Case 20-22398-MAM Doc 36-4 Filed 12/18/20 Page 27 of 165

Exhibit Cover Sheet

Party
Submitting: First American Bank – Judgment Creditor Ex. #77 2-ECF No. 8

Admitted: Yes or No (circle one)

Debtor: Stephanie Lynn Schneider

Case No.: 20-22398-MAM

Adv. No._________________

Nature of Hearing/ Motion for Relief from Automatic Stay

Docket No.: 27

United State Bankruptcy Court

Southern District of Florida

Dated ___________________ , 2020

By: _____________________, Deputy Clerk

 Case 20-22398-MAM
Case 9:20-cv-81728-RS DocumentDoc 36-4 Filed
8 Entered 12/18/20
on FLSD DocketPage 28 of 165Page 1 of 14
10/06/2020

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 20-cv-81728-RS

FIRST AMERICAN BANK, as

Successor by merger to
BANK OF CORAL GABLES, LLC,

Plaintiff, OCT O6 2020

V.

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

Defendants.
- - - - - - - - - - - - - -I
DEFENDANTS' LAURENCE SCHNEIDER and STEPHANIE SCHNEIDER
EMERGENCY TEMPORARY RESTRAINING ORDER

Defendants Laurence S. Schneider and Stephanie L. Schneider, prose litigants hereby file

their Emergency Temporary Restraining Order and as grounds state as follows:

Defendants Laurence S. Schneider (hereinafter referred to as ''Mr. Schneider") and

Stephanie L. Schneider (hereinafter referred to as "Mrs. Schneider") seek this Emergency

Temporary Restraining Order, to immediately halt Plaintiffs First American Bank and their

counsel, Keller & Bolz, LLP, from conducting any fraudulent and malicious efforts to cause further

harms to Defendants and their family regarding the fraudulent foreclosure of their home located at

17685 Circle Pond Court, Boca Raton, Florida 33496. This entire litigation is predicated on fraud.

As a result, First American Bank (hereinafter referred to as FAB) and its legal counsel, Keller &

Mesa, LLP, (formerly known as Keller & Bolz, LLP) has committed fraudulent, unsafe and

unsound practices, including but not limited to over 1,000 separate instances of wire fraud, mail

fraud, conspiracy to commit fraud, preparing of fraudulent documents for the purpose of

2-ECFNo. 8
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committing fraud, abuse of process, malicious prosecution, intimidation, defamation, unjust

enrichment, and execution of knowingly false affidavits for the purpose of committing fraud on

Defendants and numerous judges in the 15th Circuit for Palm Beach County, Florida, the United

States District Court for the Southern District of Florida and the Florida Court of Appeals.

JURISDICTION AND VENUE

1. This Court has subject matter jurisdiction over this action as it presents a federal

question pursuant to 28 U.S.C § 1331.

2. On 06/09/17, the Schneiders filed a Notice of Removal on the underlying case to this

court docketed as First American Bank v. Laurence S. Schneider and Stephanie L.

Schneider in Case no. 17-80723, assigned to the Honorable Donald M. Middlebrooks,

United States Federal District Court Judge. On 06/12/17, Judge Middlebrooks filed an

Order to Show Cause [D.E. 5]. On 06/13/17, Schneider filed a new complaint in

Schneider v. First American Bank, case no. 17-80728; which was Schneider's response

to this court's order. The Civil Cover Sheet indicated the related case, 17-80723. The

case was assigned to the Honorable Kenneth A. Marra, Senior District Court Judge,

who had the case reassigned to Judge Middlebrooks, who agreed that the new

complaint, 17-80728, met the jurisdiction and federal question.

3. This Court has diversity jurisdiction pursuant to 28 U.S.C § 1332 (a) as the amount in

issue in this action exceeds $75,000, exclusive of interest, costs, and attorneys' fees,

and is between citizens of different states (Defendants are citizens of Florida and

Plaintiff is a citizen of Illinois).

