Filing# 91178973 E-Filed 06/17/2019 10:39:34 AM

IN THE CIRCUIT COURT OF

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

CASE NO.: 502016-CA-009292

DIVISION AH

FIRST AMERICAN BANK, as

successor by merger to Bank of
Coral Gables, LLC,

Plaintiff,

V.

LAURENCE S. SCHNEIDER,
STEPHANIE L. SCHNEIDER, et al.,

____________
Defendants.
____,;/

PLAINTIFF'S, . ICAN BANK,

NOTICE O DESIGNATION

Plaintiff, by and through its undersigned counsel,

SCHNEIDER and STEPHA I . SCHNEIDER, introduce any portion of the Deposition

Transcript of Frederic Snow into evidence, and the Court admits said portions into

ereby requests that the entire Deposition Transcript of Frederick M.

FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 06/17/2019 10:39:34 AM
 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: jkeller@kellerbolz.co~

By: s/ John W. Ke/let: Ill

Florida tJ·
John W. Keller, II
229989

(andy@wymanlegalsolutions.com), Wyma lutions, 955 NW 17th Avenue, Suite

C, Delray Beach, FL - · CHARLES F. RODMAN, ESQ.

(chuck.rodman@rodmanemplo · entlaw.com), Rodman Employment Law, 181 Wells

Avenue, #201, Newton, Mr o2 q ; ALEKSANDRA NOVAKOVICH GONZALEZ, ESQ.

(foreclosures@sscla irm.com), Sachs, Sax, Caplan, Attorneys for Oaks at Boca Raton,

6111 Broken S Qr.id Pa kway, N.W., #200, Boca Raton, FL 33487; and GEOFFREY M.

CAHEN, E8Cl. (ge,off@cahenlaw.com), Cahen Law, P.A., 1900 Glades Road, Suite 270,

Boca · ~r 33431 via the E-filing Portal on this 17th day of June, 2019.

KELLER & BOLZ, LLP

By: s/ John W. Keller, Ill

John W. Keller, Ill
 Frederick Snow
March 19, 2019

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN

AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 50-2016-CA-009292
Division AH

~
FIRST AMERICAN BANK, as
Successor by merger to Bank of
Coral Gables, LLC,

vs.
Plaintiff,

~~
&
LAURENCE S. SCHNEIDER,
STEPHANIE L. SCHNEIDER, et. al, v
....

Defendants. ~
------------------------- ~ - -----------/

OF

ICK M. SNOW

G day, March 19, 2019

~ ....... 1 0:17 a.m. - 11:29 a.m.

~~ i 19
~o 190 0 N.W. Corporate Boulevard

Boca Raton, Florida 33431

Stenographically Reported By:

Lucy M. Lupo, RPR, FPR
Registered Professional Reporter
Florida Professional Reporter

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 Frederick Snow
March 19, 2019 2 to 5
Page 2 Page 4
1 APPEARANCES: 1 Deposition taken before Lucy M. Lupo,
2 On Behalf of the Plaintiff:
KELLER & BOLZ, LLP
2 Registered Professional Reporter, Florida Professional
3 121 Majorca Avenue 3 Reporter and Notary Public in and for the State of
Suite 200 4 Florida at Large, in the above cause.
4 Coral Gables, Florida 33134
BY: JOHN W. KELLER, III, ESQUIRE 5 *****
5 6 THE COURT REPORTER: Do you swear or affirm
6
7 that the testimony you're about to give will be the
7 On Behalf of the Plaintiff:
COZEN & O'CONNOR 8 truth, the whole truth, and nothing but the truth?
One North Clematis Street 9 THE WITNESS: I do, yes.
Suite 510
10 Thereupon, ~
West Palm Beach, Florida 33401
BY: SIMEON D. BRIER, ESQUIRE 11 FREDERICK M. SNOW, havin')'J)..,S first duly sworn
10 12 or affirmed, was examined and testifiedr ollows:
11
13 DIRECT EXl\MI ATION
12 On Behalf of the Defendants:
WYMAN LEGAL SOLUTIONS 14 BY MR. WYMAN:
13 955 NW 17th Avenue 15 Q.
Suite C
14 Delray Beach, Florida 33445
16 A.
BY: ANDREW WYMAN, ESQUIRE 17 Q. State your ~ l name for the record.
15 18 A. Frederk U errison Snow.
16
17
19 M~ · now, who is your present employer?
18 ALSO PRESENT: 20 ~{ American Bank.
19 Laurence S. Schneider
Md how long have you been employed by them?
20
21 I've been with First American Bank since 2006,
22
23
And you're an attorney; is that correct?
24
25 A. Yes.

