Case 9:17-cv-80728-DMM Document 30 Entered on FLSD Docket 09/01/2017 Page 1 of 3

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

CASE NO. 17-cv-80728 MIDDLEBROOKS/BRANNON

LAURENCE S. SCHNEIDER,

Plaintiff,

v.

FIRST AMERICAN BANK, as

Successor by merger to Bank of
Coral Gables, LLC,

Defendant.
/

DEFENDANT’S NOTICE OF COMPLIANCE

WITH RULE 26(a)(1) INITIAL DISCLOSURES

COMES NOW the Defendant, FIRST AMERICAN BANK (hereinafter “FAB”), by

and through its undersigned attorneys, and in accordance with Fed. R. Civ. P. 26(a)(1),

hereby files this its Initial Disclosures and states as follows:

I. Individuals Likely to Have Discoverable Information

1. Laurence Schneider.

2. Stephanie Schneider.

3. Brian Hagan/FAB.

4. Garry Smith/FAB.

5. Any individuals disclosed by the Plaintiff in his Initial Disclosures.

6. Any individuals disclosed by future pleadings, discovery or documents.

Case 9:17-cv-80728-DMM Document 30 Entered on FLSD Docket 09/01/2017 Page 2 of 3

II. Description of Documents

Likely to Have Discoverable Information

FAB does not believe that Laurence Schneider has asserted any claim upon which

relief can be granted nor does FAB believe that Laurence Schneider will be able to assert

any cause of action upon which relief can be granted. Accordingly, at this point in time,

because FAB has no idea whether or not any viable cause(s) of action might ultimately

be plead, FAB has no idea what documents might contain discoverable evidence.

III. Computation of Damages

FAB does not believe that any of the inchoate claims or allegations made by

Laurence Schneider in his First Amended Complaint have any value.

Respectfully submitted,

KELLER & BOLZ, LLP

Attorneys for
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

2
Case 9:17-cv-80728-DMM Document 30 Entered on FLSD Docket 09/01/2017 Page 3 of 3

CERTIFICATE OF SERVICE

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

Compliance was delivered to the addressee below via transmission of Notices of

Electronic Filing generated by CM/ECF on this 1st day of September, 2017:

BRENT TANTILLO, ESQ.

Tantillo Law PLLC
Counsel for Laurence Schneider
1629 K Street, NW, Suite 300
Washington DC 20006
Email: btantillo@tantillolaw.com

MANJIT SINGH GILL, ESQ.

Counsel for Laurence Schneider
6810 N. State Road 7, Suite 300
Coconut Creek, FL 33073
Email: manjit.gillesq@gmail.com

KELLER & BOLZ, LLP

By: s/Henry H. Bolz, III

Henry H. Bolz, III