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4. A national banking association is a citizen, for diversity purposes, of "the state

designated in its articles of association as its main office" Wachovia Bank v. Schmidt,

546 U.S. 303,318, (2006).

5. Venue lies in this District pursuant to 28 U.S.C § 1391(b) because the property whose

mishandling by Plaintiffs is at issue in this present lawsuit lies within the jurisdictional

limits of this court.

FACTUAL BACKGROUND

In January of 2006, Mr. Schneider was introduced to the Bank of Coral Gables (hereinafter

referred to as "BoCG") through Ela Rivero Prieto (hereinafter referred to as "Ms. Rivero-Prieto"),

who had been Mr. Schneider's personal and business banker since the mid-1990's. Ms. Rivero-

Prieto phoned Mr. Schneider, informing him that she had taken a position with a new bank and

asked me to move my personal and business accounts to the BoCG. However, she told Mr.

Schneider that the bank was not quite "open yet" but would be in the very near future. During the

conversation, Mr. Schneider apprised Ms. Rivero-Prieto that he was moving to Boca Raton and

signed a purchase-in-sale agreement to purchase a home in The Oaks of Boca Raton, which was

being custom built.

Mr. Schneider had asked Ms. Rivero-Prieto whether the bank was offering Purchase

Money Home Equity Line of Credit. Ms. Rivero-Prieto replied that the bank did offer that and

subsequently sent me a BoCG Residential Mortgage Loan Application ("FNMA Form

1003"). Pursuant to our conversation and the FNMA Form 1003, Ms. Rivero-Pieto was fully

informed that Mr. Schneider was the only borrower to sign. As required under federal law, Ms.

Rivero-Prieto executed the loan application as Vice President of the BoCG. See Exhibit 1.
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On February 20, 2006, application number 06020006, bates no. 00158-00160, the loan

commitment shows that Mr. Schneider was the sole borrower, as well as specifically identifying

that Mrs. Schneider was only required to sign the mortgage to perfect the BoCG's security interest

in the property. See Exhibit 2. However, the loan commitment was not signed by the BoCG,

which concerned Mr. Schneider and immediately communicated this to Ms. Rivero-Prieto. In her

February 27, 2006 response, Ms. Rivero-Prieto wrote, "I received you[r] fax and I have asked the

director to please sign the letter which I will then forward to you". See Exhibit 3.

On March 6, 2006, in a correspondence between Ms. Rivero-Prieto and Mr. Schneider, Mr.

Schneider wrote, "I am a little concerned that it is not coming from your new bank." Ms. Rivero-

Prieto then responded, "Regulators do not let us fund loans until the bank opens ... meanwhile the

directors are putting up the cash and they also approved the loan." See Exhibit 3, Page 3.

Not only did Mrs. Schneider not apply for the loan nor was she a borrower on the loan

commitment nor signed the HELOC at closing, the BoCG was not licensed to advertise or operate

as a bank until March, however, according to the FDIC certificate, it states that the BoCG was not

licensed or advertised as a bank until June 5, 2006. See Exhibit 4.

On the date of closing, July 28, 2006, the Disbursement Request and Authorization also showed

that Mr. Schneider was the only signatory; my wife, Mrs. Schneider did not sign this document.

See Exhibit 5.

On May O1, 2017, Henry H. Bolz III (hereinafter referred to as "Bolz"), prior counsel for

First American Bank (hereinafter referred to as FAB), sent Mr. Schneider an email and courtesy

copied my prior attorney, Kenneth E. Trent (hereinafter referred to as "Trent") at 2:54 P.M.,

admitting that he had not only received but scanned and added Bates-stamp numbers to documents

that were given to him as part of the initial production of documents. The documents were bates-
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stamped numbers SCHNEIDERS 00001 through SCHNEIDERS 00253 which included

documents such as the Loan Commitment, Disclaimer Deed, and other relevant documents that

exhibited only my signature, not that of my wife, Mrs. Schneider. See Exhibit 6.

