Filing # 159107364 E-Filed 10/12/2022 04:09:05 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.,

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Defendants.
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PLAINTIFF’S MOTION FOR

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DEFAULT AGAINST GARNISHEE 1ST FIDELITY LOAN SERVICING, LLC
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Plaintiff, First American Bank (“First American”), by and through undersigned counsel,

pursuant to Fla. Stat. § 77.081, moves for the entry of a default against garnishee 1st Fidelity
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Loan Servicing, LLC (“Garnishee”) upon the following grounds:

1. On September 15, 2022, a Writ of Garnishment directed to Garnishee was issued

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in this proceeding (“Writ of Garnishment”).

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2. On September 23, 2022, Brickell Courier Services filed its Return of Service
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stating that a true copy of the Writ of Garnishment was served on the Garnishee on
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September 20, 2022.

3. Accordingly, the deadline for Garnishee to file its Answer was October 11, 2022.

4. Based upon the foregoing, the Plaintiff moves for entry of default by the Clerk

against Garnishee for failure to serve or file any paper as required by law.


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MELAND | BUDWICK
3200 SOUTHEAST FINANCIAL CENTER | 200 SOUTH BISCAYNE BOULEVARD | MIAMI, FL 33131 | T 305-358-6363
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 10/12/2022 04:09:05 PM ***
 WHEREFORE, the Plaintiff requests the Court to direct the Clerk of the above Court to

issue a Default against garnishee 1st Fidelity Loan Servicing, LLC, and for such other relief as

this Court deems just and proper.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that, on October 12, 2022, a true and correct copy of the

foregoing was mailed via U.S. Mail to: 1st Fidelity Loan Servicing, LLC, by and through its

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Registered Agent, Laurence Schneider, 2000 Island Blvd, Unit 2001, Aventura, FL 33160;

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Laurence Schneider, 2000 Island Blvd., Unit 2001, Aventura, FL 33160; Laurence Schneider,

1199 South Federal Highway, Boca Raton, FL 33437; and Martin G. McCarthy, Esq., McCarthy

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& Yersel, PLLC, 4929 SW 74th Court, Miami, FL 33155 
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Respectfully submitted,
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s/ Meaghan E. Murphy
Meaghan E. Murphy, Esquire
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Florida Bar No. 102770

mmurphy@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-Counsel for Plaintiff

Email Designation per Fla. R. Jud.

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Admin 2.516
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mmurphy@melandbudwick.com
mramos@melandbudwick.com
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mrbstate@yahoo.com

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