From: Larry Schneider

To: aj@tantillolaw.com
Subject: Re: First American Bank ("FAB") v. Schneider
Date: Tuesday, August 29, 2017 1:39:00 PM
Attachments: RE First American Bank (FAB) v. Schneider.msg

Mr. Bolz,

Your response to the documents requested is woefully inadequate.

I do appreciate you providing me with all of the billing between Keller & Bolz and FAB concerning the
HELOC account on 17685 Circle Pond Ct. Boca Raton FL 33432. Although I do not want to sound
cynical or insinuate that you would be trying to once again trick me, thereby misrepresenting the
facts to Judge Ferrara, however, I want to confirm the following;

1. In my email dated Tuesday August 22, 2017,I requested;

“a comprehensive breakdown of the attorney’s fees you are claiming as part of this action,
and in conjunction with my payoff request. You have thus far provided me nothing more
than a blanket dollar amount, without a breakdown and itemization of the applicable
charges, costs, retainer amount(s), hours billed against the retainer, etc.”

2. In your response to this request, dated August 25, 2017 at 3:30 PM(below), the information
that you claim will be sent in by the end of day today, Monday, August 28, 2017, is stated
below as follows:

“We will email copies of those statements (from July 2016 through July 2017) to you on Monday.
Unfortunately, we are not going to be able to meet your unilaterally-scheduled deadline of Midnight
tonight.”

Unless you tell me otherwise, by the end of day today, I will interpret your answer to be providing
me with the full accounting of your representation on behalf of FAB, in any capacity, concerning my
HELOC, including legal fees and costs. You are representing to me that you have NOT billed FAB and
FAB has not compensated you personally or Keller & Bolz, in any manner whatsoever, prior to
initiating the foreclosure litigation in July 2016.   Again, You are specifically representing to me and
the Court, that you did NOT get compensated or provide any billing with the intent of being
compensated for the period of October 2015 through June 2016, from FAB or any other person or
entity, including but not limited to J.P. Morgan Chase Bank or any other counsel to J.P. Morgan
Chase Bank.

As you have expressed in your most recent frivolous motion to compel filed with the court, the
critical importance of the propety’s “present fair market value” is no more or no less important that
the amount of attorney’s fees and costs which you claim and represent are billed to FAB.

As you are likely aware, the maximum allowable attorney’s fees and costs for a Judicial Foreclosure
in the State of Florida, in accordance with HUD, Fannie Mae, Freddie Mac and the Veterans
Administration range from $2,800.00 to $3,450.00 (see below);
 · Freddie Mac allows $3,625.00 in attorney’s fees for a Judicial Foreclosure in the State of
Florida. http://www.freddiemac.com/singlefamily/service/pdf/exh57a.pdf

· The Veterans Administration allows $ 2,800.00 in attorney’s fees for a Judicial Foreclosure in
the State of Florida.
https://www.benefits.va.gov/HOMELOANS/documents/docs/allowable_attorney_fees.pdf

· Fannie Mae allows $3,450.00 in attorney’s fees for a Judicial Foreclosure in the State of
Florida. https://www.fanniemae.com/content/guide_exhibit/allowable-attorney-trustee-
foreclosure-fees.pdf

· The Department of Housing and Urban Development (“HUD”) allows $2,800.00 in attorney’s
fees for a Judicial Foreclosure in the State of Florida.
https://portal.hud.gov/hudportal/documents/huddoc?id=16-03ml.pdf

I intend to not only challenge the underlying facts of the foreclosure action, but also the amount of
attorneys costs and fees you have represented to the court. According to my calculations, you have
charged roughly one hundred times more for the litigation of this action, in which Plaintiff have
failed to produce any billing statements, requests for production, there has been no depositions, no
trial, etc.   Let me state this in a different way; you are representing to me and the court, that you
are charging and have legitimately earned, the fees and costs of approximately one hundred
foreclosures, to deprive me of my rights in this matter.

