Filing # 155585159 E-Filed 08/18/2022 08:30:29 AM

IN THE CIRCUIT COURT OF THE 15TH

JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA

FIRST AMERICAN BANK, as successor CASE No.: 502016-CA-009292

By merger to Bank of Coral Gables, LLC,

Plaintiff,

v.

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

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Defendant(s).
____________________________________/

RESPONSE TO FIRST AMERICAN BANK’S MOTION TO COMPEL DEPOSITION

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OF LAURENCE S. SCHNEIDER AND FOR SANCTIONS
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COMES NOW, Defendant LAURENCE S. SCHNEIDER (hereinafter “Defendant” and/or “L.
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Schneider”), by and through the undersigned counsel, and hereby files this Response to Plaintiff
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FIRST AMERICAN BANK’s, as successor by merger to Bank of Coral Gables, LLC (hereinafter

“Plaintiff” and/or “First American”), Motion to Compel Deposition of Defendant and for
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Sanctions, and states as follows:

1. On September 22, 2020, this Court entered a Final Judgment in favor of First American
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and order L. Schneider and his wife, Defendant Stephanie Schneider (hereinafter “S. Schneider”)
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to pay First American $1,547,391.54 with interest rate of 6.03% per year.
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2. On March 9, 2022, the Fourth District Court of Appeals entered an Opinion reversing the
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final deficiency judgment against S. Schneider and remanded for the entry of an amended

judgment against only L. Schneider.

3. On March 22, 2022, Plaintiff as Appellee filed a Motion for Rehearing, and, Motion for

Rehearing en Banc.

FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 08/18/2022 08:30:29 AM
 4. On April 28, 2022, the Fourth District Court of Appeals entered an Order denying

Plaintiff/Appellee’s Motion for Rehearing, and, Motion for Rehearing En Banc.

5. The Mandate of the Fourth District Court of Appeals reversing the final deficiency

judgment against S. Schneider and remanded for the entry of an amended judgment against only

L. Schneider.

6. Yet, the issue has yet to be dealt with regarding the Court’s lack of jurisdiction to enter the

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Final Judgment in which is the subject of these post-judgment proceedings.

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7. On June 6, 2022, First American filed its Notice of Taking Deposition of L. Schneider,

setting the deposition in person for June 28, 2022 at 10:00 a.m. at the offices of Meland Budwick

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P.A.
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8. At 2:52 a.m. on the day of the deposition, Defendant’s counsel reached out to Plaintiff’s
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counsel requesting for the deposition to either be postponed until June 29, 2022 of to commence
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at noon as the undersigned was consumed with an appellate filing in a different case, and the

undersigned sought the extension as he solely required such to provide him with the time to rest to
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be prepared for the deposition.

9. Upon Plaintiff’s confirmation that the deposition could commence at noon, the
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undersigned’s office emailed L. Schneider, and the undersigned texted L. Schneider of the new
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start time.
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10. While the undersigned was on the way to the in-person deposition, the undersigned
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requested that his office contact Plaintiff’s counsel to advise that he may be approximately twenty

(20) minutes late.

11. Shorty thereafter, the undersigned received a call from L. Schneider advising that he was

severely ill and experiencing covid like symptoms after being exposed to an individual with covid.
 12. Pursuant to L. Schneider's health, the undersigned reached out to Plaintiff's counsel to

advise that the deposition must be rescheduled, and that L. Schneider will pay the court reporter's

mv01ce.

13. When Plaintiffs counsel found out about the news, they demanded that the severely ill

Defendant log into zoom to swear under oath as to his exposure and current health state; however,

the undersigned was unable to get a hold of L. Schneider to request for such.

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14. While Plaintiffs pro hac vice counsel, Neal Litman, Esq., of Freeborn & Peters, LLP, 1 was

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emailing my office he engaged in behavior disrespecting and harassing my staff accusing her of

engaging in the unauthorized practice of law for simply stating that the undersigned spoke with

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the client, and that it is our opinion that he is too ill to provide any testimony under oath in his
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cunent state. See full composite Exhibit "A" attached hereto of all emails in the order that they
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were sent and received as Plaintiff left out the emails to our office provided by Neal Litman, Esq.
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15. Meaghan E. Murphy, Esq. has continued the parade of harassing my paralegal throughout

the Motion, while my paralegal sent every email under my direction and obtained clearance for
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such to avoid any possibility of engaging in the unauthorized practice of law, and as Meaghan E.

