Filing# 146132324 E-Filed 03/21/2022 10:28:53 PM

RETURN OF SERVICE

State of Florida County of Palm Beach Circuit Court

Case Number: 50-2016-CA-009292-XXXX-MB

Pfaintiff:
FIRST AMERICAN BANK, as successor by merger to Bank of Coral

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Gables, LLC
vs.
Defendant:

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

For:

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Meaghan Murphy
MELAND & BUDWICK, P.A.
200 South Biscayne Blvd., Suite 3200

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Miami, FL 33131

Received by Brickell Courier Services on the 8th day of March, 2022 at 5:00 pm to be served on 1st Fidelity
Loan Servicing, LLC c/o Laurence Schnefder, 1199 South Federal Highway# 369, Boca Raton, FL .,·
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33432.

b Susan Pineiro, do hereby affirm that on the 9th day of March, 2022 at 5:30 pm, I:
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SUBSTITUTE served by delivering a true copy of the Subpoena Duces Tecum for Production of
Documents and Things Without Deposition Add Schedule A with the date and hour of service
endorsed thereon by me, to: Muriel Schneider as Mother Of Registered Agent at the address of: 10172
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Chestwood Rd., Boynton Beach, FL 33437, the within named person's usual place of Abode, who
resides therein, who is fifteen (15) years of age or older and informed said person of the contents therein,
in compliance with state statutes.
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I ,certify that I am over the age of 18, have no interest in the above action, and am a Certified Process
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Server, in good standing, in the judicial circuit in which the process was served. Under penalty of perjury, I
declare that I have read the forgoing return of service and that the facts stated in it true per F.S. 92.535(2).
Notary not required
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. t'.iusaneiro
Process Server# 1644

Brickell Courier Services

P:O Box 01-1310
. Miami, FL 33101
(305) 350-3224

Our Job Serial Number: BKS-2022000248

Copyright@ 1992-2022 Database Sa!vices, Inc. - Process Seive<'s Toolbox V8.1c

'* FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 03/21/2022 10:28:53 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-XXX X-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.,

Defendants.

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_________ ______/
SUBPOENA DUCES TECUMFOR PRODUCTION
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OF DOCUMENTS AND THINGS WITHOUT DEPOSITION
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THE STATE OF FLORIDA:

TO: 1st Fidelity Loan Servicing, LLC

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c/o Laurence Schneider

1199 South Federal Highway
#369
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Boca Raton, FL 33432

YOU ARE HEREBY COMMANDED to mail to the offices of MELAND BUD WICK,
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P.A., 3200 Southeast Financial Center, 200 South Biscayne Boulevard., Miami, Florida 33131
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on or before 10:00a.m., March 25, 2022, the following:

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SEE SCHEDULE "A" ATTACHED HERETO

These items will be inspected and may be copied at that time. You will not be required to

surrender the original items. You may comply with this Subpoena by providing legible copies of

the items to be produced to the attorney whose name appears on this Subpoena on or before the

scheduled date of production. You may condition the preparation of the copies upon the payment
in advance of the reasonable cost of preparation. You may mail, email, or deliver the copies to

the attorney whose name appears on this Subpoena and thereby eliminate your appearance at the

time and place specified above. You have the right to object to the production pursuant to this

Subpoena at any time before production by giving written notice to the attorney whose name

appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE

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TAKEN.

If you fail to:

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(1) appear as specified; or

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(2) furnish the records instead of appearing as provided above; or
(3) object to this Subpoena,

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you may be in contempt of court. You are subpoenaed to appear by the following attorney, and
unless excused from this Subpoena by this attorney or the court, you shall respond to this
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subpoena as directed.
Dated: March 8, 2022.
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Meaghan E. Murphy
ER

Meaghan E. Murphy, Esquire

For the Court
MELAND BUDWICK, P.A.
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3200 Southeast Financial Center

200 South Biscayne Boulevard
Miami, Florida 33131
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Telephone: (305) 358-6363

Facsimile: (305) 358-1221
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In accordance with the Americans with Disabilities Act of 1990, persons needing a special
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accommodation to participate in this proceeding should contact Meaghan Murphy, Esquire at

Meland Budwick, P.A. telephone number (305) 358-6363, no later than two (2) days prior to
the proceeding. If hearing impaired, telephone Florida Relay Service at 1-800-955-8771 for
assistance.