is worded differently than the information which I requested, concerning the ALL of the attorney’s
fees and costs that you are billing FAB concerning the ENTIRE history of my HELOC account.

about the reply to my numerous billing practices at FAB or any collusion between your firm and FAB,
as it would have very serious consequences and repercussions; I am concerned that you

As you are likely aware,

· Freddie Mac allows $3,625.00 in attorney’s fees for a Judicial Foreclosure in the State of
Florida. http://www.freddiemac.com/singlefamily/service/pdf/exh57a.pdf

· The Veterans Administration allows $ 2,800.00 in attorney’s fees for a Judicial Foreclosure in
the State of Florida.
https://www.benefits.va.gov/HOMELOANS/documents/docs/allowable_attorney_fees.pdf

· Fannie Mae allows $3,450.00 in attorney’s fees for a Judicial Foreclosure in the State of
Florida. https://www.fanniemae.com/content/guide_exhibit/allowable-attorney-trustee-
foreclosure-fees.pdf

· The Department of Housing and Urban Development (“HUD”) allows $2,800.00 in attorney’s
fees for a Judicial Foreclosure in the State of Florida.
 https://portal.hud.gov/hudportal/documents/huddoc?id=16-03ml.pdf

For numerous purposes, including that of a voluntary good faith bond offered xxx. I anticipate that

Sent from my iPhone

On Aug 25, 2017, at 3:30 PM, Henry Bolz <hbolz@kellerbolz.com> wrote:

Mr. Schneider:

We are in the process of redacting privileged Attorney-Client and Work Product entries
from Keller & Bolz LLP’s monthly statements to FAB. I anticipate finishing that exercise
over the weekend.

We will email copies of those statements (from July 2016 through July 2017) to you on
Monday. Unfortunately, we are not going to be able to meet your unilaterally-
scheduled deadline of Midnight tonight.

Regards.

Henry H. Bolz, III

Keller & Bolz, LLP
121 Majorca Avenue, #200
Coral Gables, FL  33134
Telephone: (305) 529-8500
Telefax: (305) 529-0228
E-mail: hbolz@kellerbolz.com

______________________

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From: Larry Schneider [mailto:larry@sacapitalpartners.com]

Sent: Tuesday, August 22, 2017 1:04 PM
To: Henry Bolz <hbolz@kellerbolz.com>; Stephanie Schneider
(steffschneider13@gmail.com) <steffschneider13@gmail.com>
Cc: Garry Smith (gsmith@firstambank.com) <gsmith@firstambank.com>
Subject: RE: First American Bank ("FAB") v. Schneider

Mr. Bolz,

In preparation for our September 1, 2017 special set hearing, I am requesting a

comprehensive breakdown of the attorney’s fees you are claiming as part of this
action, and in conjunction with my payoff request. You have thus far provided me
nothing more than a blanket dollar amount, without a breakdown and itemization of
the applicable charges, cots, retainer amount(s), hours billed against the retainer, etc.
As I have repeatedly asked for this information, as well as an accurate payoff, I am
going to request this information one last time and request you provide the same to
me by midnight, August 25, 2017, prior to requesting the court compel this
information. Please provide this information by the requested date either via email, or
fax, otherwise I will seek judicial intervention.

Per your email below, you state that;

“Although FAB has not yet applied for an award of attorneys’ fees, FAB has
incurred attorneys’ fees and costs through July 2017 in the total amount of
$285,974.37.”

Attached is an email which I sent to you on June 13, 2017 (1:58 PM), requesting the
above referenced information, as well as copies FAB billing statements between
January 1, 2015 through June, 2017(Copy of Nov. 30, 2015 Letter attached). As you
recall, per your November 30, 2015 addressed to me, you specifically stated;

“All further requests for information or documents that in any fashion relate to
the $1,500,000.00 HELOC loan that was originated on July 28, 2006, should be
addressed to the undersigned at the address on this correspondence.

