••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• $1,625,072.21
0
=~=II bear interest at the rate of 5.05% per year.
3. ~of Property. Plaintiff, FIRST AMERICAN BANK, holds a lien for the total
sum supe~o all claims or estates of Defendants, on the following described property
in Palm Bea~nty, Florida:
"Lot 37 of~ Fox Hill Estates of Boca Raton, according to the Plat thereof,
as recordeain Plat Book 87, Page 4, of the Public Records of Palm Beach
County, Flo~
Commonly known a ~ 5 Circle Pond Court, Boca Raton, Florida 33496-1002
("Property"). -,. ~
4. Sale of Property. If ~ l l sum with interest at the rate described in Paragraph
2 and all costs accrued subseq~to this Judgment are not paid, the Clerk of this Court
shall sell the Property at public sa~J).."" ~ \D Q...01'1, to the highest bidder for
~ \ I
cash, except as prescribed in Para~ 5, at the Courthouse located at 205 N. Dixie
Highway in Palm Beach County in West Palm Beach, Florida, in accordance with section
45.031, Florida Statutes (2013), using the following method: By electronic sale beginning
at\O·,Gt)An\ at the prescribed date at https://mypalmbeachclerk.clerkauction.com.
5. Costs. Plaintiff, FIRST AMERICAN BANK, shall advance all subsequent costs of
this action and shall be reimbursed for them by the Clerk if Plaintiff, FIRST AMERICAN
BANK, is not the purchaser of the Property for sale, provided that the purchaser of the
Property for sale shall be responsible for the documentary stamps payable on the
certificate of title. If Plaintiff, FIRST AMERICAN BANK, is the purchaser, the Clerk shall.
Page 2 of4
CFN 20170234535
30F4
credit Plaintiff's bid with the total sum with interest and costs accruing subsequent to this
ment, or such part of it as is necessary to pay the bid in full.
istributlon of Proceeds. On filing the certificate of title the Clerk shall distribute
~~Kis of the sale, so far as they are sufficient, by paying: first, all of Plaintiff's
costs; ~ d , documentary stamps affixed to the certificate; third, Plaintiff's attorneys'
fees; fourt~e total sum due to plaintiff, less the items paid, plus interest at the rate
prescribed i~raph 2 from this date to the date of the sale; and by retaining any
remaining amou~nding further order of this Court.
7. Right of Re&!ption/Right of Possession. On filing the certificate of sale,

~
Defendants and all per11:ms, claiming under or against Defendants since the filing of the
0
Notice of Lis Pendens Siiiciw~il.~ foreclosed of all estate or claim in the Property and
Defendants' right of redempt~rescribed by section 45.0315, Florida Statutes (2013)
shall be tenninated, except as ~ims or rights under chapter 718 or chapter 720,
Florida Statutes, if any. Upon the~ of the certificate of title, the persona named on
the certificate of title shall be let into ~ssion of the Property.
8. Attorneys' Fees. The Court finds that Plaintiff, FIRST AMERICAN BANK, is
entitled to reasonable attorneys' fees, costs and expenses incurred in connection with
this action. The Court will retain jurisdiction to determine the total amounts of attorneys'
fees, costs and expenses to which Plaintiff is entitled.
9. Jurisdiction Retained. Jurisdiction of this action is retained to enter further
orders that are proper including, without limitation, a deficiency judgment.
IF THIS PROPERTY IS SOLD AT PUBLIC AUCTION, THERE MAY BE
ADDITIONAL MONEY FROM THE SALE AFTER PAYMENT OF PERSONS WHO ARE
Page 3 of 4
CFN 20170234535
40F4
ENTITLED TO BE PAID FROM THE SALE PROCEEDS PURSUANT TO THE FINAL
F YOU ARE A SUBORDINATE LIENHOLDER CLAIMING A RIGHT TO FUNDS

0
ING AFTER THE SALE, YOU MUST FILE A CLAIM WITH THE CLERK NO
LATE~ 60 DAYS AFTER THE SALE. IF YOU FAIL TO FILE A CLAIM, YOU WILL
NOT BE E~ED TO ANY REMAINING FUNDS.
DON~ ORDERED in Chambers in Palm Beach County, Florida on this ..'.1Je_
day of~••~ 2017.
~
~o Circuit Court J~e
Copies furnished to: ~~

Henry H. Bolz, Ill, Esq. /?5\
Keller & Bolz, LLP ~~
Attorneys for First American Bank~
121 Majorca Avenue, #200 v-QJ~
Coral Gables, FL 33134 ~
Laurence S. Schneider
Jay S. Levin, Esq.

Sachs, Sax, Caplan
Page4of 4
CFN 20170244727
Filing# 58504652 E-Filed 06/30/2017 02:13:33 PM OR BK 29205 PG 1606
RECORDED 07/10/2017 10:32:15
AMT
Sharon R. Bock
15 15 2
THE FIFTEENTH JUDICIAL CIRC~~T Pgs os- o7 : < Pgs)
1°
CASE NO.: 502016-CA-009292
DIVISION AW
~o
FIRST~RICAN BANK, as
su_ ccesso~.erger to Bank of
Coral Gab~LC,
~tiff,
v. ~
LAURENCE .S. SC
STEPHANIE L. SCHN&lf~
--------~~---:'
~ E D FINAL JUDGMENT
THI$ CAUSE came bef~s Court on June 26, 2017 upon Plaintiff's, FIRST
AMERICAN BANK, Motion for S u ~ Judgment (bearing a Certificate of Service dated
May 25, 2017) alld the Court havin~ed the aforementioned Motion,
.IT IS ADJUDGED that:
1. Judgment is GRANTED in fav9r of PlaU1tiff, FIRST AMERICAN BANK, and against
Defendant, LAURENCE S. SCHNEIDER.
2. Plaintiff, FIRST AMERICAN BANK, 2295. Galiano Street, Coral Gables, Florida
33134, recover from Defendant, LAURENCE.S. SCHNEIDER, 360 E Coconut Palm Road
Boca Raton, FL 33432, ·Social Security No. , the sum of $1,625,072.21,
which shall bear interest at the rater of 5.05% per year, for which let execution issue.
CFN 20170244727
20F2
3. The Court fii)ds that Plaintiff, FIRST AMERICAN BANK, is entitled to reasonable
neys' fees, costs· and expenses incurred in connection with this action. The Court
ain jurisdiction to determine the ·total amounts of attorneys• fees, costs and
0
r::JellSes to which Plaintiff is entitled.
~ERED in Chambers in Palm Beach County, Florida on this So day of_ _
9b1 dq •~2017,
~ r Circuit CourtJ
~
Copies furnished ~
Henry H. Bolz, Ill, E s ~ 0

Keller.& Bolz, LLP
Attorneys fo_r First Amer . nk
121 Majorca Avenu.e, #2
Coral Gables, FL 33134. ~
Laurence S. Schneider
360 E Co_conu_t Palm Road ~
Boca Raton, FL 33432 ~
360 e· Coconut Palm Road
Jay S. Levin, Esq.