2
 SCHEDULE A

INSTRUCTIONS

(I) All documents produced pursuant hereto are to be produced as they are kept in the

usual course of business or shall be organized and labeled (without permanently marking the

item produced) so as to correspond with the categories of each numbered request hereof.

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(2) Each draft, final document, original, reproduction, and each signed and unsigned

document and every additional copy of such document where such copy contains any

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commentary, note, notation or other change whatsoever that does not appear on the original or on

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the copy of the one document produced shall be deemed and considered to constitute a

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separate document.

(3) If any of the documents encompassed by the attached request for production of
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documents are deemed by you to be privileged, furnish all non-privileged documents and provide
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a log outlining all documents claimed as privileged that includes: (a) the type of privilege
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claimed for each document; (b) a brief description of the document; (c) the author of the

document sufficient to identify it; (d) the recipient(s) (if any); and (e) the date of the document.
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(4) When appropriate, the singular form of a word should be interpreted in the plural
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as may be necessary to bring within the scope hereof any documents which might otherwise be
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construed to be outside the scope hereof.

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(5) Electronically stored information must be produced in a manner as not to alter the
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document or any metadata associated with that document.

(6) Unless another time period is specified, this Request is addressed to documents

created since January 1, 2016.

3
 DEFINITIONS

All references to any Person (as defined below) includes his/her/its employees, agents,

servants, subsidiaries, parent company, affiliated company and any other person or entity or

Representative (as defined below) acting or purporting to act on behalf or under his/her control.

A. The connectives "and" and "or" shall be construed either disjunctively or

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conjunctively as necessary to bring within the scope of the discovery request all responses that

might otherwise be construed to be outside of its scope.

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B. "Document(s)" include every record of every type, and this term is used in the

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broadest sense and includes any medium upon which intelligence or information can be recorded

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and further includes all originals, nonidentical copies, and drafts of the following items, whether

printed, handwritten, typed, recorded, or stored on any computer or electro-magnetic storage

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device, or reproduced by hand, and whether or not claimed to be privileged or otherwise
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excludable from discovery, including without limitation: correspondence, Communications, e-

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mails, text messages (generated from any application or messaging program), voicemails,

memoranda, invoices, receipts, records, ledger cards or other accounting records, vouchers,
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checks, shop orders, diaries, policies, calendar entries, instructions, summaries of personal
A

conversations or interviews, minutes or records of meetings or conferences, transcripts, opinions

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or reports of consultants, projections, drafts, contracts, agreements, confirmations, statistical

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statements, studies, telegrams, telexes, books, notes, reports, logs, tape recordings, computer
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files, video cassettes, data compilations from which information can be obtained, charts,

photographs, notebooks, drawings, plans, printed materials of any kind, charts, financial

statements, tax returns, QuickBooks or related accounting or bookkeeping files, interoffice

communications, and any other writing of any description.

4
 C. "Including" means including but not limited to.

D. "You" and "Your" refers to you, then entity to whom this subpoena is directed,

and all Persons acting on your behalf or under your control.

E. "Person" or "Persons" includes any individual, business, firm, joint venture,

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partnership, corporation, group, association or organization, and reference to any person

throughout these requests includes such person's agent, officer, employer, employee,

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representative, contractor, sub-contractor and attorney.

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F. "Laurence Schneider" shall mean Laurence S. Schneider and all Persons acting on

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his behalf or under his control. Laurence Schneider's identifying information is as follows: (a)

date of birth: September 18, 1968; and (b) last known address: 628 SE 5th Street, #2, Delray
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Beach, FL 33483. Additional identifying information may be provided upon request.
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G. "Stephanie Schneider" shall mean Stephanie L. Schneider and all Persons acting
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on her behalf or under her control. Stephanie Schneider's identifying information is as follows:

(a) date of birth: May 13, 1968; and (b) last known address: 628 SE 5th Street, #2, Delray Beach,
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FL 33483. Additional identifying information may be provided upon request.