Murphy, Esq. indicated such was border line in the sense that my paralegal was capable ofreading
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the Notice of Taking Deposition and was able to see the signature line in the certificate of service,
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which indicated the attorney that attorney that scheduled such.

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1 eal Litman Esq. is employed by the same finn (Freeborn & Peters LLP) that Schott Fishman is employed.

Scott Fishman is a private investigator (not licensed in Florida) that harassed and stalked L. Schneider's family
children and their son 's sixteen-year-old girlfriend. The Affidavits filed by the Defendant's children (DE 584 and
REDACTE
585) assist with tbe explanation of the events. It is tbe undersigned 's belief that • • • • was working under the
direction of ea! Litman, Esq. at the time oftbese events.
 16. Until the emails received from Neal Litman, Esq., the undersigned nor L. Schneider had

any knowledge that REDACTED . intended to appear or had anything to do whatsoever with

this deposition.

17. In fact, the Notice of Taking Deposition of REDACTED only indicates that Meaghan

Murphy, Esq. was to conduct the depositions (See Exhibit “B”).

18. Plaintiff is attempting to mischaracterize the events that happened on June 28, 2022.

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19. The undersigned’s firm has already requested for dates to reschedule L. Schneider’s

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deposition from the Plaintiff (See Exhibit “A”) prior to Neal Litman, Esq.’s “tomfoolery” of email

harassment to my firm, and to date, we have yet to receive any proposed dates whatsoever.

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20. Further, the undersigned’s firm has already indicated that L. Schneider will pay the cost of
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the court reporter (See Exhibit “A”), and to date, no invoice has been received for payment.
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21. As to the fees that Neal Litman, Esq. is attempting to collect for travel, L. Schneider objects
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to these fees.

22. The trial court is also directed to eliminate from the fee award any fees attributed to time
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the wife's Polk County counsel spent traveling to and from Sarasota County. The wife could and

did hire competent counsel in Sarasota County. Belmont v. Belmont, 761 So. 2d 406, 407 (Fla. 2d
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DCA 2000) [citing therein Chandler v. Chandler, 330 So.2d 190 (Fla. 2d DCA 1976)].
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23. We are faced with the question of whether Travel time is properly included in an award of
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attorneys' fees. We think not. We are aware of no authority for including it and, indeed, Canon 2
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of the Code of Professional Responsibility indicates to the contrary when, among other factors

properly to be considered in determining a reasonable fee, it cites the fee ‘customarily charged in

the Locality for similar legal services…..Certainly a reasonable fee for Local counsel would not

contemplate the inclusion of travel time as compensable time. It would be incongruous, to say the
least, it in the ordinary case nonlocal counsel should fare better insofar as his fees may be assessed

against the other party. Chandler v. Chandler. 330 So.2d 190 (Fla. 2d DCA 1976).

24. First American has local counsel that would not charge for travel, and such request should

be denied as to the travel time of Neal Litman, Esq. based on the caselaw prohibiting such.

25. Further, First American should not be entitled to two (2) hours of attorney time in the

amount of $880 for bringing their motion and attendance at the hearing, based on the email from

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L. Schneider's counsel requesting for dates to reschedule the deposition, and offering to pay the

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court reporter fee.

26. Further, First American's request to sanction L. Schneider in the amount of $15,000.00 for

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being severely ill unable to provide his testimony is completely absurd, especially considering the
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harassment that First American has put L. Schneider's family through, including but not limited
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to, stalking, defamation, tortious interference with business relationships, seeking judgments
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against his wife, S. Schneider that they are not entitled to, and so much more.

