Filing# 138464493 E-Filed 11/13/2021 09:58:40 AM

IN THE COUNTY COURT OF THE FIFTEENTH JUDICIAL CIRCUIT

IN AND FOR PALM BEACH COUNTY, FLORIDA

FIRST AMERICAN BANK, as

successor by merger to Bank of
Coral Gables, LLC,

Plaintiff, CASE NO. 50-2016-C+ t92

CIVIL DIVISION: AH
V.

0~
Laurence S. Schneider,
Stephanie L. Schneider, et al.,
G
~
Defendants.
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EMERGENCY MOTION TO STAY S"ALE\OE'WDDUG8CB7GA232257

COMES NOW, Mercedes-Benz Finaneia Se , ices USA LLC ("MBFSUSA") 1 by and

2016 Mercedes Benz S550 with UG8CB7GA232257 ("vehicle"), that is scheduled to

be sold by Plaintiff for levy oft:a'gment against Defendants on November 18, 2021, and in support

of, states the following·

1. Financial Services USA LLC, 1s the lienholder of the

As lienholder, MBFSUSA's lien on the subject vehicle takes priority over all other

liens including the judgment that is the subject of this action. See Fla. Stat. § 679.3011.

3. MBFSUSA moves this Court in good faith, as priority lienholder of

WDDUG8CB7GA232257 to exercise its right to repossess the vehicle. To that end, the sale of

FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 11/13/2021 09:58:40 AM
said vehicle to levy the subject judgment must be stayed in order to afford MBFSUSA an extension

oftime to obtain a writ ofreplevin for the collateral that they hold a security interest in.

WHEREFORE, based on the foregoing Mercedes-Benz Financial Services USA LLC,

respectfully requests this Honorable Court to grant its Emergency Motion to Stay the sale of the

2016 Mercedes Benz S550 with VIN WDDUG8CB7GA232257 and for any others eh 1 leif this
Court deems just and proper.

Dated: November 13, 2021

Respectfully Submitted

I HEREBY CERTIFY th: o November 13, 2021, a true and correct copy of the
foregoing was electronically filed n orwarded via e-service to all parties listed on the service
list in Florida's E-filing portal

Goldfein LLC
Attorneys for Plaintiff
6750 N. Andrews Ave., Suite 200
Fort Lauderdale, FL 33309
Telephone: 470-610-0961
Facsimile: 678-666-5105
stephanie.brito@goldfeinclaims.com

By: Isl Stephanie Brito

Stephanie Brito, Esq.
Florida Bar No. 109654