Professional Documents
Culture Documents
FAB V Schneider Docket As of June 12, 2020
FAB V Schneider Docket As of June 12, 2020
FAB V Schneider Docket As of June 12, 2020
7/7/2016 1 Letter Garry S. Smith FAB SVP to Schneider, July 16, 2016
2 Doc 11 Mot. Compel Rents Ex. D Letter FAB Garry S. Smith to Schneider r
12/12/2016 Dec.
EMAIL12, FROM
2016 Letter
ATTY From FAB To Kenneth Trent (Suspended) S & A re. L
TRENT
TO L. SCHNEIDER AND
12/12/2016 BRENT TANTILLO RE.
AFFIDAVIT OPPOSING
1 08/17/2016 RENTS
CIVIL COVER SHEET
NOTICE OF EMAIL
13 08/24/2016
DESIGNATION
NOTICE OF EMAIL
14 09/01/2016
DESIGNATION
15 09/08/2016 ANSWER & AFFIRMATIVE DEFENSES-Marc Herman
18 09/20/2016 https://www.scribd.com/document/465586963/D-E-18-First-American-Bank-Notice-of-Hearing-Motion-Compel-Rent-Petition-for-Receivership-September-30-2016
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104 05/23/2017 MOTION FOR SPECIALLY SET TRIAL DATE FILED BY PLT
109 05/25/2017 May 25, 2017-5.46PM eservice-Mot Summary Judgement, 1 of 3 May 25, 2
05/26/2017 May 25, 2017-6.52PM Email Schneider To Bolz re. Insp For May 26, 2017-
May 26, 2017 FAB response to
Schneider's Qualified Written
Request.
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8/21/2017 March 6, 2017-5.37 PM Email Trent To Schneider, Tantillo & Cruz re. Ame
8/21/2017 May 9, 2017-1.19PM eservice Notice of Serivce Notice of Depositions,
8/21/2017 May 24, 2017- 12.50PM, eservice-Mot Spec. Set Trial & Unavail, May 24, 2
8/21/2017 May 24, 2017-1.20PM, Email From Schneider To Bolz re. Notice of Hearing
8/21/2017 May 24, 2017-12.43 PM, Email Schneider To Bolz re. Filing-38 Min's To R
Sept. 21, 2017-2.09 PM Email Bolz To Schneider re. Mot. Notice of Reset F
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3/6/2017 Sept. 21, 2017-9.37AM Email Bolz To Schneider- Attached Mot. Reset Sale
5/9/2017 Sept. 29, 2017 3.14 PM-Email Sch To Tantillo re. Bolz Mot. Strike
5/24/2017 April 4, 2017-9.24PM Email Trent To Schnider, Tantillo & Cruz re. Mot. Di
5/30/2017 FAB v Schneider Doc 9, Order Remanding Case To State Ct., June 23, 2017
9/29/2017 FAB v Schneider Doc 10 Remand State Ct.,-Clerical Error, June 23, 2017
6/22/2017 FAB v Schneider Doc 11 Remand State Ct., on June 23, 2017
138 07/18/2017 D.E. 146 N.O.F. Addl Ex-H, Nov. 30, 2015 Ltr. Bolz, July 18, 2017
139 07/18/2017 EXHIBIT
EXHIBIT
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NOTICE OF APPEARANCE
200 10/25/2017
CIVIL
NOTICE OF EMAIL
200 10/25/2017
DESIGNATION
MOTION FOR
200 10/25/2017 RESPONSE TO: OPPOSITION
CONTINUANCE CIVIL
TO DFTS MOTION TO
200 10/25/2017 CONTINUE EVIDENTIARY
HEARING SCHEDULED ON
200 10/25/2017 NOVEMBER 6, 2017 F/B PLT
PROOF OF PUBLICATION
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AGREED ORDER SMALL
DTD 2/5/19 STRIKING
297 01/30/2019 NOTICE OF
UNAVAILABILITY DOCKET
NOTICE OF FILING
ENTRY #285
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INTERROGS
RESPONSE TO REQ TO
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PRODUCE
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EVIDENCE/EXHIBIT LIST
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EVIDENCE/EXHIBIT LIST
FILED
NOTICE OF DEPOSITION
357 06/17/2019
DESIGNATION F/B PLT
358 06/18/2019 CLERK'S NOTE
FAB v Schneider 4th Circuit Order - Affirmed in Part-Reversed in Part, July 25, 2018
4 DE 53
5 DE 200 Ex. 8
Email From Bolz To Schneider re. FCRA Nov. 30, 2015, 1:40 PM
1 U.S. Mail
1 U.S. Mail
Email From Bolz To Schneider re. FCRA Nov. 30, 2015, 2:11 PM
U.S. Mail
Doc 24 Notice of Filing Affidavit, (pp. 7-8) FCRA Ltr, Oct. 12, 2016
Doc 24 Notice of Filing Affidavit, re. Email Sch To Hagan, Nov. 18 2015
Had attorney Trent utilized the exhibits in Schneider's Motion in Opp to
Judge Eli Breger Motion to Compel Rents, the Motion to Dismiss would not have been
denied. At the very least, the hearing on Motion to Dismiss should
Judge Eli Breger have been rescheduled so Schneider could attend and provide testimony
of Attorney Bolz central involvement in ensuring Schnieder's default
Judge Eli Breger and Conspiracy to Commit Fraud, evidenced by the Oct. 14, 2016
Motion
3. in Opp.
Although To Mot.progress
significant to Compel
hasRents.
been made, the undersigned solo
Judge Eli Breger practitioner has not yet been able to complete it, mainly due to the press
of business in other matters. Such other has not yet been able to
complete it, mainly due to the press of business in other matters. Such
other obligations include mandatory appearances in Monroe County on
2. Subsequently,
October 31st and the undersigned
November 2nct,solo practitioner
3-4 other contracted
important hearings that
bronchitis, and is under
week, and, on this date (Nov. 8) the continuation of a non-jury trial in a
aBroward
physician's
case.care.
PLEASE TAKE NOTE that due to a consent judgment upon a Bar
grievance against him, the undersigned attorney will be suspended from
practice and therefore unavailable from December 12, 2016 through
January 11, 2017. This notice should be construed as a motion to
continue any events scheduled, and toll any time periods set to elapse,
during said 30-day suspension.
Doc 40 Pla. 1st RFP L. Schneider-Email Sch. To Hagan re. 11.18.15 Email, Jan. 12, 2017
The
Doc Request forRFP
40 Pla. 1st Inspection was filed
L. Schneider justFCRA
-Bolz a day and
Ltr. a11.30.16,
half afterJan.
attorney
12, 2017 (54-55
Trent served his 30 day suspension (Dec. 12, 2016 through Jan. 11,
2016).
Doc 40 During
Pla. 1st Trents
RFP L.suspension,
Schneider, Schneider
Email Schaccommodate a suprise Errors 1.18.16 Email, Jan. 12, 2017 (
To Bolz re. Continued
inspection on December 15, 2016, in which Schneider granted
Molestina acccess to the community and view the propery, as no
advance notice was given o the Schneider's and both had prior
obligations. Schneider received a call from and Michael Alden on
January 8, 2017 for an appraisal of the propery requested by FAB.
Schneider made arrangements to meet with Alden on September 9,
2017 and submited the appraisal to FAB on September 11, 2017.
FAB's substantially redacted attorney’s fees billing, show the
conspiracy in which FAB and K & B engaged to lay the
groundwork for a Renewed Petition for Appointment of
Receivership for the actual purpose, which was to obtain an
THIS CAUSEhearing
evidentiary came ontotoextract
be heard beforeofthis
tidbits Court on from
testimony January 26,
THIS
2017 CAUSE carne on fo beAMERICAN
heard before this Court on January 26, the
Schneider. Despite Carlos Molestina's inspection on to
upon Plaintiffs, FIRST BANK, Motion Strike
December
2017 upon
Schneiders' Plaintiffs,
Affirmative FIRST AMERICAN
Defensesfor (bearing BANK, Motion
a Certificate to Strike
of Service datethe
15, 2016, Bolz files a Request Inspection. Had Bolz
Schneiders'
of Counterclaims
Decemberanother
29, 2016) (bearing
and the Court a Certificate
-having wouldof Service
reviewed date
the file, of
having
requested inspection, Schneider have obliged as
December 29, 2016) and theand Court having reviewed
heard
he hadargument
done of counsel
before. However, being otherwise
this was part ofthe
fully file, having
aadvised ih the.
purposeful
heard
intentargument
premises, of counsel
to itprejudice
is hereby the and being
ORDERED,
court otherwise fully
ADJUDGED
record and lay AND DECREED that
the groundwork for
advised ih
Plaintiff's the.