The relevance of this email shows Bolz has had both knowledge and tangible proof for

over three years that my wife, Mrs. Schneider, is not responsible for any debt related to the

mortgage. However, on 08/28/20, FAB filed a Motion for Deficiency Judgement with then

presiding Judge Lisa M. Small, which was granted by the current presiding Judge Samantha

Schosberg-Feuer. See [D.E. 533], filing no. 112473471, Ex 7.

On November 30, 2015, Bolz responded to two separate requests which were directed at

and addressed to its lender/servicer FAB. Rather than FAB responding to these October 2015

requests, one a "Qualified Written Request" ("QWR") under RESP A ("Real Estate Settlement

Procedure Act") and the other relating to the Fair Credit Reporting Act ("FCRA"), both of which

required the bank to conduct an investigation and report back to Mr. Schneider with their findings,

and the actions which FAB are taking to remediate the bank/servicer's system of records, policies

or procedures which led to their findings or wrongdoing, whether through inadvertence and

mistake or through purposeful intent. See Exhibit 8, Page 2.

FAB chose to admit that it had made errors and that Mr. Schneider's HELOC account was

current, and had always been current despite the late charges which FAB continued to assess to

Mr. Schneider's HELOC account, and continued to report Mr. Schneider's HELOC account as

derogatory and as having been paid late to the credit repositories, negatively impacting Mr.

Schneider's ability to obtain credit and impacting the cost of credit, as the account history on a

mortgage loan has the most highly weighted impact to the algorithms utilized by the credit
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repositories, which are used to determine a credit score such as FICO, Experian and Transunion.

See Document 1-2, Ex. D, Pages 5-7, Ex. 9

Due to FAB's further gross negligence and futility, only four months after FAB's Vice

President Jennifer Anderson, having made the same admissions to Mr. Schneider in her June 15,

2015 letter to Mr. Schneider, acknowledging F AB' s responsibility and fault in its reporting of Mr.

Schneider's HELOC and knowing that FAB had also filed a satisfaction of a mortgage owned by

one of the Mr. Schneider's entities, this resulted in the borrower not paying off the S & A Capital

Partners upon the sale of the Washington's home due to FAB's satisfaction of the Johnnie

Washington mortgage, which FAB neither owned nor serviced. See Document 1-2, Ex. D, Page

18, Ex. 9.

FAB harmed 1,, Fidelity Loan Servicing, one of Mr. Schneider's entities, as a function of

FAB's direct harm to Mr. Schneider, in reporting his HELOC account as late and derogatory. An

indirect consequential harm to FAB's direct harm in reporting Mr. Schneider's HELOC as

consistently late. Mr. Schneider is the guarantor of the Bank United's business line of credit to 1•

Fidelity Loan Servicing. Upon an annual review of Mr. Schneider's credit report, which reflected

an ongoing pattern of FAB's derogatory reporting of Mr. Schneider's HELOC, Bank United

became concerned that Mr. Schneider had financial troubles and cancelled 1,, Fidelity's business

line of credit. See Composite Exhibit 10, dated 11/18/15 from L. Schneider to Brian T. Hagan

of First American Bank.

Given the mounting and compounding problems, FAB chose to engage Keller & Bolz,

LLP, to respond to the October 2015 FCRA and QWR requests, to act as both a shield and a

sword.
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Bolz, had a financial interest in ensuring that Mr. Schneider's account would not be

current. This created an irreparable conflict of interest which was concealed by FAB and Keller &

Bolz.

The November 30, 2015 response letters sent by Bolz to Mr. Schneider's QWR and FCRA

letters were for the most part apologetic and Bolz asked if he could write a letter to Bank United

in an attempt to undo the harm indirectly caused to 1' Fidelity Loan Servicing as a function of
t

FAB's direct harm to Schneider in reporting his HELOC account as late. See Exhibit 11, dated

June 5, 2015, Page 2.

