Larry Schneider

From: Larry Schneider

Sent: Thursday, June 08, 2017 4:45 PM
To: Henry Bolz
Subject: 2nd Motion FOr Receivership
Attachments: Notice Of Filing - Molestina Affidavit and March 28, 2017 Receivership H....pdf; Email
From Bolz To Trent re. 2nd Inspection, March 9, 2017.pdf; Invoice Green Island
Maintenance-Oaks, March 3, 2017.pdf

Mr.Bolz,

InreviewingthecutandpastepatchworkofthefewcommunicationswhichMr.Trentactuallysenttome,thereisan
emailfromBolztoTrent,whichhehadforwardedtome.Inthatemail,youclaim

“Atthispointintime,weareintendingtocallMr.MolestinaasawitnessattheMarch28,2017hearing…(for2nd
receivershiphearing).”

IammeetingwithattorneyswiththeFloridaBartomorrowandneedtoknowifyouhadprovidedhimnewinformation,
whichcontradictsyourintenttocallMr.Molestinatojustifyyournecessityforareceivershiponawellmaintainedand
unoccupiedhouse.ItisimportantthatIknow,asthewholethingwasatotalsetup.Mr.TrenttoldmethatIneedtobe
atthehearing.Thus,theonlyreasonIattendedthehearing,alongwithmylandscaperSergioLemus,wastorefutethe
knowinglyfalseandorfraudulentaffidavitMr.Molestinasignedandinwhichyourelieduponinyourunnecessary
motionforasecondreceivership.Iunderstandtheunethicalreasoningyouhad,byspecificallynothavingMr.
Molestinaappear,ashewouldbelikelybeperjuringhimself.

Furthermore,youfoundthemotionforreceivershipsoimportant,thatyouweresuretohireacourtreporterto
documenttheeventswhichwouldunfold.ThoseeventswouldbeyouradvancedknowledgethatIwasaskedtoappear
andthatyouintendedtoextracttestimonywhichisthebasisforyourmotionforsummaryjudgment.Iunderstand
whatyoudid,IjustwanttoknowifMr.Trentknewsomethinganddidnottellme,besidesnotproperlyrepresenting
me.Ifyouhaveacommunication,inwhichyousenttoMr.Trent,whichinformshimofyourintentnottocallMr.
Molestina,itwouldbeveryhelpfulinmymeetingwiththeFloridaBartomorrow.Iknowthatyou’vecontinuously
refusedtoprovidemeanycommunications,exceptthosewhichbenefityouinfindingjustificationforyourunrelenting
filings,however,ifacommunicationdoesexist,IamabletoplacefurtherblameonMr.Trentwhodidnotoppose.He
alsodidnottellmehewaswithdrawingfromthecaseuntillateAprilandinwhichIwasnotmadeawareoftheMay1,
2017hearingonthemotiontograntMr.Trent’swithdrawalfromrepresentation.untilreceivingyouremailonMay1,
2017.

Yourassistanceisgreatlyappreciated.

Sincerely,


LarrySchneider
S&ACapitalPartners
1stFidelityLoan
MortgageResolution
305Ͳ710Ͳ4201
larry@sacapitalpartners.com


1
Filing # 52905246 E-Filed 02/23/2017 03:45:47 PM

IN THE CIRCUIT COURT OF

THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA

CASE NO.: 502016-CA-009292

DIVISION AW

FIRST AMERICAN BANK, as

successor by merger to Bank of
Coral Gables, LLC,

Plaintiff,

v.