Motion premises,
to it
Strike is hereby
Defendants', Laurence S. Schneider and
extracting testimony from Schneider through a Petition for
ORDERED,
Stephanie
Receivership ADJUDGED
L Schneider,
Hearing.First AND DECREED
Affirmative that Plaintiff's
Defense is hereby Motion
granted,to
Strike
with prejudice. TtJe Schneiders shall have no right to file an Amended
Set by Judge Peter Blanc and HearDefendants', Laurence S. Schneider and Stephanie L Schneider, First
First Affirmative Defense, and it is further ORDERED, ADJUDGED
Affirmative
AND DECREED that Plaintiff's Motion to Strike
Set by Judge Peter Blanc and HearDefense
Defendants;,is hereby granted,
Laurence with prejudice.
S. Schneider TtJe Schneiders
and Stephanie shall Second
L Schneider, have
no right
Affirmativeto file an
·Defense
Amended First Affirmative
is hereby granted. The Defense, and itshall
Schneiders is further
have 2 0 days from the
ORDERED,
entry of this ADJUDGED AND DECREED that Plaintiff's Motion to
Strike
Order in which to file an Amended Second Affirmative Defense.
Defendants;,
DONE AND Laurence ORDERED S. Schneider
in Chambers andinStephanie
Palm Beach L Schneider, Second
County, Florida
Affirmative Defense is hereby
on this 26th day of January, 2017. granted. The Schneiders shall have 20
days from the entry of this Order in which to file an Amended Second
26. In response to FIRST AMERICAN's Request for Inspection, a
Affirmative
2. On aAMERICAN
number Defense.
of walls on the exterior of the Residence,
FIRST representative, Carlos Molestina, wasthere were
granted
DONE AND
largeareas of ORDERED
cracked and in Chambers
peeling paint in Palmwas
which Beach County,
falling off. Florida
In
access to the Property on January 19, 2017. Among the findings and
on this 26th daywere
addition, of January, 2017. where the exterior paint on the as a
results of there
that inspectionnumerous
made areas
on January 19, 2017 were that:
result
6. When Mr. Schneider attemptedoftoareas
of inattention. In a number gain of the exterior
access of the house,
to the Residence
the
throughthe garage, it was determined that the garage door was marred
paint was Residence where mold and/or mildew had grown
by water stains,
inoperable. Afterdripping
we got intowater and/or debris.
theResidence See illustrative
through the front door, it
7. Asdetermined
a resultattached
photographs
was of that
the power being off,
as electrical
the Composite there
Exhibit
power was
had "C". no air conditioning
beenshut off to the or
air circulating
Residence (forwithin
reasonsinunknown
the Residence.
to the Because
undersigned).of loss of electrical
service
9. On theto initial
the Property,
approach I could
to thenot determine
Property, it waswhether
noted any
that of
thethe
exterior
appliances or light fixtures in the residence worked.
of the Property was not being maintained. Specifically, the grass on the
Property was not properly mowed and grass was non-existent where it
10. There
should havewerebeen.a lot of bushy/overgrown/dried out plants which
included bougainvillea,
11. The exterior swimming palmpool
trees
ofand
the unclipped
Residence shrubbery. See but
was fairly clear
illustrative
had a good photographs attached as Composite Exhibit "A".
These open number
and obviousof leaves and debris
deficiencies withinthe
it. It was evident
Property were that
all
because the electricity
documented through a to the Property
series had been
of photographs turned
which willoff,
be the pool's to
attached
pump/filtration system/cleaning/straining
the Affidavit of Carlos Molestina which will system
vacating was the
not property.
operating. See
illustrative
Furthermore, photographs
should theattached as Composite
tenant vacate as indicted,Exhibit "B". request
he should
the hearing be deemed moot, reducing unnecessary costs be filed with
this
Doc Court
24 Noticedirectly in support
of Filing of this(06.05.15
Affidavit, Verified Anderson
Petition toLtr),Appoint
Oct. 12, 2016
Receiver.
Doc 24 FAB Renewed Pet. Appt. Rec. Bolz FCRA Ltr Feb. 14, 2017
Doc 24 Renewed Motion Receivership- Email Sch to Hagan 11.18.15, Feb. 14, 2017
Doc 24 Not. of Filing Affidavit, re. Opp MTC Rents, Email Sch to Bolz 1.18.16, Oct. 12, 2016
Doc 24 Notice of Filing Affidavit, re. Email Sch To Hagan, Nov. 2015
Attorney Trent set his Motion to Withdraw for May 1, 2017. Trent did
not provide Schneider any notice of the hearing. Because attorney
Trent did not provide the Schneider's any notice of the May 1, 2017
hearing on his motion to withdraw, Trent and Bolz conspired to insure
that any potential affirmative Defenses and Counter Clasims based on
the 15 day rule, could be unquestionablky and forever barred by a
motion
"The for rehering,
undersigned which the
attorney... Schneider's
moves would
the Court not and
to rehear thedid not know
abouit. AsMotion
Plaintiff's such, attorney
to StrikeTrent filed a Motion
Affirmative forand
Defenses Rehearing,
Motion toand
As evidenced by Attorney Bolz crtptic email from attorney Trent on
emailed
Dismiss the filed motion to Schneider., unaware of
Counterclaims.
April 17, 2017…., Bolz filed a hearing on Schneider's Rehearing of
Counter Claims and Affirmative Defenses, knowing that Schneider
would not be at the hearing. A bold move, unless Bolz had absolute
confidence that Schneider's would not be attending the Hering on
Trent's Motion to Withdraw, as he
2017-05-01 Docs Produced by Schneiders (Bates-00012)-Jan 2016 Periodic Billing Statement, SCHNEID
2017-05-01 Docs Produced by Schneiders (Bates-00144-00145)-Email Hagan re. 1st Fid-JPMC, Nov. 18.
2017-05-01 Docs Produced by Schneiders (Bates-00228-00230) Bolz RESPA Ltr Nov. 30, 2015
Doc 108 MSJ, Ex. F Trans. History Aff. Smith, May 25, 2017 (pp. 113-127)
Doc 108 MSJ, Ex. 9 Ltr. Smith July 7, 2016 (p. 198)
Doc 108 MSJ, Ex. 10 -Smith Aug. 16, 2017 Ltr. (p. 199)
The eighth "Assessed Loan Expense Fee" line item on the statement
attached to your April 10, 2017 letter reflects a Transaction Amount of
$25.00. The basis for that charge to FAB was an unsuccessful attempt
by a local appraisal company to inspect your property on January 9,
2017. After the appraiser assigned by FAB was unable to obtain access
to your property being foreclosed (not even the outside of the
residence), Attorney
In all events, FAB hasKenneth Trentthat
determined wasthe
contacted on January
$25.00 expense that13,
FAB2017.
incurred with respect to the unsucces
Attorney Trent arranged for the property to be inspected on January 19,
2017 by Mr. Carlos Molestina from FAB.
Thus, when Garry S. Smith, S.V.P. of FAB executed Plaintiff’s First American’s Renewed Verified Petiti
The fact that Smith was in possession of the Michael Alden Exterior Only Appraisal dated January 9, 201
Information which was contained in the subsequently filed Molestina Affidavit on February 23, 2017 affid
That fraudulent Verified Petition, executed by FAB’s S.V.P. Garry S. Smith was sent email to (“ the wires
Henry H. Bolz, III., subsequently filed the knowingly fraudulent Verified Petition with the 15th Circuit Co
Henry H. Bolz, III knowingly fraudulent Verified Petition for Appointment of Receivership submitted via
FAB SVP Garry S. Smith, even took the unnecessary step to add a footnote to his Verified Petition, quotin
26. In response to FIRST AMERICAN's Request for Inspection, a FIRST AMERICAN representative, Ca
a. Bolz transcript testimony on October 28, 2016 laid out the “green pool” argument, which was then co
28. More than four months after Defendant, LAURENCE S. SCHNEIDER, attested, under oath, that he w
1. Verified Foreclosure
Note, Bolz FCRA and RESPA Emails and Letters Not part of evidence.