~ gy 3 Page 5
1 INDEX OF PROCEEDIN
~ Y 1 Q. What's your title with the bank?
2 Deposition of FREDERICK M. SNOW: PAGE
2 A. Executive vice president and general counsel.
3
C cecc e,o•ceaccoe o, ec. ( ~ 0 3 Q. How long have you held the general counsel
4 position?
5
5 A. The entire time.
6 Certificate of Oath 33
6 Q. And the executive vice president, as well?
Certificate of Reporter 34

7 Witness Notification 35
7 A. Well, when I started I was a senior vice
Errata Sheet 36
8 president, and then I was promoted executive vice
8 9 president probably ten years ago.
9 10 Q. Okay. What are your job duties as the, I
10 DEFENDANTS' EXHIBITS 11 guess, executive vice president? And then we'll ask
PAGE 12 about general counsel.
Invoice payments 22 13 A. Yes. For the bank and its holding company, I
14 am the -- I manage the legal and compliance functions.
15 Q. Okay. What's your professional address? Where
15
16 is your office?
16
17 A. 1650 Louis Avenue, Elk Grove Village, Illinois.
17
18 Q. And at what point did you become involved with
18
19
19 this collections matter?
20
20 A. I'd say approximately two years, two to three
21 21 years ago.
22 22 Q. Okay. And would that have been after suit was
23 23 filed or leading up to the suit?
24 24 A. I believe it was before the lawsuit was filed.
25 25 Q. Okay.

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 Frederick Snow
March 19, 2019 6 to 9
Page 6 Page 8
1 A. One of the bankers contacted me concerning the 1 leased. And it isn't -- it's infrequent that a one- to
2 matter. 2 four-unit residence would be commercial property.
3 Q. Okay. So, then, you weren't involved in this 3 I'll expand on that on one level. A one to
4 loan during the time it was performing; is that correct? 4 four residential property is a type of property that
5 A. Well, if it was performing, it was at the tail 5 lenders typically can package if they wanted to and sell.
6 end of performing, let me put it that way. 6 So it's known in the banking industry as one and four.
7 Q. Okay. 7 So if you had a four-flat in the city, it's
8 A. Yeah. 8 typical that the owner would occupy one unit and maybe
9 Q. And were you involved in the decision as to the 9 lease the others. But a single-family home, it's not
10 selection of outside counsel for this collections matter? 10 that corrrnon. 1
11 A. As I recall, I was. 11 Q. Okay. Now, this is a loah tli twas originated
12 Q. Okay. What went into your decision to utilize 12 by Bank of Coral Gables;
13 Keller &Bolz as the collections attorneys on this 13 A. Yes.
14 matter? 14 Q.

15 MR. KELLER: Object to form. 15 Gables;

16 THE WITNESS: My selection of Keller & Bolz was 16 A. Yes.
17 based on using them in other matters since, I'm going 17 Q. In ap year?
18 to say, approximately 2004, 2005, and, so, there were 18 A. I'm g 2015, 2016.
19 several factors. 19 Q , So, then, is this the -- was this not
20 One is the quality of their work, I would say 20 .l · t , e of loan that First American Bank would
21 the attractive billing rates, especially based on . Ming, that you had mentioned it's a residence,
22 their long experience, and the integrity of the i ' commercial.
23 lawyers with the firm. A. Yeah. No, it's not unusual for the bank.
24 BY MR. WYMAN: Q. Okay.
25 Q. Had you looked at or considered any law A. Well, most residences are owner-occupied.

Page 9
1 in Palm Beach County for pursuing this c~l ec ions 1 That's what I meant. There are certainly some that are
2 matter? 2 corrrnercial.
3 A. No. 3 Q. Okay.
4 The loan was made · am1 a ounty. That's 4 (Mr. Schneider entered the room.)
5 where the bank is located. 5 MR. KELLER: Let the record reflect that the
6 Q. for 6 defendant, Mr. Schneider, has arrived, please.
7 7 MR. WYMAN: This is Laurence Schneider.
8 County? 8 THE WITNESS: Good morning.
A. , . 9 MR. WYMAN: Good morning, Larry.
10 Q. (Ila e ~ at all engaged counsel in Palm Beach 10 BY MR. WYMAN:
11 Cou1 y-;;f o coll)-c-t'ions purposes in the last three years? 11 Q. Other than the fact that this was not an
12 \ ~ ~g. It's possible that there's a firm that 12 owner-occupied residence, was there anything else you
13 ~ 've sedf that is in -- Fort Lauderdale might have an 13 considered to be unusual or unique about this loan prior
~1~ 0ffic.i;.It's possible. I just don't know. 14 to the collections process starting?
15 y Q. Understood. 15 A. No.
16 A. I work a lot in Southern Wisconsin and Northern 16 Q. Okay.
17 Illinois, and when I -- as my practice, we travel to 17 A. There's one aspect that is different in the --
18 various counties. Very seldom do I look at counsel just 18 not different from other properties in Florida. But in
19 because they happen to be next to the courthouse. 19 Florida, there is an aspect that the homes and buildings,
20 Q. Okay. From your perspective, was there 20 it's important that they be air-conditioned, or you have
21 anything unique or unusual about this loan or the 21 mold problems. And in Illinois and Wisconsin, we
22 collections file prior to the lawsuit being filed? 22 typically don't see that.
23 A. Yes. 23 That would be the only thing I can think of
24 Q. And what would that have been? 24 where the collateral would be different.
25 A. It was commercial property because it was 25 Q. Okay. So how is that pertinent to this