WHEREFORE, Defendant LAURENCE S. SCHNEIDER respectfully requests this Court,

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deny the Plaintiffs Motion, deny the Plaintiffs request for sanctions, order the Plaintiff to provide

L. Schneider' s counsel with proposed deposition dates per their request via email (See Exhibit
A

"A", provide L. Schneider' s counsel with the invoice for the court reporter expense per their
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request via email (See Exhibit "A"), and any relief this Court finds just.
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CERTIFICATE OF SERVICE
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I CERTIFY that a copy hereof has been furnjshed on August 18, 2022, via email service to all
parties designated to receive Service of Court documents via Florida' s eFiling Portal pertaining
to this case, via e-mail to Meaghan E. Murphy, Esq. , Meland Budwick, P .A., 200 South Biscayne
Blvd., Ste. 3200, Miami, FL 33131, mmurphy@melandbudwick.com,
mramos@melandbudwick.com , and mrbstate@yahoo .com, and via email to John W. Keller, III,
Esq., Sioli REDACTED , REDACTED REDA
• •, •REREDA_ ,
jkeller@siolilaw.com and smesa@siolilaw.com.
 Respectfully Submitted,

MCCARTHY & YERSEL, PLLC

Attorneys for the Defendants
4929 SW 74th Ct.
Miami, FL 33 155
Ph.: (305) 407-8006 / Fax.: (866) 676-4671

By: /s/ Martin G. McCarthy

Emre Yersel, Esq., Florida Bar No.: 114485
Service Email: eyersel@myattorneyservices.com

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Martin G. McCarthy, Esq. Florida Bar No.: 149896
Service Email: mccarthy@myattorneyservices.com
Service Email 2: lawclerk@myattomeyservices.com

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7129122, 2:37 PM Mail - Kaitlyn Bunnell - Outlook

Re: Deposition of Larry Schneider

Levin, Neal H. <nhlevin@freeborn.com>

Tue 6/28/2022 5:24 PM
To: Martin McCarthy <mccarthy@myattorneyservices.com>
Cc: Meaghan Murphy <mmurphy@melandbudwick.com>;Emre Yersel <eyersel@myattorneyservices.com>;lsenberg, Shira R.
<sisenberg@freeborn.com>;robyn@adamsteinberglaw.com <robyn@adamsteinberglaw.com>;Kaitlyn Bunnell
< lawclerk@myattorneyservices.com >
Martin, will you be representing Larry's kids in this matter and, in either event, do you know their intentions relative to
tomorrow's scheduled depositions?

If we do not get confirmation in the next 30 minutes that they w ill be attending, we will suspend the deps and further seek
relief from the Court.

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Best,

Neal

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On Jun 28, 2022, at 12:04 PM, Levin, Neal H. <nhlevin@freeborn.com > wrot e:

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Kaitlyn, I t ru st that you are continuing this argument as a Paralegal and not trying t o assert a legal position on
behalf of Martin's client as to whether a deposition is attributable to an attorney fo r a party or the party itself.

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Clearly, it's the latter, though in either event, we fail to see how that is even remotely relevant.

What's more, your decision to exclude me from the email chain is itself compelling and will be noted for the Court
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when we seek appropriate remedies against Martin and his client for today's Tomfoolery.
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All the Best,

Neal
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From: Kaitlyn Bunnell <lawclerk@mv.attornev.services.com>

Sent: Tuesday, June 28, 2022 12:45 PM
To: Meaghan Murphy <mmurJiliv@melandbudwick.com>
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Cc: Martin McCarthy <mccarthy..@mv.attorneyservices.com>; Emre Yersel <g_yersel@myattorneyservices.com>; Melissa Ramos

<mramos@melandbudwick.com>
Subject: Re: Deposition of Larry Schneider
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EXTERNAL EMAIL:
Dear Ms. Murphy:
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As this your deposition, I am kindly writing to you to readvise that Mr. Schneider is ill and is unable to attend nor
testify per Mr. McCarthy's last communication with him. Mr. McCarthy was not able to get a hold of him after the
zoom instructions were provided.

Thank you,

Kaitlyn Bunnell, Paralegal

MCCARTHY & YERSEL, PLLC
4929 SW 74th CT

https://oullook.office.com/mail/id/AAQkADg1 MTl3Y2I4LTlzMTUtNDA1Mi04ZWY3LTAwZGZhNzYyNjVmNQAQAltX3GUGHTN MnxYOiUWcgv0%3D 1/7

7129122, 2:37 PM Mail - Kaitlyn Bunnell - Outlook

Miami, FL 33155
Telephone: (305) 407-8006
Cell: (305) 335-5543
Fax: (866) 676-4671

CONFIDENTIALITY NOTE: The infom1ation contained in this transmission is privileged and confidential intended only for
the use of the individual or entity named above. Iftbe reader of this message is not the intended recipient, you are hereby
notified that any dissemination, distribution or copying of this communication is strictly prohibited. Jfyou have received this
transmission in error, do not read it. P lease immediately reply to the sender that you have received this co1m1mnication in error
and then delete it. Thank you.