Complaint, dated August 17,
Why???
2016.
Doc 24 Notice of Filing Affidavit, (06.05.15 Anderson Ltr), Oct. 12, 2016
Doc 24 Notice of Filing Affidavit, (pp. 7-8) FCRA Ltr, Oct. 12, 2016
Doc 24 Notice of Filing Affidavit, re. Email Sch To Hagan, Nov. 2015
9. Affidavit of Garry S. Smith,
dated March 23, 2017.
Doc 24 Not. of Filing Affidavit, re. Opp MTC Rents, 1.18.16 Email(9-11), Oct. 12, 2016
Doc 24 Notice of Filing Affidavit, (06.05.15 Anderson Ltr), Oct. 12, 2016
Doc 24 Notice of Filing Affidavit, (pp. 7-8) FCRA Ltr, Oct. 12, 2016
Doc 24 Notice of Filing Affidavit, re. Email Sch To Hagan, Nov. 2015
10. Transcript of the March 28,
2017 Evidentiary Hearing
before the Honorable Thomas
Barkdull. March 28,
Thomas Barkdull
2017, there
did not
waspreside
a conspiracy
over any to evidentiary
commit fraud, hearing
perpetrated
on
between
March 28,FAB,
2017, counsel
it was for FAB
heard by and Keller
Circuit &
Court Bolz,
The perjured testimony of Daniel Eggland, SVP of FAB, had thereJudge to use
James the
T. Ferrara.
been
fraudulently misrepresented initial Petition for Appointment
a trial, would have been easily used to prove that FAB had no idea of of
Receivership
the amount owed [DEon 4],the
filed on concurrently
HELOC, due to theirwith the fraudulent
compounding of data
Complaint [DE 2] August
entry and payment 17, 2016,
application along with the Motion to Compel
incompetence
Rents [DE 11] (Upon lease being fully disclosed and provide to FAB’s
Hagan, in FAB’s fraudulent misrepresentation that the bank was
Attorney
working on Trent essentially
potential begged to options
loss mitigation attend the hearing,
in June, premised
2016. on to
Pursuant
Transcript
Conspiracy
fraud upon of
thethe
betweenMarch
court by 28, &
Keller
FAB 2017
& Evidentiary
Bolz, Henry
Keller & H.
Bolz. Hearing
Bolz, III,before
FAB’s the
the redacted attorney’s fees finally provided to Schneider, by Bolz on
Honorable
Chairman Thomas Barkdull,Wardwas utilizedalsoinbyFAB’s theMotion for
August 27,and 2917,CEO theThomas IV,entry
very first billing on far
June 2,single
2016 largest
Summary
shareholder Judgement, despite Judge Barkdull not having presided over
documentedin theFAB, FAB General Counsel and EVP Frederick S.
the March
Snow,
Series FAB
of 28, 2017Garry
S.V.P. Renewed
conferences/telephone Petition
S. Smith, who forexecuted
conferences Appointment of Wells,
numerous
with Messrs. Receivership
knowingly
Snow,
hearing.
fraudulent
and affidavits which KFirst
& Bolz submitted
Hagan
Testimony Smith/receive
was provided and
by review Mr.
American BanktoEggland,
Hagan's the Circuit
report hisCourt,
on under
conference
including the
with
foreclosure
Mr. Schneider/email
complaint [DEexchange.
2] filed on
penalty of perjury which substantially conflicted with the reasonableAugust 17, 2016
(Trial Exhibit
calculation 9), Renewed
of amount due toPetition for Appointment
FAB, provided in FAB’sofGaryReceivership
S. Smith,
[DE
SVP 53]
whofiled on February
executed 12, 2017
the Verified despite
Petition for having specificofknowledge
Appointment
that he was in possession of the January
Receivership filed on Oct. 17, 2016. [DE 1]. 9, 2017 appraisal by appraiser
11. Letter from Plaintiff, First John Alden evidenced by (Trial Exhibit 15) Loan History Report. (Note
American Bank, to Defendant, that Donald Roubitcheck, FAB’s C.F.O. had communications with Bolz
Laurence specifically referencing the Molestina affidavit, which Smith relied
12. Letter S. Schneider,
from Plaintiff, First
dated March 18, 2016. upon in the renewed petition, based on Molestina’s fraudulent affidavit
American Bank, to Defendant,
filed on February 23, 2017 [DE 57], which was prepared by Henry H.
Laurence S. Schneider,
Bolz, III and filed by K & B), to the 15th Circuit Court, that Schneider
dated April 22, 2016.
had abandoned the property, the pool was green and that Renewed
13. Letter from Plaintiff, First Petition for the appointment of a Receiver, specifically, XX, to ensued
American Bank, to Defendant, that the property was in disrepair.
The Letter from Plaintiff, First American Bank, to Defendant, Laurence S. Schneider, dated July 7, 2016 s
Laurence S. Schneider,
dated July 7, 2016.
This proves that FAB never even attemped to resolve its S.O.R. issue of
charging a late charge 15 days prior to a payment due date. This
insured that no matter what Schneider paid, even when FAB ceased
sending Schneider Pediodic Billing Statemens, and Schneider then sent
wires with round numbers, such as
This letter was sent just one day prior to the surprise foreclosure complaint filed on August 16, 2017, whic
FAB utilized this Letter Dated July 7, 2016 as Exhibit 9 in its Verified Complaint For Foreclosure. Doc 1
Likewise, in the Letter from Garry S. Smith, S.V.P. of FAB to Schneider, dated May 27, 2015, it states:
Schneiders (Bates-00002) Email Schneider to FAB Espinosa and SVP Hagan re. Attached Wire For $4,29
Schneiders (00008-00010) Email Schneider to FAB Hagan re. Continued Servicing Negligence, Decembe
Schneiders (00014) Email Schneider to FAB Hagan re. BSI Lock Box and Wire Transfer, December 1, 20
Schneiders (Bates 000019) FAB Periodic Billing Statement Due February 1, 2017
Schneiders (Bates-00035) Email FAB Hagan to Schneider re. In Person Meeting, July 30, 2015
Schneiders (Bates-00036) Letter From Jennifer Anderson FAB V.P. to Schneider re. FAB re. Credit Burea
Schneiders (Bates 0046-00047) Letter From Bolz to Schneider re. FCRA, November 30, 2015
Schneiders (Bates-00048) Email From Bolz to Schneider re. FCRA, November 30, 2015
Schneiders (Bates-00051-00056) Email FAB S.V.P. Hagan re. JPMC, November 20, 2015
Schneiders (Bates-00063-00064) Email Schneider to FAB S.V.P. Hagan re. Status of JPMC Litigation, Ju
Schneiders (Bates-00065-00067) Email Schneider to FAB S.V.P. Hagan July 30, 2016
Schneiders (Bates-00071), Letter FAB S.V.P. Smith to Schneider re. Default, July 17, 2016
Schneiders (Bates-00082-00083) Email FAB S.V.P. Hagan re. Chase-1st Fid LOC November 18, 2017
Schneiders (Bates-00087-00088) Email FAB S.V.P. Hagan to Schneider re. Deficiency, November 20, 20
Schneiders (Bates-00091-00095) Email FAB Kielbasa To Schneider re. Wrong Address June 20, 2016,
Schneiders (Bates-00096-00097) Email Schneider To Bolz & FAB re. Continued Erroneous System of Re
Schneiders (Bates-00103) Letter From Jennifer Anderson FAB V.P. to Schneider re. FAB re. Credit Burea
Schneiders (Bates-00154-00155) Letter From Bolz to Schneider re. FCRA, November 30, 2015
Schneiders (Bates-00167) Email Bolz to Schneider re. FCRA Letter, November 30, 2015
Schneiders (Bates 00224-00227) Email String From Schneider to Hagan re. Reporting, Nov. 4, 2015
Schneiders (Bates-00228-00230) Letter from Bolz To Schneider re, RESPA November. 30, 2015
Schneiders (Bates-00249)Letter From Garry S. Smith to Schneider Dated May 27, 2015, which identifies
26. Any and all Schneiders (Bates-00252) Letter From Kielbasa To Schneider re. Late Payment Notice, May 7, 2015
answers/responses to
Interrogatories propounded by
27.
any Any
Partyand all answers
in the to
above-styled
Request
action. for Admissions
propounded
28. Any and by all any Party to
response in the
above-styled
Requests action.
for Production
De 110 Ex. 28 = D.E. 53 =
propounded by any Party in the
above-styled action.