Upon Mr. Schneider and Mr. Schneider's entities which were harmed both directly and

indirectly through a conspiracy to perpetrate fraud, in order to conceal its unsafe and unsound

business practices which included the utilization of numerous frauds upon the courts, including

the two separate related cases in Florida's 15 th Circuit Court, the Florida 4th District Court of

Appeals and two separate but related cases in the United States District Court for the Southern

District of Florida (West Palm Beach).

On 08/20/15, an appraisal done by Paolo Lenata showed pictures of the property in excellent

condition.

On 08/17/16, FAB filed a Verified Petition for Appointment of Receiver signed by Garry S. Smith,

Senior Vice President. See [D.E. 4], Ex. 12.

This was filed simultaneously with the Verified Foreclosure Complaint on 08/17/16. [D.E.2]

On 08/18/16, FAB filed Plaintiffs Verified Motion to Compel Assignment of Rents. [D.E. 11].

On 09/21/16, Bolz set a hearing for the Verified Petition for Appointment of Receiver on 10/14/16.

Both motions for hearing were executed by First American Bank Senior Vice President, Garry S. Smith.

See [D.E. 19], Ex. 13.

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In addition and unbeknownst to the Schneiders, former attorney Trent filed a feeble, irrelevant

and factually inept Motion to Dismiss on 10/03/16. See [D.E. 21], Ex. 14.

In a scheme that would be repeated numerous times throughout this foreclosure litigation, Bolz set

Trent's Motion to Dismiss on Bolz's already scheduled hearings. As such, the very next day on 10/04/16,

Bolz added Defendant's Motion to Dismiss to the existing 10/14/16 hearings See [D.E. 22], Ex.15. It is

neither customary nor proper for Plaintiffs to set Defendant's motions for hearings and for Defendants to

set Plaintifrs motions for hearings.

On 10/07/16, unbeknownst to Mr. Schneider, Bolz filed First American's Memorandum of Law in

Opposition to Defendant's Motion to Dismiss with an attached exhibit purporting to be an email from

Postmaster to Garry S. Smith dated 08/12/14. The email contains a letter from Thomas E. Wells, IV,

Chairman and CEO of FAB which is irrelevant as it was not sent to Schneider, The other exhibit is a

purported letter dated 02/12/15, sent to Laurence Schneider with the incorrect mailing or property address,

which proves Schneider's allegations that upon FAB merging with BoCG, the Schneider's HELOC was

incorrectly boarded to FAB's system ofrecords. See [D.E. 23], Ex.16.

On 10/12/16, at 10:09 A.M. Trent sent Mr. Schneider an Affidavit opposing FAB's Motion to

Compel Rents. Trent wrote, "Please execute ASAP and email back to me so I can file it. Don't worry this

is not the entirety of our strategy for Friday's hearing." Trent provided no indication that the hearing was

on Trent's Motion to Dismiss. Trent knew that the Schneider's were going to be out of town on or around

08/30/16. The same day, Trent filed the Affidavit he had prepared along with key documents in which the

Mr. Schneider's Motion to Dismiss would have likely prevailed. Most notably, Exhibit I includes a letter

from Jennifer Anderson, Vice President of FAB, admitting the following, See [D.E. 24], Composite Ex.

17:

"I have received your request to not report the delinquency that occurred on the
above account in April of this year. It appears that our billing address was not correct
and your payment was late for this reason. Since this appears to be the result ofa clerical
error during our recent merger with the Bank of Coral Gables, we will continue to report
your account as paid as agreed.
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Today we have asked the credit agencies to correct your credit file to a
satisfactory status. "

Additionally, Exhibit 1 contained the 11/30/15 letter from Keller & Bolz, LLP, which responded

on behalf of FAB to Mr. Schneider's email to Brian Hagan, sent via email and certified, See [D.E. 24],

Composite Ex. 17:

"Keller & Bolz, LLP represents First American Bank ("FAB''). As you know, Bank of
Coral Gables LLC merged into and became FAB in December 2014.