Sachs, Sax, Caplan
Attorneys for The Oaks at Boca Raton_ Property Owners~ Association, Inc.
Page 2 of 2
CFN 20170245538
OR BK 29207 PG 353
RECORDED 07/10/2017 14:02:16
AMT
Sharon R. Bock
"IN: THE CIRCUIT COURT' OF CLERK & COMPTROLLER
THE. ·F-IFTE:Et~jrH _juo1CiAL OIRCUiT Pgs o353-o 354 : (2 Pgs)
IN AND FOR PALM BEACH .COUNTY, FLORIDA
1° ~ 0
FIRST. ~ICAN BANK, .as

DIVIS.ION. AW
s~ccesso~ ~~_rger to Bank· .of

Coral Gabl.,,..-~C,
~tiff,
~-
v: ..
LAURENCE S. S.CH
. .. ©.~.ER:;
.STEPHANIE L..:SCH ~• etal.,
Defen~ant ~
-------- -~11--- --·i
~ED FINAL JUDGMENT'.
Tl-iiS CAUSE .came ~ S . Gourt on June :26; 20'17 upon Plaintiffs, FIRST
~E~ICAN. BANK, MotiOI'! fc)r SQ_~ij~_gme Jlt <t>e•rii,g a. Ce~ffi.cate of. S!!!JVi~ ~-'8(1
May 25, 2017.) and the Court. having granted the -aforementioned Motion,
IT. 1·s ADJUDG~D :thJf
1.: Judgment is-GRANTED ·,n favor o(F'laintiffi FfRST AMERICAN BANKi, .and ~gainst.
.Defendant~. LAURENCE .s:. SCHNEIDER.
.2. Plaintiff, FIRST AMERICAN .BAN.Ki 2295 ·Gaiiano. Street-, Coral Gables; Florida
'33134, recover from Defendant, LAlJ.RENCE. S. :SCHNEIDER, .360 :E· co·conut Palm .Road
! the sum of S.t625\072.21,

which shall .bear interest at the rate: .of ·s.05.o/.o per ·year,. for which: let .execution .issae.
FIT .F.n· PAT .M RF.Al:H r.OTTNTV FT. SHARON R ROl:K r.1 .FRK 7/n/?.017 1·0n·OO PM
CFN 20170245538
BOOK 29207 PAGE 354
20F2
3! The CO.int finds ·that- Piaintiff.~. FIRST AMERiCAN BANK, is entitled .to reasonable·
.eys''·fees, -cosm. ·an~ e)(pet•~es •i.ncurred ih connect_ipo With tb.i.$ a.etion. The Cou.rt
'tn jllr1sd1ction to. .determine· the total amounts ·of attorneys' ·fe.es, casts· and
0
tm,1·5 to. which P.laihtiff i$ ·ent.it.led..
~ED ·in Chambers in Palm Beach. Coanty,. Florida on. this So day of_ _
'll'ilc;l·A ~ 1 7 .
~ > Circuit. co·urLlU.
~
C.opies furnished t ~
He,ny: H~ Bolt, UJ, E s ~ .

Keliet &· "Bolzi LLP . 0
Attorneys ·for First:Ameri • ·: ·k.

121 Majo~ Avenue, -#20. ~
Conti. Gt~l~s. Fl 3~134 ~~
La~rence .s. Schneider . l'n-i
::: ~~~L~~3:.~d ~~
Stephanie L Schneider ~
360 E Coconut· Palm Road
BQca R~ton, FL. 3343'2.
Jay .S. Levin, .Esq.

Sachs, -Sa)(', C$plan
Artomeys·fo.r The Oak$ at ·eoca. R.a.ton Prpperty= owners' :AssQciatioo_. I.he~
61 t1 Broken So.und Parkwayi: t+t"W.~ #200,;
eo·ca Raton, FL. 33487
.
..
••;
.. • ·~ 2.
FTT.F.n·PAT.MRF.Ar.Hr.O TTNTV FT. SHARONR ROrK rT.FRK 7/f"l/?017l·OfrOOPM •.·.·.

CFN 20180392544
Filing# 79291769 E-Filed 10/12/2018 05:09:58 PM OR BK 30184 PG 1587
RECORDED 10/15/2018 14:45:03
AMT
IN THE CIRCUIT COURT OF THE Sharon R. Bock
FIFTEENTH JUDICIAL CIRCUIT. IN AND CLERK & COMPTROLLER
FORPAIMBEACHCOUNTY,FLORIDA Pgs 1587-1590; (4Pgs)
f;
O.: 502016-CA-009292 AH
AMERICAN BANK, as
0
orby merger to Bankof
Co~bles, LLC,
~ Plainliff,
v. ~
LAURENCE~HNEIDER,
STEPHANIE L ~IDER, et al.,
Defendants. @
~ I
AID'~FINAL JUDGMENT OF FORECLOSURE
TIDS CAUSE came~ o r e this Court upon the Mandate issued by the Fomth District
Comtof Appeal dated Septemo~18, and, its Opinion dated July 25, 2018, and
accordingly, this Court enters this ~ e d Final Judgment of Foreclosure as follows:
The Cause having come bef;~ Cowt upon the Motion for Summary Judgment filed
by First American Bank which was h e ~ Court at a 45-minute specially set hearing on
Monday, Jtme 26, 2017, and the Comt, having heard and considered argument fromFirst
American Bank, it is
ORDERED AND ADJUDGED THAT:
1. Judgment is GRANTED in favor of Plaintiff, FIRST AMERICAN BANK, and

against Defendants, LAURENCE S. SCHNEIDER, STEPHANIE L SCHNEIDER and
THE OAKS AT BOCA RATON PROPERTY OWNERS' ASSOCIATION, INC.
2. Amounts Due. Plainliff, FIRST AMERICAN BANK, 2295 Galiano Street,
Coral Gables, Florida 33134, is due:
Principal $1,488,554.76
Interest fromMarch 16, 2016 to date of this Judgment $69,64652
Page 1 of 4
II -- - A
I a• - - A
-I I - - 1 1• 1 - , r-1 "I I A--• 1 - _ _ _ 1, -· --1, ~I",~ I"'""~ ft ftr ""' r ..... - · •
CFN 20180392544
Case No.50-2016-CA-009292-XXXX-MB 20F4
Florida Ad Valorem/real property truces for 2014, 2015 and 2016 $66,870 93
Total $1,625,072.21
That shall bear interest at the rate of 5.05% per year. Interest began accruing as of June
6, 2017, the date the Final Judgment was entered.
Lien of Property. Plaintiff, FIRST AMERICAN BANK, holds a lien for the
~<sum superior to all claims or estates of Defendants, on the following described
p~iinPalmBeachCounty, Florida:
"Lo of the Fox Hill Estates of Boca Raton, according to the Plat thereof, as
reco ~ Plat Book 87, Page 4, of the Public Records of Palm.Beach County,
Florida.
Cormmnly~nas 17685 Circle Pond Court, Boca Raton, Florida 33496-1002
("Property"). @
S)
4. Sale o erty. The Court is withholding having a sale of the Property,
Property and certif · t the Amended Final Judgment, dated June 30, 2017
("Monetaty Judgment''),~ing damages has not been satisfied. Upon application by
Plaintiff, FIRST AMERIC~ANK, requesting a sale of the Property and certifying
that the Monetary Judgment ~ n satisfied, 1his Court shall enter an Order
instructing the Clerk of Court to e Property.
5. Costs. Plaintiff, FIRST AMERICAN BANK, shall advance all subsequent costs
of this action and shall be reimbmsed for them by the Clerk if Plaintiff, FIRST
AMERICAN BANK, is not the purchaser of the Property for sale, provided that the
purchaser of the Property for sale shall be responsible for the documentary stamps
payable on the certificate of title. If Plaintiff, FIRST AMERICAN BANK, is the
purchaser, the Clerk shall credit Plaintiff's bid with the total sum with interest and costs
accruing subsequent to this Judgment, or such part of it as is necessary to pay the bid in
full.
6. Distnbution of Proceeds. On filing the certificate of title the Clerk shall
distnbute the proceeds of the sale, so far as they are sufficient, by paying: first, all of
Page 2 of 4
CFN 20180392544
Plaintiff's costs; second, documentary stamps affixed to the certificate; third, Plaintiff's
attorneys' fees; fourth, the total sum due to plaintiff, less the ite~ paid, plus interest at
the rate prescribed inParagraph2 from this date to the date of the sale; and by retaining
any remaining amount pending further order of this Comt.
Right of Redemption/Right of Possession. On filing the certificate of sale,
~cuidants and all persons claiming under or against Defendants since the filing of the
~ e of Lis Pendem shall be foreclosed of all estate or claim in the Property and
D e ~ ' right of redemption as prescribed by section 45.0315, Florida Statutes
(2013)~e tenninated, except as to clllllm or rights under chapter 718 or chapter 720,
Florida S ~ , if any. Upon the filing of the certificate of title, the person named on the
certificate of~ shall be let into possession of the Property.
~
8. Attom._ ....- ...,.-ees. The Court finds that Plaintiff, FIRST AMERICAN BANK, is
this action The Co .. ~ l f f l 11 retain jurisdiction to determine the total amnmts of attorneys'
fees, costs and expense~ch Plaintiff is entitled.