The June 2, 2016 communications with Boilz, Snow, Hagan, Wellsre. Hagan's meeting with Schneider.
The June 13, 2016 FAB Personal Financial Stataement, which Smnih sent to Hagan I norder to extract Sch
4. Garry S. Smith
First American Bank 80 Stratford Letter Garry Smith to Schnedier July 6, 2017
Drive Bloomingdale, IL 60108
The
Ceasation of sending Schneider periodic billing statements after the
January 18, 2016 email from Schneider.
Garry S, Smith 's made numerous frauds upon the court, including the
Verified Foreclosure complaint. T
The Renewed Petition for Appointinment of Receivership, which was
based on Molestina's fraudulent "inspection affidavit."
Garry S, Smith's response to Schneider's QWR, which Smith sent to
Schneider in a latter dated May 26, 2017, just one day after the affidait
suppoirint hs
Email with Mesa, Jan. 18, 2016 Email From Schneider to Bolz, June 8, 2016
BTantillo@walkerdimarcopc.com; btantillo@tantillolaw.com;
lwills@tantillolaw.com
BTantillo@walkerdimarcopc.com
Doc 26-2 Ex. B, FAB Jue 26, 2015 Ltr To Credit Bureau's Ack. Error
BTantillo@walkerdimarcopc.com
BTantillo@walkerdimarcopc.com
BTantillo@walkerdimarcopc.com
BTantillo@walkerdimarcopc.com; btantillo@tantillolaw.com;
lwills@tantillolaw.com
BTantillo@walkerdimarcopc.com; btantillo@tantillolaw.com;
lwills@tantillolaw.com
BTantillo@walkerdimarcopc.com; btantillo@tant
Henry
FAB &H.KELLER
Bolz, III&fraudulent filing of misrepresented
BOLZ FRAUDULENT FILING OF that Schneider
had sent Bolz any Response to Order To
SCHNEIDER'S ORDER TO SHOW CASE IN THE U.S. Show Cause. Bolz
FEDERAL
fraudulentlyCOURT
DISTRICT misrepresented
FOR THEthatS.D.F.L.,
the fraudulent
WAS filing
USEDwas TOserved to the
DEFRAUD
Schneider's
SCHNEIDER viaAND
ECF/UM.
JUDGE MIDDLEBROOKS. THE FRAUD IN
THE FEDERAL COURT UPON THE FEDERAL DISTRICT COURT
JUDGE WAS USED TO FRAUDULENTLY DEFRAUD CIRCUIT
COURT JUDGE SUSAN LUBITZ THAT THE MSJ HEARING
SHOULD PROCEED WITHOUT SCHNEIDER.
Exhibit B
Garry S. Smith, FAB's S.V.P. who had commited perjury in the Complaint, Motion to Compel Rents, Mo
FAB's "Broker-Manager" Carlos Molestina, who signed Henry H. Bolz, III fraudulent affidavit
Daniel Pische Daniel Pische attended the January 26, 2017 hearing on FAB's Motion to Dismiss C.C. and Strike A.D. H
Robert Jurgensen
Laurence S. Schneider
Stephanie L. Schneider
1. Verified Foreclosure
Complaint, dated August 17,
2016.
2. Credit Agreement, dated July
28, 2006.
4.
3. Answer,
Mortgage,Affirmative
dated July Defenses
28,
and Counterclaim filed by
2006.
Defendants, Laurence S.
Schneider and Stephanie L.
Schneider, bearing a Certificate
of Service date of November 11,
2016.
5. Answer, Amended
Affirmative Defenses, and
Amended Counterclaim filed by
Defendants,
6. Affidavit Laurence S. S.
of Laurence
Schneider
Schneider in and Stephanieto L.
Opposition
Schneider, bearingtoaCompel
Plaintiff's Motion Certificate D.E. 200 = D.E. 110= D.E. 40 = D.E.
of Service date of March
Assignment of Rents, dated6, 2017.
October 12, 2016. [D.E. 24] Doc 200 Ex. 4 Doc 24, 1.18.16 Email To Bolz Ltr
Doc 259 Ex. 2 (31-62) Transcript Mot. Receivership-Rents, Oct. 28, 2016
Doc 259 Ex. 3 (63-88) Transcript Hearing Judge Lubitz, Jan. 26, 2017
Doc 259 Ex. 4 (89-108) Transcript Mot. Insp. Barkdull, March 23, 2017
Doc 259 Ex. 5 (109-147) Transcript Renewed Mot. Receivership-(Barkdull-Ferrera), March 28, 2017
Doc 259 Ex. 6 (148-156)Transcript Mot. Dismiss C.C. & A.D. Barkdull, Apr 28, 2017
Doc 259 Ex. 7 (157-164) Transcript Trent Mot. W.D., Ferrera, May 1, 2017
Doc 259 Ex. 9 (193-232) Transcript Mot. Stay Pending Appeal-Small, Nov. 6, 2017
Doc 259 Ex. 10 (233-290) Transcript Evid. Hearing Stay Pending Appeal, Nov. 8, 2017
Doc 259 Ex. 13 (389-392) Email re. Mot. Spl Set Trial, May 24, 2017
Doc 259 Ex. 14 (393-394) Email Bolz To Schneider re. Req. for Production, May 17, 2017
Doc 259 Ex. 15, (395-396) Email Schneider to Trent re. Molestina's Inspection Report, March 9, 2017
Doc 259 Ex. 16 (397-399) Email Schneider To Bolz, May 26, 2017
Doc 259 Ex. 17 (400-412) Notice of Filing-Affidavit FAB Molestaina, Feb. 23, 2017
Doc 290 Ex. 1 Fla. 4th Circuit
Court of Appeals Order, Oct. 11,
2017(p.
Doc 29027)
Ex. 2 Mandate Distric
Court of Appeal Fourth Dist.,
9.17, 2018
Doc 290 (p.3 28)
Ex. Order District
Court of Appeal Fourth Dist.,
9.17,290
Doc 2018(pp. 29-30) Set Aside
Ex. 4 Motion
Judgement July 11, 2017(pp. 31-
33)
Doc 290 Ex. 5 Schneider Motion
For Reconsideration, Vacate
Judgement, July 18, 2017
Doc 290 Ex. 6 Exhibits To Mot.
Reconsideration, July 18, 2017
(pp. 66-71)
Doc 290 Ex. 7 Exhibits To Mot.
for Rehearing, July 18, 2017 (pp.
72-90)
Doc 290 Ex. 8 Not. of Appeal,
July 18, 2017 (pp. 90-91)
Doc 290 Ex. 9 Amended Not. of
Appeal, July 18, 2017 (pp.92-93)
Doc 290 Ex. 10 FAB Response
Set Aside Judgement, Jan. 29,
2019(pp.
Doc 94-103)
290 Ex. 11 Req. Stay
Pending Appeal, Aug. 2, 2017
(pp.
Doc 104-119)
290 Ex. 12 Req. Stay
Pending Appeal, Aug. 2, 2017
(pp.
Doc 104-119)
290 Ex. 13 Amended
Appelant Brief Dec. 13,
2017(pp.120-180)
Doc 290 Ex. 14 Appelants
Corrected Reply Brief
Doc 290 Ex. 15 Email Bolz To
Trent re. Trial & Depo's April 17,
2017 (pp.204-205)
Doc 290 Ex. 16 Ex. H To Mot.