This letter responds to that email which you sent to Brian Hagan at 3:05 p.m., on Friday,
October 30, 2018. That email can arguably he viewed as an attempt by you to dispute
directly with FAB. In accordance with 15 U.S.C. § 168JS-2(a)(8) of the Consumer
Credit Protection Part of the Fair Credit Reporting Act ("FCRA ''), information
that FAB provided to credit reporting agencies earlier this year.

In accordance with the FCRA, FAB has conducted a11 investigation and reviewed
that information in which you provided with respect to the disputed late payme11t
information you identified. After completing its investigation, F AB
communicated with all of the major/national credit reporting agencies and
advised them that all of your past dye payment notices have been reversed, and
that you have been making all payments as agreed. This letter is being timely sent
to you in accordance with 15 U.S.C. §, 166/i.

Your November 18, 2015 (7:46 p.m. EST) and November 19, 2015 (4:37 p.m.
EST) emails to Brian Hagan indicate that in addition to "immediately
remediating the reporting errors" (done), FAB needs to "send any letters needed
to rectify the harms" and identified the Bank United-1st Fidelity revolving Line
of Credit as having been affected. Do you still want/need FAB to write to Bank
United (or might such a letter now be unnecessary)? Please let me know.

All further requests for information for documents in any fashion relate to any
complaints or disputes that you might have pursuant to the FCRA should be
addressed to the undersigned at the address on this correspondence."

The significance of this correspondence was that Bolz had not only admitted that FAB had

continued the negligent servicing of Mr. Schneider's federally related mortgage loan, but additionally Bolz

purposely, deceptively and fraudulently omitted to inform Mr. Schneider that Bolz and the law firm of

Keller & Bolz were acting in a capacity of a debt collector as required under state and federal statutes.

Additionally, the 11/20/15 email sent by Bolz to Mr. Schneider and copied Garry S. Smith, James

Burton, Brian Hagan, and Frederick M. Snow. This demonstrates that Smith, who signed the Verified
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Foreclosure Complaint, the Verified Petition for Appointment of Receivership, Motion for Summary

Judgement, and most notably is the same individual who responded to Mr. Schneider's FCRA requests and

QWR requests on 05/26/17 and 09/18/17, the purposeful conspiracy to commit fraud upon the Schneiders

and the Schneiders' entities, all of which have been delivered through the predicate RICO acts of mail fraud

and wire fraud. In fact, Smith specifically lists the prior FCRA and QWR requests sent from Keller & Bolz

to Schneider evidencing the common purpose of the RICO Enterprise.

Had these documents, which were attached to Mr. Schneider's Opposition to FAB's Motion to

Compel Rents and in Mr. Schneider's Complaint filed in the United States District Court for the Southern

District of Florida been articulated for the purpose of exposing Keller & Bolz and FAB's conspiracy to

commit fraud, in the Federal Complaint filed in 17-80728 on 06/13/17 (which were in response to the

Honorable Judge Donald M. Middlebrooks 06/12/17 Order to Show Cause), at the very first hearing in this

matter on 10/14/16 in the foreclosure matter before the Honorable Judge Eli Breger, the Schneiders would

not have been put through four years of absolute abuse, hundreds of thousands of dollars in attorney's fees

trying to undo this fraudulent conspiracy, when that time and money should have been utilized as a Public

Officer/Private Attorney General in the capacity/obligation as a Relator in a False Claims Act Case against

JP Morgan Chase, for "knowingly making false statements for the receipt of payment and the avoidance of

its obligations upon the United States Treasury, and 19 States including Florida and Illinois which have

similar FCA laws. See Schneider ex. rel v JPMorgan Chase Bank, case no. 14-cv-01047-RMC,

Document 102, Ex. 18.

Instead, on October 14, 2016, while out of town, Judge Breger did not rule on the Verified Petition

to Appoint Receivership of Motion to Compel Rents. Instead, the Motion to Dismiss, which was filed by

Trent, without Mr. Shcneider's knowledge, and set for hearing by Bolz, by even confusing Judge Breger,

applying a 10-day rule. Thus the 10/3/16 Motion To Dismiss, was set on 10/4/16 so it could be heard on

10/14/16. See [D.E.26], Ex. 19.

