Filing# 141580262 E-Filed 01/07/2022 02:19:45 PM

IN THE CIRCUIT COURT OF THE 15TH

mDICIAL 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,

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vs.

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

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Defendants.
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FIRST AMERICAN BANK'S MOTION FOR
WRIT OF GARNISHMENT TO 1sT FIDELITY LOAN SERVICING, LLC
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Plaintiff, First American Bank ("First American"), pursuant to section 77.03, Florida
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Statutes, requests that this Court issue a writ of garnishment against the Garnishee, 1st Fidelity

Loan Servicing, LLC ("Garnishee") and further states as follows:

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1. On September 22, 2020, this Court entered a Final Judgment ("Judgment") in

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favor of First American and ordered Defendant, Laurence Schneider ("Schneider") to pay First
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American $1,547,391.54, which shall bear interest at the 6.03% per year. A copy of the
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Judgment is attached as Exhibit A.

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2. As of the date of this Motion, the Judgment remains due and unsatisfied.

3. First American is unaware of any physical property owned by Schneider on which

a levy can be made to sufficiently satisfy the Judgment.

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

FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 01/07/2022 02:19:45 PM
 4. In full or partial satisfaction of the Judgment, First American seeks to garnish all

funds and property held by Garnishee belonging to Schneider.

5. First American has reason to believe that Garnishee is indebted to, or has tangible

or intangible personal property belonging to, Schneider in its possession or control that can be

used toward satisfaction of the outstanding Judgment.

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Therefore, First American requests that the Court issue a writ of garnishment against

Garnishee, in the form attached as Exhibit B, as to whatever tangible and intangible personal

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property belonging to Schneider that the Garnishee has in its possession or control.

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Dated: January 7, 2022.

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Respectfully submitted,

s/ Meaghan E. Murphy
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Meaghan E. Murphy, Esquire
Florida Bar No. 102770
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mmurphy@melandbudwick.com
Alina A. Gomez, Esquire
Florida Bar No. 1010500
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agomez@melandbudwick.com
MELAND BUDWICK, P.A.
200 South Biscayne Boulevard, Suite 3200
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Miami, Florida 33131

Telephone: (305) 358-6363
Facsimile: (305) 358-1221
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Co-Counselfor Plaintiff
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Email Designation per Fla. R. Jud.

Admin2.516
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mmurphy@melandbudwick.com
agomez@melandbudwick.com
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mramos@melandbudwick.com
mrbstate@yahoo.com

MELAND I BUDWICK
3200 SOUTHEAST FINANCIAL CENTER I 200 SOUTH BISCAYNE BOULEVARD I MIAMI, FL 33131 IT 305-358-6363
 CFN 20200357886
Filing# 113749101 E-Filed 09/22/2020 11:30:53 AM OR BK 31773 PG 704
RECORDED 09/24/2020 11 :03:56
Palm Beach County, Florida
AMT
IN THE CIRCUIT COURT OF Sharon R. Bock
THE FIFTEENTH JUDICIAL CIRCUIT CLERK & COMPTROLLER
IN AND FOR PALM BEACH COUNTY, FLORfl'Ii);~704-0706; (3Pgs)

CASE NO.: 502016-CA-009292

DMSION AH

FIRST AMERICAN BANK, as

successor by merger to Bank of
Coral Gables, LLC,

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Plaintiff,

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v.

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

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Defendants.
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FINAL JUDGMENT
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THIS ACTION came before the Court upon Plaintiff's, First American Bank, Motion for

Deficiency Judgment bearing a Certificate of Service dated August 27, 2020 [DE 533], the
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Amended Final Judgment of Foreclosure (Supplemental Judgment) dated February 26, 2020 [DE

384], the Certificate of Sale dated August 3, 2020 [DE 519], and the Certificate of Title dated
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August 17, 2020 [DE 525]. Accordingly, this Court having granted the Motion for Deficiency

Judgment by Order dated September 21, 2020, hereby enters this Final Judgment, whereby it is
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ORDERED AND ADJUDGED THAT:

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1. Judgment is GRANTED in favor of Plaintiff, FIRST AMERICAN BANK, and against

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Defendants, LAURENCE SCHNEIDER and STEPHANIE SCHNEIDER, jointly and

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severally.