On Jun 28, 2022, at 11:40 AM, Levin, N eal H. <nhlev in@freeborn.com> wrote:

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I am now counsel of record. I do believe I was asking factual questions. and have not received factual responses. To the
contrary, you are sending us a bunch of malarkey.

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On Jun 28, 2022, at 11 :38 AM. Kaitlyn Bunnell <lawc lerk@mY.attorneY.services.com> wrote:

External Email

Mr. Levin: Unless if you have something factual and not vexatious, please refrain from

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sending our firm emails.

Thank you,

Kaitlyn Bunnell, Paralegal

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MCCARTHY & YERSEL, PLLC
4929 SW 74th CT
Miami, FL 33155
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Telephone: (305) 407-8006

Cell: (305) 335-5543
Fax: (866) 676-4671
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CONFIDENTIALITY NOTE: The information contained in this transmission is privileged and

confidential intended only for the use of the individua l or entity named above. lf the reader of this
message is not the intended recipient, you are hereby notified that any dissemination, distribution or
copying of this communication is strictly prohibited. lf you have received this transmission in error,
do not read it. Please immediately reply to the sender that you have received this communication in
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error and then delete it. Thank you.

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From: Levin, Neal H.<nhlevin@freeborn.com>

Sent: Tuesday, June 28, 2022 12:34 PM
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To: Kaitlyn Bunnell <lawclerk@mv.attornev.services.com>

Cc: Martin McCarthy <mccarthy..@mv.attornev.services.com>; Meaghan Murphy
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<mmurP-.bv@melandbudwick.com>; Emre Yersel <g_v.ersel@mv.attornev.services.com>; Isenberg, Shira

R. <sisenberg@freeborn.com>; roby.n.@adamsteinberglaw.com <robv.n@adamsteinberglaw.com>
Subject: Re: Deposition of Larry Schneider

Was he ·severely ill" at 3 a.m. w hen he w as conspiring with Martin over the appellate brief deadlines?
Was he "severely ill" at 9:12 this morning when you advised Larry of the new start time, per your email?
Was he "severely ill" at noon, when he w as supposed to be here and Martin indicated that they were 20 minutes
late?

On Jun 28, 2022, at 11 :22 AM, Kaitlyn Bunnell < lawclerk@myattorneY.services.com> wrote:

External Email

I have spoken with Mr. McCarthy, and it is our impression that Mr. Schneider is
severely ill; however, he is attempting to call him now and will advise thereafter.

https://outlook.office.corn/rnail/id/AAQkADg1 MTl3Y2I4LTlzMTUtNDA1Mi04ZWY3LTAwZGZhNzYyNjVmNQAQAltX3GUGHTN MnxYOiUWcgv0%30 2/7

7129122, 2:37 PM Mail - Kaitlyn Bunnell - Outlook

Thank you,

Kaitlyn Bunnell, Paralegal

MCCARTHY & YERSEL, PLLC
4929 SW 74th CT
Miami, FL 33155
Telephone: (305) 407-8006
Cell: (305) 335-5543
Fax: (866) 676-467 l

CONFIDENTIALITY NOTE: The information contained in this transmission is

privileged and confidential intended only for the use of the individua l or entity named
above. If the reader of this message is not tl1e intended recipient, you are hereby
notified that any dissemination, distribution or copying of this communication is stri ctly
prohibited. If you have received this transmission in en-or, do not read it. Please
immediate ly reply to the sender that you have received this communication in error and
then delete it. Thank you.