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H. The use of the singular form of any word includes the plural and vice versa.
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 DOCUMENTS TO BE PRODUCED

For the period January 1, 2016 to the present, unless otherwise noted, You are directed

to produce the following Documents:

1. All contracts and agreements between you and Laurence Schneider.

2. For the time period of January 1, 2018 to the present, all contracts and agreements

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between you and Stephanie Schneider.

3. Documents evidencing all payments or transfers you have made to Laurence

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Schneider and the reasons for such payments.

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4. For the time period of January 1, 2018 to the present, documents evidencing all

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payments or transfers you have made to Stephanie Schneider and the reasons for such payments.

5. For the time period of January 1, 2018 to the present, documents evidencing all
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payments or transfers you have made to Jordyn Schneider and the reasons for such payments.
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6. For the time period of January 1, 2018 to the present, documents evidencing all
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payments or transfers you have made to Zachary Schneider and the reasons for such payments.

7. Documents evidencing any payments you have made to third parties for debts
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owed by or services performed for Laurence Schneider.

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8. For the time period of January 1, 2018 to the present, documents evidencing any
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payments you have made to third parties for debts owed by or services performed for Stephanie
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Schneider.
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9. Documents sufficient to identify your members and their membership interests.

10. Documents sufficient to identify your officers and/or directors.

11. Documents sufficient to identify the individual(s) that control any of your bank

accounts.

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in advance of the reasonable cost of preparation. You may mail, email, or deliver the copies to

the attorney whose name appears on this Subpoena and thereby eliminate your appearance at the

time and place specified above. You have the right to object to the production pursuant to this

Subpoena at any time before production by giving written notice to the attorney whose name

appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE

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TAKEN.

If you fail to:

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( 1) appear as specified; or

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(2) furnish the records instead of appearing as provided above; or
(3) object to this Subpoena,

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you may be in contempt of court. You are subpoenaed to appear by the following attorney, and
unless excused from this Subpoena by this attorney or the court, you shall respond to this
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subpoena as directed.
Dated: March 8, 2022.
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MeaghanE.Murphy
ER

Meaghan E. Murphy, Esquire

For the Court
MELAND BUDWICK, P.A.
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3200 Southeast Financial Center

200 South Biscayne Boulevard
Miami, Florida 33131
A

Telephone: (305) 358-6363

Facsimile: (305) 358-1221
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In accordance with the Americans with Disabilities Act of 1990, persons needing a special
N

accommodation to participate in this proceeding should contact Meaghan Murphy, Esquire at

Meland Budwick, P.A. telephone number (305) 358-6363, no later than two (2) days prior to
the proceeding. If hearing impaired, telephone Florida Relay Service at 1-800-955-8771 for
assistance.

2
 SCHEDULE A

INSTRUCTIONS

( 1) All documents produced pursuant hereto are to be produced as they are kept in the

usual course of business or shall be organized and labeled (without permanently marking the

item produced) so as to correspond with the categories of each numbered request hereof.

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(2) Each draft, final document, original, reproduction, and each signed and unsigned

document and every additional copy of such document where such copy contains any

O
commentary, note, notation or other change whatsoever that does not appear on the original or on

C
the copy of the one document produced shall be deemed and considered to constitute a

ED
separate document.

(3) If any of the documents encompassed by the attached request for production of
FI
documents are deemed by you to be privileged, furnish all non-privileged documents and provide
TI

a log outlining all documents claimed as privileged that includes: (a) the type of privilege
ER

claimed for each document; (b) a brief description of the document; (c) the author of the

document sufficient to identify it; (d) the recipient(s) (if any); and (e) the date of the document.
C

(4) When appropriate, the singular form of a word should be interpreted in the plural
A

as may be necessary to bring within the scope hereof any documents which might otherwise be
T

construed to be outside the scope hereof.

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(5) Electronically stored information must be produced in a manner as not to alter the
N

document or any metadata associated with that document.

( 6) Unless another tirne period is specified, this Request is addressed to documents

created since January 1, 2016.