Reconsideration, July 18, 2017
(pp.206-212)
Doc 290 Ex. 17 Bolz Email To
Schneider re. June 26, 2017 MSJ
Hearing May 26, 2017 (p.213)
Doc 290 Ex. 18 Email Schneider
To Bolz, May 26, 2017
Doc 290 Ex. 19 Email May 26,
2017 12.53 PM (pp.216-219)
Doc 290 Ex. 20 Bolz May 26,
2017 Ltr. Judge Ferrara, May 26,
2017 (pp.222-223)
Doc 290 Ex. 20 Instructions
Judge Barkdull (pp. 219-220)
Doc 290 Ex. 21 May 26, 20167
Ltr Bolz to Ferrara, May 26, 2017
Doc 290 Ex. 22 FedEx Envelope
Bolz To Ferrara, May 30, 2017
(pp.223-224)
Doc 290 Ex. 23 Email Bolz To
Schneider re. Ltr To J. Ferrara,
May 26, 2017
Doc 290 Ex. 24(pp. 225-227)
June 2, 2017
Order(Tantillo & Trent) (pp. 228-
Doc 290 Ex. 25 Email Schneider
231)
To Bolz June 23, 2017 re. June
26, 2017 Hearing MSJ (pp.232-
233)
Doc 290 Ex. 26 Transcript June
26, 2017 (pp.234-261)
Doc 290 Ex. 27 JUne 2, 2017
Order re. June 2, 2017 MSJ
Hearing (pp.262-265)
Doc 290 Ex. 28 Hearings Set by
K & B (pp.266-267)
Doc 290 Ex. 30 Appelle's
Opposition Feb. 7, 2018 (pp.268-
231)
United States District Court Southern District of Florida
1 Docket: First American Bank v. Schneider, Case No. 9:17-cv- 80723-
DMM (Removal).
Florida Fourth District Court of Appeal Docket: Schneider v. First
2
American Bank, Case No.: 4D17-2239 (Appellate Action).
United States District Court Southern District of Florida
3 Docket: Schneider v. First American Bank, Case No.: 9-17- cv-
80728-DMM (Federal Court Action).
4 Keller & Bolz, LLP's Redacted Billing Invoices (State Action).
Keller & Bolz, LLP's Redacted Billing Invoices (Appellate
5
Action).
Keller & Bolz, LLP's Reacted Billing Invoices (Federal Court
6
Action).
Keller & Bolz, LLP's Redacted Billing Memos (State Action and
7
Appellate Action).
8 Keller & Bolz, LLP's Redacted Billing Memos (Federal Court Action).
Doc 356 Exhibit 8c-Sch v FAB Doc 26 Amended Complaint, Aug. 21, 2017
D.E. 442 2017 Exterior Only Appraisal
.
3 Furthermore, like the appellate court in Brindise, this Court
should find it significant that Defendants contractually agreed
with their lender on the procedure by which they would
payments due. See Exhibit "A," at pps. 3-4 and Exhibit "B," at p.
4 of the Verified receive notice of any default and the manner in
which their lender could accelerate all
Foreclosure Complaint. See also, Brindise, 183 So. 3d 1220-
1221.
Order should not have been calendared. No Meet & Confer b/c
Trent Suspension.
Not
Garrycommunication to Schneider
S. Smith's Verified Petitionand
for Brent Tantilloofon Service
Appointment
List
Receivership based on knowingly fraudulent affidavit which was
conducted by Carlos Molestina on January 19, 2017.
Furthermore, Garry S. Smith was in possession of the actual
January 9, 2017 Exterior Only Appraisal conducted by Florida
State Certified Appraiser Alden.
sounds pretty unreasonable to me please articulate the reason
that you need a follow-up inspection so that I can properly
evaluate your request
Bolz used specifically ambigious language-"Defendants' Motion
for Rehearing Dated April 24, 2017"
Ties to Chase, Vbery Personal Matter, Jordyn
See Doc 169 Email From Schneider To Bolz re. S & A &
Discovery -FAB v Sch, May 15, 2017
a. The electricity on the Property had been disconnected. As a result, it could not be determined whether the residence's air conditioning syst
b. The inside of the Property was empty; there was no furniture of any type or nature.
c. The landscaping on the Property was not being currently maintained in that the grass is not being properly mowed and there were a lot of b
d. The Property's swimming pool's cleaning/filtering system was
not working.
e. The Property was not being maintained insofar as the residence's exterior is concerned; there were areas of mold and mildew on the exterio
These open and obvious deficiencies with the Property were all documented through a series of photographs which will be attached to the Af
the “green pool” argument, which was then conspired to be included in Carlos Molestina’s fraudulent affidavit (DE 57] filed on February 23, 2017, via th
. SCHNEIDER, attested, under oath, that he would "be moving into the subject property as soon as possible" (Exhibit "D"), the Property subject to this fo
2
nt, Laurence S. Schneider, dated July 7, 2016 shows that FAB did nothing to correct its system of records. As indicated on the July 7, 2016 letter from Ga
ts Verified Complaint For Foreclosure. Doc 108 MSJ, Ex. 9 (198) Ltr. Smith July 7, 2016, May 25, 2017, in which FAB continued to charge a late fee 15
Please confirm
this wire has
agan re. Attached Wire For Sept. 2015 Billing Cycle, September 30, 2015 been received
and credited
a and SVP Hagan re. Attached Wire For $4,297.83 August 2015 Billing Cycletowards the
August 2015
payment of
HELOC
#40000006.
r September 2016 ,
It is disturbing
that you were
told the "credit
ovember 1, 2015 reporting is
accurate" by
ecember 1, 2015 staff. Despite
the numerous
conversations
re. Continued Servicing Negligence, December 1, 2015
with multiple
employees at
March 1, 2015 the bank over
the past six
months, my
efforts and
patience was to
no avail.
Shared honest
and
confidential
information, as
a professional,
a customer and
ober 30, 2015
on a very
personal level. I
anuary 1, 2015 reasonably
Iexpected
am waiting to
honest
get particular
and
Minimum
information
confidential
Payment Due
from 8S1 as
information,
Minimum
Lock Box and Wire Transfer, December 1, 2015 $708,894.38
Iregarding
had sent a
aAndprofessional,
Payment"AccessDue
wire
investoron
a$655,163.80,
customer
Loan Expenseand
Monday
relations for
and
on
And a very
Fees" "Access
9/7/2016-
$4,500
As
lockFirst
box asset
youup.I
personal
Loan level.
Expense
$13,974.98;
Minimum
requested.
American
reasonably
Fees" 9/7/2016-
10/5/2016-
Payment
Ban.k's Due
senior
expected
$13,974.98;
$17,034.77; that if
$680,998.10,
representative
Due January 1, 2017 you went out of
10/5/2016-
11/9/2016-
And
in "Access
Florida,
your way toI
$17,034.77;
$1,998.27;
Loan Expense
would likemeto
March 1, 2017 meet with
11/9/2016-
11/30/2016-
Fees"
meet 9/7/2016-
with you
in person to
$1,998.27;
$10,248.66;
$13,974.98;
to betterthe
discuss
11/30/2016-
12/14/2016-
Due February 1, 2017 10/5/2016-
understand
matter, that the
$10,248.66;
$16,507.06; you
$17,034.77;
circumstances
did so in
12/14/2016-
1/18/2017- good
C Loan History 7/28/2006-11/30/2015 11/9/2016-
surrounding
faith and that
$16,507.06
$25.00(John
$1,998.27;
your recent
the
Aldenerroneous
Exterior
11/30/2016-
email toancJMilton
biffing
Appraisal
$10,248.66;
Espinoza (and
credit reporting
performed
12/14/2016-
your borrower,
e. In Person Meeting, July 30, 2015 problems
1/9/2017); with
$16,507.06;
Johtmie
my account
2/10/2017-
Washington).
were resolved I
AB V.P. to Schneider re. FAB re. Credit Bureau Reporting, June 5, 2015 $23,069.12
did leave a
as you
message
represented for to
der re. FCRA, November 30, 2015 you yesterday
me. The banks
but wanted to
unwillingness
. FCRA, November 30, 2015 reach out via
to address its
email as well.
corrupted
Please
systemlet of me
know where
records, despite
and
overwhen
20 you
re. JPMC, November 20, 2015 would be
documented
available to
requests, plus
S.V.P. Hagan re. Status of JPMC Litigation, July 30, 2016 meet. Thank
the gross
you.
negligence
S.V.P. Hagan July 30, 2016 shown by the
bank in filing a
neider re. Default, July 17, 2016 release of lien
and satisfaction
of mortgage for
re. Chase-1st Fid LOC November 18, 2017
a loan it did not
own (Johnnie
to Schneider re. Deficiency, November 20, 2015 Washington - S
& A Capita!
chneider re. Wrong Address June 20, 2016, Partners
mortgage),
& FAB re. Continued Erroneous System of Records, January 18, 2016 shows the
banks
unwillingness
AB V.P. to Schneider re. FAB re. Credit Bureau Reporting, June 5, 2015
to comply with
federal and
ed, Oct. 1, 2015 state mortgage
servicing and
consumer
protection laws.