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From: Levin, Neal H. <nhlevin@freeborn.com>
Sent: Tuesday, June 28, 2022 12:14 PM

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To: Kaitlyn Bunnell <lawclerk@mv.attornev.services.com>; Martin McCarthy
<mccarthy.@mv.attornev.services.com>
Cc: Meaghan Murphy <J!l.!!lli.!Jl.b.y.@melandbudwick.com>; Emre Yersel
<g_v.ersel@mv.atto rnev.services.com>; Isenberg, Shira R.
<sisenbeni@freeborn.com>; roby.n.@adamsteinberglaw.com<robyn@adamsteinberg@

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w.com>
Subject: Re: Deposition of Larry Schneider

Here are the steps that need to be taken:

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1. Larry will join the Zoom call immediately to swear under oath as to his exposure, complete with
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name of the party to whom he was exposed for independent verification;
2. We will then set a date for the continued exam.
3. The fees and costs that we will seek include:
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Court Reporter, including Zoom charges

1 hour of non-prep counsel time for Meaghan
My travel time and expenses from Chicago

Zoom instructions:
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Join Zoom Meeting

htt12s://melandbudwick.zoom.us/j/87003876883?
12wd=SXN6NjdRYv.9oM0P-Y.VFA4ZHJORCtmdz09
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Meeting ID: 870 0387 6883

Passcode: 157518
One tap mobile
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+19292056099,,87003876883#,,,, *157518# US {New York)

+13017158592,,87003876883#,,,, * 157518# US {Washington DC)
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We look forward to Martin's agreement to the foregoing and Laurence and Martin joining the call
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shortly. We will wait until 12:30.

Neal

On Jun 28, 2022. at 11:04 AM, Kaitlyn Bunnell

<lawclerk@mY.attomeY.services.com> wrote:

External Email

Good afternoon Ms. Murphy,

I attempted to call your office; however, the call was disconnected

and I was unable to get through. Mr. Schneider has reached out to
us to advise that he was exposed to someone with covid, and is

https://oullook.office.com/mail/id/AAQkADg1 MTl3Y214LTlzMTUtNDA1Mi04ZWY3LTAwZGZhNzYyNjVmNQAQAltX3GUGHTN M nxYOiUWcgv0%3O 3/7

7129122, 2:37 PM Mail - Kaitlyn Bunnell - Outlook

now feeling ill. Mr. McCarthy asked that you provide us with the
invoice for the court reporter, and we will pay such.

My apologies for any inconveniences this may cause.

When possible, please provide us dates to reschedu le.

Further, please provide me with the Returns of Service for Jordyn

and Zachary Schneider.

lliank you,

Kaitlyn Bunnell, Paralegal

MCCARTHY & YERSEL, PLLC
4929 SW 74th CT
Miami, FL 33155
Telephone: (305) 407-8006

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Cell: (305) 335-5543
Fax: (866) 676-4671

CONFIDENTIALITY NOTE: The infomrntion contained in this

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transnussion is privileged and confidential intended only for the use of tlie
individual or entity named above. lfthe reader of this message is not the
intended recipient, you are hereby notified that any dissemination,
distribution or copying of this communication is strictly prohibited. If you
have received this transmission in en-or, do not read it. Please immediately

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reply to the sender that you have received this communication in error and
then delete it. Thank you.
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From: Meaghan Murphy <mmurruiy..@melandbudwick.com>
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Sent: Tuesday, June 28, 2022 6:59 AM
To: Martin McCarthy <mccarthy..@myattorneyservices.com>
Cc: Emre Verse! <~yersel@myattorneyservices.com>; Kaitlyn Bunnell
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<lawclerk@mv.attorneyservices.com>; Neal H. Levin

<n h levin@freeborn.com>
Subject: Re: Deposition of Larry Schneider
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Good morning,

We can move the start time today to noon to accommodate you and Mr.
Schneider.

As for Jordyn and Zachary, it is our opinion that that were properly serviced by
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substitute service on June 14 and expect them to appear tomorrow.