2.Plaintiff, FIRST AMERICAN BANK, 540 Biltmore Way, Coral Gables, Florida

33134, shall recover from Defendants, LAURENCE SCHNEIDER, 17685 Circle Pond

Court, Boca Raton, Florida 33496-1002, Social Security No.: t,>y . ,,,,t,•u,.•£AZ( and

STEPHANIE SCHNEIDER, 17685 Circle Pond Court, Boca Raton, Florida 33496-

Page 1 of 3

FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 09/22/2020 11 :30:53 AM EXHIBIT A
 CFN 20200357886
BOOK 31773 PAGE 705
Case No.50-2016-CA-009292-X XXX-MB 2 OF 3

1002, Social Security No.: I/ .,,,,,.?-:~,·P"\'·' 1 the sum of $1,547,391.54, for which let

execution issue.

3. The Total Amount Due due shall bear interest at the rate of 6.03% per year.

4. The Comt previously determined that Plaintiff, FIRST AMERICAN BANK, is entitled

to reasonable attorneys' fees, costs, and expenses incurred in connection with this action.

Accordingly, the Court retains jurisdiction to determine the total amounts of attorneys' fees,

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costs, and expenses to which Plaintiff is further entitled, to enter further orders that are proper,

and to supplement the final deficiency judgment as appropriate.

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DONE AND ORDERED in Chambers in Palm Beach County, Florida.
_____ __:.·--------~
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~
50,2016;CA~00!J2!J2,XXXX•MB :_oo/22/2020
Samantha Schosbo{g Foucr:::Judgo
"'-----~~.::::§> .• ,, ··_..::..:_ __ _

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C:::--- ·-
sd-iorn:cA-009292~xxxx-MB 09i2212020
Samantha Schosberg f euer
Judge
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Copies furnished to:
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John W. Keller, III. Esq.

Keller & Mesa, LLP
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Attorneys for First American Bank

121 Majorca Avenue, #200
Coral Gables, FL 33134
Email:31celler@kellerbolz.com
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Laurence S. Schneider
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Defendant
17685 Circle Pond Court
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Boca Raton, FL 33496

Email: larry@sacapitalpartners.com
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Stephanie L. Schneider
Defendant
17685 Circle Pond Court
Boca Raton, FL 33496
Email: steffschneider13@gmail.com

Page 2 of3
 CFN 20200357886
BOOK 31773 PAGE 706
Case No. 50-2016-CA-009292-XXXX-MB 3 OF 3

Aleksandra Novakovich Gonzalez, Esq.

Sachs, Sax, Caplan
Attorneys for The Oaks at Boca Raton Property Owners' Association, Inc.
6111 Broken Sound Parkway, N.W., #200,
Boca Raton, FL33487
Email: agonzalez@ssclawfirm.com

Geoffrey M. Cahen, Esq.

Cahen Law, P.A.,
Attorneys for It's AN ew Day Corporation,
Real Estate & Finance, Inc., S&A
Capital Partners, Inc. Mortgage
Resolution Servicing, LLC and

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1' 1 Fidelity Loan Servicing, LLC
1900 Glades Road, Suite 270
Boca Raton, FL 3343 !Email: geoff@cahenlaw.com

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.!{..- -~ Page 3 of3

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I hereby certify the foregoing is a true copy of the record in my office

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with red tions, if any as required by law as of this day, Sep 22, 2021.
Joseph er , R Beach County, Florida.
BY ~elf.'t!~~~Lfl_{!__!:_~~~1Z==-□ eputy Clerk
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 IN THE CIRCUIT COURT OF THE 15TH
WDICIAL 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,