3
 DEFINITIONS

All references to any Person (as defined below) includes his/her/its employees, agents,

servants, subsidiaries, parent company, affiliated company and any other person or entity or

Representative (as defined below) acting or purporting to act on behalf or under his/her control.

A. The connectives "and" and "or" shall be construed either disjunctively or

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conjunctively as necessary to bring within the scope of the discovery request all responses that

might otherwise be construed to be outside of its scope.

O
B. "Document(s)" include every record of every type, and this term is used in the

C
broadest sense and includes any medium upon which intelligence or information can be recorded

ED
and further includes all originals, nonidentical copies, and drafts of the following items, whether

printed, handwritten, typed, recorded, or stored on any computer or electro-magnetic storage

FI
device, or reproduced by hand, and whether or not claimed to be privileged or otherwise
TI

excludable from discovery, including without limitation: correspondence, Communications, e-

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mails, text messages (generated from any application or messaging program), voicemails,

memoranda, invoices, receipts, records, ledger cards or other accounting records, vouchers,
C

checks, shop orders, diaries, policies, calendar entries, instructions, summaries of personal
A

conversations or interviews, minutes or records of meetings or conferences, transcripts, opinions

T

or reports of consultants, projections, drafts, contracts, agreements, confirmations, statistical

O

statements, studies, telegrams, telexes, books, notes, reports, logs, tape recordings, computer
N

files, video cassettes, data compilations from which information can be obtained, charts,

photographs, notebooks, drawings, plans, printed materials of any kind, charts, financial

statements, tax returns, QuickBooks or related accounting or bookkeeping files, interoffice

communications, and any other writing of any description.

4
 C. "Including" means including but not limited to.

D. "You" and "Your" refers to you, then entity to whom this subpoena is directed,

and all Persons acting on your behalf or under your control.

E. "Person" or "Persons" includes any individual, business, firm, joint venture,

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partnership, corporation, group, association or organization, and reference to any person

throughout these requests includes such person's agent, officer, employer, employee,

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representative, contractor, sub-contractor and attorney.

C
F. "Laurence Schneider" shall mean Laurence S. Schneider and all Persons acting on

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his behalf or under his control. Laurence Schneider's identifying information is as follows: (a)

date of birth: September 18, 1968; and (b) last known address: 628 SE 5th Street, #2, Delray
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Beach, FL 33483. Additional identifying information may be provided upon request.
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G. "Stephanie Schneider" shall mean Stephanie L. Schneider and all Persons acting
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on her behalf or under her control. Stephanie Schneider's identifying information is as follows:

(a) date of birth: May 13, 1968; and (b) last known address: 628 SE 5th Street, #2, Delray Beach,
C

FL 33483. Additional identifying information may be provided upon request.

A

H. The use of the singular form of any word includes the plural and vice versa.
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O
N

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 DOCUMENTS TO BE PRODUCED
For the period January 1, 2016 to the present, unless otherwise noted, You are directed

to produce the following Documents:

1. All contracts and agreements between you and Laurence Schneider.

2. For the time period of January 1, 2018 to the present, all contracts and agreements

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between you and Stephanie Schneider.

3. Documents evidencing all payments or transfers you have made to Laurence

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Schneider and the reasons for such payments.

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4. For the time period of January 1, 2018 to the present, documents evidencing all

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payments or transfers you have made to Stephanie Schneider and the reasons for such payments.

5. For the time period of January 1, 2018 to the present, documents evidencing all
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payments or transfers you have made to Jordyn Schneider and the reasons for such payments.
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6. For the time period of January 1, 2018 to the present, documents evidencing all
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payments or transfers you have made to Zachary Schneider and the reasons for such payments.

7. Documents evidencing any payments you have made to third parties for debts
C

owed by or services performed for Laurence Schneider.

A

8. For the time period of January 1, 2018 to the present, documents evidencing any
T

payments you have made to third parties for debts owed by or services performed for Stephanie
O

Schneider.
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9. Documents sufficient to identify your members and their membership interests.

10. Documents sufficient to identify your officers and/or directors.

11. Documents sufficient to identify the individual(s) that control any of your bank

accounts.