Meaghan Murphy
Meland Budwick, P.A.
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On Jun 28, 2022, at 2:52 AM, Martin McCarthy

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<mccarthy.@mY.attomeY.services.com> wrote:
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EXTERNAL EMAIL:
Dear Ms. Murphy:

My apologies for the after-hours email. Both myself and

Mr. Schneider had an unrelated appellate deadline
yesterday, Monday, June 27, 2022, which ran into the
evening. Due to this unforeseen but unavoidable delay
we could not speak until this evening. Mr. Schneider
bas requested that I reach out to determine whether you
would be willing to postpone his deposition to
Wednesday, June 29, 2022 (to my understanding neither
Zack or Jordyn have been served) beginning and ending
at your convenience, push back tomon-ow's start time to
1pm, and continue into either the morning or afternoon

https://oullook.office.com/mail/id/AAQkADg1 MTl3Y2l4LTlzMTUtNDA1Mi04ZWY3LTAwZGZhNzYyNjVmNQAQAltX3GUGHTN M nxYOiUWcgv0%3D 4/7

7129122, 2:37 PM Mail - Kaitlyn Bunnell - Outlook

of Wednesday, June 29, 2022, or at the minimum push

back today's starting ti.me to noon on Tuesday, June 28,
2022. Thank you for your consideration of these
req11ests. I cannot imagine cite Court Reporter will have
any objection due to the likelihood that Mr. Sclmeider's
deposition will be protracted due to the nan1re of the
Parties and their history.

I have a 830am Family motion calendar hearing, but I

will reach out to you al its conclusion.

Sincerely Yours,

Martin G. McCarthy, Esq.

MCCARTHY & YERSEL, PLLC
4929 SW 74th CT, Ste 5
Miami, Florida 33155

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(305) 407-8006 office
(866) 676-467 1 facsimile
(305)522-6224 cellular
email: mccarth:v.@m:v.attome:v.services.com

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Our Address Changed! Please note effective Februa1y
22, 2021 , our new Office Address is 4929 SW 74th CT,
Ste 5, Miami, f L 33155

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Confidentiality Notice: Thjs e-mail transmission, and
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any documents, files or previous e-mail messages
attached to it may contain confidential information that
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is legally privileged If you are not the intended
recipient, or a person responsible for del ivering it to the
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intended recipient, you are hereby notified that any

disclosure, copying, distribution or use of any of the
information contained in or attached to this
transmission is STRICTLY PROHIBITED. If you have
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received this transmission in error, please immediately

notify us by reply e-mail, or by telephone at the direct
dial number above and destroy the original transmission
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and its attachments without reading or saving in any

manner. Thank you.
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NEAL H. LEVIN
Attorney at Law
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<image001.jpg>

+1(312) 360-6530 direct

nhlevin@freebom.com

Freeborn & Peters LLP

311 Sout h Wacker Drive, Suite 3000
Chicago, IL 60606

www.freeborn.com

Neal H. Lev in Bio

Connect on Linkedln

https://outlook.office.com/mail/id/AAQkADg1MTl3Y2I4LTlzMTUtNDA1Mi04ZWY3LTAwZGZhNzYyNjVmNQAQAltX3GUGHTN MnxYOiUWcgv0%3D 5/7

7129122, 2:37 PM Mail - Kaitlyn Bunnell - Outlook
How the CelebritY. Surgeon Scu/12.ted His Prev.
Chicago [rain's Feature
Plav.book of.Fraud's Aftermath

NEAL H. LEVIN
Attorney at Law

<image001.jpg>

+1(312) 360-6530 direct

nhlevin@freeborn.com

Freeb orn & Peters LLP

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311 South Wacker Drive, Suite 3000
Chicago, IL 60606

www.freeborn.com

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Neal H. Levin Bio
Connect on Linkedln
How the CelebritY.. Surgeon Scu/12.ted His Prev.
Chicago [rain's Feature

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Plav.book of_ Fraud's Aftermath

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NEAL H. LEVIN
Attorney at Law
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<image001.jpg>
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+1(312) 360-6530 direct

nhlevin@freeborn.com

Freeborn & Peters LLP

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311 South Wacker Drive, Suite 3000

Chicago, IL 60606
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www.freeborn.com
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Neal H. Levin Bjo

Connect on linkedln
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How the CelebritY. Surgeon Scu/12.ted His Prev.