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 Frederick Snow
March 19, 2019 10 to 13
Page 10 Page 12
1 particular property? 1 A. Well, see, I would say that, in my experience,
2 A. It's pertinent because in the course of the 2 if we ask for a receiver and the judge gives us the rents
3 litigation, the property was occupied by a tenant. And 3 and the ability to inspect the property, that would mean
4 in the course of it, I came to understand that 4 we prevailed. That's how I would view it.
5 Mr. Schneider had terminated the tenancy. 5 Q. Okay. But you are aware that the motions
6 And so my concern was that if the electricity 6 themselves were denied by the court to have a receiver
7 was shut off and the air conditioning wasn't functioning, 7 appointed.
8 the collateral could diminish in value. 8 A. I'm not aware because of the order we got. I
9 Q. Okay. What caused that concern? Was it just 9 would submit that we prevailed in what was important,
10 speculation that the air conditioning wouldn't have been 10
11 on? Or did you have actual information that you 11 collection of the rent.
12 obtained? 12 Q. Okay. Was a receive:r;..-ever ap ir:rted?
13 A. It was reported that the electricity wasn't on. 13 A. No, because we gQ - ~ e jud(eprevailed on
14 Q. Reported by whom? 14 our motion by giving ~ l:ian~ - i other words, the key
15 A. I don't know. I don't remember. 15 to the receivership is1 to ~ \e rent and apply it, and
16 Q. Okay. But at some point you were told this 16 to have a responsi~ i ~e sure the electricity is
17 information that the electricity at the house was not on? 17 on and that the propert is being maintained. That's the
18 A. Yes. 18 essence.
19 Q. I think you said that the tenant -- that 19 her it's through a receivership or the
20 Mr. Schneider had terminated the tenancy. 20 be rent directly and having somebody
21 A. Yeah. 21 roperty with access, you know, it's not very
22 Q. But sometime after the lawsuit had been filed. d1f eren, from my perspective. So I would say it was --
23 A. I think so, yeah. 3 m view, it was not denied. It was changed, amended.
24 Q. Okay. What was the purpose, ' Q. Okay. And so there was a determination that
25 receiver with the complaint? the bank was allowed to do inspections of the property,

Page 13
1 A. Well, that was the purpose, to 1 correct?
2 were actually two purposes. One is.Apreserve ttie A. Yes.
3 collateral. And as I understand,l!. ~t;qhe en ,that was Q. Do you know if they -- were inspections done?
4 being charged was in excess of4he1 ost maintain the Do you know how many or how frequently?
5 property and the interest om the loj , so that part of A. No, I can't tell you how frequently.
6 the rent could have been use~ y down principal. I have a lot on my plate, so things come --
7 Q. Fair enough. Just what you remember.
8 and reducing the pri the loan. A. And I hear that the property was inspected.
9 Q. Oka~ So - was a motion that had been I know that there was one issue because it was
10 filed rel~ n ~ the rent payments to have them a gated community, so there had to be some coordination.
11 to rM~ ank, separate from the appointment of I was aware of that.
12 ; ·s that your understanding? Q. Okay. And were there appraisals of the
13 o. property done, as well, during the course of the
;-1 kay. Are you aware that the bank obtained an 14 litigation?
15 r -er to receive the rent payments? 15 A. I don't know. I don't recall one.
16 A. Yes. 16 Q. Okay. So from the bank's perspective, they
17 Q. Okay. 17 considered this a commercial loan.
18 A. That was -- we had, as I recall, filed a motion 18 A. Yes.
19 for receiver, and the judge gave us the assignment of the 19 Q. And the loan amount was a million and a half,
20 rents and the right to inspect, which was acceptable to 20 correct, ultimately?
21 the bank -- 21 A. That would be an approximate.
22 Q. But otherwise -- 22 Q. Approximate. Okay.
23 A. -- at that point in time. 23 A. It could be above or below that.
24 Q. Okay. But it otherwise denied the motion for 24 Q. Is that considered a large loan, by First
25 the receiver twice. 25 American Bank's standards?