9. Jurisdiction Reta@. Jwisdiction of this action is retained to enter further
orders that are proper incl~out limitation, a deficiency judgment

IF THIS PROPERTY IS SO~UBLIC AUCTION, THERE MAY BE
ADDITIONAL MONEY FROM THE SALE AFTER PAYMENT OF PERSONS WHO ARE
ENTITLED TO BE PAID FROM THE SALE PROCEEDS PURSUANT TO THE FINAL
JUDGMENT.
Page 3 of 4
CFN 20180392544
IF YOU ARE A SUBORDINATE LIENHOLDER CLAIMING A RIGHT TO FUNDS

REMAINING AFTER THE SALE, YOU MUST FILE A CLAIM WITH THE CLERK NO
THAN 60 DAYS AFTER THE SALE. IF YOU FAIL TO FILE A CLAIM, YOU WILL
E ENTITLED TO ANY REMAINING FUNDS.
JNE AND ORDERED in West Palm Beach, Palm_Beach County, Florida.
~o ~~1_on~ ·/?·'?.;!/? ·.
&a}o-t:,.:0.012.12;~.-
WP .A.,. I-~ .. . . • U~5!?.,ll::,Yu~.
~ ~-2lii&CCA-009292-XXXX-MB ioii2noi.li
~ ~L-ill
~ Judg_e
~
Copies fmnished to:~
~
Herny H. Bolz, Ill, Es
Keller & Bolz, LLP
Attorneys for First Ameri
121 Majorca Avenue, #200
Coral Gables, FL 33134 @
Email: hbolz@kellerbolz.com ~
Ryan D. Gesten, Esq. ~

The Law Offices of Ryan D. Geste~
Attorneys for Laurence and Stephani ider
200 South Andrews Avenue, 9 Floo ~
th
Fort Lauderdale, FL 33301

Email: ryan@gestenlaw.com
Aleksandra Novakovich Gonzalez, Esq.

Sachs, Sax, Caplan
Email: agonzalez@ssclawfirm.com
Page 4 of 4
CFN 20180392544
Filing# ?9291769 E-Filed 10/12/2018 05:09:58 PM OR BK 30184 PG 1587
RECORDED 10/15/2018 14:45:03 .
AMT
1N THE CIRCUIT COURT OF THE . Sharon R. Bock ·
FIFTEENTH JUDICIAL CIRCUIT. IN AND CLERK & COMPTROLLER
FORPAIMBEACHCOUN TY,FLORIDA Pgs 1587-1590; (4Pgs)
ENO.: S02016-CA-009292 AH
T AMERICAN BANK, as
0
ssor by merger to Bank of i 111111 i"liil ilill lllii lillllflli 111-U 111n11r-
C~les, I.LC, CFN 20180393416
0
~
OR BK 30186 PG 0720
Plaintiff, RECORDED 10/16/2018 10:34:27
Palm Beach Count~, Florida
Sharon R. Bock,CLERK &COMPTROLLER
v. ~ ~pg~_OZ20_~ 723; (4P9S)
- -- . - - -· -· ... -- - ·-· - .
LAURENC~_,HNEIDE R,
STEPHAN~rIDE R, etal,
Defendants. ~ / .
,FJNAJ.,JUDGMEN TOFFORECLOSUR E .
. THIS CAUSE c ~ o r e this Comt upon the Mandate issued by the Fourth District
Comtof Appeal dated Septe~,018, and, its Opiniondated July 25, 2018, and
(2 '
accordingly, this Court enters Amended Final.Judgment of Foreclosme as follows:
The Cause having come b i , ~ Co~ upon the Motion for SUlllllllIY Judgment flied
by First American Banlc which was h ~ the Court at a 45-rnhn:rte specially set hearing on
Mooday,.June ·26, 2017, and the Court,~ heard and considered argument fromFirst
AmericanB~ it is
ORDERED AND ADJtJDGED THAT:
1. Judgment is GRANTED in favor of Plaintiff, FIRST AMERICAN BANK, and

against Defendants, LAURENCE S. SCHNEIDER, STEPHAN]E L SCHNEIDER and
THE OAKS AT BOCA RATON PROPERTY OWNERS' ASSOCIATION, INC.
2. Amoonis Due. Plaintiff, FIRST AMERICAN BANK, 2295 Galiano Street,
Coral Gables, Florida 33134, is due:
Principal $1,488,554.76
JnterestfromMarch 16, 2016 to dat~ of this Judgment $69,646.52
Page 1 of 4 ·
FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK. CLERK, 10/12/2018 05:09:58 PM
._,...,...,,,...,'W' I V'V'I I '-11::,V' I ~ I
CFN 20180392544 CFN#20180393416

BOOK 30184 PAGE 1-
Case No.50-2016-CA-009292-XXXX-MB 20F 4 Page 2 of 4
Florida Ad Valorem'real property taxes for 2014, 2015 and 2016 $66,87093
Total $1,625,072.21
That shall bear interest at the rate of 5.05% per year. Interest began accruing as of J\llle
26, 2017, the date the Final Judgment was entered.
0 .
~- Lien of P~operty. ·Plaintiff, _FIR.ST AMERICAN BANK, ho Ids a lien for the
~s~ superior~ all claims or estates of Defendants, on the following· desc~oed
. ~erty in Palm Beach Count¥, Florida: .
" of the Fox Hill Estates of Boca Raton, according to the Plat thereof, as
reco in Plat Book 87, Page 4, of the Public Records of Palm Beach County,
Flori
Col1llll0nl~wna s 17685 Circle Pond CotD1, Boca Raton, Flodda 33496-1002
("Property'').@ . .
4. Sale ~erty. The Court is withholding having a sale of 111: Property,
pending applicati~t>lain tiff, FIRST AMERICAN BANK, requesting a sale of the

Property and c e J ~ t the Amended Final Judgment, da~d J\llle 30, 2017
~ . '
("Monetary Judgment' ing damages has not been satisfied. Upon application by
Plaintiff, FIRST AME ~ANK, requesting a sale of the Property and certifying
·that the Monetary Jud~ment ~ t been satisfied, this Court shall enter an '?rder
instructing the Clerk of Co~the Property.
S. Cosls. Plaintiff, FIR~~CAN BANK, shall advance all subsequent costs
of this action and shall be reimbursed for them by the Clerk if Plaintiff, FIRST
Al\1ERICAN BANK, is not the purchaser of the Property for sale, provided that the
purchaser of the Property for sale shall be respomible for the documentary stamps
payable _on the certificate of title. If ~laintiff, FIRST AMERICAN BANK, is· the
p:urcbaser, the Clerk shall credit Plaintifrs bid with the total sum with interest and costs
accruing subsequent to this Judgment, or such part of it as is necessary to pay the bid in
full.
6. Distribution of Proceeds. On filing~ certificate of title the Clerk.shall
distnoute the proceeds of the sale, so far as they are sufficient, by paying: first, all of
Page2of4
..,,"''-'''""'-' I"'"'' I ""9t,"' • ,.__,
CFN 20180392544
BOOK 30184 PAGE 1 CFN#20180393416
Case No.50-2016-CA-009292-XXXX-MB 3 OF 4 Page 3 of 4
Plaintiff's costs; second, docmnentary stamps affixed to the certificate; third, Plaintiff's
attorneys' fees; fourth, the tof:81 swn due to plaintiff, less the items paid, plus interest at
the rate prescnbed in Paragraph 2 from this date to the date of the sale; and by retaining
1 any ren:eioing amount pending further order of this Court.