Chicago [rain's Feature
Playpook of_ Fraud's Aftermath

NEAL H. LEVIN
Attorney at Law

< image00 1Jpg >

+1(312) 360-6530 d irect

https://outlook.office.corn/mail/id/AAQkADg1 MTl3Y2I4LTlzMTUtNDA1Mi04ZWY3LTAwZGZhNzYyNjVmNQAQAltX3GUGHTN MnxYOiUWcgv0%3D 6/7
7129122, 2:37 PM Mail - Kaitlyn Bunnell - Outlook

nhlevin@freeborn.com

Freeborn & Peters LLP

311 South Wacker Drive, Suite 3000
Chicago, IL 60606

www.freeborn.com

Neal H. Levin Bio

Connect on LinkedIn

How the CelebritY.. Surgeon Sculeted His Prev..

Chicogo Crain's Feature

Plav..book of_ Fraud's Af!ermath

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NEAL H. LEVIN
Attorney at Law

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Freeborn ,-
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+1(312) 360-6530 direct
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nhlevin@freeborn.com

Freeborn & Peters LLP

311 South Wacker Drive, Suite 3000
CE

Chicago, IL 60606

www.freeborn.com
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Neal H. Levin Bio

Connect on Linkedln
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How the CelebritY.. Surgeon Sculeted His Prev..

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Chicago Crain's Feature

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Plav..book of.Fraud's Aftermath

https://outlook.office.corn/mail/id/AAQkADg1 MTl3Y2I4LTlzMTUtNDA1Mi04ZWY3LTAwZGZhNzYyNjVmNQAQAltX3GUGHTN M nxYOiUWcgv0%3D 717

Filing # 150956764 E-Filed 06/06/2022 06:21:58 PM

IN THE CIRCUIT COURT OF THE 15TH

JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA

CIRCUIT CIVIL DIVISION: AH

CASE NO. 50-2016-CA-009292-XXXX-MB

FIRST AMERICAN BANK, as successor

by merger to Bank of Coral Gables, LLC,

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Plaintiff,
vs.

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

Defendants.

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___________________________________/
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NOTICE OF TAKING DEPOSITION
Date and time coordinated with opposing counsel
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PLEASE TAKE NOTICE that pursuant to Florida Rule of Civil Procedure 1.310 and
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1.560, First American Bank will take the deposition of the below-named persons on the dates and
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times indicated below:

Name Date and Time Place

Laurence Schneider Tuesday, June 28, 2022 Meland Budwick, P.A.
A

at 10:00 a.m. EDT 200 S. Biscayne Blvd.

Suite 3200
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Miami, FL 33131
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N

Regarding the matters described in the subpoena attached hereto. The deposition will be taken
upon oral examination before a court reporter Veritext Court Reporter, Notary Public, in and for
the State of Florida at Large, or some other officer duly authorized by law to take deposition. This
deposition is being taken for discovery, use at trial, or any other purpose permitted under the Rules
of Civil Procedure and Rules of Evidence. The deposition will continue from hour to hour and
from day to day until completed.

MELAND I BUDWICK
3200 SOUTHEAST FINANCIAL CENTER I 200 SOUTH BISCAYNE BOULE VA RD I MIAMI , FL 33131 I T 305-358-6363
In accor<lance with the Americans with Disabilities Act of 1990, persons needing a special
accommodation to participate in this proceeding shouhl contact Meaghan E. Murphy, Esquire
at Melaml Budwick, P.A. telephone number (305) 358-6363, no later th,m seven (7) days prior
to the proceeding. If hearing impaire,l, telephone Florida Relay Service at 1-800-955-8771 for
assistance.

CERTIFICATE OF SERVICE

I CERTIFY that the foregoing document has been furnished to all registered users via the

PY
Florida Courts e-Filing Portal on June 6, 2022.

s/ Meaghan E. Murphy

CO
Meaghan E. Murphy, Esquire
Florida Bar No. 102770
lmmurphy@melandbudwick.com1
MELAND BUDWICK, P.A.

D
200 South Biscayne Boulevard, Suite 3200
Miami, Florida 33131
IE
Telephone: (305) 358-6363
Facsimile: (305) 358-1221
IF
Counsel for Plaintiff
RT

Email Designation per Fla. R. Jud.

Admin 2.516
melandbudwick.com
CE

ahoo.com
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N

MELAND I BUDWICK
3200 SOUTHEAST FINANCIAL CENTER I 200 SOUTH BISCAYNE BOULEVARD I MIAMI, FL 33131 I T 305-358-6363