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 Frederick Snow
March 19, 2019 14 to 17
Page 14 Page 16
A. A lot of loans are much bigger now, a lot of 1 Q. Okay. Were either of those gentlemen with the
2 loans are much smaller. 2 Bank of Coral Gables when FAB acquired them?
3 Q. As far as commercial loans go? 3 A. No.
4 A. Whether they're residential or commercial, that 4 Q. And a Mr. Jergenson (phonetic) . Do you know
5 would be a larger than average residential loan. But a 5 who that might reference?
6 small commercial loan or medium-sized commercial loan? 6 A. No.
7 I mean, we have a lot of residential and 7 Q. Thomas Wells?
8 commercial loans that would be -- well, commercial loans 8 A. Yes. He's the chairman and chief executive
9 that would be tens of thousands or hundreds of thousands. 9 officer of First American Bank.
10 Q. A couple of names I've seen in some of the 10 Q. I saw at least eight or nin~ instances where
11 billing records that I want to ask you about -- 11 his name shows up in the billing ~r~ from Keller &
12 A. Yes. 12 Bolz, where he had been involved in comri~~;i,cations,
13 Q. -- who these people are. 13 conversations. It looked li .e m stly pifone calls.
14 Who is Gary Smith? 14 A. Yes.
15 A. Gary Smith is a manager who typically works in 15 Q. Is that unusual that t ne chairman and CEO of
16 residential real estate for our bank. 16 the bank would be~ o\ veo in a collections matter such
17 Q. And was that his role at that time when -- or 17 as this one? ( )
18 at the time that the loan went to collections, was 18 A. No. '-1
19 Mr. Smith -- he was generally residential real estate 19
20 loans? 20
21 A. Generally residential. 21 y, wealth management and commercial. And
22 I can't tell you his exact title. He was a To~9'i s oversees several apartments including
23 senior manager. 3 re.siflential real estate. So he would be involved in --
24 Q. Okay. So even though this was, what you'r ' e would tend to be involved in collections that were
25 telling me, a commercial loan, it was being handl like this one- to four-unit residences.

Page 17
1 residential loan officer? Is he a l n ,· fi r Q. Okay. So does he also oversee commercial real
2 fair? 2 estate loans?
3 A. Yes. Yes. 3 A. No. That is another banker.
4 And the reason is, 4 Q. Okay.
5 one-four-unit residence. 5 A. We're a very flat organization. We don't have
6 Q. Sure. So the comme dential 6 a lot of levels of management. And I would say the
7 distinction is a li~ blurry in this instance? 7 senior managers of the bank are probably about eight
8 A. Yes, a litt~ bi t 8 people. And we communicate almost daily with each other
9 Q. Oka . Who i yBrian Hagen (phonetic), if you 9 on various things.
10 10 Q. Okay.
11 11 A. Yeah.
12 . o is that? 12 Q. Understanding that he oversees residential real
13 rian Hagen runs our commercial banking 13 estate, is it unusual, though, that he would actually get
~1 1v1s_;i,on in Coral Gables. 14 on the phone and be involved in phone calls with counsel
15 Q. Who was responsible for overseeing this loan? 15 on the ground, so to speak, as opposed to just receiving
16 Was it Mr. Smith? 16 reports and having people that work for him report up to
17 A. As I recall, it was Brian Hagen. And then, I 17 him?
18 believe, Brian asked Mr. Smith to oversee it. 18 A. No, it's not unusual.
19 Q. Okay. So Mr. Hagen, was he a manager of 19 He certainly knows Mr. Keller. And he's a
20 Mr. Smith's? 20 great guy to work for because he's always looking to take
21 A. No, not a direct manager. He would be more 21 work off my desk instead of the other way around.
22 senior. 22 Q. Right.
23 Q. Okay. 23 A. So he's -- maybe almost surprising for a
24 A. So Brian Hagen, I would say, is a senior 24 chairman, he will perform activities that he might expect
25 commercial banker for the bank. 25 me to do or somebody on my staff to do.