°J.
.
Right of Redemption/Rigbt of Possession. On filing the certificate of sale,
~.6:ndants and all persons claiming under or against Defendants since the fding of the
~ce of Lis Pendens shall be foreclosed of all estate or claim in the Property and
o4ms• right of redemption as prescribed ~Y section ·4s.o315, Florida"Statutes .
(201~ be te~ted, except as to claims or rights under chapter 718 or chapter 720,
Florida ~ s , if any. Upon the filing of the certificate of ~tie, the person named on the
certificate o ~ shall be let into possession of the Property.
8. · Atto~ees. The Court fmds that Plaintiff, FIRST AMERICAN BANK, is
entitled to reaso~meys • fees, costs and expenses incmed in connection with
this action. The Co~retain jwisdiction to determine the total lll!Dunls of attorneys•
fees, costs and expe~,c.hich Plaintiff is entitled.
9. • J urisdietion R ~ . Jurisdiction of this action is retained to enter further
orders that are proper incl~ithout limitation, a deficiency judgment. .
IF THIS PROPERTY IS SO~UBUC AUCTION, THERE MAY BE
ADDITIONAL MONEY FROM THE :AFI'ER PAY1v1ENT OF PER.SONS WHO ARE
ENTITLED TO BE PAID FROM THE SALE PROCEEDS PURSUANT TO THE.FINAL
JUDGMENT.
Page 3 of 4
CFN 20180392544
BOOK 30184 PAGE 1590 CFN#201803934 16
Page 4 of 4
IF YOU ARE A SUBORDINATE UENHOLDER CLAIMING A RIGHT TO FUNDS

REMAINING AFTER THE SALE, YOU MUST FILE A CLAIM WITH THE CLERK NO
LATER THAN 60 DAYS AFTER THE SALE. IF YOU FAIL TO FILE A CLAIM, YOU WILL
NOT BE ENTITLED TO ANY REMAINING FUNDS. .
.o DONE AND ORDERED in West Palm Beach, Pa~:Beach Co11111y: ~lorida.. .
·. D~0092D Z7~.
l~\. . . ..• ~c5.~•~-~lffe ·
_:/-?/?'
@
~~
2
·.. so.20~~~-~92!i2-~-MB . ioii2iioia
~v usas..s~l
~ . Judg~
Copies_~d to: ·
Henry H. e@, Esq.

Keller & Bolz,
Attorneys for F ~--..-.c:-_rican Bank
121 Majorca Avem~~Mr..?00
Coral Gables, FL .
Etmil: hbo lz@kelleli·btlliOU>
Ryan D. Gesten, Esq.

The Law Offices of RymM~le
Attorneys for Lamence and~IB!Qit
200 South Andrews Avenue, th
Fort Lauderdale, FL 33301 /?t..
Email: ryan@gestenlaw.com ~~
Aleksandra Novakovich Gonzalez,~"' .

Sachs, Sax, Caplan · ~~
Attorneys for The Oaks at Boca Ra~rty Owners~ Association, Inc.
Email: agonzalez@ssclawfinn.com
Page 4 of 4
I hereby certify the foregoing is a true copy of the

record in my office
with r e d ~ if any a. s r~quired by law as of this day, Oct 16, 2018.
Sharon ~ ~ a i m Beach County, Florida
BY ~ . Deputy Clerk
Exhibit 2
Larry Schneider
From: Henry Bolz <hbolz@kellerbolz.com >

Sent: Friday, May 26, 2017 12:53 PM
To: Larry Schneide r
Subject: RE: First American Bank v. Schneide r et al.
Attachments: E2 Schneider 05-24-17.pdf; E2 Schneider 05-16-17 .pdf
Mr. Schneid er,
I am in receipt of and have reviewe d your email to me of 11 :12 a.m. today. I

take this opportu nity to
respond to the stateme nts and request s set out therein .
Your advices that you are "unavai lable from betwee n June 26, 2017 and July
5, 2017" preclud es our
ability to set the Motion for Summa r Judgme nt down for hearing on June 26,
2017. We will pursue
alternat e dates for the hearing .
For the reasons that I gave you in my email to you of yesterd ay (copy attache
d for ease of referenc e),
neither First America n Bank nor Keller & Bolz, LLP are willing to acquies ce in
your request for yet
another "ten busines s days" standstill.
Our office has no knowled ge or informa tion about your relation ship with Attorne
y Kenneth Trent
between August 2016 and the present . With that said, Attorne y Trent was your
record legal counsel
up to May 1, 2017. Accordi ngly, any and all of the corresp ondence, pleadin gs
and docume nts that
you have request ed in your email of earlier today will have to come from him.
Keller & Bolz, LLP
cannot and will not provide you with any of that informa tion.
In respons e to your query as to when you should expect to receive First America
n Bank's respons es
to the April 24, 2017 First Reques t for Production, as I stated to you in my May
16, 2017 email (copy
attache d for ease of referenc e), First America n Bank will not be respond ing to
those Reques ts due to
deficien cies (A-E) identifie d in my email.
Regards,
Herny H. Bolz, III

Keller & Bolz, LLP
Coral Gables, FL 33 134
Telephone: (305) 529-850 0
Telefax: (305) 529-0228
E-mail: hbolz@k ellerbolz .com
IMPORTANT: THIS E-MAIL. AND ANY ATTACHME NTS THERETO. IS INTENDED

FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS
ADDRESSE D AND MAY CONTAIN INFORMAT ION THAT IS LEGALLY PRIVILEGE
D. CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER
APPLICABL E LAW IF THE READER OF THIS E-MAIL IS NOT THE INTENDED
RECIPIENT, OR THE EMPLOYEE OR AGENT RESPONSI BLE FOR
DELIVERIN G THE E-MAIL TO THE INTENDED RECIPIENT, YOU A RE HEREBY
NOTIFIED THAT ANY DISSEMINA TION. DISTRIBUTION OR COPYING OF
THIS COMMUNICATION IS STRICT LY PROHIBITE D. IF YOU HAVE RECEIVED
THIS E-MAIL IN ERROR, PLEASE IMMEDIATE LY NOTIFY THE SENDER BY
E-MAIL OR TELEPHON E (IF CONTACT INFORMATION IS PROVIDED ) AND
PERMANEN TLY DELETE THE ORIGINAL OR ANY PRINTOUT THEREOF.
From: Larry Schneider [mailto:larry@sacapitalpartners .com]
Sent: Friday, May 26, 2017 11:12 AM
To: Henry Bolz <hbolz@kellerbolz.com>
Subject: RE: First American Bank v. Schneider et al.
Mr. Bolz,
I am unavailable from between June 26, 2017 and July 5, 2017.
As you are aware, your unrelenting actions and filings in this matter, especially in the past month, while I have been
attempting to retain counsel in this matter, continues to prejudice my ability to engage competent counsel. As such, I
request that you not fi le any additional actions in this matt er for ten business days, so that I can get proper legal
representation in this matter.
Furthermore, as you are aware, my prior counsel in this matter, Mr. Trent has been problematic in my representation
and has specifically NOT informed me of the numerous communications and gyrations in this litigation. I have
requested that Mr. Trent immediately provide me with all communications between him/his office and you/your firm in
this matter. Several attorneys who I have spoken to, are weary of taking t his case due to the circumstances which had
occurred In the past with prior counsel and the rate in which you are fast tracking this foreclosure action. Mr. Trent has
provided me with w hat I believe is a fraction of the communications between your firms.
As such, please send me a copy of all communications, correspondences or othe rwise between you and or you r office,
both to and from my formal counsel Mr. Trent. Let me know if there is a fee you will charge for this and how much the
total cost will be, prior to providing me with the communications. For the above mentioned reasons, I request t hat you
please refrain from making any unnecessary addition filings, pleadings, hearings or otherwise for five business days from
being provided with the t otality of the communications between you and your firm and Mr. Trent and his
firm. Likewise, I have made a request to Mr. Trent for a complete copy of my entire case file including all
communications w ith opposing counsel. I have not yet received a reply from him .
If you are unable or unwilling to assist me in providing the communications, please let me know immediately. Without
the communications, I am not able to obtain competent counsel, as they have concerns of communications which I am
not aware of, which may have adversely affected my represe ntation in this matte r.
Agai n, for the above mentioned reasons, I do not agre e t o the proposed hearing for the Motion for Summary
Judgment. Please confirm that you are in receipt of the First Request For Production which I sent on April 24, 2017, and
when we can expect to receive FAB's responses to these requests.
Sincerely,
Larry Schneider
305-710-4201
la rrv@saca pita Ipartners.corn
From: Henry Bolz [mailto:hbolz@kellerbolz.com)

Sent: Friday, May 26, 2017 9:53 AM
2
To: Larry Schneider <larry@sacapitalpartners.com>; Stephanie Schneider (steffschneider13@gmail.com)
<steffschneider13@gmail.com>
Subject: First American Bank v. Schneider et al.
Mr. and Mrs. Schneider,
In accordance with the Court's procedures, we are attempting to coordinate a hearing on the Motion
for Summary Judgment (filed yesterday). The earliest possible hearing date that we can now get is
1:30 p.m. or 2:30 p.m. on Monday, June 26, 2017. Please let us know (by noon) if you can attend the
hearing on June 26, 2016 and at what time.
Regards.
Henry H. Bolz, Ill

Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
E-mail: hbolz@kellerbolz.com
IMPORTANT: THIS E-MAIL, AND ANY ATTACHMENTS THERETO, IS INTENDED FOR THE USE
OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN
INFORMATION THAT IS LEGALLY PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM
DISCLOSURE UNDER APPLICABLE LAW. IF THE READER OF THIS E-MAIL IS NOT THE
INTENDED RECIPIENT, OR THE EMPLOYEE OR AGENT RESPONSIBLE FOR DELIVERING THE
E-MAIL TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY
DISSEMINATION, DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY
PROHIBITED. IF YOU HAVE RECEIVED THIS E-MAIL IN ERROR, PLEASE IMMEDIATELY
NOTIFY THE SENDER BY E-MAIL OR TELEPHONE (IF CONTACT INFORMATION IS PROVIDED)
AND PERMANENTLY DELETE THE ORIGINAL OR ANY PRINTOUT THEREOF.
3
Exhibit 3
KELLER & BOLZ
Limited Liability P-,mnership
JOHN W. KELLER, 111* 121 MAJORCA AVENUE TELEPHONE (305) 529-8500

HENRY H. BOLZ, lll SUlTE 200 TELErAX (305) 529-0228
CORAL GABLES. FL 33 134
SHEY LA MESA WWW.KELLERBOLZ.COM
EMA IL: hbolz@kellerbolz.c.:orn
*Board Certified in
Admiralty & Maritime Law
May 26, 2017
Via Federal Express
The Honorable James T. Ferrara

Palm Beach County Circuit Court
205 N Dixie Highway, Room 10.1208
West Palm Beach , FL 33401
Re: First American Bank v. Laurence S. Schneider, et al. ; Palm

Beach County Circuit Court Case No. 16-CA-9292
Dear Judge Ferrara:
Our firm represents the Plaintiff, First American Bank ("First American"), in the
above-referenced action. We write for the dual purposes of (1) apprising you of the
present status/circumstances of this action and (2) requesting a special set hearing on
First American's Motion for Summary Judgment and Incorporated Memorandum of Law,
bearing a Certificate of Service date of May 25, 2017.
Status of this Action
First American instituted this foreclosure action on August 17, 2016. On November
16, 2016, the Defendants, Laurence S. Schneider and Stephanie L. Schneider
(collectively "the Schneiders") filed their Answer and Affirmative Defenses to First
American's Verified Foreclosure Complaint, which included two Affirmative Defenses. On
January 26 , 2017, this Court entered an Order Striking the Schneiders' Affirmative
Defenses. The Schneiders were granted 20 days from the entry of the Court's January
26 Order to file amended affirmative defenses.
On March 6, 2017 - 39 days after entry of this Court's January 26 Order - the
Schneiders filed their Amended Affirmative Defenses. The Schneiders asserted three
Amended Affirmative Defenses. On April 7, 2017, this Court entered an Order striking all
three Amended Affirmative Defenses with prejudice. This Court specifically denied the
Schneiders' motion for leave to file second amended affirmative defenses. Accordingly,
the Schneiders have no affirmative defenses.
On March 22, 2017, former counsel for the Schneiders, Attorney Kenneth Trent,
filed and served his Motion to Withdraw. On May 1, 2017, the Court granted the Motion.
The Schneiders have not retained new counsel.
The Honorable James T. Ferrara
May 26, 2017
Page 2
This action is currently set for trial on the Court's June 28, 2017 (20 day) trial
calendar.
Motion for Summary Judgment
On May 25, 2017, First American filed and served its Motion for Summary
Judgment and Incorporated Memorandum of Law ("Motion for Summary Judgment"). A
copy of First American's Motion for Summary Judgment is enclosed. In accordance with
this Court's Divisional Instructions, undersigned contacted the Schneiders in effort to
coordinate a special set hearing on the Motion for Summary Judgment on June 26, 2017.
Mr. Schneider responded by stating: "I am unavailable between June 26, 2017 and July
5, 2017." 1
A review of First American's Motion for Summary Judgment will quickly

demonstrate that there is no genuine issue of material fact and that First American is
entitled to judgment as a matter of law. The Schneiders have admitted that they executed
the Note and/or Mortgage and that they defaulted under the terms of Note and Mortgage
by: (i) failing to pay the monthly interest payment due on May 1, 2016 and all subsequent
payments, (ii) failing to pay the entire balance owing in a single balloon payment on July
28, 2016 and (iii) failing to pay the Florida Ad Valorem property taxes on the property
(which is the subject of this foreclosure) for 2014, 2015 and 2016.
Both for the convenience of all parties and judicial economy, First American's
Motion for Summary Judgment should be heard before the beginning of the non-jury trial
calendar on June 28, 2017.
As the Schneiders refuse to agree to a hearing date, First American respectfully

requests that the Court set a 45 minute special set hearing on First American's Motion
for Summary Judgment on any of the seven business days between June 15, 2017 (the
21 st day following the filing of First American's Motion for Summary Judgment) and June
25, 2017 (prior to the beginning of the June 28, 2017 trial calendar period).
e t r u -y
u ~,
\,
\ ' ()_/
·. Bolz, Ill
HHB/Amh/Encl.
cc: Laurence S. Schneider (via email)
Stephanie L. Schneider (via email)
Jay S. Levin, Esq. (via email)
(all w/o encl.)
Since Attorney Trent's withdrawal, undersigned has attempted on numerous occasions to

coordinate hearings, depositions, etc. , directly with the Schneiders. The Schneiders have uniformly ignored
undersigned's requests or stated they are unavailable.
Exhibit 4
Filing # 57246092 E-Filed 06/02/2017 02:42:09 PM
IN THE CIRCUIT COURT OF THE FlFTEENTH JUDICIAL CIRCUIT