PMC, November 18., 2015
Thanks for the
reply. I have
eider re. FCRA, November 30, 2015 the payment
history that you
mmitment, February 26. 2006 requested, and
am told that the
A Letter, November 30, 2015 credit reporting
is accurate. I
will double
der to Hagan re. Reporting, Nov. 4, 2015
check to see
what
eider re, RESPA November. 30, 2015 correspondence
we have with
DueOctober 1, 2016 the credit
reporting
get that toand
agencies you
hneider Dated May 27, 2015, which identifies and confirms that FAB was charging a Late charge prior to the payment due date. Case in point, the May 2
as well.
will get that to
you as well.
der re. Late Payment Notice, May 7, 2015
y during the March 28, 2017 Hearing for FAB's Renewed Motion for Appointment of Receivership is prima faciue fraud. The hearing transcript was util
ondition of the subjec poroperty on January 19, 2017 would haeve proven to be a fraudulent misrepresenbtation to appraial ordered by FAB on January 8,
ce video of Molestina entering and exiting the Oaks community on December 15, 2016, which was granted by Schneider.
ich Smnih sent to Hagan I norder to extract Schneider's total finaincial picture,
The November
30, 2015 FCRA
email sent by
attorney Bolz to
Schneider
N/A
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 22nd day of June, 2017:
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 22nd day of June, 2017:
Minimum
Minimum Amout
Amout Due
Due September 1, 2017
October 1, 2017 $917,436.37 & Proof
$650,437.20-Neiher K&
of Delivery via U.S. Mail
B nor FAB would provide payoff because the conspiracy o
commi fraud, including the $13, 974.88 was K & B and FAB
conspiraing to commit fraud for the period of June 2, 2016
through July 29, 2016. This heavily redacted K & B billing
statement is attached as Exhibit C.
gement and members of its Board of Directors, who had already provided false and/or fraudulent affidavits and/or testimony from being exposed by Schn
n the Complaint, Motion to Compel Rents, Motion of Appointment of Receivership, Amended Motion for Appointment of Receivership, Motion for Summ
AB's Motion to Dismiss C.C. and Strike A.D. However, since he did not testify, K & B and GFAB could use Piche testimony in the November 6, 2017 M
Fraud-Hearing
James
FerraraNOT
Judge Barkdull
laint, June 13, 2017
Doc 26-2 Ex. B, FAB Jue 26, 2015 Ltr To Credit Bureau's Ack. Errror, Aug. 21, 2017
Doc 26-3 Ex. C, Schneider Credit Report Oct. 27, 2015, Aug. 21, 2017
Doc 26-4 Ex. D, Email 11.4.15 re. Continued Errors To Bureau, Aug. 21, 2017
Doc 26-5 Ex. E K & B Nov. 30, 2015 FCRA, Aug. 21, 2017
nowingly fraudulent Verified Petition for Appointment of Receivership, prepared by Henry H. Bolz, III. Specifically, the Verified Petition stated;
los Molestina of FAB, which materially contradicted the January 9, 2017 Alden appraisal.
e recipients Bolz choose to include for service of the fraudulent Verified Petition.
ceivership, in which Bolz, who had admitted to having never done a real estate foreclosure, specifically addressed his concern about the pool motor going
mong the findings and results of that inspection made on January 19, 2017 were that:
mold and mildew on the exterior of the house, instances where paint was cracking and flaking off the walls and there was noticeable streaking in differen
which will be attached to the Affidavit of Carlos Molestina which will be filed with this Court directly in support of this Verified Petition to Appoint Rece
led on February 23, 2017, via the wires, which formed he basis of FAB Garry S. Smith’s fraudulent Renewed Verified Petition For Appointment of Recei
), the Property subject to this foreclosure action has remained and remains unoccupied, without electrical power and, essentially abandoned.
n the July 7, 2016 letter from Garry S. Smith S.V.P. of FGAB, the letter dated July 7, 2017 shows a late charge due in the letter, for the July 2015 payment
$0.00 $4,698.54
$0.00 $50,263.82
$234.93 $4,648.29
$59,610.65
n June 13, 2017 by Garry S. Smith. Rather than using he information to evaluate Schneider’s Loss Mitigation Options, despite FAB engaging in a fraudul
continued to charge a late fee 15 days prior to the payment due date and would report the HELOC as being late, on or around the same time hat the late ch
Late Charge
Total Amount
$0.00
$0.00
$179.23
$7,700.25
unsel, FAB and Keller & Bolz purposefully withheld any payoff requested by Schneider or Schneider’s prior counsel, as the conspiracy to commit fraud, e
###
The hearing transcript was utilized in FAB;s MSJ and conflicts with the affidavit of indebitedbness submitted by FAB's SVP Garry S. Smith dated May
The discovery documents which were produced by Schneider, via attorney Brent Tantillo to attorney Kenneth Trent in September 2016.
and in which Henry H. Bolz, III informed Schneider that attorney Trent produced Bates
ny from being exposed by Schneider, FAB could not utilze
ern about the pool motor going out and the pool turning green. "Mr. Bolz: Is a pool motor going out and the pool turning green in the backyard?" Pg. 30
noticeable streaking in different areas of the residence.
tially abandoned.
etter, for the July 2015 payment due date which would not have been late until fifteen days after the payment due date.
pite FAB engaging in a fraudulent conspiracy, one in the same Garry S. Smith
nd the same time hat the late chare was assessed, thus, the reason FAB discontinued to sending Schneider Periodic Billing Statements after Schneider sent
e conspiracy to commit fraud, evidenced through the K & B August 27, 2017 substantially redacted attorney’s fees billing statement, precisely match the a
VP Garry S. Smith dated May 25, 2017. See hearing transcript.
tember 2016.
g green in the backyard?" Pg. 30 from October 28, 2016 hearing (Exhibit "J").”
g Statements after Schneider sent Bolz the January 16, 2016 email, that FAB was still harming Schneider’s credit
g statement, precisely match the amount which FAB SVP Garry S. Smith represented in his fraudulent Affidavit of Indebtedness, May 25, 2017 Motion fo
tedness, May 25, 2017 Motion for Summary Judgement. Smith knew that the fraudulent Affidavit of Indebtedness XX, despite claiming, “the Petition fo
despite claiming, “the Petition for Appointment of Receiver and the facts alleged therein are true and correct to the best of my knowledge and belief,” was
f my knowledge and belief,” was a knowingly fraudulent misrepresentation, on a document which Smith executed, knowing it was going to be filed as a c
wing it was going to be filed as a court document. That fraudulent executed affidavit was sent via the wires to Henry H. Bolz, III, who subsequently filed t
olz, III, who subsequently filed the knowingly fraudulent executed affidavit in the court record, which was sent via use of the wires.
Date Docket No. Description
6/26/2016 Doc 105 Defendant JPMC Cross Motion for TRO
2/28/2017 MRS v JPMo
Doc 147 Plaintiff's Memo of Law-Motion To Compel
3/6/2017 MRS v JPMo
Doc 151-17 Plaintiff's Amended Rico Statement
3/14/2017 MRS v JPMo
Doc 153 Defendants Memorandum of Law In Opposition to Plaintif's Motion to C
4/6/2017 MRS v JPMo
Doc 157 Defendant JPMC Memo in Opposition to Plantiff's Fourth Amended Com
4/14/2017 MRS v JPMo
Doc 165 Plaintiff's Memo Challenging Confidentiality Bryan Bly and Erika Lance
4/18/2017 MRS v JPMC
Doc 1 MRS v JPMC 17-00044 Doc 1 - Motion To Compel Erika Lance Deposit
4/18/2017 MRS v JPMC
Doc 1 Ex. A-1 MRS v JPMC 17-00044 Doc 1 Ex. A-1 Exhibit 4 Fourth Amended Comp
4/18/2017 MRS v JPMC
Doc 1 Ex. A-2 MRS v JPMC 17-00044 Doc 1 Ex. A-2 Fourth Amended Complaint (pp.