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To add insult to injury the lower court required Mr. Schneider to respond to each and every redacted

billing entry costing Mr. Schneider hundreds of thousands of dollars in the thousands of just the line by line

responses and they had the audacity to bill thousands of dollars in the federal court that Mr. Schneider had

to reply to without knowing what the fraudulent billing was even for including fees and costs for the

fraudulent remand. The inspection is further memorialized in the ONE-MILLION DOLLARS in Keller &

Bolz almost completely redacted attorneys fees and costs, granted by the lower court for Keller & Bolz to

perpetrate the ongoing frauds. See Ex. 20, Bolz Deposition FAB - Atty's Fees - 000487 and 000468,

March 21, 2019.

On 02/11/20, the Court granted FAB approximately a million dollars in fees. See Ex. 21.

On May 18, 20 Keller & Bolz submitted another million dollars for fees on fees fully redacted

invoices, in which the Court ordered line by line objections to hundreds of pages of redacted billing

statements. We need relief because there is an Order to compel line by line responses to another million

dollars of fully redacted fees on fees. See Filing #107618158 dated 05/18/20 at 2:05:44 P.M, Ex. 22.

On September 9, 2020, Mr. Schneider filed an Emergency Temporary Restraining Order

in the matter of First American Bank v. Laurence S. Schneider and Stephanie S. Schneider, Case

No. 502016-CA-009292, in response to FAB's Motion to Obtain a Writ of Possession for our

primary residence, addressing the maliciously perpetuated frauds committed by First American

Bank and Keller & Bolz. See [D.E. 376], Ex. 23.

The Order also indicated Judge Lisa Small's had granted an Order requmng Mr.

Schneider's response to the line-by-line objections to thousands of pages of redacted attorney's

fees and costs based on a fraudulent foreclosure, a task that could not possibly be completed

without the help of multiple attorneys knowing that The Schneiders' did not have any counsel,

despite their request for an extension to complete this request, while trying to manage the workload

of tracking, reading and responding to the copious filings done by Keller & Bolz. The Temporary

Restraining Order included a separate instance of Mr. Schneider's former counsel being
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intimidated into withdrawing from this case. On October 5, 2017, Bolz filed a complaint against

prior counsel, Brent Tantillo (hereinafter referred to as "Tantillo"), for the unlicensed practice of

law. See [D.E. 569], filing no. 112820114, Page 2, Ex. 24.

However, the Honorable District Court Judge Donald M. Middlebrooks, had granted

attorney Tantillo pro hac vice in a related federal case, 17-80728, related to 17-80723.

Bolz and Shey la Mesa (hereinafter referred to as "Mesa") had filed hundreds of documents

in the purportedly "verified" document such as the Verified Complaint for Foreclosure, Verified

Petition of Appointment of Receiverships, numerous motions for property inspections, numerous

motions to compel discovery, affidavits, opposition to motions, hearings, etc. however, had Bolz

actually believed that attorney Tantillo was engaging in the unlicensed practice of law, Bolz and

Mesa would be ethically obligated to immediately file a timely complaint with the Florida Bar,

which their October 5, 2017 Bar Complaint would appear to have met their ethical obligation.

Additionally, during the March 27, 2019 Trial for Attorney's Fees, Bolz admitted to

coordinating the motions to dismiss Mr. Schneider's counterclaims and affirmative defenses by

setting hearings for these motions during the time in which Trent was suspended by the Florida

Bar. To make matters more complicated, attorney Trent filed a Notice of Absence instead of a

Notice of Suspension, which is required by the Florida Bar, for the intention to purposely avoid

the court's awareness of this suspension, leaving Mr. and Mrs Schneiders with no legal

representation, allowing Keller & Bolz and FAB an unfair advantage.