FORECLOSURE DMSION AW
CASE NO.50-2016-CA-009292-XXXX-MB
FIRST AMERICAN BANK,
P Iaintiff/P etitioner
vs.
LAURENCE S SCHNEIDER,
STEPHANIE L. SCHNEIDER,
JEFFREY MARC HERMAN,
et al.,
Defendant/Respondents.
___________ _ ____ /
ORDER SPECIAL SETTING HEARING
(45 minutes reserved}
The following matter has been specially set for hearing before Presiding Judge . Please see
board outside of C~~o~m 4A for courtroom d}\:ig tion in the Palm Beach County
Courthouse, 205N.Dix1e Highway, WestPalmBeac FL~'LlOl:
DATE:June26,2017 ,
TIME: 02:30 pm
;-
MATTER: MOTION FOR S U ~ Y JUB>GMENT
By scheduling this hearing o t~e C,o rt's online scheduling system, the party
scheduling the hearing confirms tha~ since the filing of the subject motion, the lead
attorneys for the parties have s~ en t9Yeach other in person or by phone in a good faith
effort to resolve or narrow the ·s ue aised.
THIS MOTION IS SPEi LLY SET AND CANNOT BE CANCELED OR
RESET EXCEPT BY COU!UrORDER.
THE SETTING P TY, HAVING ELECTRONICALLY RECEIVED THE SIGNED
ORDER SPECIALLY SETTING THIS HEARING, SHALL IMMEDIATELY ATTACH A
COMPLETE ~ RVICE WITH ADDRESSES LIST AND SERVE A COPY OF THIS ORDER
TO ALLPAR.'.fl'ES OF RECORD (EVEN IF THEY ARE NOT PARTICIPATING) AND FILE
WITH ~~lE () ERK'S OFFICE A NOTICE OF SERVICE OF THE ORDER SPECIAL
SETTING flEARlNG.
Pagel of 3
Case No. 50-2016-CA-009292-XXXX-MB
It is the intent of this Court to dispose of the subject matter of the spec ially set motion on
the date and time appearing above. Accordingly, counsel must either: (1) be present personally or
by telephone conference call at the hearing (telephone appearance must be approved in
advance); or (2) submit an agreed order disposing of the motion
Hard copies of the motion, any other pleadings addressed by the motion, and memoranda,
not to exceed ten (10) double spaced pages, with highlighted case authority shall be delivered
directly to my office no later than seven (7) days in advance of the hearing and should designate
the date and time of the hearing which they reference.
DONE AND ORDERED in West Palm Beach, Palm Beach County, Florida, this 2nd
day of June, 2017.
50-2016-CA-009292-XXXr MB 06i02!2017
J_ames T. Ferrara
Clrcult Judge
COPIES TO:
HENRYH. BOLZ 121 MAJO~~ HBOLZ@KELLERBOLZ.CO

SUITE 200 M
co~ GABLES, FL 33134 ahart@ke llerbo lz .com
JAYS.LEVIN SOUND J1evin@ssclawfirm.com
,w forec losures@ssclawfinncom
jaylevin.esq@gmail.com
BO,,CARATON, FL 33487
LAURENCE S. SCHNEIDER 360 EAST COCONUT PALM LARRY@SACAPITALPART
ROAD NERS.COM
BOCA RATON, FL 33432
STEPHANIE i . 360 EAST COCONUT PALM LARRY@SACAPITALPART
SCHNEIDER ROAD NERS.COM
BOCA RATON, FL33432
Page 2 of 3
Case No.50-2016-CA-009292-XXXX-MB
This notice is provided pursuant to Administrative Order No. 2207 9/12
"If you are a person with a disability who needs any accommodation
in order to participate in this proceeding, you are entitled, at no cost to
you, to the provision of certain assistance. Please contact Tammy Anton,
Americans with Disabilities Act Coordinator, Palm Beach County
Courthouse, 205 North Dixie Highway West Palm Beach, Florida 33401;
telephone number (561) 355 4380 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; jf you are
hearing or voice impaired, call 711."
"Si usted es una persona minusvalida que ~ecesita algun

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 Tammy Anton, 205 N. Dixie
Highway, West Palm Beach, Florida 33401; telefoJro numero (561) 355-
4380, por lo menos 7 dias antes de Ia cita fijacla para su comparecencia en
los tribunales, o inmediatamente despues de ecibir esta notificacion si el
tiempo antes de Ia comparecencia q u'e se ha programado es menos de 7
dias; si usted tiene discapacitacion del oido
T
o de la voz, llame al 711."
/
"Si ou se yon moun ki enfim ki bezwen akomodasyon pou w ka
patisipe nan pwosedi sa, ou kalifye san ou pa gen okenn laj an pou w peye,
gen pwovizyon pou jwen k'.ek ed. Tanpri kontakte Tammy Anton,
koodonate pwogram Uwa pou ameriken ki Enfim yo nan Tribinal Konte
Palm Beach la ki nan 205 North Dixie Highway, West Palm Beach, Florida
33401; telefon Ii s (561) 355 4380 nan 7 jou anvan dat ou gen randevou
pou paret nan tri inal Ia, ou byen imedyatman apre ou fin resevwa
konvokasyon an si le ou gen pou w par et nan tribinal la mwens ke 7 j ou; si
OU gen woblem pou w tande oubyen pale, rele 711."
Page 3 of 3
Exhibit 5
Case 9:17-cv-80723-DMM Document 8 Entered on FLSD Docket 06/22/2017 Page 1 of 2
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
CASE NO. 17-CV-80723-MIDDLEBROOKS/BRANNON
FIRST AMERICAN BANK, as

Successor by Merger to Bank of
Coral Gables, LLC,
Plaintiff,
V.
LAURENCE SCHNEIDER, STEPHANIE

L. SCHNEIDER, et al. ,
______________
Defendants.
/
NOTICE OF FILING
COMES NOW the Plaintiff, FIRST AMERICAN BANK, by and through its
undersigned counsel and in accordance with the applicable Federal Rules of Civil
Procedure, hereby notifies the Court and all parties of the filing of the Defendants',
LAURENCE SCHNEIDER and STEPHANIE SCHNEIDER, Response to Order to Show
Cause bearing a Certificate of Service Date of June 21 , 2017.
Respectfully submitted,
KELLER & BOLZ, LLP

Attorneys for
Telephone: (305) 529-8500
Telefax: (305) 529-0228
Email: hbolz@kellerbolz.com
By: s/Henry H. Bolz, Ill

Henry H. Bolz, 111
Florida Bar No. 260071
Case 9:17-cv-80723-DMM Document 8 Entered on FLSD Docket 06/22/2017 Page 2 of 2
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing Notice of
Filing was delivered to the addressee below via transmission of Notices of Electronic
Filing generated by CM/ECF on this 22 nd day of June, 2017:
LAURENCE SCHNEIDER, Pro Se