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STEPHANIE L. SCHNEIDER, et al.,

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Defendants.
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WRIT OF GARNISHMENT TO 1ST FIDELITY LOAN SERVICING, LLC

TO THE STATE OF FLORIDA:

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To All and Singular the Sheriffs of the State:

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Garnishee: 1st Fidelity Loan Servicing, LLC

c/o Laurence Schneider
1199 South Federal Highway
#369
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Boca Raton, FL 33432

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YOU ARE COMMANDED to summon the Garnishee, to serve an answer to this Writ of
Garnishment on Meaghan Murphy, Esq., Plaintiffs attorney, whose address is 200 South
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Biscayne Blvd., Suite 3200, Miami, FL 33131, within twenty (20) days after service on the
Garnishee, exclusive of the day of service, and to file the original with the Clerk of the Court
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either before service on the attorney or immediately thereafter, stating whether the Garnishee is
indebted to Defendant Laurence Schneider at the time of the answer or was indebted at the time of
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service of the Writ, or at any time between such times, and in what sum and what tangible and
intangible personal property of the Defendant Laurence Schneider the Garnishee is in possession
or control of at the time of the answer or had at the time of service of this Writ, or at any time
between such times, and whether the Garnishee knows of any other person indebted to the
Defendant Laurence Schneider or who may be in possession or control of any of the property of
the Defendant Laurence Schneider. The amount set forth in Plaintiffs motion is $1,547,391.54,
plus interest at 6.03% per year.

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EXHIBIT B
 Failure to file an answer within the time required may result in entry of judgment against
the Garnishee for the amount stated above.

Dated on this _ _ day of ______, 2022, in Palm Beach County, Florida.

By: _ _ _ _ _ _ _ _ _ _ __
JOSEPH ABRUZZO
Clerk of Courts

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 NOTICE TO DEFENDANT OF RIGHT AGAINST GARNISHMENT OF WAGES,
MONEY, AND OTHER PROPERTY
The Writ of Garnishment delivered to you with this Notice means that wages, money, and other
property belonging to you have been garnished to pay a court judgment against you. HOWEVER,
YOU MAY BE ABLE TO KEEP OR RECOVER YOUR WAGES, MONEY, OR PROPERTY.
READ THIS NOTICE CAREFULLY.
State and federal laws provide that certain wages, money, and property, even if deposited in a
bank, savings and loan, or credit union, may not be taken to pay certain types of court judgments.
Such wages, money, and property are exempt from garnishment. The major exemptions are listed

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below on the form for Claim of Exemption and Request for Hearing. This list does not include all
possible exemptions. You should consult a lawyer for specific advice.

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IF AN EXEMPTION FROM GARNISHMENT APPLIES TO YOU AND YOU WANT TO
KEEP YOUR WAGES, MONEY, AND OTHER PROPERTY FROM BEING GARNISHED,

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OR TO RECOVER ANYTHING ALREADY TAKEN, YOU MUST COMPLETE A FORM
FOR CLAIM OF EXEMPTION AND REQUEST FOR HEARING AS SET FORTH BELOW

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AND HAVE THE FORM NOTARIZED. IF YOU HAVE A VALID EXEMPTION, YOU
MUST FILE THE FORM WITH THE CLERK'S OFFICE WITHIN 20 DAYS AFTER THE
DATE YOU RECEIVE THIS NOTICE OR YOU MAY LOSE IMPORTANT RIGHTS. YOU
MUST ALSO MAIL OR DELIVER A COPY OF THIS FORM TO THE PLAINTIFF OR THE
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PLAINTIFF'S ATTORNEY AND THE GARNISHEE OR THE GARNISHEE'S ATTORNEY
AT THE ADDRESSES LISTED ON THE WRIT OF GARNISHMENT. NOTE THAT THE
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FORM REQUIRES YOU TO COMPLETE A CERTIFICATION THAT YOU MAILED OR