The letter was signed by Henry H. Bolz, III and was prepared on Keller & Bolz
letterhead.

As such, you have an obligation to provide me the information which I have continued
to request pursuant to federal and state mortgage servicing and consumer protection
laws. At the very least, I need the monthly periodic billing statements which FAB sent
or claimed to have sent during that period.

I have also made numerous timely requests for the production of documents which
FAB has still not been provided. Please provide me the FAB production which I have
requested. This is all important documentation, which I have the right to obtain and
FAB has an obligation to provide concerning this litigation.

This evidence is necessary to provide the court with an accurate understanding of the
facts of the case. As such, I am going to request this information one last time and
request you provide the same to me by midnight, August 25, 2017, prior to requesting
the court compel this information.

Thank you in advance for your cooperation.

Larry Schneider
305-710-4201

From: Henry Bolz [mailto:hbolz@kellerbolz.com]

Sent: Friday, August 11, 2017 3:43 PM
To: Larry Schneider; Stephanie Schneider (steffschneider13@gmail.com)
Cc: Garry Smith (gsmith@firstambank.com)
Subject: First American Bank ("FAB") v. Schneider

Dear Mr. Schneider,

Your email to me at 12:37 p.m. on August 8, 2017 requested, among other

things, “a payoff letter, good through August 11, 2017.” Although we are
uncertain as to exactly what you are looking for when you refer to a
“payoff letter,” we think that the following information should fully respond
to your request in this regard.

At the time that the Final Judgment of Foreclosure was entered by the
Palm Beach Circuit Court on June 26, 2017, amounts due, owing and
unpaid existed in the following categories:

Unpaid Principal $1,488,554.76

Interest from March 16, 2016 (the date of

First American Bank’s receipt of your last
payment on the HELOC) through June 26,
2017 69,646.52

            Unpaid Ad Valorem Real Property Taxes

(2014, 2015 and 2016)        66,870.93

Total Amount of Final Judgment in

Foreclosure $1,625,072.21

The Final Judgment of Foreclosure stated that the Final Judgment amount
“shall bear interest at the rate of 5.05% per year” (Florida’s statutory rate
of interest on the date that the Final Judgment of Foreclosure was
entered). Interest on the Final Judgment of Foreclosure at 5.05%
translates to $224.84 per day. Between June 27, 2017 and August 15,
2017, there have been 50 days, which translates to an additional interest
of $11,242.00 having accrued.

Although FAB has not yet applied for an award of attorneys’ fees, FAB has
incurred attorneys’ fees and costs through July 2017 in the total amount of
$285,974.37.

At the present time, the total outstanding mortgage debt, including

attorney’s fees and costs, is $1,922,288.58. You can consider this figure
to be the amount which, if paid to FAB by August 15, 2017, FAB will
accept as full and complete payment/resolution of those claims which FAB
is asserting against Laurence Schneider and Stephanie Schneider in this
foreclosure litigation.

Regards,

Henry H. Bolz, III

Keller & Bolz, LLP
121 Majorca Avenue, #200
Coral Gables, FL  33134
Telephone: (305) 529-8500
Telefax: (305) 529-0228
E-mail: hbolz@kellerbolz.com

______________________

IMPORTANT: THIS E-MAIL, AND ANY ATTACHMENTS THERETO, IS INTENDED FOR THE USE OF THE
INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS LEGALLY
PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. IF THE READER
OF THIS E-MAIL IS NOT THE INTENDED RECIPIENT, OR THE EMPLOYEE OR AGENT RESPONSIBLE FOR
DELIVERING THE E-MAIL TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY
DISSEMINATION, DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU
HAVE RECEIVED THIS E-MAIL IN ERROR, PLEASE IMMEDIATELY NOTIFY THE SENDER BY E-MAIL OR
TELEPHONE (IF CONTACT INFORMATION IS PROVIDED) AND PERMANENTLY DELETE THE ORIGINAL OR ANY
PRINTOUT THEREOF.