Case 9:17-cv-80728-DMM Document 29 Entered on FLSD Docket 08/31/2017 Page 1 of 3

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
Case No.: 17-80728-MIDDLEBROOKS/BRANNON

LAURENCE SCHNEIDER,

Plaintiff,

vs.

FIRST AMERICAN BANK, as successor

by merger to Bank of Coral Gables, LLC

Defendant.
_________/

PLAINTIFF’S NOTICE OF COMPLIANCE WITH

INITIAL RULE 26(A)(1) DISCLOSURES

Plaintiff LAURENCE SCHNEIDER (“Schneider”), in accordance with Fed. R. Civ. P.

26(a)(10, gives Notice of his Compliance with this Rule. Pursuant to this Rule, Schneider is

providing Defendant FIRST AMERICAN BANK (“FAB”) with this notice, his initial disclosures

of each individual known or currently believed to have discoverable information, and those

documents within Schneider’s custody, possession or control and which Schneider may use to

support his claims:

Disclosure of Individuals

Schneider discloses the following individuals who are known, or are believed to have,

knowledge regarding Schneider’s claims:

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1. Laurence Schneider

2. Stephanie Schneider

3. Kenneth Trent-Laurence Schneider’s former counsel

4. Henry Bolz-FAB’s counsel

5. James Kielbasa-FAB

6. Jennifer Anderson-FAB

7. Milton Espinoza-FAB

8. Brian Hagan-FAB

Disclosure of Documents

The First Amended Complaint filed by Schneider, with accompanying exhibits, will be

used by Schneider to support his claims. Bates-labeled copies of correspondence between

Schneider and FAB not otherwise attached as exhibits to the First Amended Complaint will be

provided to FAB.

Computation of Damages

Schneider estimates that the case is valued at approximately $1.5 million.

Dated: August 31, 2017

By: /s/ Brent S. Tantillo

Brent S. Tantillo
btantillo@tantillolaw.com
TANTILLO LAW PLLC
1629 K Street, NW, Suite 300
Washington, DC 20006
Telephone: (786) 506-2991
(pro hac vice)

and

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Manjit Singh Gill

mgill@tantillolaw.com
6810 N. State Road 7, Suite 300
Coconut Creek, FL 33073
Telephone: (954) 617-8188
Fax: (954) 246-5662

Attorneys for Plaintiff

CERTIFICATE OF SERVICE

I hereby certify that on this 31st day of August, 2017, I electronically filed the foregoing

document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document

was delivered to the addressee below via transmission of Notice of Electronic Filing generated by

CM/ECF.

Henry H. Bolz, III

KELLER & BOLZ, LLP
Attorneys for First American Bank
121 Majorca Avenue, #200
Coral Gables, FL 33134
Telephone: (305) 529-8500
Telefax: (305) 529-0228
Email: hbolz@kellerbolz@com; ahart@kellerbolz@com

/s/ Manjit S. Gill

Manjit S. Gill
Florida Bar No. 0189601