360 Coconut Palm Road
Boca Raton , FL 33432
Email: Larry@sacapitalpartners.com
KELLER & BOLZ, LLP
By: s/Henry H. Bolz, Ill

Henry H. Bolz, 111
2
t 06/22/2017 Page 1 of 1
Case· 9:17-cv-80723-DMM Document 8-1 Entered on FLSD Docke
UNIT ED STAT ES DISTR ICT COUR T

FOR THE SOUT HERN DISTR ICT OF FLOR IDA
WEST PALM BEAC H DIVIS ION
FIRST AMER ICAN BANK , Case No.: 9:17-c v-807 23-DM M
Plaint iff DEFE NDAN TS' RESP ONSE TO

COUR T'S ORDE R TO SHOW CAUS E
vs.
RECEIVED
LAUR ENCE SCHN EIDE R;
STEPHANIE SCH.NEIDER JtJM2 2 2~1:?
Defen dants
d to as ''D<.:fen c!arr,:;'')
Defendants Stepha nie and Laurence Schne ider (hereinafter referre
of this action filed Juue ~),
hereby respon d to this Court 's sua sponte review as to the removal
0,1
2017, as follows.
remedies to preven t
this Court, Schne ider v. First
the sale of the subjec t proper ty in the separately filed action before
American Bank, Case No. 9: l 7-cv-80728-DMM.

nl~
Respectfully Submi tted this ~ Day ofJun e 2017
Laurence Schne ider and Steph anie Schnei der

360 E. Cocon ut Palm Road
- ·:.. J t: . :
1
Exhibit 6
Larry Schneider
.From: Larry Schneider

Sent: Frid~y, June 23, 2017 4:09 PM
To: Henry Bolz
Cc: Stephanie Schneider (steffschneider13@gmail.com); Jay Levin, Esq.; Jay Levin Esq.
(foreclosures@ssclawfirm.com) .
Subject: Re: First American Bank v'. Schneider, et al. - Palm Bea~h Circuit Court Case No.
.2016-009292
Mr. Bo_lz,
As I had explained to you, I am in _

Phoeni_x doi_ng depositions and will not be back in town unti Thursday of next week.
Please note that I will be filing a notice with t_he court ..

. . . . . } .
Additionally, you have refused t_
o produce any billing statement or any Request f<;>r Prodoction.
Sincerely,
Late Schneider
·Sent from my iPhone

. r
_On Jun. 23, 2017, at 7:25. AM, Hen·ry Bolz. <hbolz@kelledi'olz.com:;,,_wrote:
~
Mr. arid Mrs. Schneider,
a
Although you may have already seen It we ach a copy of United States District Court Judge Donald
Middlebrooks'
. . june 22, .2cii7
. Order'reinar,dmg
J " the Foreclosure Litigation back.to Circuit Court. ·
The Order Remanding Case to State d urt has been filed with the Circuit Court and the Circuit Court
·again has jurisdiction over
.
tfte
, Foreclosure
. Litigation.
We are advised by ~ Circuit Court that First American Bank'·s Motion for Summary Judgment (bearing a
Certificat_
e of Se~ ice date of May 25,· 2017) remains scheduled to be heard by the Circuit Court at 2:30
p.m. on .Mo dam yne 26, 2017; 45 minutes has. been set <jside for this hearing. A copy of Judge
Ferrara's June 2, 7,017 Order Special Setting Hearing is atta.ched for ease of reference. ·
,,.
Henry H. Bolz, III

• • + •
Keller & Bolz, LLP .

Coral Gables, FL :33134
Telephone: (305) 529-85Q0
Telefax: (305) 529-0228
_E-mail: hbolz@kellerbolz.com
1
IMPORTANT: THIS E-MAIL AND ANY ATTACHMENTS THERETO. IS iNTENDED FOR THE USE OF THE INDIVIDUAL OR
ENTITY
WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS LEGALLY PRIVILEGED, CONFIDENTIAL AND EXEMPT TO
FROM
DISCLOSURE UNDER APPLICABLE LAW. IF THE READER OF THIS E-MAIL IS NOT THE INTENDED RECIPIENT, OR THE
EMPLOYEE
OR AGENT RESPONSIBLE FOR DELIVERING THE E-MAIL TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED
THAT ANY
DISSEMINATION, DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED
.
THIS E-MAIL IN ERROR, PLEASE IMMEDIATELY NOTIFY THE SENDER BY E-MAIL OR TELEPHONE (IF CONTACT INFORMATION
. PROVIDED) AND PERMANENTLY DELETE THE ORIGINAL OR ANY PRINTOUT THEREOF. IS
. . . .
<#9 Order <?fRemand 06-22-17.pci.f.>
<2017-06.:02 Order Spc Set'Hrg- MSJ.pdf.>
2
Exhibit 7
1
1 IN THE CI RCUIT COURT OF THE 15TH JUDICIAL CIRCUIT

2
3 CASE NO .: 50 - 2016-CA-009292-XXXX- MB
4
5 FIRST AMERICAN BANK,

6 Plaintiff/Petitioner ,
7 vs .
8 LAURENCE S . SCHNEIDER,
9 STEPHANIE L . SCHNEIDER ,
10 JEFFREY MARC HERMAN ,
11 et al . ,
12 Defendant/Respondents.
13
- - - - - -- - -- - - -- - - I
14
15 TRANSCRIPT OF PROCEEDINGS
16
BEFORE
17 THE HONORABLE SUSAN LUBITZ
18
19
20 Palm Beach County Courthouse

21 205 North Dixie Highway
22 West Palm Beach , Florida 33401
23
24 June 26 th , 2017
25
JULIO A. MOCEGA & ASSOCIATES 305-374-0181

2
1 APPEARANCES :
2
3 For the Plaintiff :
4 HENRY BOLZ , ESQUIRE
5 121 Majorca Avenue , Suite 200
6 Coral Gables , Florida 33134
7 305 - 529 - 8500
8 hbolz@kellerbolz.com
9
10 ALSO PRESENT :
11 THE CASE MANAGER
12
13
14
15
16
17
18
19
20
21
22
23
24
25
JULIO A. MOCEGA & ASSOCIATES 305-374 - 0181

3
1 THEREUPON :
2 THE CLERK : And what's the young man ' s name

3 that we need to - I know it ' s Schneider, but what ' s
4 his first name?
5 THE COURT: Laurence --
6 MR. BOLZ : Laurence Schneider.
7 THE COURT : Schneider .
8 MR . BOLZ : And his wife is Stephanie
9 Schneider.
10 THE COURT: Stephanie Schneider

11 THE CLERK: All right. Laurence and Stephanie
12 Schneider .
13 THE COURT REPORTER: I ' m here for this case,

14 Your Honor . I ' m here for this case.
15 THE COURT : Okay. Except , let me go back and
16 get my - I guess I took all my notes. Just tell
17 the deputy; just tell the deputy I went back to get
18 my notes for this.
19 THE CLERK : Yes, ma ' am. She went to get her
20 notes.
21 THE BAILIFF: She - my judge does the same
22 thing. Sits down there with me in trial - the
23 attorney was like, remember when I said that? No .
24 You didn ' t say that . Counsel , he said this . I'm
25 like , yeah. No representation for the client in

4
1 the hall .
2 THE COURT : Thank you , Deputy .