HAND DELIVERED COPIES TO THE PLAINTIFF OR THE PLAINTIFF'S ATTORNEY
AND THE GARNISHEE OR THE GARNISHEE'S ATTORNEY.
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If you request a hearing, it will be held as soon as possible after your request is received by the
court. The plaintiff or the plaintiffs attorney must file any objection within 8 business days if you
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hand delivered to the plaintiff or the plaintiffs attorney a copy of the form for Claim of
Exemption and Request for Hearing or, alternatively, 14 business days if you mailed a copy of the
form for claim and request to the plaintiff or the plaintiffs attorney. If the plaintiff or the
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plaintiffs attorney files an objection to your Claim of Exemption and Request for Hearing, the
clerk will notify you and the other parties of the time and date of the hearing. You may attend the
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hearing with or without an attorney. If the plaintiff or the plaintiffs attorney fails to file an
objection, no hearing is required, the writ of garnishment will be dissolved and your wages,
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money, or property will be released.

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IF YOU HAVE AVALID EXEMPTION, YOU SHOULD FILE THE FORM FOR CLAIM OF
EXEMPTION IMMEDIATELY TO KEEP YOUR WAGES, MONEY, OR PROPERTY FROM
BEING APPLIED TO THE COURT WDGMENT. THE CLERK CANNOT GIVE YOU
LEGAL ADVICE. IF YOU NEED LEGAL ASSISTANCE YOU SHOULD SEE A LAWYER.
IF YOU CANNOT AFFORD A PRIVATE LAWYER, LEGAL SERVICES MAY BE
AVAILABLE. CONTACT YOUR LOCAL BAR ASSOCIATION OR ASK THE CLERK'S
OFFICE ABOUT ANY LEGAL SERVICES PROGRAM IN YOUR AREA.

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 CLAIM OF EXEMPTION AND REQUEST FOR HEARING

I claim exemptions from garnishment under the following categories as checked:

_ _ 1. Headoffamilywages. (You must check a. orb. below.)
_ _ a. I provide more than one-half of the support for a child or other dependent and have net
earnings of$750 or less per week.
_ _ b. I provide more than one-half of the support for a child or other dependent, have net
earnings of more than $750 per week, but have not agreed in writing to have my wages garnished.
2. Social Security benefits.
3. Supplemental Security Income benefits.

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4. Public assistance (welfare).
5. Workers' Compensation.
6. Reemployment Assistance or Unemployment Compensation.

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7. Veterans' benefits.
8. Retirement or profit-sharing benefits or pension money.

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9. Life insurance benefits or cash surrender value of a life insurance policy or proceeds of
annuity contract.

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10. Disability income benefits.
11. Prepaid College Trust Fund or Medical Savings Account.
12. Other exemptions as provided by law.
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _(explain)

I request a hearing to decide the validity of my claim. Notice of the hearing should be given to me
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at:
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Address:
Telephone Number:
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I CERTIFY UNDER OATH AND PENALTY OF PERWRY that a copy of this CLAIM
OF EXEMPTION AND REQUEST FOR HEARING has been furnished by (circle one) United
States mail or hand delivery on (insert date)_ _ _ _, to: _ _ _ _ _ _ _ _ _ (insert names
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and addresses of Plaintiff or Plaintiffs attorney and of Garnishee or Garnishee's attorney to whom
this document was furnished).
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[CONTINUES ON NEXT PAGE]

I FURTHER CERTIFY UNDER OATH AND PENALTY OF PERWRY that the

statements made in this request are true to the best of my knowledge and belief.

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Defendant's signature
Date- - - - - - - - - - - - - -

STATE OF FLORIDA
COUNTY OF

Sworn and subscribed to before me this ____ day of (month and year), by (name of person
making statement)
Notary Public/Deputy Clerk

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Personally Known _ _ OR Produced Identification_ _
Type ofldentification Produced_ _ _ _ _ _ _ __

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