LAURENCE S. SCHNEIDER,
STEPHANIE L. SCHNEIDER,
JEFFREY MARC HERMAN,
UNKNOWN TENANT #1, UNKNOWN
TENANT #2 and THE
OAKS AT BOCA RATON PROPERTY
OWNERS’ ASSOCIATION, INC.,

Defendants.
/

NOTICE OF FILING
AFFIDAVIT

COMES NOW the Plaintiff, FIRST AMERICAN BANK, by and through its

undersigned counsel, and in accordance with the applicable Florida Rules of Civil

Procedure, hereby gives notice to the Court and all counsel of the filing of the Affidavit of

Carlos Molestina in support of Plaintiff’s Renewed Verified Petition for Appointment of

Receiver which is scheduled be to heard before this Court on March 28, 2017 at 1:00

o’clock p.m.
 Respectfully submitted,

KELLER & BOLZ, LLP

Attorneys for Plaintiff
121 Majorca Avenue, #200
Coral Gables, FL 33134
Telephone: (305) 529-8500
Telefax: (305) 529-0228
Email: hbolz@kellerbolz.com

By: s/Henry H. Bolz, III

Henry H. Bolz, III
Florida Bar No. 260071

CERTIFICATE OF SERVICE

WE HEREBY CERTIFY that a true and correct copy of the foregoing Notice of

Filing Affidavit was delivered to: KENNETH ERIC TRENT, ESQ.

(trentlawoffice@yahoo.com), Trent Law Office, Attorneys for Laurence and Stephanie

Schneider, 831 East Oakland Park Blvd., Fort Lauderdale, FL 33334; STUART S.

MERMELSTEIN, ESQ. (smermelstein@hermanlaw.com, mconnor@hermanlaw.com),

Herman Law, Attorneys for Jeffrey Herman, 3351 NW Boca Raton Blvd., Boca Raton, FL

33431; and JAY S. LEVIN, ESQ. (foreclosures@ssclawfirm.com), Sachs, Sax, Caplan,

Attorneys for Oaks at Boca Raton, 6111 Broken Sound Parkway, N.W., #200, Boca

Raton, FL 33487 via the E-filing Portal on this 23rd day of February, 2017.

KELLER & BOLZ, LLP

By: s/Henry H. Bolz, III

Henry H. Bolz, III

2
Larry Schneider

From: Kenneth Eric Trent, P.A. <trentlawoffice@yahoo.com>

Sent: Thursday, March 09, 2017 11:49 AM
To: Larry Schneider; Brent Tantillo
Subject: Fw: First American Bank v. Schneider
Attachments: 2017-02-23 N-of Filing Aff.pdf

Kenneth Eric Trent, P.A.

831 E. Oakland Park Blvd.
Ft. Lauderdale, FL 33334
(954) 567-5877-phone
(954) 567-5872 fax
trentlawoffice@yahoo.com
www.foreclosuredestroyer.com

----- Forwarded Message -----

From: Henry Bolz <hbolz@kellerbolz.com>
To: "Kenneth Trent Esq. (trentlawoffice@yahoo.com)" <trentlawoffice@yahoo.com>
Sent: Thursday, March 9, 2017 9:36 AM
Subject: First American Bank v. Schneider

Attorney Trent,

Carlos Molestina is First American Bank’s Brokers Sales Manager. His January 19, 2017 inspection
of the Schneider’s residence at 17685 Circle Pond Road was informal.

His hand-written notes and communications with me constitute either work product or attorney-client
privilege and will not be produced. Carlos Molestina’s Affidavit dated February 23, 2016 which we
filed with the Court on that same date (you were provided with a copy), constitutes his inspection
report. In an abundance of caution, our Notice of Filing, his Affidavit (and his photographs) are
attached for your ease of reference.

At this point in time, we are intending to call Mr. Molestina as a witness at the March 28, 2017
hearing. In order for Mr. Molestina’s testimony to be meaningful, it will be necessary for him to revisit
the property. Again, can you provide us with a time and date between Monday, March 20, 2017, and
Thursday, March 23, 2017 when Mr. Molestina can revisit the residence?
Regards,

Henry H. Bolz, III

Keller & Bolz, LLP
121 Majorca Avenue, #200
Coral Gables, FL 33134
Telephone: (305) 529-8500
Telefax: (305) 529-0228
E-mail: hbolz@kellerbolz.com
1
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