Finally, the temporary restraining order was accompanied by a Forensic Handwriting

Report which proved the ambiguous signature on Defendants' Response to Court's Order to Show

Cause to be a forgery and a fraud, although Bolz submitted this document multiple times claiming
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the signature was that of Mrs. Schneider or Mr. Schneider, the report verifies the validity and

evidence of this fraud. See Exhibit 25.

In addition to this Expert Report, Mr. Schneider had also notified the clerk that he was

going to be out of the state to participate in depositions of key witnesses in a District Court Case

pending in the Southern district of New York (15-00293) in a simultaneous litigation against

JPMorgan Chase. This is additional evidence that Mr. Schneider could not have possibly signed

the Order because he was not physically in the state during the time in which that Order was signed

and mailed. Mr. Schneider also did not receive any notifications regarding Judge Middlebrooks

Motion to Show Cause via CM/ECF and there was no email address listed on the complaint for

Mr. Schneider even though opposing counsel had used his email address to notify him of filings

in the past.

The Emergency Temporary Restraining Order was dismissed based on a technicality and

no further investigation was issued to verify these proven claims.

Given the complexity of this litigation which will be further divulged in a separate filing, and due

to the perpetuation of frauds including the Order Granting the Deficiency Judgement based on a fraudulent

foreclosure, Mrs. Schneider now has to consider filing for Chapter 13 Bankruptcy for a debt that she does

not owe. This action will cause irreparable harm to both Mrs. Schneider's perfect credit and will directly

impact the stock of Mr. Schneider's company. In addition, Mr. Schneider has filed letters from Mrs.

Schneider's psychiatrist, Dr. Nicole Pearl, stating that this unnecessary and fraudulent foreclosure has

caused Mrs. Schneider's mental state has progressively deteriorated and she is now not only being seen and

treated for the mental damage this litigation has caused, but has also been unable to live at home with her

family and children for the past four weeks as a result of this damage. The Schneider's two children,

Zachary and Jordyn Schneider, are currently being treated medically for anxiety and depression caused by

this litigation. In addition, Jordyn Schneider suffers from two auto-immnune disorders which has resulted
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in flare-ups, hindering her ability to function day- to-day without chronic pain due to the rapid progression

and stress inflicted by this unjust litigation. Mr. Schneider is now being treated medically for anxiety,

depression, insomnia, and dangerously high blood pressure as a result of the inconceivable pressure, stress,

and workload this deeply rooted and fraudulent foreclosure has caused. As a prose litigant, Mr. Schneider

spends at least sixteen hours a day and works through most nights seeking rectification and justice for the

wrongful and fraudulent damages done to Mr. Schneider, Mrs. Schneider, the Schneider family and the

Schneider's entities.

WHEREFORE, the Defendants Laurence Schneider and Stephanie Schneider respectfully

request this Honorable Court to enter a Temporary Restraining Order halting Plaintiffs First

American Bank from conducting any fraudulent and malicious efforts to cause further harm to

Defendants and their family.

Respectfully submitted,

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F
LAURENCE SCHNEIDER, Pro Se
17685 Circle Pond Court
--
Boca Raton, FL 33496
Tel: 561-322-5103
Email: larry(w,sacapitalpartners.com
Secondary: Jordyn.schneiderl 998r@gmail.com

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been served via
the Florida Court's E-filing Portal Automatic Email Service pursuant to Florida Rule of Judicial
Administration 2.516, on this_§_day of October, 2020, to Aleksandra Novakovich Gonzalez,
Esq., (foreclosures@sscla\\rfirm.com), Sachs, Sax Caplan, Attorneys for The Oaks at Boca
Raton POA, Inc., 6111 Broken Sound Parkway, N.W, #200, Boca Raton, FL 33487; and John
W. Keller, III, (jkellerc@kellermesa.com), Keller & Mesa, LLP, Attorneys for First American
Bank, 121 Majorca Avenue, #200, Coral Gables, FL 33134.

Laurence Schneider, Pro Se -s