4/18/2017 MRS v JPMC
Doc 1 Ex. A-3 MRS v JPMC 17-00044 Doc 1 Ex. A-3 Fourth Amended Complaint (pp.
4/18/2017 MRS v JPMC
Doc 1 Ex. A-4 MRS v JPMC 17-00044 Doc 1 Ex. A-4 Fourth Amended Complaint (pp.
4/18/2017 MRS v JPMC
Doc 1 Ex. A-5 MRS v JPMC 17-00044 Doc 1 Ex. A-5 Fourth Amended Complaint, (pp.
5/12/2017 MRS v JPMo
Doc 181 Plaintiff's Reply In Further Support of Motion Challenging The Designati
5/12/2017 MRS v JPMo
Doc 181-1 IN THE MATTER OF NATIONWIDE Title Clearing Assurance of Volu
5/18/2017 MRS v JPMo
Doc 184 Memo and Order re. Plaintiff's Motion to Compel Discovery
5/25/2017 MRS v JPMo
Doc 185 Hearing Transcript MRS v JPMC heald in the United States District Cour
6/15/2017 MRS v JPMo
Doc 189 Notice of Plaintiff's Motion For A Temporary Restraining Order
6/15/2017 MRS v JPMo
Doc 190 Plaintiff's Memorandum In Support For A Temporary Restraining Order
6/15/2017 MRS v JPMo
Doc 191 Declaration Laurence Schneider In Support of Temporary Restraining Ord
6/15/2017 MRS v JPMo
Doc 191-4 Exhibit 4
6/15/2017 MRS v JPMo
Doc 191-2 Exhibit 2 -- Lien Releases
6/15/2017 MRS v JPMo
Doc 191-3 Exhibit 3 -- Vacations
6/16/2017 MRS v JPMo
Doc 194 Robert Wick, of Covington & Burling LLP, Counsel for Defendants Lette
6/19/2017 MRS v JPMo
Doc 196 Tantillo Letter To Swain re. TRO
6/19/2017 MRS v JPMo
Doc 197 Tantillo Letter Judge Swain re. Inadverent Error in Doc 196
6/30/2017 MRS v JPMo
Doc 203 Joint Letter Judge Francis re. Discovery
7/6/2017 MRS v JPMo
Doc 205 Memorandum & Order re. Outstanding Discovery
7/20/2017 Doc 210 NON-PARTIES’ SUPPLEMENTAL MEMORANDUM OF LAW IN OP
5/11/2018 Doc 295 JPMorgan Chase Answer Fourth Amended Complaint,
3/8/2019 MRS v JPMo
Doc 363-15 MRS v JPMC -Pla. 4th Amended Complaint, March 8, 2019
3/8/2019 MRS v JPMo
Doc 363-29 MRS v JPMC Michadl Bentalia-Homel;and Security-Schneider Phone Ex
Doc 113 Defendnat JPMC's Cross Motion in Support of Protect
8/18/2017 U.S. ex rel. Laurence Schneider v J.P. Morgan Chase Bank, et al. Motion
Doc 353-81 MRS v JPMC -Text Chase Employee-Fucked The Most
0260032-Text Extraction Iphone-Schneider
8/18/2017
Transcript Appeal
11/18/2013 Schneider v Schneider v JPMC 13-01223, All Qui Tam Standing Orders Judge Anderson, Doc 1, November 18, 2013
5/6/2013 Schneider v Schneider v JPMC 13-01223, Doc 2, Hidden Civil Cover Sheet, May 6, 2013
2/26/2019 MRS v JPMC Pla. Doc's sent to Mediator. Feb. 26, 2019
11/1/2013 Schneider v Schneider v JPMC 13-01223, Doc 20, Motion & Memorandum in Support for Partial Lift of the Seal, November 1,
11/6/2013 Schneider v Schneider v JPMC 13-01223, Doc 21, Order Granting Partial Lift of Seal, November 6, 2013
1/13/2014 Schneider v Schneider v JPMC 13-01223, Doc 24, US Notice of Declination, January 13, 2014
2/8/2014 TEXT FROM JEFF MCGRANE RE.AFP RETALIATION, FEBRUARY 8, 2014
2/24/2014 Schneider v Schneider v JPMC 13-01223, Doc 42, Order to Unseal Entire Docket, February 24, 2014
8/4/2016 United States ex el Schneider v JPMC 13-01223, Doc 63, Motion For Compliance With Unsealing Orders, August 4
11/6/2013 Schneider v Schneider v JPMC 13-01223, Doc 22, Hidden Email From Clerk To USDOJ re. Order Partial Unseal, November 6,
1/13/2014 Schneider v Schneider v JPMC 13-01223, Doc 29, Florida Notice of Non Intervention, January 13, 2014
1/13/2014 Schneider v Schneider v JPMC 13-01223, Doc 34, IL Notice of Declination, January 13, 2014
11/26/2014 Schneider v Letters From Black To State AG's re. Amended SME, Nov. 26, 2014
11/12/2015
4/30/2015 Schneider v Schneider v JPMC 14-01047 Doc 88 Relators Motion in Opposition to Motion for Partial Lift Of Seal.. April 30, 20
11/12/2015 Schneider v Schneider v JPMC 14-01047 Doc 105-1 Chase's Memo Support MTD 2nd Amd. Complaint, November 12, 2015
11/24/2015 Schneider v Schneider v JPMC 14-01047 Doc 107, Draft
CERTIFICATE
- Relator's Opposition
OF SERVICE
to Chase
- I hereby
Motion,certify
Nov. 24,
that2015
on November 24, 20
Hagan
position to Plaintif's Motion to Compel and in Support Cross Motion For Protective Order, March 14, 2017
o Plantiff's Fourth Amended Complaint
ality Bryan Bly and Erika Lance of Nationwide Title Clearing
To Compel Erika Lance Deposition, April 18, 2017
Exhibit 4 Fourth Amended Complaint (pp. 1-57), April 18, 2017
Fourth Amended Complaint (pp. 58-130), April 18, 2017
Fourth Amended Complaint (pp. 131-215), April 18, 2017
Fourth Amended Complaint (pp. 216-350), April 18, 2017
Fourth Amended Complaint, (pp. 352-358), April 18, 2017
otion Challenging The Designation of Third Party Witnesses Bryan Bly And Erika Lance
Title Clearing Assurance of Voluntary Compliance, December 5, 2015
o Compel Discovery
n the United States District Court for the District of Southern New York on May 10, 2017
orary Restraining Order
A Temporary Restraining Order
ort of Temporary Restraining Order
LP, Counsel for Defendants Letter to Judge Swain re. Adjournment of Plaintiff's TRO
1/19/2017
2/23/2017
1 11/30/2015 First American Bank v Bolz RESPA Letter Nov. 30, 2015
2 11/30/2015 First American Bank v Received via U.S.
Bolz RESPA LetterMail
Nov. 30, 2015
3 5/1/2017 First American Bank v Schneiders (Bates-00228-00230) Letter from Bolz To Schneider re, RESPA November. 30, 20
Email Schneider To Bolz re. Continued Erroneous Reporting, Jan. 16, 2016
Number Date Case Docket EnDescription
1 1/16/2016 Original Email January
Doc 24 Affidavit 16, 2016 re.
of Schneider
2 10/12/2016 First Ameri D.E. 24 Opp.
Doc 40Receivership (pp. 7-8),
Affidavit Schneder re.Oct.
3 12 2016
1/12/2017 First Ameri D.E. 40 Opposition of Rents, Jan. 12,
4
Doc 53 FAB Verified Petition
2/14/2017 First Ameri D.E. 53 2017
Appointment Receivership
5 5/26/2017 First Ameri D.E. 110 Doc 110 Ex. 8
6 5/26/2017 First Ameri D.E. 110 Doc 110 Ex. 25
7 5/26/2017 First Ameri D.E. 110 Doc 110 Ex. 28
8 6/8/2017 First Ameri Email String Schneider and K & B
9 10/25/2017 First Ameri D.E. 200 Shelya
Doc 200Mesa
Ex. 6
10 10/25/2017 First Ameri D.E. 200 Doc 200 Ex. 28
11 First Ameri D.E. 269 Doc 269 Ex. 11
2017-05-01 Schneider
Docs v First
Produced by
13 5/1/2017 American Bank Doc 1 Exhibit
First American Bank v Schneiders (Bates-00096-00097)F
2017-05-01 Docs Produced by
14 5/1/2017 First American Bank v FCRA Ltr 11.30.15
Schneiders (Bates-00154-00155)
15 FCRA Ltr 11.30.15
Schneider v First American Bank
16 Doc 1 Complaint
Schneider Exhibit F, Bank
v First American June 13,
2017
Doc
17 Doc 26
356Amended Complaint
Ex. 8c Schneider Exhibit
v First
F, Aug. 21,Bank
American 2017Doc 26 Amended
Complaint Exhibit F, Aug. 21, 2017
Qualified Written Request (“QWR”) sent Written
Qualified by GarryRequest
Smith May 26, 2017
(“QWR”)
Schneidersent by 17-80728
v FAB Garry Smith
May 26,
Complaint2017
Schneider vDoc
FAB1-2 Ex. H
17-80728
Complaint,
Amended June 13,
Complaint 2017
Doc 26-5
Doc 259 Ex. 11 Schneider v FAB
Ex.
17-80728 Doc 1-2 Ex. H21, 2017
H Complaint, Aug.
Complaint,
Doc 356 Ex. Aug. 21, 2017v FAB
8c Schneider
17-80728 Amended Complaint Doc
26-5 Ex. H Complaint, Aug. 21,
Letter From FAB S.V.P. Garry Smith
2017 to Schneider July 7, 2016
7/7/2016 Original
Doc 11 Exhibit D Petition for
Appointment of Receivership
Doc 108 Exhibit E Plaintiff's Motion
for Summary Judgement
Doc 108 Exhibit 9 Plaintiff's Motion
for Summary Judgement
Doc 110 Exhibit 13 Plaintiff's Trial
10/25/2017 Exhibit
Doc 200List
Exhibit 11 Plaintiff's
5/1/2017 Exhibits for Evidenary Hearing
Schneiders (Bates-00071) Letter
Supercedes
From Smith Bond
To Schneider July2 7,
Motion for Sanctions Exhibit -
2016
Schneiders (Bates-00071) Letter
From Smith To Schneider July 7,
2016
Letter From FAB S.V.P. Garry Smith to Schneider May 27, 2015
Original Letter
2017-05-01 DocsFrom FAB S.V.P.
Produced by
5/1/2017 Garry
Schneiders (Bates-00249)May
Smith to Schneider May27,
2015
27, 2015 Leter From Garry Smith
MFS Exhibit 5 - May 25, 2017 9:53 AM re. MSJPlease let me know by noon.
MFS Exhibit 6 - May 26, 2017 11:12 AM I am unavailable from between June 2, 2017 and July 5,
MFS Exhibit 7 - May 26, 2017 12:53 AM Your advices that you are “unavailable from between Jun
MFS Exhibit 8 - May 26, 2017, 9:53AM, 11:12AM 12:53 PM
MFS Exhibit 8 FedEx May 26, 2017-Would not be received before May 27, 2017 (Saturday) May 27, 20
MFS Exhibit 9 FedEx Delivery May 30, 2017
MFS Exhibit 10 - Email from Bolz to Scheider sA review of First American's Motion for Summary Judgm
demonstrate that there is no genuine issue of material fac
entitled to judgment as a matter of law. The Schneiders h
the Note and/or Mortgage and that they defaulted under t
by: (i) failing to pay the monthly interest payment due on
payments, (ii) failing to pay the entire balance owing in a
28, 2016 and (iii) failing to pay the Florida Ad Valorem
(which is the subject of this foreclosure) for 2014, 2015 a
MFS Exhibit 11-Service of Court Documents JunBTantillo@walkerdimarcopc.com on email. Can anyon
Why would there be a Special Set Hearing for 30 Minute
10/18/2018 Garry S. Sm
https://www.scribd.com/document/465581516/Payoff-Letter-From-FAB-Garry-S-Smith-Oct-1
with Alden.
d Jan. 9, 2017 appraisal to FAB on Jan. 13, 2017.
ring as the only intent of filing the motion was to create an appearance of Schneider not being cooperative and was one of many motion for inspections an
went out there in January, the power was off. We found the property to be, in general, not in good array and order. We've got a motion to appoint receiver
being rented?
n June 2, 2017 and July 5, 2017.Confirm receipt of First request For Production April 24, 2017
vailable from between June 26, 2017 and July 5, 2017” precludes our ability to set the Motion for Summary Judgment down for hearing on June 26, 2017
17 (Saturday) May 27, 2017 Sunday, May 29, 2017 (Monday-Memorial Day)
history, which is
f many motion for inspections and hearings on motions for inspections, when Schneider had been accomodating.
e got a motion to appoint receiver scheduled for an evidentiary hearing on Tuesday and --
own for hearing on June 26, 2017. We will pursue alternate dates for the hearing.
6/26/2017 Doc 126, Final Judgement (Sale Aug. 10, 2017) June 26, 2017
6/27/2017 Doc 125 Final Judgement, June 27, 2017
7/6/2017 Doc 130 Amended Final Judgement-LS, July 6, 2017
7/11/2017 Doc 131 Motion For Rehearing, July 11, 2017
7/18/2017 Doc 144 Not. of Corrected Exhibits-JUdgements, July 18, 2017
7/18/2017 D.E. 144 N.O.F. Corrected Exhibits-Judgements, July 18, 2017
7/18/2017 Doc 135 Order Granting MSJ Refiled, July 18, 2017
7/18/2017 Doc 138 Ord. Den. Mot. Vacate Judgement-Lubits, July 18, 2017
7/21/2017 Doc 152 Notice Scrivners Error, July 21, 2017
10/12/2018 D.E. 225 Amended Final Judgement of Foreclosure, Oct. 12, 2018
2/26/2020 D.E. 384 Amended Final Judgement Feb. 26, 2020
6/3/2020 Doc 444 Motion Reset Sale, June 3, 2020
Laurence Schneider, USA, The States of California, Delaware, Georgia, Hawaii, Illinois, Indiana, Iowa, Massachusetts, Minnesot
U.S. District Court District of South Carolina (Columbia) CIVIL DOCKET FOR CASE #: 3:13-cv-01223-JFA
Laurence Schneider, USA, The States of California, Delaware, Georgia, Hawaii, Illinois, Indiana, Iowa, Massachusetts, Minnesot
U.S. District Court District of South Carolina (Columbia) CIVIL DOCKET FOR CASE #: 3:13-cv-01223-JFA
-00044 -JDW-AEP
a, Iowa, Massachusetts, Minnesota, Montana, Nevada, New Jersey, New Mexico, New York, North Carolina, Rhode Island, Tennessee, Virginia, and the
-cv-01223-JFA
a, Iowa, Massachusetts, Minnesota, Montana, Nevada, New Jersey, New Mexico, New York, North Carolina, Rhode Island, Tennessee, Virginia, and the
-cv-01223-JFA
SE #: 9:17-cv-80723-DM M
Number: 4D17-2239
and, Tennessee, Virginia, and the District of Columbia ex rel v JP Morgan Chase Bank National Association et sl
and, Tennessee, Virginia, and the District of Columbia ex rel v JP Morgan Chase Bank National Association et sl
Aug. 9, 2016 7.15PM Email Schneider To Hagan re. FCA and Add'l Harms,
June 1, 2015-10.58.PM Email Schneider To Kielbasa re. No Receipt of June 1, 2015 HELOC Billing,
June 1, 2016 10.44PM Email From Schneider To Hagan, Re. Tenant Status,
Jan. 19, 2016-8.13PM Email Schneider To Hagan re. Jan 18, 2016-Bond People
July 5, 2016-9.50AM Email Schneider To Trent re. Executed Engagement MRS-S&A-1st Fid v JPMC,
Sanctions
March 8, 2017-3.47PM Email Trent To Schneider re. Interragatories, RFP's-Amd Def or CC,,
March 6, 2017-5.37 PM Email Trent To Schneider, Tantillo & Cruz re. Amended Ans. & C.C.,
Steff Deed
March 16., 2017-11.11 AM-Email From Cruz To Trent re. Discovery,
Oct. 18, 2018-10.35AM Email Bolz To Gheston w. Payoff $2,350,694.40, as of