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 Frederick Snow
March 19, 2019 18 to 21
Page 18 Page 20
1 Q. So, then, the property and the loan is being 1 bank.
2 overseen by a residential real estate loan officer, and 2 Q.Right. Okay.
3 then, ultimately, being overseen by Mr. Wells who 3 So First American Bank already had a presence
4 oversees only the residential real estate loans? 4 down here in Florida before the acquisition of the Bank
5 A. Well, he's the chairman of the bank. So, 5 of Coral Gables.
6 ultimately, the gentleman that oversees corrrnercial 6 A. Yes, that's true.
7 reports to Mr. Wells. So it's more of an informal 7 Q. Is there a written retainer agreement in place
8 designation. 8 between FAB and Keller &Bolz related to this matter?
9 Q. Is it unusual for the bank to seek receivership 9 A. No.
10 in a situation where -- in a residential -- over a piece 10 Q. Okay. Is there, though -- ,_related to this
11 of residential real estate? 11 matter, is there a retainer agreemeht ~ place for other
12 MR. KELLER: Object to form. 12 collections matters?
13 THE WITNESS: No. 13 A. I recall that we .J:f letter with
14 Well, it's an unusual -- it is less than 14 Keller & Bolz with re -,ection matter.
15 average, or 50 percent. You wouldn't have -- because 15 Q. Meani , a singular incident?
16 it's so rare to have the situation, it's commercial 16 A. Yes.
17 or it's an investment property, and you have a 17 Q. Okay. e of dealing, your history
18 tenant, that's what makes it unusual. 18 in dealin with Kele &Bolz, there is not a -- you're
19 It's very common in investment real estate for 19
20 the bank to ask for a receiver. And whether there's 20 · tten retainer agreement in place.
21 a receiver or whether the rent is turned over, the But I've used Keller &Bolz in collection
22 bank is generally pleased with that result.
23 BY MR. WYMAN: All right. And what is your understanding of
24 Q. Okay. e terms and representation for this particular -- for
25 A. As you may realize, the Schneider matter?

Page 21
A. Well, the terms would be they would bill at
2 because the receiver will cost money 2 their billing rates by the hour, or a fraction of the
3 Q. Of course. 3 hour, for the work that was performed. And then included
4 A. 4 would be if there were any out-of-pocket expenses.
5 beneficial to the bank. In an advantage 5 Q. What's your understanding of what the hourly
6 to the bank not to have a r use you're saving 6 rates were that were being billed to the bank for this
7 that cost. 7 matter?
8 Q. Okay. 8 A. Well, Keller &Bolz has three attorneys. And I
9 understand~ that I ~ ard you correctly. 9 recall that the partners have the same billing rate, and
10 (th~ ~elationship betweenFAB and Keller &Bolz 10 that the associate has a lower billing rate. And they
11 goe~ ac to }co . Is that what I understood? To your 11 have paralegal.
12 kno~ edge. 12 I can't tell you the exact amount. I think
13 o my knowledge it would be approximately 2004, 13 that the partners bill at a rate that would be in the
;-1~ 20.0S: And, actually, now that I think about it, it's 14 mid-$300 per hour.
15 ~ bably more likely to be 2005, because I started with 15 Q. Is that the rate that they bill the bank on
16 the bank -- it was about the time I started with the 16 other collections matters, as well?
17 bank. 17 A. Yes. I believe that their rates have increased
18 Q. Okay. 18 once in the years that I've worked with them. That was
19 A. And that was, as I recall, the end of 2000 -- 19 many years ago. The increase was prior to this matter.
20 it could even be 2006. But 2005, 2006 is probably -- 20 Q. Okay. Upon the increase, that's something they
21 gosh. 21 discussed with you, and you agreed and approved it.
22 Let's see. 22 A. Yes.
23 2005 or 2006. 23 Q. Okay.
24 Q. Okay. 24 MR. WYMAN: John, when I had been e-mailing
25 A. It's about the same time I started with the 25 with Henry, he indicated that a verification page of

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March 19, 2019 22 to 25
Page 22 Page 24
1 the interrogatories was coming with you guys today. 1 produced to us by your counsel during the course of
2 Did he mention that to you? 2 litigation for the attorneys' fees issue, representing to
3 MR. KELLER: He e-mailed it to you yesterday. 3 us that these were, I guess, proofs of payment made by
4 But I brought the originals if you want to look at 4 the bank to Keller &Bolz for invoices throughout the
5 thm. 5 litigation.
6 MR. WYMAN: Well, I have -- nothing's changed 6 A. Yes. I'm not contesting it. We keep very good
7 in the answers to interrogatories? 7 records. I don't always see the records in paper form.
8 MR. KELLER: No. 8 I just don't see thm.
9 It's my understanding that was sent to you 9 Q. Okay. When invoices were generated on this
10 yesterday by e-mail. 10 matter and submitted to the bank, wouJ.{=hey go to you?
11 MR. WYMAN: Oh, I don't -- okay. 11 A. I recall that the invoices~ can't tell you
12 MR. KELLER: Here it is now. 12 the initial invoices. They mi h have~ just to me.
13 MR. WYMAN: All right. I don't think I saw it. 13 Jmey wdi'ld go to Gary
14 MR. KELLER: But nothing changed in the 14 Smith and to me simulo/eo]s1 by mail.
15 contents. 15 Q. Okay. \:\._
16 MR. WYMAN: Okay. The answers also still have 16 A. And i ~ evenJlgcv been that initially they
17 the attachments to thm? 17 came by mail to~~1::1 I just cannot rmember exactly.
18 MR. KELLER: Correct. 18 But I think most ~ nm came to me by e-mail.
19 MR. WYMAN: Okay. 19 hen internally, what's the process for
20 MR. KELLER: For the record, we're talking 20 nvoices?
21 about the notice of service of answers to . Well -- and when you say "invoices," are
22 interrogatories, under certificate date of or legal fees?
23 February 7, 2019, to which the answers were provided Yes. Specifically this matter.
24 under certificate dated 11th day of March 2019. Oh, okay. Because depending on the matter, it
25 (Defendants' Composite Exhibit 1, invoice might be handled differently.

Page 25
1 1 Q. Right.
2 BY MR. WYMAN: 2 A. What happened -- Gary is an experienced
3 Q. IfI can show you what " · , or 3 manager. And he gets invoices on matters that he and his
4 identification -- after your eounse at it -- as 4 department are managing, and I generally won't see those.
5 Composite Exhibit 1 to ~he de'-siti . . . 5 Q. "Won't," you said?
6 If you can flip th:r; ugh · is Composite 6 A. Will not see those.
7 7 Q. Okay.
8 documents are. 8 A. And in my -- and some of those will be reviewed
9 A. Oka'r. The d~ ument I'm looking at is a 9 by a lawyer that works for me, or me, but he would be
10 collecti~ of -- I don't know -- let's say 20 pages, and 10 asked. But because of the commercial nature of it, he
11 each are 1-abele , automatic invoice payment notice." 11 asked me to review the bills. So on this case, I
12 ~t '~ y. Are these bank records, records from 12 reviewed the invoices.
13 Q. Okay.
13 "'~ ~
; . ~ i',, , I don't know. 14 A. And Gary would process the payments. And by
15 y Q. So you haven't seen documents like this before? 15 processing thm -- I would review thm and that would be
16 A. No. 16 it, and then he would process thm for payment and it
17 Q. Okay. I'll just represent to you that these 17 would go into the loan systm.
18 were produced to us in the course of this litigation 18 Q. Okay. So part of your review is for approving
19 relating to the issue of attorneys fees. 19 the payment of the invoices; is that correct?
20 A. By the way, they could be from us. 20 A. Yes.
21 Q. Oh, okay. 21 Q. Okay. So you review thm, you approve thm,
22 A. I just don't deal in thm. 22 you tell Gary, "They're okay. Please process the
23 Q. You're not familiar with the form? 23 payments. "
24 A. Not familiar with the form of thm, yeah. 24 A. Yes.
25 Q. Okay. I'll just represent to you they were 25 Q. Okay. At any point during the course of the

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Page 26 Page 28
1 litigation, did you find any of the amounts being 1 counterclaim, there's no answer, there's no defenses.
2 invoiced to the bank on this matter objectionable? 2 There's whatever the bank deemed necessary to get the
3 A. No. 3 lawsuit moving.
4 Q. Okay. Ballparking it here, based on what the 4 A. Essentially, when you're working out a loan --
5 fee claim is, it looks like the claim is in excess of a 5 and when I say "working out," I mean pre-litigation. We
6 half-million dollars in fees. 6 often see borrowers or counsel raise various legal
7 A. Yes. 7 issues. That would be frequent.
8 Q. Okay. Did you think that the hours that were 8 Q. You said raised by borrowers or counsel?
9 put into this matter were necessary? 9 A. Or their counsel.
10 A. Yes. 10 Q. Or their counsel.
11 Q. And what's that feeling based upon? 11 From your recollection,
12 A. When I look at necessity, I look at what the -- 12 ' n.?
13 there's several elements, but we're filing a collection 13 A.
14 action, that's one aspect. And then we have to respond 14 Q. Okay.
15 to counterclaim defenses, that sort of thing, that the 15
16 other party might bring. 16 minutes.
17 So I look at the necessity and the 17 (A re
18 reasonableness of the fees related to the issues that are 18 BY MR. WYMAN:
19 raised in the matter. 19 a couple of other things I forgot to ask
20 Q. From your experience relating to collections 20
21 matters and foreclosures here in South Florida, was the
22 billing on this file, or the amounts billed, higher than Another name in the records that we saw.
23 what you typically see? David Roubitchek. Do you know who this is?
24 MR. KELLER: Object to form. Yes. But it would be Don Roubitchek.
25 THE WITNESS: Q. And who is Don Roubitchek?

Page 29
A. Don Roubitchek is now the retired chief
2 2 financial officer of First American Bank.
3 South Florida compared to I 3 Q. When did he retire?
4 states and Wisconsin. 4 A. About a year ago.
5 commercial collection, 5 Q. At some point during the course of the
6 BY MR. WYMAN: 6 litigation?
Q. 7 A. Yeah, probably.
8 Q. But he had some involvement with certain
9 corrrnunications, phone calls, regarding this case, as
10 usual -- as I recall, there were 10 well, when he was active?
11 , or 14 identifiable counterclaims or 11 A. He could have, but none that I was aware of.
12 efenses, and that's unusual, and the matter 12 Q. Okay. So, again -- and I know that you're sort
appeal. There were aspects of it that would 13 of at the, what you described, as a handful of executives
14 involved in all the operations of the business.
Right. 15 A. Yes.
16 Not as unusual for a corrrnercial collection. 16 Q. Again, is it unusual to have a CEO and a CFO of
17 Q. Okay. In reviewing the invoices and the time 17 the bank involved in a residential foreclosure?
18 being claimed on this matter, I observed that there were 18 MR. KELLER: Asked and answered.
19 approximately 93 hours put into this file from the poin~ 19 MR. WYMAN: I didn't ask about the CFO until
20 it went to Keller &Bolz as a collection matter to the 20 just now.
@ day the complaint was filed . 21 THE WITNESS: Well, it would not be unheard of.
22 Do you consider that to be excessive? 22 It wouldn't be common, put it that way.
23 A. No. It all depends on what was involved. 23 BY MR. WYMAN:
24 Q. By that point in time, there's been -- 24 Q. Okay. And just to jump around a bit.
25 certainly before the complaint is filed, there's been no 25 A. Yeah.

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 Frederick Snow
March 19, 2019 30 to 33
Page 30 Page 32
1 Q. Just touching back briefly about the 1 there.
2 relationship with Keller &Bolz and First American Bank. 2 If he orders it, I would like a copy, please.
3 A. Yes. 3 THE COURT REPORTER: Thank you.
4 Q. Approximately, I guess, over the past five 4
5 years, approximately, how many foreclosure matters have 5 (The depcsition was concluded at 11:29 a.m.)
6 Keller &Bolz handled for First American Bank? 6
7 A. Okay. In the last five years? 7 (Reading and signing of the deposition was not waived by
8 Q. Yeah. 8 the witness and all parties. )
9 A. I mean, I'm not sure I can remember all of 9
10 them. I think I could recall three. 10
11 Q. Okay. 11
12 A. Three matters. 12
13 Q. Okay. And I guess one last thing. In looking 13
14 through the time records, I had pulled out instances of 14
15 communications that the firm had had with you -- 15
16
17
18
A. Yes.
Q. -- either through e-mail or through telephone
conferences, and I totaled up over 150 of them for this :; G
19 matter. And --
~~ 4'
20
21
A. So I understand.
Q. Sure. 21 ~y
22 A. 150, you mean -- when you say that, time
23 entries? Is that what you're talking about?
24 Q. Time entries where your name came up, again '
25 related to either communication. Mostly it's e-rna,i 11

Page 33
1 instead of phone calls. 1 CERTIFICATE OF OATH
2
2 A. Yes.
3 STATE OF FLORIDA
3 Q. And, again, I had asked Q
4 COUNTY OF PALM BEACH
4 is usual for residential fo r
5
5 MR. KELLER: Obje ·.
6 I, Lucy M. Lupo, Registered Professional Reporter,
6 THE WITNESS: It be unusual, if I'm
7 Florida Professional Reporter, Notary Public, State of
7 involved in th~ e, to have that many 8 Florida, certify that FREDERICK M. SNOW personally
8 communications ove th time period that we're 9 appeared before me on the 19th day of March, 2019, and
9 talking~ ut. S~ 'd say no, it's not unusual. 10 was duly sworn.
10 ~ WYMAN: Okay. I don't have any other 11 Signed this 21st day of March, 2019.

12
11
13
C"°''·
, . KELLER: No questions.
But I stand corrected. I was given these to
12
13

14
15
;-1~ erve them to you.
15 y MR. WYMAN: Oh, okay. 16
17
16 MR. KELLER: Meaning, I'm giving Attorney Wyman
18
17 the notice of service of answers to interrogatories
19
18 with a good color copy of the signature page.
20
19 MR. WYMAN: Fair enough. Thank you. 21
20 MR. KELLER: Sorry. Lucy M. Lupo, RPR, FPR
21 MR. WYMAN: That's all right. 22 Notary Public - State of Florida
22 THE COURT REPORTER: Counsel, are you ordering Commission No.: FF 930750
23 at this time? 23 Commission Expires: November 14, 2019

24 MR. WYMAN: Let me discuss that with my client. 24

25 MR. KELLER: And you've got one set of exhibits 25

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 Frederick Snow
March 19, 2019 34 to 36
Page 34 Page 36
CERTIFICATE OF REPORTER 1 ERRATA SHEET
2 DO NOT WRITE ON THE TRANSCRIPT~ENTER CHANGES ON THIS PAGE

3 STATE OF FLORIDA 3 IN RE: First American Bank vs. Schneider

COUNTY OF PALM BEACH FREDERICK M. SNOW

4 March 19, 2019 JOB #1894379
5
5
6 I, Lucy M. Lupo, Registered Professional Reporter,
Page No. Line No. Change Reason
Florida Professional Reporter, certify that I was
6
authorized to and did stenographically report the
7
deposition of FREDERICK M. SNOW, pages 1 through 32; that
8
10 a review of the transcript was not requested; and that
9
11 the transcript is a true record of my stenographic notes.
10
12 11
13 I further certify that I am not a relative, employee, 12
14 attorney, or counsel of any of the parties, nor am I a 13
15 relative or employee of any of the parties' attorneys or 14
16 counsel connected with the action, nor am I financially 15

17 interested in the action. 16

18 17
18
19 Dated this 21st day of March, 2019.
19
20
20
21
21
22
er p na 1es of perjury, I declare that I have read
oing document and that the facts stated in it
23 LUCY M. LUPO, RPR, FPR
Registered Professional Reporter

24 Florida Professional Reporter FREDERICK M. SNOW

25

1 WITNESS
2
3 March 21, 2019
4
5 FREDERICK M. SNOW
c/o JOHN W. KELLER, III, E
6 KELLER & BOLZ, LLP
121 Majorca Avenue
Suite 200
Coral Gables, Flor~d~ 4 .
8
9 IN RE: First Ameri ~ vs. Schneider
Dep , i ion : + a~ n March 19, 2019
10 U . Legal Support Job t 1894379
11
12 Th ~ ~ script yf the above proceeding is now available
fo your y iew.
13 AP~ eas ~
.
to schedule an appointment between the hours
~ ~ 0 a.m. and 4:00 p.m., Monday through Friday, at a
egal Support office located nearest you.
5
ease complete your review within a reasonable time.
16
17 Sincerely,
18 Lucy M. Lupo, RPR, FPR
U.S. Legal Support, Inc.
19 444 West Railroad Avenue, Suite 300
West Palm Beach, Florida 33401
20 (561) 835-0220
21
CC via transcript:
22 ANDREW WYMAN, ESQ.
JOHN W. KELLER, III, ESQ.
23
24
25

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 Frederick Snow
March 19, 2019 1
agreed 21:21 14,19 20:8,
Exhibits 9 agreement 23,24 21:3,8,
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7 22:23 16 30:24 31:3 14,16,19 13:21,22
ago 5:9,21 18:1,2,17,20 approximately
21:19 29:4 19:1,8,9,10,

U.S. LEGAL SUPPORT

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 Frederick Snow
March 19, 2019 2

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32:5
15:13 23:3,6 27:1

U.S. LEGAL SUPPORT

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 Frederick Snow
March 19, 2019 3

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26:1,8 28:11

U.S. LEGAL SUPPORT

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 Frederick Snow
March 19, 2019 4
29:3 even 14:24 feeling 26:11
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14 31:4

U.S. LEGAL SUPPORT

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 Frederick Snow
March 19, 2019 5

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 Frederick Snow
March 19, 2019 6
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U.S. LEGAL SUPPORT

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 Frederick Snow
March 19, 2019 7
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 Frederick Snow
March 19, 2019 8

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 Frederick Snow
March 19, 2019 9

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 Frederick Snow
March 19, 2019 10
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 Frederick Snow
March 19, 2019 11
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 Frederick Snow
March 19, 2019 12
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 Frederick Snow
March 19, 2019 13
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