3 THE BAILIFF : You got it.
4 THE COURT : All right . This i s First American
5 Bank versus Laurence Schne i der and Stephanie
6 Schneider . And this is plaintiff ' s motion for
7 s ummary judgement.
8 One matte r that I had noticed in pulling up

9 the Cler k' s docket sheet , and that is the
10 Defendants have moved to remand this to United
11 States District Cou r t for the Southern District of
12 Florida .
13 And , although it hasn ' t been filed yet , you
14 have presented me with an orde r from t h e US
15 District Court remanding the case back to the State
16 Court. So , I --
17 MR . BOLZ : Yes , ma ' am . But - it was removed
18 th
on June 9 , and it was remanded , I believe , on the
19 22 nd so , which was last Thu rsday .
20 THE COURT : Right . Okay . So , let me hand you
21 your copy.
22 MR . BOLZ : Yo u r Honor , you ' re welcome to keep
23 it . I have lots of copi es on that note .
24 THE COURT : Well , as long as it ' s filed in the
25 court file .

5
1 MR. BOLZ : Yes, it is .

2 THE COURT : I don ' t think I have to keep it.
3 And you are Mr .
4 MR . BOLZ : I'm Henry Bolz .
5 THE COURT : Henry Bolz. Okay.
6 MR. BOLZ: Of the law firm of Keller and Bolz .
7 THE COURT : I think you ' ve appeared in front
8 of me before .
9 MR . BOLZ: Yes , ma'am.
10 THE COURT: Okay .
11 MR. BOLZ : You handl ed the initial motion to
12 dismiss and motion to strike hearing . In this - I
13 thin k i t would have been in November.
14 THE COURT : Oh , okay. According to your
15 review of the case , you had advised the Court that
16 the affirmative defenses have been stricken , as has
17 the counter- claim . Am I correct?
18 MR . BOLZ : You struck them . Some with
19 prejudice , some without prejudice in November .
20 There was - they were refiled, amended , and they
21 were stricken with prejudice or dismissed with
22 prejudice in February , I believe .
23 THE COURT : Okay .
24 MR . BOLZ : Yeah . There are no affirmative
25 defenses . There is no counter-claim.
JUL I O A. MOCEGA & ASSOCIATES 305-374-01 81

6
1 THE COURT: Okay . So , why don ' t you proceed?

2 MR . BOLZ: Your Honor , we ' re - first off , I
3 just want to , just very quickly , explain what has
4 happened .
5 THE COURT : Oh , Mr. Bolz , before - you
6 proceed, the one thing I do want to see is the
7 notice of today ' s hearing . I ' ve looked through the
8 docket sheets and couldn ' t find it .
9 I just want to make sure that there is a
10 notice of hearing that was provided to the
11 defendants , who are now prose .
12 MR . BOLZ : Le t ' s see . Orde rs special setting
13 hearing entered by , or s i gned by, Judge Ferrara on
14 J une 2 nd , 2017 , Your Honor.
15 THE COURT : Okay .
16 MR . BOLZ : Your Honor , just - the case was
17 remanded back to t he - to this court on Thursday .
18 And we , however , did not get the order until -
19 early Friday morning .
20 When the orde r came in , I wrote to -sent an e -
21 mail to Laurence Schneider and Stephanie Schneider
22 and advised them that the hearing was going to go
23 fo rward. And on 4:09 p . m. Friday, I received an e -
24 mail - I haven ' t shown i t to the Court , but it ' s
25 short.
JULIO A. MOCEGA & ASSOCIATES 305 - 374-018 1

7
1 It says , Mr . Bolz , as I have explained to you,

2 I am in Phoenix doing depositions and will not be
3 back in town until Thursday of next week . Please
4 note that I will be filing a notice with the Court.
5 Additionally, you have refused to produce any
6 billing statement or any request for production .
7 Sincerely, it says Late Schneider. Not Larry
8 Schneider . I don ' t know .
9 And so , he has not filed the promised notice
10 with the Court that he said he was . I just wan t
11 the Court to be aware of that.
12 THE COURT : Okay . He hasn't filed any notice
13 on unavailability , nor has he filed a motion t o
14 continue the case?
15 MR . BOLZ : Neither .
16 THE COURT : Okay . Let's proceed.
17 MR . BOLZ : Your Honor , first off , just to - we
18 have the original promissory note and mortgage . We
19 would suggest that when we get back to the office
20 today we will send these by FedEx with a notice of
21 filing and put them in the - -
22 THE COURT: I think you can file them wi t h the
23 Court now .
24 MR . BOLZ : I'm happy to . I ' m giving you the
25 origina l.
JULIO A . MOCEGA & ASSOCIATES 30 5 - 37 4- 0 1 81

Ex. 29 Verified Mot. Set Aside Judgement, 2019

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Filing # 83842970 E-Filed 01/24/2019 01:17~59 PM

IN THE CIRCUIT COURT OF THE 1511-!

CASE NO. 50-2016-CA-009292

FIRST AMERICAN BANK,

The plaintiffs, Laurence S. Schneider and Stephanie L. Schneider (collectively, ''the

judgment in favor of First American. Specifically, the Schneiders allege that:

subsequently consulted, told Bolz they were unavailable;

of the hearing from June 26, 2017;

while the Schneiders were out of state and unavailable; and

the motion to stay.

costs, and expenses to which First American is entitled.

2. On September 7, 2018, First American filed a motion to tax appellate costs to

Laurence Schneider in the amount of$1,797.35.

Allegations in the Other Action

to withdraw as counsel, stating in the motion:

Trent was not "in touch" with the Schneiders). {Id.).

summary judgment. (Compl. ,r 17). Bolz wrote:

In accordance with the Court's procedures, we are attempting to coordinate

I am unavailable from between June 26, 2017 and July S, 2017.

[Emphasis added]. (Compl. ,r 18; Ex. 2).

In response, Bolz wrote:

[Emphasis added]. (Compl. ,r 19; Ex. 2).

to state court. (Compl. 131).

still out of town. (Compl. ,r 37).

still out of town. (Id.).

On Friday, June 23, 2017, Bolz sent an e-mail to Mr. Schneider:

As I had explained to you, I am in Phoenix doing depositions and will not

(Compl. ,I 40; Ex. 6).

exchange with Bolz:

THE COURT: Okay. He [Laurence Schneider] hasn't filed any notice on

MR. BOLZ: Neither.

THE COURT: Okay. Let's proceed.

(Compl. ,r 45; Ex. 7).

dates other than June 26, 2016). (Compl. ,r 46).

[the] court before which an execution or other process based on a final

[The] prevention of an unsuccessful party [from] presenting his case, by

American to execute on its judgments.

Under penalties of perjury, I declare that

Dated: January..22, 2019.

RESPECTFU LLY SUBMITTED .

BY: Isl Charles F. Rodman. Esq.

RESPECTFULLY SUBM ITTED,

BY: Isl Andrew D. Wyman. Esq.

BY: Isl Andrew D. Wyman, Esq.

HENRY H. BOLZ, Ill, Esq.

ALEKSANDRA NOVAKOVICH GONZALEZ, Esq.

CHARLES F. RODMAN, Esq.

IN THE CIRCUIT COURT OF THE I 5nt

VERIFIED COMPLAINT TO SET ASIDE JUDGMENT

The plaintiffs, Laurence S. Schneider and Stephanie L. Schneider (collectively, ''the

1. The plaintiff, Laurence S. Schneider ("Mr. Schneider"). is a resident of Palm Beach

2. The plaintiff; Stephanie L. Schneider (''Mrs. Schneider"), is a resident of Palm

Beach County, Florida.

3. The defendant, First American Bank ("First American"), is an lllinois banking

corporation with a principal place of business in Elk Grove Village, Illinois.

Circle Pond Court, Boca Raton, Florida.

Esquire ("Trent"), filed an Answer and Affirmative Defenses.

could not represent the Schneiders.

his representation of the Schneiders was at the same level.

motion to withdraw as counsel, stating in the motion: