D.E. 140 Vacate, July 18, 2017

Filing # 59196253 E-Filed 07/18/2017 10:13:06 PM
EXHIBIT A
Larry Schneider
From: La rry Schneider

Sent: Thursday, June 08, 2017 12:11 PM
To: Henry Bolz
Cc: steffschneider13@gmail .com
Subject: Notice of Unavailability
Attachments: Document.pdf; Sch neider v JPMC Appeal as Docket 17-7003.pdf; Schneider v JPMC
Appeal 17-7003- Order Approving Bri ef of t he U.S., May ....pdf
Mr. Bolz,
I have been asked by counsel in the False Claim Act Chase against JPMorgan Cha se, to be in Washington D.C. the week of
June 12th, 2017- June 15th, 2017. As such, both my wife and I are unavailable for your emergency hearing you have set
for Monday, June 12, 2017 (to coincide w ith your vacation schedule and deny me fair access to justice).
The reason for the request is that the United States Office of t he Solicitor General, has filed a motion for an extension to
f ile an Amicus Brief in pending Schneider v. JPMorgan Chase False Claims Act. The U.S. appeal s court case 17-7003. On
May 17, 2017, the United States Office of the Solicitor General requested the court grant an extension to file a brief of
Amicus Curiae (see 28 C.F.R. § 0.20.0).
The United States Office of the Solicitor General's Motion states the following:
This appeal arises from a qui tam suit brought under the False Claims Act (FCA}, 31 U.S.C. § 3729 et
seq. Among other things, the relator alleges that Chase falsely claimed to have complied with several
requirements under the National Mortgage Settlement consent judgment in order to avoid making additional
payments to the United States, and that Chase submitted false certifications to obtain payments under the
Department of Treasury's Home Affordable Modification Program and/or concealed material information
relevant to those payments.
The United States asks the Court's leave to file such a brief as amicus curiae by June 14, 2017, if approved by
the Solicitor General. This extension is necessary to permit the Solicitor General to consult with relevant
government components and for the government to prepare a brief, if authorized, in accord with the Solicitor
General's instructions.
The issues presented by this appeal are of importance to the United States, and an amicus brief filed by the
United States may be of assistance to the Court in this case. As False Claims Act suits are brought in the name
and on behalf of the United States. The United States was a party to the National Mortgage Settlement, the
terms of which are at issue in this case, and to other contracts and settlements that can give rise to suits under
the False Claims Act. The United States also operates the Home Affordable Modification Program that may
be at issue in this appeal.
The requested extension should not prejudice any party. As noted, the appellee's brief is currently due on July
17, 2017, and the appellant's reply brief is due on July 31, 2017. Therefore, if the United States were to file an
amicus brief by June 14, 2017, there would be ample time under the existing schedule for both parties to
address any issues raised in the government's brief. We have conferred with counsel for both parties and are
authorized to state that this motion is unopposed.
CONCLUSION
1
For the foregoing reasons, we respectfully request that the Court extend the time, to and including June
14, 2017, for the United States to file an amicus brief in support of appellant or neither party if authorized
by the Solicitor General.
On May 9, 2017, the United States Solicitor General' s motion for extension to file an Amicus Brief by Wednesday, June
14, 2017 was granted by the Court of Appeals for the District of Columbia (attached).
I also want to let you know in full disclosure, that the State of Florida along with eighteen other States and the District of
Columbia have an ongoing interest in this litigation, as these States Attorney General's Offices were also plaintiff's in the
dismissed federal FCA action, as these States also have simila r False Claims Act Laws.
I have been advised by cou nsel in the matter, to be available for meetings with various members of the United States
Department of Justice, the United States Office of the Solicitor General and several regulators and agencies of the
Federal Government, starting early Monday morning June 12, 2017 through after hours June 14, 2017, if
necessary. Thus, our depositions will also need to be rescheduled. I request that we begin to have a bi-lateral meet
and confer process regarding the litigation in this matter, rather than your numerous and expeditious filings, in which
you have not met your obligation as to numerous meet and confer responsibilities.
Please let me know if you oppose my motion to reschedu le the pending June 12, 2017 hearing and rescheduling the
depositions scheduled for June 13, 2017 and June 14, 2017 in the case of First American Bank v. Schneider pending in
the Palm Beach Circuit Court. Please let me know by 3:00 p.m.via written communication.
Sincerely,
Larry Schneider
305-710-4201
[email protected]
2
larry Schneider
From: Larry Schneider

Sent: Tuesday, June 13, 2017 1:58PM
To: Henry Bolz
Subject: Schneider/FAB
Mr. Bolz,
I hope that you had a productive trip to Newark last week and returned safely.
Wearing my hat as the borrower in this matter, please provide me w ith detailed payoff figures for the HELOC, which
specifically breaks out the outstanding principal balance, interest rate, per diem, late charges, corpo rate advances, legal
fees, costs and any other line items utilized in calculating the payoff figures. Also, please break down the nature and
scope of each, billing increment periods by which you billed, along with the hourly rates which you command and in
which any of t he other attorney's, paralegals and anyone else who aided you in t he prosecution have billed. Also, please
notate as whether any of t he cost s or fees are not recoverable per the terms of the HELOC between Schneider and FAB.
Additionally, we have not received the history of billing statements sent by FAB in this matter between January 2015
through June 2017.
We look forward to your cooperation so we can bring this litigation to a timely and efficient resolution of the matters
involved.
Sincerest appreciation,
Larry Schneider
305-710-4201
larry@sacapita lpartners.com
1
Larry Schneider

Sent: Friday, June 23, 2017 4:09 PM
To: Hen ry Bolz
Cc: Stephanie Schneider ([email protected]); Jay Levin, Esq.; Jay Levin Esq.
([email protected])
Subject: Re: First American Bank v. Schneider, et al. - Palm Beach Circuit Court Case No.
2016-009292
Mr. Bolz,
As I had explained to you, I am in Phoenix doing depositions and wil l not be back in town until Thursday of next week.
Please note that I will be filing a notice with the court.
Additionally, you have refused to produce any billing statement or any Request for Production.
Sincerely,
Late Schneider
Sent from my iPhone
On Jun 23, 2017, at 7:25AM, Henry Bolz <hbolz@kellerbolz .com> wrote:
Mr. and Mrs. Schneider,
Although you may have already seen it, we attach a copy of United States District Court Judge Donald
Midd lebrooks' June 22, 2017 Order remanding the Foreclosure Litigation back to Circuit Court.
The Order Remanding Case to State Court has been filed with the Circuit Court and the Circuit Court
again has jurisdiction over the Foreclosure Litigation .
We are advised by the Circuit Court that First American Bank's Motion for Summary Judgment (bearing a
Certificate of Service date of May 25, 2017) rema ins scheduled to be heard by the Circuit Court at 2:30
p.m . on Monday, June 26, 2017. 45 minutes has been set aside for this hearing. A copy of Judge
Ferrara's June 2, 2017 Order Special Setting Hearing is attached for ease of reference.
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: [email protected]
1
IMPORTANT: THIS E-MAIL AND ANY ATTACHMENTS THERETO. IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY TO
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<#9 Order ofRemand 06-22-17.pdf>

<2017-06-02 Order Spc Set Hrg - MSJ.pdf>
2
Larry Schneider

Sent: Thursday, June 08, 2017 4:45PM
To: Henry Bolz
Subject: 2nd Motion FOr Receivership
Attachments: Notice Of Filing - Molestina Affidavit and March 28, 2017 Receivership H.... pdf; Email
From Bolz To Trent re. 2nd Inspection, March 9, 2017.pdf; Invoice Green Island
Maintenance-Oaks, March 3, 2017. pdf
Mr. Bolz,
In reviewing the cut and paste patchwork of the few communications which Mr. Trent actually sent to me, there is an
emai l from Bolz to Trent, which he had forwarded to me. In that email, you claim
"At this point in time, we are intending to call Mr. Mo/estina as a witness at the March 28, 2017 hearing ...(for 2nd
receivership hearing)."
I am meeting with attorneys with the Florida Bar tomorrow and need to know if you had provided him new information,
which contradicts your intent to call Mr. Molestina to justify your necessity for a receivership on a well maintained and
unoccupied house. It is important that I know, as the whole thing was a total set up. Mr. Trent told me that I need to be
at the hearing. Thus, the only reason I attended the hearing, along with my landscaper Sergio Lemus, was to refute the
knowingly false and or fraudulent affidavit Mr. Molestina signed and in wh ich you relied upon in your unnecessary
motion for a second receivership. I understand the unethical reasoning you had, by specifically not having Mr.
Mo lestina appear, as he would be likely be perjuring himself.
Furthermore, you found the motion for receivership so important, that you were sure to hire a court reporter to
document the events which would unfold. Those events wou ld be your advanced knowledge that I was asked to appear
and that you intended to extract testimony which is the basis for your motion for summary judgment. I understand
what you did, I just want to know if M r. Trent knew something and did not tell me, besides not properly representing
me. If you have a communication, in which you sent to Mr. Trent, which informs him of your intent not to call Mr.
Molestina, it would be very helpful in my meeting with the Florida Bar tomorrow. I know that you've continuously
refused to provide me any communications, except those which benefit you in f inding justification for your unre lenting
filings, however, if a communication does exist, I am able to place further blame on Mr. Trent who did not oppose. He
also did not tell me he was withdrawing from the case until late April and in which I was not made aware of the May 1,
2017 hearing on the motion to grant Mr. Trent's withdrawal from representation. until receiving your email on May 1,
2017.
Your assistance is greatly appreciated.
Sincere ly,
Larry Schneider
S & A Capital Partners
51
1 Fidelity Loan
Mortgage Resolution
305-710-4201
[email protected]
1
Larry Schneider

To: Henry Bolz
Subject: RE: First American Bank v. Schneiders - Compliance with Trial Order
Attachments: FCRA Letter Bolz To Schneider, November 30, 2015.pdf; Email Schneider to Bolz- FAB
HELOC Loan (FCRA) Contiunesed Erroneus Repo .... pdf; Letter From Jennifer Anderson
Acknowledging Bank Errors, June 5, 2015.pdf
Ms. Mesa,
I appreciate your communication. I will be filing a letter and motion noting your opposition to our motion.
For clarification, the case in which discovery is being utilized by regulators, stems from the breach of contract, fraud and
Civil RICO pending in the District Court for the Southern District of New York as MRS v. JPMC 15-00293, Docket as of
June 8, 2017(attached). Also attached is the fourth amended complaint, which has been fully briefed and awaiting a
ruling on the Civil RICO claims. The Contract Claims, Fraud in the Inducement and Negligent Misrepresentation are
specifically not dismissed. Stephanie has been both an employee and a shareholder in the Plaintiff's entities. Thus, her
knowledge and further attestation of certain facts are of importance in the matter described below.
Since you are Mr. Bolz associate, please provide me with all of the communications, documentation and the underlying
data which Mr. Bolz relied upon in his November 30, 2015 letter addressed to me and in response FCRA request from
First American Bank. As per the last sentence in Mr. Bolz letter addressed to me, he specifically instructed me to had
specifically instructed me as follows:
"All further requests for information and documentation that in any fashion relate to the $1,500,000 HELOC loan
that was originated on July 28, 2006, should be addressed to the undersigned at the address on this
correspondence."
As such, I immediately notified Mr. Bolz of yet additional fraudulent misrepresentations reported to the credit bureau's
regarding my account. I immediately sent Mr. Bolz a communication, as he specifically instructed with the relevant
information. Despite his letter Mr. Bolz did not respond to my communication about the continued billing and false
reporting problems. In addition, he did not return two calls regarding the matter in January 2016. Please provide me
with all relevant documentation and information which Mr. Bolz utilized in attempting to once again act on behalf of
FAB to rectify the fraudulent reporting.
Mr. Bolz did not represent that he was a debt collector in this letter his November 30, 2015 letter. Furthermore, he has
direct knowledge of Defendants fraudulent reporting of the information. Is Mr. Bolz now claiming that he was acting as
a debt collector at that time.
Also note, that Mr. Bolz acknowledged Defendants erroneous reporting and asked if I still need a letter to rectify some
of the harms caused to my 1st Fidelity line of credit be closed. Mr. Bolz was aware ofthe priorfalse reporting by FAB
prior to his November 30, 2015 letter and subsequent to the November 30, 2015 letter.
Please provide the requested information immediately, along with a copy of all of the the monthly billing statements
between January 2015 through May 1, 2017.
Thank you,
1
Larry Schneider
From: Henry Bolz [mailto:[email protected]]

To: Larry Schneider <[email protected] >
Cc: Stephanie Schneider ([email protected]) <[email protected] >; Henry Bolz
<[email protected]>
Subject: RE : First American Bank v. Schneiders- Compliance with Trial Order
Mr. Schneider,
My name is Sheyla Mesa, I am Mr. Bolz' associate. I briefly shared the contents of your emails to Mr.
Bolz of 12:11 p.m., 12:40 p.m. and 1:19 p.m. today. We take this opportunity to respond to the
requests set therein.
Neither First American Bank nor Keller & Bolz, LLP are willing to acquiesce in your request to
reschedule the June 12, 2017 hearings on Mrs. Schneider's Motion to Drop Party and/or Dismiss
Case (bearing a Certificate of Service date of May 24, 2017) and First American Bank's Motion for
Specially Set Trial Date (bearing a Certificate of Service date of May 23, 2017). On May 24, 2017,
Mrs. Schneider noticed her Motion for hearing. Further, as evidenced by the documents attached to
your email, Mrs. Schneider is not a party to the Schneider v. JPMorgan Chase litigation . Accordingly,
Mr. Bolz will be at the hearing on Monday, June 12, 2017, at 8:45a.m.
We will not reschedule your June 13, 2017 deposition or Mrs. Schneider's June 14, 2017 deposition .
As Mr. Bolz stated in his May 26, 2017 email to you, our office has no knowledge or information about
your relationship with Attorney Kenneth Trent between August 2016 and the present. With that said,
Attorney Trent was your record legal counsel up to May 1, 2017. Accordingly, any and all of the
correspondence that you have requested in your email of earlier today will have to come from
him. Keller & Bolz, LLP cannot and will not provide you with any of that information.
We are in receipt of your first request for production.
Lastly, Mr. Bolz' flight has been delayed for about an hour, he will endeavor to call you this evening .
Regards.
Sheyla Mesa
Ke ller & Bolz, LLP
Telephone: 305-529-8500
Telefax: 305-529-0228
2
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.
From: Larry Schneider [mailto:[email protected]]

To: Henry Bolz <[email protected]>
Mr. Bolz,
It appears that our communications had been sent to each other almost concurrently. Thus, despite the 3:00 pm
deadline I requested in a different email regarding my notice of unavailability for the June 12, 2017 hearing and
subsequent rescheduling of the depositions on the 13th and 14th . I will hold off on filing my motion to reschedule the
Monday, June 12, 2017 hearing with the court until you have provided your position to either consent, oppose or take
no position . According to your email below, you will not be available until 4:30pm due to your trave l schedule. Thus, I
will postpone the filing of a motion until 7:00pm, to allow you time to confer with your client. If I do not hear back from
you by 7:00 p.m., I will assume that you are in opposition of the aforementioned motion and wi ll note the motion
accordingly. If you have specific verbiage you would like me to state in t he motion, again, please notify me in writing by
7:00p.m.
Larry Schneider

Sent: Thursday, Ju ne 08, 2017 12:40 PM
Subject: Re: First American Bank v. Schneide rs - Compliance with Trial Order
Mr. Bolz,
With all due respect, we have both individually, and as such mutually requested that all communications be in w rit ing
due to the unfortunate circumstances surrounding Mr. Trent's former representation in this matter.
I have very few comm unications which purportedly transpired between my prior co unsel Mr. Trent and yo ur office. I
have already filed the first of several actions I am taking against him in this matter. Nonetheless, I have had great
difficulty in obtaining counsel. As such, and despite your email already advising me that you cannot and will not provide
me with communications between your office and Mr. Trent, I humbly ask you to please reconsider my request for the
communications between cou nsei(Not between yo u and your client).
Lastly, I wanted to confirm that you have received the First Request for Document Productio n in this case. It's been
somewhat of a lesson learned "the hard way." I have never used t he electronic filing syst em in Palm Beach County and
3
thought my email to you met the requirements. I greatly appreciate your assistance. If you have received it, please let
me know if there are any other deficiencies which would prevent FAB's production of t his f irst set of Document
Requests. I am preparing a second set of document requests and wa nt to ma ke sure t hey are received both correct ly
and timely.
Please respond via email with an agenda for the proposed ca ll. I w ill review and will ca ll you to discuss the scope of the
items presented in the agenda.
Larry Schneider
Sent from my iPhone
On Jun 8, 2017, at 11:20 AM, Henry Bolz <[email protected]> wrote:
Mr. Schneider:
I land in Newark at about 4:30p.m. I w ill call you from my cell phone at that time.
Regards.
Henry H. Bolz, III

Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
IMPORTANT THIS E-MAIL, AND ANY ATTACHMENTS THERETO. IS INTENDED FOR THE USE OF THE INDIV IDUAL OR ENTITY TO
WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS LEGALLY PRIVILEGED CONFIDENTIAL AND EXEMPT FROM
OR AGENT RESPONSIBLE FOR DELIVERING THE E-MAI L TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY
DISSEMINATION. DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED

Sent: Thursday, June 8, 201710:54 AM
Subject: RE: First American Bank v. Schneiders- Compliance with Trial Order
Importance: High
Mr. Bolz,
I w as in a meet ing and just turned on my phone, to see your email which provided for a short 54 minute
w indow of opportunity to respond.
This is similar to t he same pattern of unethical practices you have displayed in this action, you have once
again sent me a comm unication with a deadline of less than one hour to respond . In this instance, you
have been slightly mo re accommodating by allowing me 54 minutes to respond. In your prior email,
allow ing me 38 minutes to respond, which was a noon deadline. As you are aware, I was able to
4
respond by 11:58 a.m .. (two minutes before the However, it was to no avai l, as you did not
acknowledge receipt of the communication or return the correspondence in a timely manner. Instead
you filed a document which we once again did not meet and confer about.
Thus, I suspect you filed whatever document we were intending to meet and confer about, as you in
have done so many times this month.
I am available after 3:00 p.m., if you would are willing to meet and confer about any of the outstanding
issues.
Larry Schneider

Sent: Thursday, June 08, 2017 9:06AM
To: Larry Schneider <[email protected]>; Stephanie Schneider (steffschneide [email protected])
<[email protected]>
Subject: First American Bank v. Schneiders- Compliance with Trial Order
Palm Beach County Circuit Court Judge James Ferrara's May 16, 2017 Trial Order (copy attached for ease
of reference) requires that by no later than the 201h business day prior to trial, "the parties shall confer"
to discuss settlement, simplify the issues and discuss objections to trial exhibits.
It is my intention to set up a conference call by and between the three of us at 10:00 a.m. today. We
would greatly appreciate it if you would attempt to make yourselves available to participate in a short
conference call at that time.
Regards,
Henry H. Bolz, III

Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
IMPORTANT: THIS E-MAIL. AND ANY ATTACHMENTS THERETO. IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY TO
5
Larry Schneider

To: Henry Bolz
Mr. Bolz,
It appears that our communications had been sent to each other almost concurrently. Thus, despite the 3:00 pm
deadline I requested in a different email regarding my notice of unavailability for the June 12, 2017 hearing and
subsequent rescheduling of the depositions on the 13th and 14th . I will hold off on filing my motion to reschedule the
Monday, June 12, 2017 hearing with the cou rt until you have provided your position to either consent, oppose or take
no position. According to your email below, you will not be available until4:30 pm due to your travel schedule. Thus, I
will postpone the filing of a motion until 7:00pm, to allow you time to confer with your client. If I do not hear back from
you by 7:00p.m., I will assume that you are in opposition of the aforementioned motion and will note the motion
accordingly. If you have specific verbiage you would like me to state in the motion, again, please notify me in writing by
7:00p.m.
Larry Schneider

Subject: Re: First American Bank v. Schneiders- Compliance with Trial Order
Mr. Bolz,
With all due respect, we have both individually, and as such mutually requested that all communications be in writing
I have very few communications which purportedly transpired between my prior counsel Mr. Trent and your office.
have already filed the first of several actions I am taking against him in this matter. Nonetheless, I have had great
me with communications between your office and Mr. Trent, I humbly ask you to please reconsider my request for the
communications between counsel( Not between you and your client).
Lastly, I wanted to confirm that you have received the First Request for Document Production in this case. It's been
somewhat of a lesson learned "the hard way." I have neve r used the electronic filing system in Palm Beach County and
me know ifthere are any other deficiencies which would prevent FAB's production of this first set of Document
Requests. I am preparing a second set of document requests and want to make sure they are received both correctly
and timely.
Please respond via email with an agenda for the proposed call. I will review and will ca ll you to discuss the scope of the
items presented in the agenda.
1
Larry Schneider
Sent from my iPhone
Mr. Schneider:
I land in Newark at about 4:30 p.m. I will call you from my cell phone at that time.
Regards.
Henry H. Bolz, III

Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
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

Sent: Thursday, June 8, 2017 10:54 AM
To: Henry Bolz <hbolz@ke llerbolz.com>
Importance: High
Mr. Bo lz,
I was in a meeting and just turned on my phone, to see your email which provided for a short 54 minute
w indow of opportunity to respond .
This is similar to the same pattern of unethical practices you have displayed in this action, you have once
again sent me a comm unication with a deadline of less than one hour to respond. In this instance, you
have been slightly more accommodating by allowing me 54 minutes to respond. In your prior email,
allowing me 38 minutes to respond, which was a noon deadline. As you are aware, I was able to
respond by 11:58 a.m .. (two minutes before the However, it was to no avail, as you did not
acknowledge receipt of the communication or return the correspondence in a timely manner. Instead
you f iled a document which we once again did not meet and confer about.
have done so many times this month.
I am available after 3:00 p.m., if you would are willing to meet and confer about any of the outstanding
issues.
2
Larry Schneider

To: Larry Schneider <[email protected]>; Stephanie Schneider ([email protected] )
<steffschneider13 @gmail.com>
Subject: First American Bank v. Schneiders - Compl iance with Trial Order
Palm Beach County Circuit Court Judge James Ferrara's May 16, 2017 Trial Order (copy attached for ease
of reference) requires that by no later than the 20th business day prior to trial, "the parties sha ll confer"
It is my intention to set up a conference ca ll by and between the three of us at 10:00 a.m. today. We
would greatly appreciate it if you wou ld attempt to make yourselves availa ble to participate in a short
conference call at that time.
Regards,
Henry H. Bolz, III

Keller & Bolz, LLP
Coral Gables, FL 33 134
Telephone: (305) 529-8500
Telefax: (305) 529-0228
WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS LEGALLY PRIVI LEGED. CONFIDENTIAL AND EXEMPT FROM
OR AGENT RESPO NSI BLE FOR DELIVERING THE E-MAIL TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFI ED THAT ANY
DISSEM INATION, DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED
PROVIDED) AND PERMANENTLY DELETE THE ORIGINAL OR A NY PRINTOUT THEREOF.
3
Larry Schneider

To: Henry Bolz
Subject: Re: First American Bank v. Schneiders - Compliance with Trial Order
Mr. Bolz,
With all due respect, we have both individually, and as such mutually requested that all communications be in writing
I have very few communications which purportedly transpired between my prior counsel Mr. Trent and your office.
have already fi led the first of severa l actions I am taking against him in this matter. Nonetheless, I have had great
me w ith communications between your office and Mr. Trent, I humb ly ask you to please reconsider my request for the
communications between counse l(Not between you and your client).
Lastly, I wanted to confirm that you have received the First Request for Document Production in this case. It's been
somewhat of a lesson learned "the hard way." I have never used the electronic fi ling system in Palm Beach County and
me know ifthere are any other deficiencies which would prevent FAB's production ofthis first set of Document
Requests. I am preparing a second set of document requests and want to make sure they are received both correctly
and timely.
Please respond via email with an agenda for the proposed call. I will review and will call you to discuss the scope of the
items presented in t he agenda.
Larry Schneider
Sent from my iPhone
Mr. Schneider:
I land in Newark at about 4:30p.m. I will call you from my cell phone at that time.
Regards.
Henry H. Bolz, III

Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
1
IMPORTANT: THIS E-MAIL. AND ANY ATIACHMENTS THERETO. IS INTENDED FOR THE USE OF THE INDIV IDUAL OR ENTITY TO
OR AGENT RESPONSIBLE FOR DELIVERING THE E-MAI L TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY

Sent: Thursday, June 8, 2017 10:54 AM
Subject: RE: First American Bank v. Schneiders- Compliance with Trial Order
Importance: High
M r. Bolz,
I was in a meeting and just turned on my phone, to see your email which provided for a short 54 minute
window of opportunity to respond.
This is sim ilar t o the same pattern of unethical practices you have displayed in this action, you have once
again sent me a communication w ith a deadline of less than one hour to respond. In this instance, you
have been slightly more accommodating by allowing me 54 minutes to respond. In your prior email,
allow ing me 38 minutes to respond, which was a noon deadline. As you are aware, I was able t o
respond by 11:58 a.m .. (two minutes before the However, it was to no avail, as you did not
acknowledge receipt of t he communication or return the correspondence in a timely manner. Instead
you f iled a document which we once again did not meet and confer about.
have done so many times t his month .
I am available after 3:00 p.m., if you would are wil ling to meet and confer about any of the outstanding
issues.
Larry Schneider

To: Larry Schneider <[email protected]>; Stephanie Schneider ([email protected])
<[email protected]>
Subject: First American Bank v. Schneiders - Compliance w ith Trial Order
Palm Beach County Circuit Court Judge James Ferrara's May 16, 2017 Trial Order (copy att ached for ease
of reference) requires that by no later than the 201h business day prior to trial, "the parties shall confer"
It is my intention to set up a conference call by and between the three of us at 10:00 a.m. today. We
would greatly appreciate it if you would attempt to make yourselves avai lable t o participate in a short
conference call at that time .
Regards,
2
Henry H. Bolz, III
Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
IMPORTANT: THIS E-MAIL AND ANY ATTACHMENTS THERETO. IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY TO
DISSEMINATION, DISTRIBUTION OR COPYI NG OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED
3
USCA Case #17-7003 Document #1679708 Filed: 06/14/2017 Page 1 of 77
[ORAL ARGUMENT NOT YET SCHEDULED]

No. 17-7003
IN THE UNITED STATES COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT
UNITED STATES OF AMERICA, EX REL. LAURENCE SCHNEIDER, ET AL.,

Plaintiffs,
LAURENCE SCHNEIDER,
Plaintiff-Appellant,
v.
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION; JPMORGAN

CHASE & CO.; CHASE HOME FINANCE, LLC,
Defendants-Appellees.
On Appeal from the United States District Court for the District of Columbia
BRIEF FOR THE UNITED STATES AS AMICUS CURIAE

SUPPORTING NEITHER PARTY
CHAD A. READLER
Acting Assistant Attorney General
CHANNING D. PHILLIPS
United States Attorney
MICHAEL S. RAAB
ADAM C. JED
(202) 514-8280
Attorneys, Appellate Staff
Civil Division, Room 7240
U.S. Department of Justice
950 Pennsylvania Ave., N.W.
Washington, DC 20530
CERTIFICATE AS TO PARTIES, RULINGS, AND RELATED CASES
A. Parties and Amici
The named plaintiffs are United States of America, ex rel. Laurence Schneider;
State of California, ex rel. Laurence Schneider; State of Delaware, ex rel. Laurence
Schneider; State of Florida, ex rel. Laurence Schneider; State of Georgia, ex rel.
Laurence Schneider; State of Hawaii, ex rel. Laurence Schneider; State of Illinois, ex
rel. Laurence Schneider; State of Indiana, ex rel. Laurence Schneider; State of Iowa, ex
rel. Laurence Schneider; Commonwealth of Massachusetts, ex rel. Laurence
Schneider; State of Minnesota, ex rel. Laurence Schneider; State of Montana, ex rel.
Laurence Schneider; State of Nevada, ex rel. Laurence Schneider; State of New Jersey,
ex rel. Laurence Schneider; State of New Mexico, ex rel. Laurence Schneider; State of
New York, ex rel. Laurence Schneider; State of North Carolina, ex rel. Laurence
Schneider; State of Rhode Island, ex rel. Laurence Schneider; State of Tennessee, ex
rel. Laurence Schneider; Commonwealth of Virginia, ex rel. Laurence Schneider;
District of Columbia, ex rel. Laurence Schneider. The plaintiff-appellant is Laurence
Schneider. The defendants-appellees are JPMorgan Chase Bank, National
Association; JPMorgan Chase & Co.; and Chase Home Finance, LLC. The United
States is participating as amicus curiae.
B. Rulings Under Review
The plaintiff-appellant is appealing from the December 22, 2016 judgment and
decision issued by the Honorable Rosemary M. Collyer, United States District Court
for the District of Columbia, in Case No. 14-cv-1047, ECF Nos. 118 and 119. The
district court’s opinion and order are reproduced in the Joint Appendix at JA1 and
JA23, respectively. No citation is yet available in the Federal Supplement. The
district court’s opinion can be found at 2016 WL 7408826.
C. Related Cases
This case has not previously been before this or any other court. The plaintiff-
appellant’s complaint alleges fraud related to the National Mortgage Settlement
consent judgment, which was entered in United States v. Bank of America Corp., No. 12-
cv-361 (D.D.C.). This Court heard an appeal arising from that case, United States v.
Bank of America Corp., 753 F.3d 1335 (D.C. Cir. 2014).

TABLE OF CONTENTS
Page(s)
CERTIFICATE AS TO PARTIES, RULINGS,

AND RELATED CASES
GLOSSARY
INTRODUCTION AND INTERESTS OF THE

UNITED STATES ................................................................................................................ 1
STATEMENT OF THE ISSUE ......................................................................................... 2
PERTINENT STATUTES AND REGULATIONS ....................................................... 2
STATEMENT OF THE CASE .......................................................................................... 3
I. False Claims Act .............................................................................................. 3
II. Factual Background and Prior Proceedings ................................................. 4
A. National Mortgage Settlement ................................................................. 4
B. Factual Background and Procedural History ......................................... 7
SUMMARY OF ARGUMENT ........................................................................................... 9
STANDARD OF REVIEW ............................................................................................... 11
ARGUMENT ....................................................................................................................... 11
A. An Enforcement Action Under the Consent

Judgment Is an Action Seeking to Compel
Compliance with the Terms of the Judgment. .......................................... 13
B. This Case Is Not an Enforcement Action

Under the Consent Judgment. ..................................................................... 17
C. Additional Provisions of the Consent Judgment

Confirm This Conclusion. ............................................................................ 20
CONCLUSION ................................................................................................................... 25
CERTIFICATE OF COMPLIANCE WITH FEDERAL

RULE OF APPELLATE PROCEDURE 32(a)
CERTIFICATE OF SERVICE
ii
TABLE OF AUTHORITIES
Cases: Page(s)
Allison Engine Co. v. United States ex rel. Sanders,

553 U.S. 662 (2008) .......................................................................................................... 18
Avco Corp. v. U.S. Dept. of Justice,

884 F.2d 621 (D.C. Cir. 1989) ......................................................................................... 19
Beckett v. Air Line Pilots Ass’n,

995 F.2d 280 (D.C. Cir. 1993) ........................................................................................ 16
Cumberland Coal Res., LP v. Federal Mine Safety & Health Review Comm’n,
717 F.3d 1020 (D.C. Cir. 2013) ....................................................................................... 15
Firefighters Local Union No. 1784 v. Stotts,

467 U.S. 561 (1984) .......................................................................................................... 24
*Frew v. Hawkins,
540 U.S. 431 (2004) ..............................................................................................13, 15, 16
General Motors Corp. v. United States,

496 U.S. 530 (1990) .......................................................................................................... 15
Gunter v. Atlantic Coast Line R.R,

200 U.S. 273 (1906) .......................................................................................................... 16
Kirtsaeng v. John Wiley & Sons, Inc.,

133 S. Ct. 1351 (2013) ................................................................................................. 14-15
*Kokkonen v. Guardian Life Ins. Co.,

511 U.S. 375 (1994) ................................................................................................ 9, 15, 16
Merrion v. Jicarilla Apache Tribe,

455 U.S. 130 (1982) .......................................................................................................... 24
*Peacock v. Thomas,
516 U.S. 349 (1996) ...................................................................................................... 9, 15
* Authorities upon which we chiefly rely are marked with asterisks.

iii
Rainwater v. United States,

356 U.S. 590 (1958) ............................................................................................................ 3
Riggs v. Johnson Cty.,

73 U.S. (6 Wall.) 166 (1868)............................................................................................. 15
Rufo v. Inmates of Suffolk Cty. Jail,

502 U.S. 367 (1992) .................................................................................................... 13, 16
Salazar v. Buono,
559 U.S. 700 (2010) .......................................................................................................... 15
Sault Ste. Marie Tribe of Chippewa Indians v. Engler,

271 F.3d 235 (6th Cir. 2001) ...................................................................................... 16-17
Seaboard Air Line Ry. v. Koennecke,

239 U.S. 352 (1915) .......................................................................................................... 19
Segar v. Mukasey,
508 F.3d 16 (D.C. Cir. 2007) ........................................................................................... 20
Solis v. Current Dev. Corp.,

557 F.3d 772 (7th Cir. 2009) ........................................................................................... 17
Spallone v. United States,

493 U.S. 265 (1990) .......................................................................................................... 16
State Farm Fire & Cas. Co. v. United States ex rel. Rigsby,
137 S. Ct. 436 (2016) ........................................................................................................ 23
Steel Co. v. Citizens for a Better Env’t,

523 U.S. 83 (1998) ............................................................................................................ 15
Thatcher v. Kohl’s Dep’t Stores, Inc.,

397 F.3d 1370 (Fed. Cir. 2005) ....................................................................................... 16
Tourangeau v. Uniroyal, Inc.,

101 F.3d 300 (2d Cir. 1996) ............................................................................................. 16
Travelers Indem. Co. v. Dingwell,

884 F.2d 629 (1st Cir. 1989) ............................................................................................ 16
iv
United States v. Bank of Am. Corp.,

753 F.3d 1335 (D.C. Cir. 2014) ............................................................................. 4, 11, 14
United States v. Bank of Am.,

78 F. Supp. 3d 520 (D.D.C. 2015) .................................................................................... 6
United States v. Batchelder,

442 U.S. 114 (1979) .......................................................................................................... 19
United States v. Bornstein,

423 U.S. 303 (1976) .......................................................................................................... 18
United States v. Cherokee Nation of Okla.,

480 U.S. 700 (1987) .......................................................................................................... 24
United States v. ITT Cont’l Baking Co.,

420 U.S. 223 (1975) .......................................................................................................... 20
United States v. McNinch,

356 U.S. 595 (1958) .......................................................................................................... 17
United States v. Neifert-White Co.,

390 U.S. 228 (1968) ............................................................................................................ 3
United States v. Science Applications Int’l Corp.,

626 F.3d 1257 (D.C. Cir. 2010) ....................................................................................... 19
United States v. Van Oosterhout,

96 F.3d 1491 (D.C. Cir. 1996) ......................................................................................... 18
United States ex rel. Burke v. Record Press, Inc.,

816 F.3d 878 (D.C. Cir. 2016) ......................................................................................... 17
United States ex rel. Davis v. District of Columbia,

793 F.3d 120 (D.C. Cir. 2015) ......................................................................................... 17
United States ex rel. Eisenstein v. City of New York,

556 U.S. 928 (2009) .................................................................................................... 17, 18
v
United States ex rel. Harper v. Muskingum Watershed Conservancy Dist.,

842 F.3d 430 (6th Cir. 2016), petition for cert. filed,
(U.S. Apr. 25, 2017) (No. 16-1278) ........................................................................... 19-20
United States ex rel. Heath v. AT&T, Inc.,

791 F.3d 112 (D.C. Cir. 2015) ........................................................................................... 3
United States ex rel. McBride v. Halliburton Co.,

848 F.3d 1027 (D.C. Cir. 2017) ....................................................................................... 18
United States ex rel. Onnen v. Sioux Falls Indep. Sch. Dist. No. 49-5,
688 F.3d 410 (8th Cir. 2012) ........................................................................................... 24
Universal Health Servs., Inc. v. United States ex rel. Escobar,

136 S. Ct. 1989 (2016) ................................................................................................ 18, 19
Vermont Agency of Nat. Res. v. United States ex rel. Stevens,

529 U.S. 765 (2000) ............................................................................................................ 3
U.S. Constitution:
Art. III, § 2, cl. 3 ................................................................................................................... 21
Amend. VI ............................................................................................................................. 21
Statutes:
False Claims Act, 31 U.S.C. § 3729 et seq. .................................................................. 1, 3, 11

31 U.S.C. § 3729(a)............................................................................................................. 4
31 U.S.C. § 3729(a)(1) ...................................................................................................... 19
31 U.S.C. § 3729(a)(1)(A) .................................................................................................. 4
31 U.S.C. § 3729(a)(1)(B)................................................................................................... 4
31 U.S.C. § 3729(a)(1)(C) .................................................................................................. 4
31 U.S.C. § 3729(a)(1)(G) ........................................................................................ 4, 8, 20
31 U.S.C. § 3730(b)(1) ............................................................................................. 3, 4, 19
31 U.S.C. § 3730(b)(2) ..................................................................................................... 23
31 U.S.C. § 3730(d) ............................................................................................................ 3
31 U.S.C. § 3732(a)........................................................................................................... 21
Fraud Enforcement and Recovery Act of 2009,

Pub. L. No. 111-21, 123 Stat. 1617 ................................................................................ 18
vi
Rule:
Fed. R. Crim. P. 18 ............................................................................................................... 21
Legislative Material:
S. Rep. No. 345, 99th Cong., 2d Sess. (1986)...................................................................... 3
Other Authorities:
*Black's Law Dictionary (10th ed. 2014) ........................................................................... 9, 15
20 Charles Alan Wright & Mary Kay Kane,

Federal Practice and Procedure (2d ed. 2017 Supp.) ............................................................ 13
vii
GLOSSARY
Chase JPMorgan Chase
Consent J. Consent judgment
FCA False Claims Act
JA Joint Appendix
[ORAL ARGUMENT NOT YET SCHEDULED]

No. 17-7003
IN THE UNITED STATES COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT
UNITED STATES OF AMERICA, EX REL. LAURENCE SCHNEIDER, ET AL.,

Plaintiffs,
LAURENCE SCHNEIDER,
Plaintiff-Appellant,
v.
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION; JPMORGAN

CHASE & CO.; CHASE HOME FINANCE, LLC,,
Defendants-Appellees.
On Appeal from the United States District Court for the District of Columbia
BRIEF FOR THE UNITED STATES AS AMICUS CURIAE
INTRODUCTION AND INTERESTS OF THE UNITED STATES
This is a qui tam suit brought under the False Claims Act, 31 U.S.C. § 3729 et
seq. (FCA), alleging misconduct by JPMorgan Chase Bank. Among other things, the
relator alleges that Chase falsely claimed to have complied with several requirements
under the National Mortgage Settlement consent judgment to avoid making additional
payments to the United States. The district court dismissed the case, holding, inter
alia, that the FCA claims relating to that settlement could not proceed because the
relator failed to “exhaust” procedures in the consent judgment that govern an
“enforcement action under th[e] Consent Judgment.”
We take no position here on the merits of the relator’s underlying claims. We
declined to intervene in the case. And although we are a party to the National
Mortgage Settlement, we have not asked the district court that issued the consent
judgment to enforce the judgment’s terms against Chase. But the United States, in
whose name and whose behalf this False Claims Act suit was brought, has an interest
in the resolution of the “exhaustion” issue before this Court. The United States is a
party to the National Mortgage Settlement, which involves not just Chase but several
other banks. And the United States is a party to other settlements and contracts that
can give rise to suits under the False Claims Act and to other actions (civil or criminal)
alleging fraud. We are therefore participating on the narrow “exhaustion” question
addressed by the district court.
STATEMENT OF THE ISSUE
Whether a False Claims Act suit may allege fraud arising from the National
Mortgage Settlement consent judgment, without first following procedures that
govern “[a]n enforcement action under th[e] Consent Judgment.”
PERTINENT STATUTES AND REGULATIONS
The issue on which we are participating does not directly concern the text of
any statutes or regulations. The addendum to appellant’s brief reproduces certain
2
provisions of the National Mortgage Settlement consent judgment. For the Court’s
convenience, we have reproduced additional provisions in an addendum to this brief.
STATEMENT OF THE CASE
I. False Claims Act
The False Claims Act, 31 U.S.C. § 3729 et seq., is used broadly “in defending the
Federal treasury,” and it is a “powerful tool in deterring fraud.” S. Rep. No. 345, 99th
Cong., 2d Sess. 4 (1986). Congress enacted the FCA in 1863 “with the principal goal
of stopping the massive frauds perpetrated by large private contractors during the
Civil War.” Vermont Agency of Nat. Res. v. United States ex rel. Stevens, 529 U.S. 765, 781
(2000) (brackets and internal quotation marks omitted). But the Act was intended to
“reach all types of fraud, without qualification, that might result in financial loss to the
Government.” United States v. Neifert-White Co., 390 U.S. 228, 232 (1968).
Many of the Act’s “prohibitions can be enforced through both criminal and
civil actions by the federal government.” United States ex rel. Heath v. AT&T, Inc., 791
F.3d 112, 116 (D.C. Cir. 2015). 1 “In addition, the Act authorizes private individuals—
known as relators—to bring a qui tam civil action ‘in the name of the Government,’
and to share in any damages recovered.” Ibid. (citation omitted); 31 U.S.C.
§ 3730(b)(1), (d); see generally Vermont Agency, 529 U.S. at 781. A civil suit may be
1
The original Act “provided both criminal and civil sanctions.” Rainwater v.
United States, 356 U.S. 590, 592 n.8 (1958). “The criminal provision remains on the
books and is currently codified separately, as amended, at 18 U.S.C. § 287.” Vermont
Agency, 529 U.S. at 782 n.11.
3
brought either by the Attorney General or a relator seeking civil penalties plus three
times the amount of the government’s damages. 31 U.S.C. § 3729(a), (b)(1).
The FCA imposes civil liability for a variety of deceptive practices involving
government funds and property. Among other things, the Act renders liable any
person who “knowingly presents, or causes to be presented, a false or fraudulent
claim for payment or approval,” 31 U.S.C. § 3729(a)(1)(A); any person who
“knowingly makes, uses, or causes to be made or used, a false record or statement
material to a false or fraudulent claim,” id. § 3729(a)(1)(B); any person who
“knowingly makes, uses, or causes to be made or used, a false record or statement
material to an obligation to pay or transmit money or property to the Government, or
knowingly conceals or knowingly and improperly avoids or decreases an obligation to
pay or transmit money or property to the Government,” id. § 3729(a)(1)(G); and any
person who “conspires” to engage in such acts, id. § 3729(a)(1)(C); see id. § 3729(b)(1)
(defining “knowingly”).
II. Factual Background and Prior Proceedings
A. National Mortgage Settlement
In March 2012, the United States, forty-nine states, and the District of
Columbia filed a complaint and proposed consent judgment in the United States
District Court for the District of Columbia against several mortgage servicers,
including JPMorgan Chase. JA2; United States v. Bank of Am. Corp., 753 F.3d 1335,
4
1336 (D.C. Cir. 2014) (per curiam). 2 The complaint alleged a variety of misconduct in
the servicers’ home mortgage practices, and the proposed consent judgment
implemented a negotiated settlement. Ibid.; see Dkt. Nos. 10-14, United States v. Bank
of Am., No. 12-cv-361 (D.D.C.).
Under that consent judgment, Chase agreed to pay a penalty; to provide
approximately $3.675 billion in various forms of consumer relief, such as loan
forgiveness; and to comply with certain business practice requirements called
“Servicing Standards.” Consent Judgment, No. 12-cv-361 ¶¶ 3, 5 (D.D.C. Apr. 4,
2012) (Consent J.); Consent J. Ex. D. The United States released a number of claims
but did not release “[a]ny liability based upon obligations created by th[e] Consent
Judgment.” Consent J. Ex. F, § (11)(n).
The consent judgment also contains provisions for monitoring the banks’
compliance. The agreement established a Monitoring Committee, Consent J. Ex. E,
§ B; an Independent Monitor to assess compliance, Consent J. ¶ 7; Consent J. Ex. E
§§ C(1), (5), D; creation of metrics for evaluating compliance with certain servicing
standards, Consent J. Ex. E § C(12), (23) & Sch. E-1; and rules governing
enforcement actions by the parties or Monitoring Committee, id. § J.
2
The other defendant banks were Ally, Bank of America, Citibank, and Wells
Fargo. See United States. v. Bank of Am., No. 12-cv-361 (D.D.C.).
5
The parties agreed that if Chase fails to meet its consumer relief obligations,
Chase would “pay an amount equal to 125% of the unmet commitment,” or 140% in
specific circumstances. Consent J. Ex. D(10)(d).3 With respect to servicing standards
for which there are established metrics, if the Monitor concludes that Chase is
exceeding the allowable error rate, the Monitor notifies Chase of a “Potential
Violation,” and Chase has a right to cure within a set time frame. Consent J. Ex. E,
§§ D(3), (5), E(1)-(6). If Chase cures, there is no other “remedy under th[e] Consent
Judgment . . . with respect to such Potential Violation.” Id. § E(6). If Chase does not
timely cure such a “Potential Violation,” “[i]n the event of an action to enforce
[Chase’s] obligations,” the court can order “non-monetary equitable relief, including
injunctive relief, directing specific performance under the terms of th[e] Consent
Judgment, or other non-monetary corrective action,” and the court “may award”
agreed-to “civil penalties.”4 Id. § J(3)(a), (b). With respect to other alleged
noncompliance—such as violation of servicing standards not subject to a metric or
other obligations—the court may order only non-monetary injunctive relief. Id.
§ J(3), (a); see United States v. Bank of Am., 78 F. Supp. 3d 520, 530 (D.D.C. 2015).
3
If there is a “payment due” under the provision governing unmet consumer
relief obligations, one half “shall be allocated to the United States” and the other half
divided among the state parties. Consent J. Ex. E, § J(3)(c)(3).
4
Penalties based on servicing standards are generally paid to the states, unless
the standard relates to conduct in bankruptcy, in which case it is paid to the United
States or as otherwise directed by the Director of the United States Trustee Program.
Consent J. Ex. E, § J(3)(c)(1)-(2).
6
The “Enforcement Terms” also state that Chase’s “obligations under this
Consent Judgment shall be enforceable solely in the U.S. District Court for the
District of Columbia” and that “[a]n enforcement action under th[e] Consent
Judgment may be brought by any Party to this Consent Judgment or the Monitoring
Committee.” Consent J. Ex. E, § J(2). Ordinarily “prior to commencing any
enforcement action, a Party must provide notice to the Monitoring Committee of its
intent to bring an action to enforce th[e] Consent Judgment.” Ibid. The committee
then has “21 days to determine whether to bring an enforcement action.” Ibid. If the
committee declines to do so, “the Party must wait 21 additional days . . . before
commencing an enforcement action.” Ibid.
The United States has not invoked the consent judgment’s procedures or
otherwise asked the district court to enforce the terms of the judgment against Chase.
Based on the information currently available to it, including the reports filed by the
Monitor, the United States is unaware of any violation of the agreed-to terms.
B. Factual Background and Procedural History
1. The plaintiff in this case is a relator who filed a qui tam suit against
JPMorgan Chase under the False Claims Act and similar state laws. JA27, JA39,
JA94-JA116 (Second Am. Compl.). As relevant here, relator alleges that Chase
violated the so-called “reverse” provision of the False Claims Act when Chase claimed
to have complied with various aspects of the National Mortgage Settlement, thereby
avoiding additional payments and penalties required under the consent judgment.
7
JA27, JA35, JA70-JA75, JA80-JA95. That FCA provision imposes liability on any
person who, among other things, “knowingly makes, uses, or causes to be made or
used, a false record or statement material to an obligation to pay or transmit money or
property to the Government” or who “knowingly conceals or knowingly and
improperly avoids or decreases an obligation to pay or transmit money or property to
the Government.” 31 U.S.C. § 3729(a)(l)(G). 5
2. The district court granted Chase’s motion to dismiss. JA1-JA22 (opinion);
JA23 (order). As relevant here, the court held that relator could not sue because he
“failed to exhaust the dispute resolution procedures required by the National
Mortgage Settlement before filing suit.” JA12-JA14. The court reasoned that in a
False Claims Act suit, “Relator stands in the position of the Federal Government,”
and the federal government could not sue Chase before following the consent
judgment’s “mandatory pre-litigation steps.” JA13. In the court’s view, these
included “notice to the allegedly noncompliant bank, the Monitor, and the
Monitoring Committee,” “good faith efforts to reach agreement,” notification of the
Monitoring Committee of intent to file an enforcement action, waiting twenty-one
days for the Monitoring Committee to consider whether it would sue, and then
waiting an additional twenty-one days. Ibid.
5
The United States declined to intervene in the suit, Dkt. Nos. 24, 96, as did
other states, under whose state False Claims Acts the relator had also brought suit,
see, e.g., Dkt. Nos. 25-37, 41, 43, 70-72, 75-76, 83, 95, 97, 104.
8
SUMMARY OF ARGUMENT
The agreement to undertake procedures before bringing an “enforcement
action under th[e] Consent Judgment” governs a specific type of action—one asking
the district court to enforce that judgment, i.e., to compel compliance with the terms
of the judgment. This term does not govern the broader set of actions—civil or
criminal—where the agreement, embodied in the consent judgment, is a backdrop for
an alleged fraud and one allegation would also establish noncompliance.
An “enforcement action under” a consent judgment is an action asking a court
to use its inherent authority to compel compliance with that judgment. The term
“enforcement action under” commonly refers to the cause of action and/or
governing source of law. And the “enforcement of a judgment” is “[a] court’s action
to compel a person to comply with the terms of a judgment.” Black’s Law Dictionary
645 (10th ed. 2014). This is ordinarily an invocation of a court’s inherent power to
enforce its judgments, see Peacock v. Thomas, 516 U.S. 349, 356-357 (1996), and is
equally true for consent judgments, where a “breach of the agreement would be a
violation of the order, and ancillary jurisdiction to enforce the agreement would
therefore exist.” Kokkonen v. Guardian Life Ins. Co., 511 U.S. 375, 381 (1994). In other
words, an action to compel compliance is an “enforcement action under” the relevant
judgment.
Conversely, in common legal usage, a suit filed under the False Claims Act is
not described a suit under the contract or program that gave rise to the alleged
9
fraudulent conduct. Instead, it is commonly described as an “action under the False
Claims Act.” Many garden-variety FCA suits allege that the defendant engaged in
fraudulent conduct in the course of performing (or purporting to perform) its
obligations under a contract. It does not follow that compliance with contractual
dispute-resolution mechanisms is necessary before the United States (or a relator) can
bring such FCA suits. Nor does it follow that such mechanisms govern other civil or
criminal actions for fraud.
If Chase failed to satisfy the requirements of the consent judgment, the United
States could avail itself of the judgment’s remedies and ask the district court to
enforce that judgment. But even if Chase’s alleged misconduct also constituted a
violation of the consent judgment, the FCA suit here is an effort to enforce the
distinct (though overlapping) obligations imposed by the FCA. Indeed, a suit under
the False Claims Act does not merely allege that Chase breached an agreed-to
obligation. The False Claims Act is not a vehicle for punishing garden-variety
breaches of contract, and it contains distinct elements, including a scienter
requirement. Whatever expectation Chase may have had about the procedures
outlined in the agreement, Chase could have had no reasonable expectation that
claims of knowingly false statements or concealment to avoid monetary obligations
would have to be routed through the procedures described in the consent judgment.
If there were any doubts, several other provisions and applicable interpretive
guides further demonstrate that the pre-enforcement procedures do not apply to an

10
FCA action. These include unitary references to the court where the consent
judgment is filed and enforced; textual clues suggesting that there is only a single type
of “enforcement action”; substantial limits on the remedies available in an
enforcement action; and a presumption that contracts would not constrain the
ability of the United States and state governments, established by statute, to pursue
actions for fraud against the sovereign.
STANDARD OF REVIEW
This Court reviews the interpretation of a consent judgment de novo. United
States v. Bank of Am. Corp., 753 F.3d 1335, 1337 (D.C. Cir. 2014) (per curiam).
ARGUMENT
The relator in this case filed suit under the False Claims Act, 31 U.S.C. § 3729 et
seq. (FCA), alleging, among other things, that JPMorgan Chase knowingly engaged in
fraudulent conduct to conceal and to avoid a financial obligation to the United States.
The United States declined to intervene in this suit and does not take the position that
Chase failed to comply with the terms agreed to in the National Mortgage Settlement.
But the United States has a significant interest in the legal theory underlying the
district court’s decision to dismiss these claims.
The district court held that before the United States or a relator could bring a
False Claims Act suit premised on fraud in the execution of the settlement agreement,
they first had to undertake agreed-to procedures governing “enforcement actions
11
under th[e] Consent Judgment.” 6 That holding appears to rest on the mistaken
premise that the United States (and the forty-nine state parties) agreed to undertake
the pre-enforcement procedures before bringing any action where the factual
allegations include failure to comply with the agreed-to terms of the consent
judgment.
That premise is mistaken. Properly understood, the agreement to undertake
certain procedures before bringing an “enforcement action under th[e] Consent
Judgment” governs a specific type of action—one asking the district court to compel
compliance with the terms of the judgment. It does not govern the broader set of
actions—civil or criminal—where the agreed-to terms are the backdrop for an alleged
fraud and one allegation would also establish noncompliance with the judgment.
6
The district court appears to have made one error in describing those
procedures. In addition to describing the procedure of notifying and waiting for the
Monitoring Committee, the district court stated that “a party wishing to dispute
compliance by a signatory bank” would first have to “give notice to the allegedly
noncompliant bank, the Monitor, and the Monitoring Committee” and “engage in
good faith efforts to reach agreement.” JA13. We do not understand that provision
to apply here or to be a condition precedent to an enforcement action. In a section
titled “Dispute Resolution Procedures,” the consent judgment provides that Chase,
“the Monitor, and the Monitoring Committee will engage in good faith efforts to
reach agreement on the proper resolution of any dispute concerning any issue arising
under th[e] Consent Judgment,” and that “[s]ubject to” the enforcement section
described below, “in the event that a dispute cannot be resolved,” they “may petition
the Court for resolution of the dispute.” Consent J. Ex. E, § G. Those “Dispute
Resolution Procedures” do not refer to the government parties (the United States and
the various states), but just to the “Servicer [(banks)], the Monitor, and the
Monitoring Committee.” Ibid. Moreover, those procedures are not described as a
prerequisite to an enforcement action. Ibid.
12
Here, as in many other contexts, multiple sorts of actions may be brought
under multiple sources of law for the same conduct. And like other actions for fraud,
FCA suits must allege more than a failure to comply with agreed-to terms, including
scienter. In particular, whatever expectation Chase may have had about remedies,
Chase could not have reasonably expected that knowingly making false statements,
using false records, or concealing or improperly avoiding monetary obligation to the
United States would be remedied only within the limited procedures set out for
enforcement actions and not under other sources of law, such as the False Claims Act.
The agreement is the backdrop for the alleged misconduct. But the charge of fraud is
not merely an attempt to enforce the terms of the agreement.
A. An Enforcement Action Under the Consent Judgment Is an Action

Seeking to Compel Compliance with the Terms of the Judgment.
1. “A consent judgment or consent decree is a settlement that includes an
injunction, or some other form of specific relief, and that is formally entered by the
court and enforceable by contempt.” 20 Charles Alan Wright & Mary Kay Kane,
Federal Practice and Procedure § 104, at 879 n.2 (2d ed. 2017 Supp.). It “embodies an
agreement of the parties and thus in some respects is contractual in nature.” Rufo v.
Inmates of Suffolk Cty. Jail, 502 U.S. 367, 378 (1992). “But it is an agreement that the
parties desire and expect will be reflected in, and be enforceable as, a judicial decree
that is subject to the rules generally applicable to other judgments and decrees.” Ibid.;
see Frew v. Hawkins, 540 U.S. 431, 437 (2004). A consent judgment is interpreted
13
pursuant to “standard principles of contract law.” United States v. Bank of Am. Corp.,
753 F.3d 1335, 1337 (D.C. Cir. 2014) (per curiam) (interpreting same judgment).
In a provision governing “Enforcement Terms,” Consent J. ¶ 6; Consent J.
Ex. E, the judgment provides that it “shall be filed in the U.S. District Court for the
District of Columbia” and “shall be enforceable therein.” Consent J. Ex. E, § J(1). It
further explains that “obligations under th[e] Consent Judgment shall be enforceable
solely in the U.S. District Court for the District of Columbia” and that “[a]n
enforcement action under th[e] Consent Judgment may be brought by any Party to
th[e] Consent Judgment or the Monitoring Committee.” Id. § J(2). Ordinarily, “prior
to commencing any enforcement action, a Party must provide notice to the
Monitoring Committee of its intent to bring an action to enforce th[e] Consent
Judgment.” Ibid. The committee then has “21 days to determine whether to bring an
enforcement action.” Ibid. If the committee declines to do so, “the Party must wait
21 additional days . . . before commencing an enforcement action.” Ibid.
2. These pre-enforcement procedures govern an action invoking the district
court’s inherent authority to compel compliance with its judgment. The procedures
must occur before “commencing any enforcement action,” which is most naturally
read as shorthand for the previously-described “enforcement action under th[e]
Consent Judgment,” Consent J. Ex. E, § J(2), rather than governing any enforcement
action of any kind (such as an action concerning unrelated subject matter). Although
the word “under” does not have a “uniform, consistent meaning,” Kirtsaeng v. John
14
Wiley & Sons, Inc., 133 S. Ct. 1351, 1359 (2013), the term “enforcement action under”
ordinarily refers to the cause of action and/or the governing source of law. See, e.g.,
Steel Co. v. Citizens for a Better Env’t, 523 U.S. 83, 86 (1998) (“enforcement action under
the citizen-suit provision of the Emergency Planning and Community Right-To-
Know Act of 1986”); General Motors Corp. v. United States, 496 U.S. 530, 535 (1990)
(“enforcement action under § 113(b) of the [Clean Air] Act”); Cumberland Coal Res., LP
v. Federal Mine Safety & Health Review Comm’n, 717 F.3d 1020, 1022 (D.C. Cir. 2013)
(“enforcement actions under the Mine Safety Act”).
The “enforcement of [a] judgment” is “[a] court’s action to compel a person to
comply with the terms of a judgment.” Black’s Law Dictionary 645 (10th ed. 2014); see,
e.g., Salazar v. Buono, 559 U.S. 700, 712 (2010). This is ordinarily not an action brought
under any distinct authority but rather is an invocation of a court’s “ancillary
jurisdiction” to use its “inherent power to enforce its judgments.” See Peacock v.
Thomas, 516 U.S. 349, 356-357 (1996); see also Riggs v. Johnson Cty., 73 U.S. (6 Wall.)
166, 187 (1868) (“if the power is conferred to render the judgment or enter the
decree, it also includes the power to issue proper process to enforce such judgment or
decree”). In other words, it is an “enforcement action under” the relevant judgment.
This is equally true with respect to consent judgments. A key reason to submit
a settlement for entry by the court as a consent judgment is to render the agreement
“enforceable as, a judicial decree that is subject to the rules generally applicable to
other judgments and decrees.” Frew, 540 U.S. at 437; see Kokkonen v. Guardian Life
15
Ins. Co., 511 U.S. 375, 380-381 (1994). A “breach of the agreement would be a
violation of the order, and ancillary jurisdiction to enforce the agreement would
therefore exist.” Id. at 381; see Rufo, 502 U.S. at 378 (consent decree “is an agreement
that the parties desire and expect will be reflected in, and be enforceable as, a judicial
decree that is subject to the rules generally applicable to other judgments and
decrees”); Spallone v. United States, 493 U.S. 265, 276 (1990) (describing “inherent
power” to “enforce the consent judgment”); Beckett v. Air Line Pilots Ass’n, 995 F.2d
280, 286 (D.C. Cir. 1993) (similar); see also Frew, 540 U.S. at 439 (“enforcing the
decree vindicates an agreement”); Gunter v. Atlantic Coast Line R.R., 200 U.S. 273, 292
(1906) (similar).
Therefore, in common legal usage, when people refer to actions to enforce
consent judgments, they are generally referring to requests that courts use their
inherent authority to compel compliance with the judgment. E.g., Thatcher v. Kohl’s
Dep’t Stores, Inc., 397 F.3d 1370, 1373 (Fed. Cir. 2005) (only a party to the consent
decree may “proceed with a contempt action to enforce the judgment under the terms
of the consent judgment”); Tourangeau v. Uniroyal, Inc., 101 F.3d 300, 305, 308, 309 (2d
Cir. 1996) (describing such an action as an “action to enforce the Consent
Judgment”); Travelers Indem. Co. v. Dingwell, 884 F.2d 629, 639-640 (1st Cir. 1989)
(describing possible “action to enforce the consent judgment”); see also, e.g., Beckett,
995 F.2d at 286 (court had authority in “action to enforce th[e] Consent Decree”
because “a trial court retains jurisdiction to enforce consent decrees”); Sault Ste. Marie
16
Tribe of Chippewa Indians v. Engler, 271 F.3d 235, 238 (6th Cir. 2001) (“the continuing
enforcement of a consent judgment is rightfully considered an extension of the
original lawsuit”); Solis v. Current Dev. Corp., 557 F.3d 772, 775 (7th Cir. 2009)
(“enforcement orders” with respect to consent decrees “are postjudgment orders”).
B. This Case Is Not an Enforcement Action Under the Consent

Judgment.
This case is not an enforcement action under the consent judgment. Instead, it
is a suit under the False Claims Act alleging fraud against the United States. As noted,
the term “enforcement action under” ordinarily refers to the cause of action and/or
the governing source of law. Thus, in common legal usage, a suit filed under the False
Claims Act is not a suit under the contract or program that gave rise to the alleged
fraudulent conduct. Instead, it is an “action under the False Claims Act.” See, e.g.,
United States ex rel. Eisenstein v. City of New York, 556 U.S. 928, 929 (2009) (“when the
United States declines to formally intervene in a qui tam action brought under the
False Claims Act”); id. at 932 (“A private enforcement action under the FCA is called
a qui tam action”); United States v. McNinch, 356 U.S. 595, 595-596 (1958) (“This case . .
. involves three separate actions by the Government to recover damages and
forfeitures under the False Claims Act.”); United States ex rel. Burke v. Record Press, Inc.,
816 F.3d 878, 881 (D.C. Cir. 2016) (“when resolving an action under the False Claims
Act, including one implicating a contract”); United States ex rel. Davis v. District of
Columbia, 793 F.3d 120, 125 (D.C. Cir. 2015) (describing what can “serve as the basis
17
for a qui tam action under the [False Claims Act]”) (court’s alteration); United States v.
Van Oosterhout, 96 F.3d 1491, 1492 (D.C. Cir. 1996) (“The government filed this
action under the False Claims Act to recover monies paid out under Small Business
Administration (SBA) loan guaranties”). 7
If Chase failed to satisfy the requirements of the consent judgment, the United
States could avail itself of the consent judgment’s remedies and ask the district court
to enforce the judgment. But even if Chase’s alleged misconduct also constituted a
violation of the consent judgment, the FCA suit here is not an effort to enforce the
consent judgment or obligations arising under that judgment. Rather, it is an effort to
enforce the distinct (though overlapping) obligations imposed by the FCA. Indeed,
many garden-variety FCA suits allege that the defendant engaged in fraudulent
conduct in the course of performing (or purporting to perform) its obligations under
a contract. It does not follow that compliance with contractual dispute-resolution
mechanisms is necessary before the United States (or a relator) can bring such FCA
7
See also, e.g., Universal Health Servs., Inc. v. United States ex rel. Escobar, 136 S. Ct.
1989, 1996, 2002 (2016) (describing misconduct “actionable under the False Claims
Act”); Allison Engine Co. v. United States ex rel. Sanders, 553 U.S. 662, 672 (2008)
(“Recognizing a cause of action under the FCA for fraud directed at private entities”);
United States v. Bornstein, 423 U.S. 303, 308 (1976) (“the Government brought this civil
action in a Federal District Court under the False Claims Act”); cf., e.g., United States ex
rel. Eisenstein, 556 U.S. at 930 (“the United States is a ‘real party in interest’ in a case
brought under the FCA”); United States ex rel. McBride v. Halliburton Co., 848 F.3d 1027,
1030 (D.C. Cir. 2017) (“McBride brings two claims under the FCA”); Fraud
Enforcement and Recovery Act of 2009, Pub. L. No. 111-21, § 4(f)(1), 123 Stat. 1617,
1625 (applying amendments “to all claims under the False Claims Act . . . pending on
or after that date.”).
18
suits. Nor does it follow that such mechanisms govern other civil or criminal actions
for fraud.
Even if the alleged conduct would, by itself, violate both the consent judgment
and the False Claims Act, it does not follow that any legal proceeding under the FCA
is also an enforcement action under the consent judgment. Here, as in other contexts,
multiple sorts of actions may be brought under multiple sources of law for the same
conduct. See, e.g., United States v. Batchelder, 442 U.S. 114, 125 (1979) (prosecutors
have discretion to “proceed under” or “charge under” various statutes based on the
same conduct); Seaboard Air Line Ry. v. Koennecke, 239 U.S. 352, 354 (1915) (cause of
death action could have been brought “under” either of two statutes).
Moreover, a suit under the False Claims Act does not merely allege that Chase
breached an agreed-to obligation. The False Claims Act is not “a vehicle for
punishing garden-variety breaches of contract.” Universal Health Servs. v. United States
ex rel. Escobar, 136 S. Ct. 1989, 2003 (2016). It is the “primary litigative tool for the
recovery of losses sustained as the result of fraud against the government,” Avco Corp.
v. U.S. Dept. of Justice, 884 F.2d 621, 622 (D.C. Cir. 1989) (emphasis added), and
contains distinct elements. Most significantly, the FCA contains a scienter
requirement, 31 U.S.C. § 3729(a)(1), (b)(1), that “help[s] to ensure that ordinary
breaches of contract are not converted into FCA liability.” United States v. Science
Applications Int’l Corp., 626 F.3d 1257, 1271 (D.C. Cir. 2010); see, e.g., United States ex
rel. Harper v. Muskingum Watershed Conservancy Dist., 842 F.3d 430, 436-437 (6th Cir.
19
2016) (applying mens rea requirement for “reverse” FCA claim), petition for cert. filed
(U.S. Apr. 25, 2017) (No. 16-1278).
The scienter requirement is a distinct prerequisite to FCA liability that a party
to the consent judgment would not need to establish in order to seek relief under the
judgment itself. Whatever expectation Chase (or any other party to an agreement with
the United States) may have that procedures outlined in the agreement would be the
exclusive means of alleging innocent or merely negligent violations, Chase could have
had no reasonable expectation that the sorts of claims brought under the False Claims
Act would have to be routed through those procedures. Thus, Chase could not have
reasonably expected that knowingly making false statements, knowingly using false
records, or knowingly concealing or improperly avoiding monetary obligation to the
United States, see 31 U.S.C. § 3729(a)(1)(G) (“reverse” FCA provision), would be
remedied only within the limited procedures set out in the consent judgment and not
under other sources of law, such as the False Claims Act.
C. Additional Provisions of the Consent Judgment Confirm This

Conclusion.
Even if there were serious ambiguity about what constitutes an enforcement
action under the consent judgment, the consent judgment must be read as a “whole,”
and “‘reliance upon certain aids to construction is proper, as with any other
contract.’” Segar v. Mukasey, 508 F.3d 16, 22-23 (D.C. Cir. 2007) (quoting United States
v. ITT Cont’l Baking Co., 420 U.S. 223, 238 (1975)). Several other provisions and
20
applicable interpretive guides further demonstrate that the pre-enforcement
procedures do not apply to an FCA action.
First, the consent judgment provides that it “shall be filed in the U.S. District
Court for the District of Columbia (the ‘Court’) and shall be enforceable therein”
(Ex. E, § J(1)); and that Chase’s “obligations under this Consent Judgment shall be
enforceable solely in the U.S. District Court for the District of Columbia” (id. § J(2)).
The unitary reference to the court where the consent judgment is filed and enforced is
consistent with the commonplace understanding, discussed above, that an
enforcement action under a consent judgment is a request that a court enforce its own
judgment. The terms governing where enforcement of the judgment may occur are
an awkward fit for the broader proposition that any action, including an action for
fraud arising from the judgment, is the type of enforcement action to which the
judgment’s procedural terms apply. 8
Second, the consent judgment provides that “[a]n enforcement action under
this Consent Judgment may be brought by any Party to this Consent Judgment or the
8
In a civil suit or criminal prosecution based on that fraud, venue is not
necessarily proper in the district that approved the consent judgment. See, e.g., 31
U.S.C. § 3732(a) (FCA venue provision); Fed. R. Crim. P. 18 (criminal venue rules);
U.S. Const. amend. VI (same); U.S. Const. art. III, § 2, cl. 3 (same). Under Chase’s
and the district court’s apparent premise, after the government followed the pre-
enforcement procedures, it would appear that the government could bring such a civil
or criminal action only if the applicable venue provisions happened to place the
matter in the U.S. District Court for the District of Columbia or if the parties would
waive any venue rights.
21
Monitoring Committee.” Ex. E, § J(2). That appears to contemplate a single type of
enforcement action, rather than a range of all litigation predicated in part on violations
of the judgment. The fact that such an action can be brought by any party or by the
Monitoring Committee fits comfortably with the understanding that the referenced
enforcement action is an action asking the district court to compel compliance. But
it fits awkwardly with the broader reading that undergirds the district court’s holding.
Neither every party nor the Monitoring Committee can necessarily bring every kind of
fraud action arising from the agreement. Moreover, the district court’s premise seems
entirely to exclude a qui tam suit, which would be brought by a relator.
Third, ordinarily “prior to commencing any enforcement action, a Party must
provide notice to the Monitoring Committee of its intent to bring an action to enforce
this Consent Judgment.” Consent J. Ex. E, § J(2). The committee then has “21 days
to determine whether to bring an enforcement action.” Ibid. If the committee
declines to do so, “the Party must wait 21 additional days . . . before commencing an
enforcement action.” Ibid. Like the provision describing who may bring an
enforcement action, this appears to contemplate only a single type of enforcement
action. Thus, the judgment does not expressly say whether, if the Monitoring
Committee brings an enforcement action, the United States may not. That would not
raise concerns if the contemplated action were a traditional action to compel
compliance; once one entity initiated the action, no one else would need to. Similarly,
the judgment does not say what would occur if the Monitoring Committee and parties
22
brought different kinds of actions—if the government provided notice and the
committee asked the district court to compel compliance, could the United States
bring a criminal prosecution for fraud? If an “enforcement action under th[e]
Consent Judgment” swept so broadly, the pre-enforcement procedures would
presumably address some of these issues.
In addition, these procedures are a poor fit for qui tam suits. Contrary to the
district court’s suggestion (JA14), in our view a relator is not a party to the judgment
and therefore cannot use these procedures. But apart from any uncertainty whether a
stranger to the judgment could invoke its procedures, the district court’s premise
would subvert other provisions of the False Claims Act. The FCA requires relators to
file qui tam complaints under seal to avoid alerting defendants to the possibility of a
government investigation. 31 U.S.C. § 3730(b)(2); see State Farm Fire & Cas. Co. v.
United States ex rel. Rigsby, 137 S. Ct. 436, 443 (2016). Relators’ invoking the consent
judgment’s procedures before filing suit would undermine that important function.
And if a relator had to ask the United States to invoke the consent judgment’s
procedures before the relator could file suit, that would undermine the role that the
FCA assigns to relators and could perhaps deter relators who fear that the United
States might then bring the FCA suit instead. It seems particularly anomalous to
construe the consent judgment to make a relator’s right to file a qui tam suit
contingent on steps that the FCA itself discountenances.
23
Fourth, the pre-enforcement procedures delay and appear to confer a veto over
the United States’ and state parties’ ability to bring an “enforcement action.” Under
the district court’s premise, the United States could not file an FCA suit, or perhaps a
criminal case, until first notifying the Monitoring Committee and giving the
committee an opportunity to act. And if the committee did “commenc[e] an
enforcement action,” it appears that the United States may not be able to do so. The
ability of a government to pursue actions for fraud against the sovereign is an
important power. And the False Claims Act specifically establishes the power to
bring such suits and the procedures governing such suits. Agreements with the
United States must be construed narrowly to avoid foreclosing the later exercise of
sovereign authority. See United States v. Cherokee Nation of Okla., 480 U.S. 700, 707
(1987); Merrion v. Jicarilla Apache Tribe, 455 U.S. 130, 148 (1982). At the very least, it
would be surprising if the United States and state parties agreed to vastly limit their
own legal authority to proceed against a bank for outright fraud. See Firefighters Local
Union No. 1784 v. Stotts, 467 U.S. 561, 574-575 (1984) (“it seems highly unlikely” that
a city would “bargain away” important programs and “[h]ad there been any intention”
to make a significant policy change, “it is much more reasonable to believe that there
would have been an express provision to that effect”); cf. United States ex rel. Onnen v.
Sioux Falls Indep. Sch. Dist. No. 49-5, 688 F.3d 410, 414-415 (8th Cir. 2012).
Fifth, in a section titled “Enforcement Action”—the same term that triggers
the pre-enforcement procedures—the consent judgment establishes available

24
remedies. “In the event of an action to enforce [Chase’s] obligations . . . and to seek
remedies for an uncured Potential Violation for which [Chase’s] time to cure has
expired, the sole relief available” is ordinarily “Equitable Relief,” constituting “[a]n
order directing non-monetary equitable relief, including injunctive relief, directing
specific performance under the terms of this Consent Judgment, or other non-
monetary corrective action.” Consent J. Ex. E, § J(3)(a). The court “may award”
defined “civil penalties” for uncured “Potential Violation[s],” id. § J(3)(b). It would be
passing strange to so severely limit the remedies available in any action arising, even in
part, from the failure to comply with the consent judgment’s terms—including actions
for fraud.
CONCLUSION
The judgment of the district court should be vacated and remanded for further
proceedings.9
9
Chase raised many other arguments below and may repeat those arguments as
alternative grounds for affirmance. We do not address those issues at this time, as
they have not yet been (and may not be) briefed to this Court.
25
Respectfully submitted,
CHAD A. READLER
Acting Assistant Attorney General
CHANNING D. PHILLIPS
United States Attorney
MICHAEL S. RAAB
ADAM C. JED
(202) 514-8280
Attorneys, Appellate Staff
Civil Division, Room 7240
U.S. Department of Justice
950 Pennsylvania Ave., N.W.
Washington, DC 20530
JUNE 2017
26
CERTIFICATE OF COMPLIANCE WITH

FEDERAL RULE OF APPELLATE PROCEDURE 32(a)
I hereby certify that this brief complies with the requirements of Fed. R. App.
P. 32(a)(5) and (6) because it has been prepared in 14-point Garamond, a
proportionally spaced font. I further certify that this brief complies with the type-
volume limitation of Fed. R. App. P. 32(a)(7)(B) because it contains 6,468 words,
excluding the parts of the brief exempted under Rule 32(a)(7)(B)(iii), according to the
count of Microsoft Word.
/s/ Adam Jed

Adam C. Jed
I hereby certify that on June 14, 2017, I electronically filed the foregoing brief
with the Clerk of the Court for the United States Court of Appeals for the District of
Columbia Circuit by using the appellate CM/ECF system.
/s/ Adam Jed

Adam C. Jed
ADDENDUM
ADDENDUM TABLE OF CONTENTS
Consent Judgment, No. 1:12-cv-00361 (D.D.C. Apr. 4, 2012): Page
Consent Judgment ............................................................................................... Add. 1
Consent Judgment Ex. D (excerpts)................................................................. Add. 8
Consent Judgment Ex. E.................................................................................. Add. 11
Consent Judgment Ex. F (excerpts)................................................................ Add. 28

Case 1:12-cv-00361-RMC Document 10 Filed 04/04/12 Page 1 of 92
91
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA FILED
APH- 4 2012
Clerk, U.S. Ulstnc·( <X tlanKruptcy
) Courts for the District of Columbia
UNITED STATES OF AMERICA, )
eta!., )
)
Plaintiffs, )
(rH"""
J \._.; _,;.__
) I t ...
v. )
) Civil Action No. - - - -
BANK OF AMERICA CORP. eta!., )
)
Defendants. )
)
)
)
)
)
______________________________ )
CONSENT JUDGMENT
WHEREAS, Plaintiffs, the United States of America and the States of Alabama, Alaska,
Arizona, Arkansas, California, Colorado, Connecticut, Delaware, Florida, Georgia, Hawaii,
Idaho, Illinois, Indiana, Iowa, Kansas, Louisiana, Maine, Maryland, Michigan, Minnesota,
Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico,
New York, North Carolina, North Dakota, Ohio, Oregon, Rhode Island, South Carolina, South
Dakota, Tennessee, Texas, Utah, Vermont, Washington, West Virginia, Wisconsin, Wyoming,
the Commonwealths of Kentucky, Massachusetts, Pennsylvania and Virginia, and the District of
Columbia filed their complaint on March 12, 2012, alleging that J.P. Morgan Chase & Company
and J.P. Morgan Chase Bank, N.A. (collectively, "Defendant") violated, among other laws, the
Unfair and Deceptive Acts and Practices laws of the Plaintiff States, the False Claims Act, the
Add. 1
91
Financial Institutions Reform, Recovery, and Enforcement Act of 1989, the Servicemembers
Civil Relief Act, and the Bankruptcy Code and Federal Rules of Bankruptcy Procedure;
WHEREAS, the parties have agreed to resolve their claims without the need for
litigation;
WHEREAS, Defendant, by its attorneys, has consented to entry of this Consent Judgment
without trial or adjudication of any issue of fact or law and to waive any appeal if the Consent
Judgment is entered as submitted by the parties;
WHEREAS, Defendant, by entering into this Consent Judgment, does not admit the
allegations of the Complaint other than those facts deemed necessary to the jurisdiction of this
Court;
WHEREAS, the intention of the United States and the States in effecting this settlement
is to remediate harms allegedly resulting from the alleged unlawful conduct of the Defendant;
AND WHEREAS, Defendant has agreed to waive service of the complaint and summons
and hereby acknowledges the same;
NOW THEREFORE, without trial or adjudication of issue of fact or law, without this
Consent Judgment constituting evidence against Defendant, and upon consent of Defendant, the
Court finds that there is good and sufficient cause to enter this Consent Judgment, and that it is
therefore ORDERED, ADJUDGED, AND DECREED:
I. JURISDICTION
1. This Court has jurisdiction over the subject matter of this action pursuant to 28
U.S.C. §§ 1331, 1345, 1355(a), and 1367, and under 31 U.S.C. § 3732(a) and (b), and over
Defendant. The Complaint states a claim upon which relief may be granted against Defendant.
Venue is appropriate in this District pursuant to 28 U.S.C. § 1391(b)(2) and 31 U.S.C. § 3732(a).
2
Add. 2
91
II. SERVICING STANDARDS
2. Defendant shall comply with the Servicing Standards, attached hereto as Exhibit
A, in accordance with their terms and Section A of Exhibit E, attached hereto.
III. FINANCIAL TERMS
3. Payment Settlement Amounts. Defendant shall pay into an interest bearing escrow
account to be established for this purpose the sum of $1,121,188,661, which sum shall be added
to funds being paid by other institutions resolving claims in this litigation (which sum shall be
known as the "Direct Payment Settlement Amount") and which sum shall be distributed in the
manner and for the purposes specified in Exhibit B. Defendant's payment shall be made by
electronic funds transfer no later than seven days after the Effective Date of this Consent
Judgment, pursuant to written instructions to be provided by the United States Department of
Justice. After Defendant has made the required payment, Defendant shall no longer have any
property right, title, interest or other legal claim in any funds held in escrow. The interest
bearing escrow account established by this Paragraph 3 is intended to be a Qualified Settlement
Fund within the meaning ofTreasury Regulation Section 1.4688-1 ofthe U.S. Internal Revenue
Code of 1986, as amended. The Monitoring Committee established in Paragraph 8 shall, in its
sole discretion, appoint an escrow agent ("Escrow Agent") who shall hold and distribute funds as
provided herein. All costs and expenses of the Escrow Agent, including taxes, if any, shall be
paid from the funds under its control, including any interest earned on the funds.
4. Payments to Foreclosed Borrowers. In accordance with written instructions from
the State members of the Monitoring Committee, for the purposes set forth in Exhibit C, the
Escrow Agent shall transfer from the escrow account to the Administrator appointed under
Add. 3
91
Exhibit C $1,489,813,925.00 (the "Borrower Payment Amount") to enable the Administrator to
provide cash payments to borrowers whose homes were finally sold or taken in foreclosure
between and including January 1, 2008 and December 31, 2011; who submit claims for harm
allegedly arising from the Covered Conduct (as that term is defined in Exhibit G hereto); and
who otherwise meet criteria set forth by the State members of the Monitoring Committee. The
Borrower Payment Amount and any other funds provided to the Administrator for these purposes
shall be administered in accordance with the terms set forth in Exhibit C.
5. Consumer Relief Defendant shall provide $3,675,400,000 of relief to consumers
who meet the eligibility criteria in the forms and amounts described in Paragraphs 1-8 of Exhibit
D, and $53 7,000,000 of refinancing relief to consumers who meet the eligibility criteria in the
forms and amounts described in Paragraph 9 of Exhibit D, to remediate banns allegedly caused
by the alleged unlawful conduct of Defendant. Defendant shall receive credit towards such
obligation as described in Exhibit D.
IV. ENFORCEMENT
6. The Servicing Standards and Consumer Relief Requirements, attached as Exhibits
A and D, are incorporated herein as the judgment of this Court and shall be enforced in
accordance with the authorities provided in the Enforcement Tenns, attached hereto as Exhibit E.
7. The Parties agree that Joseph A. Smith, Jr. shall be the Monitor and shall have the
authorities and perform the duties described in the Enforcement Tetms, attached hereto as
Exhibit E.
8. Within fifteen (15) days ofthe Effective Date ofthis Consent Judgment, the
participating state and federal agencies shall designate an Administration and Monitoring
Committee (the "Monitoring Committee") as described in the Enforcement Tetms. The

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Monitoring Committee shall serve as the representative of the participating state and federal
agencies in the administration of all aspects of this and all similar Consent Judgments and the
monitoring of compliance with it by the Defendant.
V. RELEASES
9. The United States and Defendant have agreed, in consideration for the terms
provided herein, for the release of certain claims, and remedies, as provided in the Federal
Release, attached hereto as Exhibit F. The United States and Defendant have also agreed that
certain claims, and remedies are not released, as provided in Paragraph 11 of Exhibit F. The
releases contained in Exhibit F shall become effective upon payment of the Direct Payment
Settlement Amount by Defendant.
10. The State Parties and Defendant have agreed, in consideration for the terms
provided herein, for the release of certain claims, and remedies, as provided in the State Release,
attached hereto as Exhibit G. The State Parties and Defendant have also agreed that certain
claims, and remedies are not released, as provided in Part IV of Exhibit G. The releases
contained in Exhibit G shall become effective upon payment of the Direct Payment Settlement
Amount by Defendant.
VI. SERVICEMEMBERS CIVIL RELIEF ACT
11. The United States and Defendant have agreed to resolve certain claims arising
under the Servicemembers Civil Relief Act ("SCRA") in accordance with the terms provided in
Exhibit H. Any obligations undertaken pursuant to the terms provided in Exhibit H, including
any obligation to provide monetary compensation to servicemembers, are in addition to the
obligations undertaken pursuant to the other terms of this Consent Judgment. Only a payment to
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an individual for a wrongful foreclosure pursuant to the terms of Exhibit H shall be reduced by
the amount of any payment from the Borrower Payment Amount.
VII. OTHER TERMS
12. The United States and any State Party may withdraw from the Consent Judgment
and declare it null and void with respect to that party if the Defendant does not make the
Consumer Relief Payments (as that term is defined in Exhibit F (Federal Release)) required
under this Consent Judgment and fails to cure such non-payment within thirty days of written
notice. by the party.
13. This Court retains jurisdiction for the duration of this Consent Judgment to
enforce its terms. The parties may jointly seek to modify the terms of this Consent Judgment,
subject to the approval of this Court. This Consent Judgment may be modified only by order of
this Court.
14. The Effective Date of this Consent Judgment shall be the date on which the
Consent Judgment has been entered by the Court and has become final and non-appealable. An
order entering the Consent Judgment shall be deemed final and non-appealable for this purpose if
there is no party with a right to appeal the order on the day it is entered.
15. This Consent Judgment shall remain in full force and effect for three and one-half
years from the date it is entered ("the Term"), at which time the Defendants' obligations under
the Consent Judgment shall expire, except that, pursuant to Exhibit E, Defendants shall submit a
final Quarterly Report for the last quarter or portion thereof falling within the Term and
cooperate with the Monitor's review of said report, which shall be concluded no later than six
months after the end of the Tem1. Defendant shall have no further obligations under this
Consent Judgment six months after the expiration of the Term, but the Court shall retain
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jurisdiction for purposes of enforcing or remedying any outstanding violations that are identified
in the final Monitor Report and that have occurred but not been cured during the Term.
16. Except as otherwise agreed in Exhibit B, each party to this litigation will bear its
own costs and attorneys' fees associated with this litigation.
17. Nothing in this Consent Judgment shall relieve Defendant of its obligation to
comply with applicable state and federal law.
18. The sum and substance of the parties' agreement and of this Consent Judgment
are reflected herein and in the Exhibits attached hereto. In the event of a conflict between the
terms of the Exhibits and paragraphs 1-18 of this summary document, the tem1s of the Exhibits
shall govern.
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SO ORDERED this _4ctay of 11/:'t~
I
'2012
UNITED STATES DISTRICT JUDGE
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EXHIBIT D
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Consumer Relief Requirements
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EXHIBIT E
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Enforcement Terms
A. Implementation Timeline. Servicer anticipates that it will phase in the

implementation of the Servicing Standards and Mandatory Relief Requirements
(i) through (iv), as described in Section C.12, using a grid approach that
prioritizes implementation based upon: (i) the importance of the Servicing
Standard to the borrower; and (ii) the difficulty of implementing the Servicing
Standard. In addition to the Servicing Standards and any Mandatory Relief
Requirements that have been implemented upon entry of this Consent Judgment,
the periods for implementation will be: (a) within 60 days of entry of this
Consent Judgment; (b) within 90 days of entry of this Consent Judgment; and (c)
within 180 days of entry of this Consent Judgment. Servicer will agree with the
Monitor chosen pursuant to Section C, below, on the timetable in which the
Servicing Standards and Mandatory Relief Requirements (i) through (iv) will be
implemented. In the event that Servicer, using reasonable efforts, is unable to
implement certain of the standards on the specified timetable, Servicer may apply
to the Monitor for a reasonable extension of time to implement those standards or
requirements.
B. Monitoring Committee. A committee comprising representatives of the state
Attorneys General, State Financial Regulators, the U.S. Department of Justice,
and the U.S. Department of Housing and Urban Development shall monitor
Servicer’s compliance with this Consent Judgment (the “Monitoring Committee”).
The Monitoring Committee may substitute representation, as necessary. Subject
to Section F, the Monitoring Committee may share all Monitor Reports, as that
term is defined in Section D.2 below, with any releasing party.
C. Monitor
Retention and Qualifications and Standard of Conduct
1. Pursuant to an agreement of the parties, Joseph A. Smith Jr. is appointed
to the position of Monitor under this Consent Judgment. If the Monitor is
at any time unable to complete his or her duties under this Consent
Judgment, Servicer and the Monitoring Committee shall mutually agree
upon a replacement in accordance with the process and standards set forth
in Section C of this Consent Judgment.
2. Such Monitor shall be highly competent and highly respected, with a
reputation that will garner public confidence in his or her ability to
perform the tasks required under this Consent Judgment. The Monitor
shall have the right to employ an accounting firm or firms or other firm(s)
with similar capabilities to support the Monitor in carrying out his or her
duties under this Consent Judgment. Monitor and Servicer shall agree on
the selection of a “Primary Professional Firm,” which must have adequate
capacity and resources to perform the work required under this agreement.
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The Monitor shall also have the right to engage one or more attorneys or
other professional persons to represent or assist the Monitor in carrying
out the Monitor’s duties under this Consent Judgment (each such
individual, along with each individual deployed to the engagement by the
Primary Professional Firm, shall be defined as a “Professional”). The
Monitor and Professionals will collectively possess expertise in the areas
of mortgage servicing, loss mitigation, business operations, compliance,
internal controls, accounting, and foreclosure and bankruptcy law and
practice. The Monitor and Professionals shall at all times act in good faith
and with integrity and fairness towards all the Parties.
3. The Monitor and Professionals shall not have any prior relationships with
the Parties that would undermine public confidence in the objectivity of
their work and, subject to Section C.3(e), below, shall not have any
conflicts of interest with any Party.
(a) The Monitor and Professionals will disclose, and will make a
reasonable inquiry to discover, any known current or prior
relationships to, or conflicts with, any Party, any Party’s holding
company, any subsidiaries of the Party or its holding company,
directors, officers, and law firms.
(b) The Monitor and Professionals shall make a reasonable inquiry to
determine whether there are any facts that a reasonable individual
would consider likely to create a conflict of interest for the
Monitor or Professionals. The Monitor and Professionals shall
disclose any conflict of interest with respect to any Party.
(c) The duty to disclose a conflict of interest or relationship pursuant
to this Section C.3 shall remain ongoing throughout the course of
the Monitor’s and Professionals’ work in connection with this
Consent Judgment.
(d) All Professionals shall comply with all applicable standards of
professional conduct, including ethics rules and rules pertaining to
conflicts of interest.
(e) To the extent permitted under prevailing professional standards, a
Professional’s conflict of interest may be waived by written
agreement of the Monitor and Servicer.
(f) Servicer or the Monitoring Committee may move the Court for an
order disqualifying any Professionals on the grounds that such
Professional has a conflict of interest that has inhibited or could
inhibit the Professional’s ability to act in good faith and with
integrity and fairness towards all Parties.
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4. The Monitor must agree not to be retained by any Party, or its successors
or assigns, for a period of 2 years after the conclusion of the terms of the
engagement. Any Professionals who work on the engagement must agree
not to work on behalf of Servicer, or its successor or assigns, for a period
of 1 year after the conclusion of the term of the engagement (the
“Professional Exclusion Period”). Any Firm that performs work with
respect to Servicer on the engagement must agree not to perform work on
behalf of Servicer, or its successor or assigns, that consists of advising
Servicer on a response to the Monitor’s review during the engagement and
for a period of six months after the conclusion of the term of the
engagement (the “Firm Exclusion Period”). The Professional Exclusion
Period and Firm Exclusion Period, and terms of exclusion may be altered
on a case-by-case basis upon written agreement of Servicer and the
Monitor. The Monitor shall organize the work of any Firms so as to
minimize the potential for any appearance of, or actual, conflicts.
Monitor’s Responsibilities
5. It shall be the responsibility of the Monitor to determine whether Servicer
is in compliance with the Servicing Standards and the Mandatory Relief
Requirements (as defined in Section C.12) and whether Servicer has
satisfied the Consumer Relief Requirements, in accordance with the
authorities provided herein and to report his or her findings as provided in
Section D.3, below.
6. The manner in which the Monitor will carry out his or her compliance
responsibilities under this Consent Judgment and, where applicable, the
methodologies to be utilized shall be set forth in a work plan agreed upon
by Servicer and the Monitor, and not objected to by the Monitoring
Committee (the “Work Plan”).
Internal Review Group
7. Servicer will designate an internal quality control group that is
independent from the line of business whose performance is being
measured (the “Internal Review Group”) to perform compliance reviews
each calendar quarter (“Quarter”) in accordance with the terms and
conditions of the Work Plan (the “Compliance Reviews”) and satisfaction
of the Consumer Relief Requirements after the (A) end of each calendar
year (and, in the discretion of the Servicer, any Quarter) and (B) earlier of
the Servicer assertion that it has satisfied its obligations thereunder and the
third anniversary of the Start Date (the “Satisfaction Review”). For the
purposes of this provision, a group that is independent from the line of
business shall be one that does not perform operational work on mortgage
servicing, and ultimately reports to a Chief Risk Officer, Chief Audit
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Executive, Chief Compliance Officer, or another employee or manager

who has no direct operational responsibility for mortgage servicing.
8. The Internal Review Group shall have the appropriate authority, privileges,
and knowledge to effectively implement and conduct the reviews and
metric assessments contemplated herein and under the terms and
conditions of the Work Plan.
9. The Internal Review Group shall have personnel skilled at evaluating and
validating processes, decisions, and documentation utilized through the
implementation of the Servicing Standards. The Internal Review Group
may include non-employee consultants or contractors working at
Servicer’s direction.
10. The qualifications and performance of the Internal Review Group will be
subject to ongoing review by the Monitor. Servicer will appropriately
remediate the reasonable concerns of the Monitor as to the qualifications
or performance of the Internal Review Group.
Work Plan
11. Servicer’s compliance with the Servicing Standards shall be assessed via
metrics identified and defined in Schedule E-1 hereto (as supplemented
from time to time in accordance with Sections C.12 and C.23, below, the
“Metrics”). The threshold error rates for the Metrics are set forth in
Schedule E-1 (as supplemented from time to time in accordance with
Sections C.12 and C.23, below, the “Threshold Error Rates”). The
Internal Review Group shall perform test work to compute the Metrics
each Quarter, and report the results of that analysis via the Compliance
Reviews. The Internal Review Group shall perform test work to assess the
satisfaction of the Consumer Relief Requirements within 45 days after the
(A) end of each calendar year (and, in the discretion of the Servicer, any
Quarter) and (B) earlier of (i) the end of the Quarter in which Servicer
asserts that it has satisfied its obligations under the Consumer Relief
Provisions and (ii) the Quarter during which the third anniversary of the
Start Date occurs, and report that analysis via the Satisfaction Review.
12. In addition to the process provided under Sections C.23 and 24, at any
time after the Monitor is selected, the Monitor may add up to three
additional Metrics and associated Threshold Error Rates, all of which
(a) must be similar to the Metrics and associated Threshold Error Rates
contained in Schedule E-1, (b) must relate to material terms of the
Servicing Standards, or the following obligations of Servicer: (i) after the
Servicer asserts that it has satisfied its obligation to provide a refinancing
program under the framework of the Consumer Relief Requirements
(“Framework”), to provide notification to eligible borrowers indicating
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that such borrowers may refinance under the refinancing program

described in the Framework, (ii) to make the Refinancing Program
available to all borrowers fitting the minimum eligibility criteria described
in 9.a of the Framework, (iii) when the Servicer owns the second lien
mortgage, to modify the second lien mortgage when a Participating
Servicer (as defined in the Framework) reduces principal on the related
first lien mortgage, as described in the Framework, (iv) with regard to
servicer-owned first liens, to waive the deficiency amounts less than
$250,000 if an Eligible Servicemember qualifies for a short sale under the
Framework and sells his or her principal residence in a short sale
conducted in accordance with Servicer’s then customary short sale process,
or (v) without prejudice to the implementation of pilot programs in
particular geographic areas, to implement the Framework requirements
through policies that are not intended to disfavor a specific geography
within or among states that are a party to the Consent Judgment or
discriminate against any protected class of borrowers (collectively, the
obligations described in (i) through (v) are hereinafter referred to as the
“Mandatory Relief Requirements”), (c) must either (i) be outcomes-based
(but no outcome-based Metric shall be added with respect to any
Mandatory Relief Requirement) or (ii) require the existence of policies
and procedures implementing any of the Mandatory Relief Requirements
or any material term of the Servicing Standards, in a manner similar to
Metrics 5.B-E, and (d) must be distinct from, and not overlap with, any
other Metric or Metrics. In consultation with Servicer and the Monitoring
Committee, Schedule E-1 shall be amended by the Monitor to include the
additional Metrics and Threshold Error Rates as provided for herein, and
an appropriate timeline for implementation of the Metric shall be
determined.
13. Servicer and the Monitor shall reach agreement on the terms of the Work
Plan within 90 days of the Monitor’s appointment, which time can be
extended for good cause by agreement of Servicer and the Monitor. If
such Work Plan is not objected to by the Monitoring Committee within 20
days, the Monitor shall proceed to implement the Work Plan. In the event
that Servicer and the Monitor cannot agree on the terms of the Work Plan
within 90 days or the agreed upon terms are not acceptable to the
Monitoring Committee, Servicer and Monitoring Committee or the
Monitor shall jointly petition the Court to resolve any disputes. If the
Court does not resolve such disputes, then the Parties shall submit all
remaining disputes to binding arbitration before a panel of three arbitrators.
Each of Servicer and the Monitoring Committee shall appoint one
arbitrator, and those two arbitrators shall appoint a third.
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14. The Work Plan may be modified from time to time by agreement of the
Monitor and Servicer. If such amendment to the Work Plan is not
objected to by the Monitoring Committee within 20 days, the Monitor
shall proceed to implement the amendment to the Work Plan. To the
extent possible, the Monitor shall endeavor to apply the Servicing
Standards uniformly across all Servicers.
15. The following general principles shall provide a framework for the
formulation of the Work Plan:
(a) The Work Plan will set forth the testing methods and agreed
procedures that will be used by the Internal Review Group to
perform the test work and compute the Metrics for each Quarter.
(b) The Work Plan will set forth the testing methods and agreed
procedures that will be used by Servicer to report on its
compliance with the Consumer Relief Requirements of this
Consent Judgment, including, incidental to any other testing,
confirmation of state-identifying information used by Servicer to
compile state-level Consumer Relief information as required by
Section D.2.
(c) The Work Plan will set forth the testing methods and procedures
that the Monitor will use to assess Servicer’s reporting on its
compliance with the Consumer Relief Requirements of this
Consent Judgment.
(d) The Work Plan will set forth the methodology and procedures the
Monitor will utilize to review the testing work performed by the
Internal Review Group.
(e) The Compliance Reviews and the Satisfaction Review may include
a variety of audit techniques that are based on an appropriate
sampling process and random and risk-based selection criteria, as
appropriate and as set forth in the Work Plan.
(f) In formulating, implementing, and amending the Work Plan,
Servicer and the Monitor may consider any relevant information
relating to patterns in complaints by borrowers, issues or
deficiencies reported to the Monitor with respect to the Servicing
Standards, and the results of prior Compliance Reviews.
(g) The Work Plan should ensure that Compliance Reviews are
commensurate with the size, complexity, and risk associated with
the Servicing Standard being evaluated by the Metric.
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(h) Following implementation of the Work Plan, Servicer shall be

required to compile each Metric beginning in the first full Quarter
after the period for implementing the Servicing Standards
associated with the Metric, or any extension approved by the
Monitor in accordance with Section A, has run.
Monitor’s Access to Information
16. So that the Monitor may determine whether Servicer is in compliance with
the Servicing Standards and Mandatory Relief Requirements, Servicer
shall provide the Monitor with its regularly prepared business reports
analyzing Executive Office servicing complaints (or the equivalent);
access to all Executive Office servicing complaints (or the equivalent)
(with appropriate redactions of borrower information other than borrower
name and contact information to comply with privacy requirements); and,
if Servicer tracks additional servicing complaints, quarterly information
identifying the three most common servicing complaints received outside
of the Executive Office complaint process (or the equivalent). In the event
that Servicer substantially changes its escalation standards or process for
receiving Executive Office servicing complaints (or the equivalent),
Servicer shall ensure that the Monitor has access to comparable
information.
17. So that the Monitor may determine whether Servicer is in compliance with
the Servicing Standards and Mandatory Relief Requirements, Servicer
shall notify the Monitor promptly if Servicer becomes aware of reliable
information indicating Servicer is engaged in a significant pattern or
practice of noncompliance with a material aspect of the Servicing
Standards or Mandatory Relief Requirements.
18. Servicer shall provide the Monitor with access to all work papers prepared
by the Internal Review Group in connection with determining compliance
with the Metrics or satisfaction of the Consumer Relief Requirements in
accordance with the Work Plan.
19. If the Monitor becomes aware of facts or information that lead the Monitor
to reasonably conclude that Servicer may be engaged in a pattern of
noncompliance with a material term of the Servicing Standards that is
reasonably likely to cause harm to borrowers or with any of the Mandatory
Relief Requirements, the Monitor shall engage Servicer in a review to
determine if the facts are accurate or the information is correct.
20. Where reasonably necessary in fulfilling the Monitor’s responsibilities
under the Work Plan to assess compliance with the Metrics or the
satisfaction of the Consumer Relief Requirements, the Monitor may
request information from Servicer in addition to that provided under
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Sections C.16-19. Servicer shall provide the requested information in a

format agreed upon between Servicer and the Monitor.
21. Where reasonably necessary in fulfilling the Monitor’s responsibilities
under the Work Plan to assess compliance with the Metrics or the
satisfaction of the Consumer Relief Requirements, the Monitor may
interview Servicer’s employees and agents, provided that the interviews
shall be limited to matters related to Servicer’s compliance with the
Metrics or the Consumer Relief Requirements, and that Servicer shall be
given reasonable notice of such interviews.
Monitor’s Powers
22. Where the Monitor reasonably determines that the Internal Review
Group’s work cannot be relied upon or that the Internal Review Group did
not correctly implement the Work Plan in some material respect, the
Monitor may direct that the work on the Metrics (or parts thereof) be
reviewed by Professionals or a third party other than the Internal Review
Group, and that supplemental work be performed as necessary.
23. If the Monitor becomes aware of facts or information that lead the Monitor
to reasonably conclude that Servicer may be engaged in a pattern of
noncompliance with a material term of the Servicing Standards that is
reasonably likely to cause harm to borrowers or tenants residing in
foreclosed properties or with any of the Mandatory Relief Requirements,
the Monitor shall engage Servicer in a review to determine if the facts are
accurate or the information is correct. If after that review, the Monitor
reasonably concludes that such a pattern exists and is reasonably likely to
cause material harm to borrowers or tenants residing in foreclosed
properties, the Monitor may propose an additional Metric and associated
Threshold Error Rate relating to Servicer’s compliance with the associated
term or requirement. Any additional Metrics and associated Threshold
Error Rates (a) must be similar to the Metrics and associated Threshold
Error Rates contained in Schedule E-1, (b) must relate to material terms of
the Servicing Standards or one of the Mandatory Relief Requirements,
(c) must either (i) be outcomes-based (but no outcome-based Metric shall
be added with respect to any Mandatory Relief Requirement) or (ii)
require the existence of policies and procedures required by the Servicing
Standards or the Mandatory Relief Requirements, in a manner similar to
Metrics 5.B-E, and (d) must be distinct from, and not overlap with, any
other Metric or Metrics. Notwithstanding the foregoing, the Monitor may
add a Metric that satisfies (a)-(c) but does not satisfy (d) of the preceding
sentence if the Monitor first asks the Servicer to propose, and then
implement, a Corrective Action Plan, as defined below, for the material
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term of the Servicing Standards with which there is a pattern of

noncompliance and that is reasonably likely to cause material harm to
borrowers or tenants residing in foreclosed properties, and the Servicer
fails to implement the Corrective Action Plan according to the timeline
agreed to with the Monitor.
24. If Monitor proposes an additional Metric and associated Threshold Error
Rate pursuant to Section C.23, above, Monitor, the Monitoring Committee,
and Servicer shall agree on amendments to Schedule E-1 to include the
additional Metrics and Threshold Error Rates provided for in Section C.23,
above, and an appropriate timeline for implementation of the Metric. If
Servicer does not timely agree to such additions, any associated
amendments to the Work Plan, or the implementation schedule, the
Monitor may petition the court for such additions.
25. Any additional Metric proposed by the Monitor pursuant to the processes
in Sections C.12, C.23, or C.24 and relating to provision VIII.B.1 of the
Servicing Standards shall be limited to Servicer’s performance of its
obligations to comply with (1) the federal Protecting Tenants at
Foreclosure Act and state laws that provide comparable protections to
tenants of foreclosed properties; (2) state laws that govern relocation
assistance payments to tenants (“cash for keys”); and (3) state laws that
govern the return of security deposits to tenants.
D. Reporting
Quarterly Reports
1. Following the end of each Quarter, Servicer will report the results of its
Compliance Reviews for that Quarter (the “Quarterly Report”). The
Quarterly Report shall include: (i) the Metrics for that Quarter; (ii)
Servicer’s progress toward meeting its payment obligations under this
Consent Judgment; (iii) general statistical data on Servicer’s overall
servicing performance described in Schedule Y. Except where an
extension is granted by the Monitor, Quarterly Reports shall be due no
later than 45 days following the end of the Quarter and shall be provided
to: (1) the Monitor, and (2) the Board of Servicer or a committee of the
Board designated by Servicer. The first Quarterly Report shall cover the
first full Quarter after this Consent Judgment is entered.
2. Following the end of each Quarter, Servicer will transmit to each state a
report (the “State Report”) including general statistical data on Servicer’s
servicing performance, such as aggregate and state-specific information
regarding the number of borrowers assisted and credited activities
conducted pursuant to the Consumer Relief Requirements, as described in
Schedule Y. The State Report will be delivered simultaneous with the
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submission of the Quarterly Report to the Monitor. Servicer shall provide

copies of such State Reports to the Monitor and Monitoring Committee.
Monitor Reports
3. The Monitor shall report on Servicer’s compliance with this Consent
Judgment in periodic reports setting forth his or her findings (the “Monitor
Reports”). The first three Monitor Reports will each cover two Quarterly
Reports. If the first three Monitor Reports do not find Potential Violations
(as defined in Section E.1, below), each successive Monitor Report will
cover four Quarterly Reports, unless and until a Quarterly Report reveals a
Potential Violation (as defined in Section E.1, below). In the case of a
Potential Violation, the Monitor may (but retains the discretion not to)
submit a Monitor Report after the filing of each of the next two Quarterly
Reports, provided, however, that such additional Monitor Report(s) shall
be limited in scope to the Metric or Metrics as to which a Potential
Violation has occurred.
4. Prior to issuing any Monitor Report, the Monitor shall confer with
Servicer and the Monitoring Committee regarding its preliminary findings
and the reasons for those findings. Servicer shall have the right to submit
written comments to the Monitor, which shall be appended to the final
version of the Monitor Report. Final versions of each Monitor Report
shall be provided simultaneously to the Monitoring Committee and
Servicers within a reasonable time after conferring regarding the
Monitor’s findings. The Monitor Reports shall be filed with the Court
overseeing this Consent Judgment and shall also be provided to the Board
of Servicer or a committee of the Board designated by Servicer.
5. The Monitor Report shall: (i) describe the work performed by the Monitor
and any findings made by the Monitor’s during the relevant period, (ii) list
the Metrics and Threshold Error Rates, (iii) list the Metrics, if any, where
the Threshold Error Rates have been exceeded, (iv) state whether a
Potential Violation has occurred and explain the nature of the Potential
Violation, and (v) state whether any Potential Violation has been cured. In
addition, following each Satisfaction Review, the Monitor Report shall
report on the Servicer’s satisfaction of the Consumer Relief Requirements,
including regarding the number of borrowers assisted and credited
activities conducted pursuant to the Consumer Relief Requirements, and
identify any material inaccuracies identified in prior State Reports. Except
as otherwise provided herein, the Monitor Report may be used in any
court hearing, trial, or other proceeding brought pursuant to this Consent
Judgment pursuant to Section J, below, and shall be admissible in
evidence in a proceeding brought under this Consent Judgment pursuant to
Section J, below. Such admissibility shall not prejudice Servicer’s right
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and ability to challenge the findings and/or the statements in the Monitor
Report as flawed, lacking in probative value or otherwise. The Monitor
Report with respect to a particular Potential Violation shall not be
admissible or used for any purpose if Servicer cures the Potential
Violation pursuant to Section E, below.
Satisfaction of Payment Obligations
6. Upon the satisfaction of any category of payment obligation under this
Consent Judgment, Servicer, at its discretion, may request that the Monitor
certify that Servicer has discharged such obligation. Provided that the
Monitor is satisfied that Servicer has met the obligation, the Monitor may
not withhold and must provide the requested certification. Any
subsequent Monitor Report shall not include a review of Servicer’s
compliance with that category of payment obligation.
Compensation
7. Within 120 days of entry of this Consent Judgment, the Monitor shall, in
consultation with the Monitoring Committee and Servicer, prepare and
present to Monitoring Committee and Servicer an annual budget providing
its reasonable best estimate of all fees and expenses of the Monitor to be
incurred during the first year of the term of this Consent Judgment,
including the fees and expenses of Professionals and support staff (the
“Monitoring Budget”). On a yearly basis thereafter, the Monitor shall
prepare an updated Monitoring Budget providing its reasonable best
estimate of all fees and expenses to be incurred during that year. Absent
an objection within 20 days, a Monitoring Budget or updated Monitoring
Budget shall be implemented. Consistent with the Monitoring Budget,
Servicer shall pay all fees and expenses of the Monitor, including the fees
and expenses of Professionals and support staff. The fees, expenses, and
costs of the Monitor, Professionals, and support staff shall be reasonable.
Servicer may apply to the Court to reduce or disallow fees, expenses, or
costs that are unreasonable.
E. Potential Violations and Right to Cure
1. A “Potential Violation” of this Consent Judgment occurs if the Servicer
has exceeded the Threshold Error Rate set for a Metric in a given Quarter.
In the event of a Potential Violation, Servicer shall meet and confer with
the Monitoring Committee within 15 days of the Quarterly Report or
Monitor Report indicating such Potential Violation.
2. Servicer shall have a right to cure any Potential Violation.
3. Subject to Section E.4, a Potential Violation is cured if (a) a corrective
action plan approved by the Monitor (the “Corrective Action Plan”) is
determined by the Monitor to have been satisfactorily completed in
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accordance with the terms thereof; and (b) a Quarterly Report covering the
Cure Period reflects that the Threshold Error Rate has not been exceeded
with respect to the same Metric and the Monitor confirms the accuracy of
said report using his or her ordinary testing procedures. The Cure Period
shall be the first full quarter after completion of the Corrective Action Plan
or, if the completion of the Corrective Action Plan occurs within the first
month of a Quarter and if the Monitor determines that there is sufficient
time remaining, the period between completion of the Corrective Action
Plan and the end of that Quarter.
4. If after Servicer cures a Potential Violation pursuant to the previous
section, another violation occurs with respect to the same Metric, then the
second Potential Violation shall immediately constitute an uncured
violation for purposes of Section J.3, provided, however, that such second
Potential Violation occurs in either the Cure Period or the quarter
immediately following the Cure Period.
5. In addition to the Servicer’s obligation to cure a Potential Violation
through the Corrective Action Plan, Servicer must remediate any material
harm to particular borrowers identified through work conducted under the
Work Plan. In the event that a Servicer has a Potential Violation that so
far exceeds the Threshold Error Rate for a metric that the Monitor
concludes that the error is widespread, Servicer shall, under the
supervision of the Monitor, identify other borrowers who may have been
harmed by such noncompliance and remediate all such harms to the extent
that the harm has not been otherwise remediated.
6. In the event a Potential Violation is cured as provided in Sections E.3,
above, then no Party shall have any remedy under this Consent Judgment
(other than the remedies in Section E.5) with respect to such Potential
Violation.
F. Confidentiality
1. These provisions shall govern the use and disclosure of any and all
information designated as “CONFIDENTIAL,” as set forth below, in
documents (including email), magnetic media, or other tangible things
provided by the Servicer to the Monitor in this case, including the
subsequent disclosure by the Monitor to the Monitoring Committee of
such information. In addition, it shall also govern the use and disclosure
of such information when and if provided to the participating state parties
or the participating agency or department of the United States whose
claims are released through this settlement (“participating state or federal
agency whose claims are released through this settlement”).
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2. The Monitor may, at his discretion, provide to the Monitoring Committee

or to a participating state or federal agency whose claims are released
through this settlement any documents or information received from the
Servicer related to a Potential Violation or related to the review described
in Section C.19; provided, however, that any such documents or
information so provided shall be subject to the terms and conditions of
these provisions. Nothing herein shall be construed to prevent the Monitor
from providing documents received from the Servicer and not designated
as “CONFIDENTIAL” to a participating state or federal agency whose
claims are released through this settlement.
3. The Servicer shall designate as “CONFIDENTIAL” that information,
document or portion of a document or other tangible thing provided by the
Servicer to the Monitor, the Monitoring Committee or to any other
participating state or federal agency whose claims are released through
this settlement that Servicer believes contains a trade secret or confidential
research, development, or commercial information subject to protection
under applicable state or federal laws (collectively, “Confidential
Information”). These provisions shall apply to the treatment of
Confidential Information so designated.
4. Except as provided by these provisions, all information designated as
“CONFIDENTIAL” shall not be shown, disclosed or distributed to any
person or entity other than those authorized by these provisions.
Participating states and federal agencies whose claims are released
through this settlement agree to protect Confidential Information to the
extent permitted by law.
5. This agreement shall not prevent or in any way limit the ability of a
participating state or federal agency whose claims are released through
this settlement to comply with any subpoena, Congressional demand for
documents or information, court order, request under the Right of
Financial Privacy Act, or a state or federal public records or state or
federal freedom of information act request; provided, however, that in the
event that a participating state or federal agency whose claims are released
through this settlement receives such a subpoena, Congressional demand,
court order or other request for the production of any Confidential
Information covered by this Order, the state or federal agency shall, unless
prohibited under applicable law or the unless the state or federal agency
would violate or be in contempt of the subpoena, Congressional demand,
or court order, (1) notify the Servicer of such request as soon as
practicable and in no event more than ten (10) calendar days of its receipt
or three calendar days before the return date of the request, whichever is
sooner, and (2) allow the Servicer ten (10) calendar days from the receipt
of the notice to obtain a protective order or stay of production for the
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documents or information sought, or to otherwise resolve the issue, before

the state or federal agency discloses such documents or information. In all
cases covered by this Section, the state or federal agency shall inform the
requesting party that the documents or information sought were produced
subject to the terms of these provisions.
G. Dispute Resolution Procedures. Servicer, the Monitor, and the Monitoring
Committee will engage in good faith efforts to reach agreement on the proper
resolution of any dispute concerning any issue arising under this Consent
Judgment, including any dispute or disagreement related to the withholding of
consent, the exercise of discretion, or the denial of any application. Subject to
Section J, below, in the event that a dispute cannot be resolved, Servicer, the
Monitor, or the Monitoring Committee may petition the Court for resolution of
the dispute. Where a provision of this agreement requires agreement, consent of,
or approval of any application or action by a Party or the Monitor, such agreement,
consent or approval shall not be unreasonably withheld.
H. Consumer Complaints. Nothing in this Consent Judgment shall be deemed to
interfere with existing consumer complaint resolution processes, and the Parties
are free to bring consumer complaints to the attention of Servicer for resolution
outside the monitoring process. In addition, Servicer will continue to respond in
good faith to individual consumer complaints provided to it by State Attorneys
General or State Financial Regulators in accordance with the routine and practice
existing prior to the entry of this Consent Judgment, whether or not such
complaints relate to Covered Conduct released herein.
I. Relationship to Other Enforcement Actions. Nothing in this Consent Judgment
shall affect requirements imposed on the Servicer pursuant to Consent Orders
issued by the appropriate Federal Banking Agency (FBA), as defined in 12 U.S.C.
§ 1813(q), against the Servicer. In conducting their activities under this Consent
Judgment, the Monitor and Monitoring Committee shall not impede or otherwise
interfere with the Servicer’s compliance with the requirements imposed pursuant
to such Orders or with oversight and enforcement of such compliance by the FBA.
J. Enforcement
1. Consent Judgment. This Consent Judgment shall be filed in the U.S.
District Court for the District of Columbia (the “Court”) and shall be
enforceable therein. Servicer and the Releasing Parties shall waive their
rights to seek judicial review or otherwise challenge or contest in any
court the validity or effectiveness of this Consent Judgment. Servicer and
the Releasing Parties agree not to contest any jurisdictional facts,
including the Court’s authority to enter this Consent Judgment.
2. Enforcing Authorities. Servicer’s obligations under this Consent
Judgment shall be enforceable solely in the U.S. District Court for the
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District of Columbia. An enforcement action under this Consent

Judgment may be brought by any Party to this Consent Judgment or the
Monitoring Committee. Monitor Report(s) and Quarterly Report(s) shall
not be admissible into evidence by a Party to this Consent Judgment
except in an action in the Court to enforce this Consent Judgment. In
addition, unless immediate action is necessary in order to prevent
irreparable and immediate harm, prior to commencing any enforcement
action, a Party must provide notice to the Monitoring Committee of its
intent to bring an action to enforce this Consent Judgment. The members
of the Monitoring Committee shall have no more than 21 days to
determine whether to bring an enforcement action. If the members of the
Monitoring Committee decline to bring an enforcement action, the Party
must wait 21 additional days after such a determination by the members of
the Monitoring Committee before commencing an enforcement action.
3. Enforcement Action. In the event of an action to enforce the obligations
of Servicer and to seek remedies for an uncured Potential Violation for
which Servicer’s time to cure has expired, the sole relief available in such
an action will be:
(a) Equitable Relief. An order directing non-monetary equitable relief,
including injunctive relief, directing specific performance under
the terms of this Consent Judgment, or other non-monetary
corrective action.
(b) Civil Penalties. The Court may award as civil penalties an amount
not more than $1 million per uncured Potential Violation; or, in the
event of a second uncured Potential Violation of Metrics 1.a, 1.b,
or 2.a (i.e., a Servicer fails the specific Metric in a Quarter, then
fails to cure that Potential Violation, and then in subsequent
Quarters, fails the same Metric again in a Quarter and fails to cure
that Potential Violation again in a subsequent Quarter), where the
final uncured Potential Violation involves widespread
noncompliance with that Metric, the Court may award as civil
penalties an amount not more than $5 million for the second
uncured Potential Violation.
Nothing in this Section shall limit the availability of remedial

compensation to harmed borrowers as provided in Section E.5.
(c) Any penalty or payment owed by Servicer pursuant to the Consent

Judgment shall be paid to the clerk of the Court or as otherwise
agreed by the Monitor and the Servicer and distributed by the
Monitor as follows:
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1. In the event of a penalty based on a violation of a term of

the Servicing Standards that is not specifically related to
conduct in bankruptcy, the penalty shall be allocated, first,
to cover the costs incurred by any state or states in
prosecuting the violation, and second, among the
participating states according to the same allocation as the
State Payment Settlement Amount.
2. In the event of a penalty based on a violation of a term of

the Servicing Standards that is specifically related to
conduct in bankruptcy, the penalty shall be allocated to the
United States or as otherwise directed by the Director of the
United States Trustee Program.
3. In the event of a payment due under Paragraph 10.d of the

Consumer Relief requirements, 50% of the payment shall
be allocated to the United States, and 50% shall be
allocated to the State Parties to the Consent Judgment,
divided among them in a manner consistent with the
allocation in Exhibit B of the Consent Judgment.
K. Sunset. This Consent Judgment and all Exhibits shall retain full force and effect
for three and one-half years from the date it is entered (the “Term”), unless
otherwise specified in the Exhibit. Servicer shall submit a final Quarterly Report
for the last quarter or portion thereof falling within the Term, and shall cooperate
with the Monitor’s review of said report, which shall be concluded no later than
six months following the end of the Term, after which time Servicer shall have no
further obligations under this Consent Judgment.
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EXHIBIT F
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any pending adversary proceedings, contested matters, appeals, and other actions filed by the
United States Trustee against any other party wherein the COMPANY, its affiliates, or employees
and officers of the COMPANY or its affiliates, is a party or otherwise involved; or (3) a waiver
of, or restriction or prohibition on, the United States Trustees’ ability, to the extent permitted by
law, informally or formally, in individual bankruptcy cases, to seek a cure of material
inaccuracies in the COMPANY’s or its affiliates’ mortgage-related claims filed in a bankruptcy
case and based on the Covered Bankruptcy Conduct, but not to impose monetary sanctions or
other punitive relief against the COMPANY or its affiliates in addition to such cure; provided,
however, that this provision shall not constitute a waiver of, or restriction or prohibition on, the
COMPANY’s or its affiliates’ ability to dispute whether the United States Trustees have authority
or ability to seek such a cure.
(10) For the purposes of this Release, the term “affiliated entity” shall mean
entities that are directly or indirectly controlled by, or control, or are under common control with,
the COMPANY as of or prior to 11:59 p.m., Eastern Standard Time, on February 8, 2012. The
term “control” with respect to an entity means the beneficial ownership (as defined in Rule 13d-3
promulgated under the Securities Exchange Act of 1934, as amended) of 50 percent or more of
the voting interest in such entity.
(11) Notwithstanding any other term of this Release, the following claims of
the United States are specifically reserved and are not released:
(a) Any liability arising under Title 26, United States Code (Internal
Revenue Code);
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(b) Any liability of individuals (including current or former directors,
officers, and employees of the COMPANY or any affiliated entity) who have received or receive
in the future notification that they are the target of a criminal investigation (as defined in the
United States Attorneys’ Manual); have been or are indicted or charged; or have entered or in the
future enter into a plea agreement, based on the Covered Servicing Conduct, the Covered
Origination Conduct, and the Covered Bankruptcy Conduct (collectively, the “Covered
Conduct”);
(c) Any criminal liability;
(d) Any liability to the United States for any conduct other than the
Covered Conduct, or any liability for any Covered Conduct that is not expressly released herein;
(e) Any and all claims whether legal or equitable, in connection with
investors or purchasers in or of securities or based on the sale, transfer or assignment of any
interest in a loan, mortgage, or security to, into, or for the benefit of a mortgage-backed security,
trust, special purpose entity, financial institution, investor, or other entity, including but not
limited to in the context of a mortgage securitization or whole loan sale to such entities
(“Securitization/Investment Claims”). Securitization/Investment Claims include, but are not
limited to, claims based on the following, all in connection with investors or purchasers in or of
securities or in connection with a sale, transfer, or assignment of any interest in loan, mortgage or
security to, into, or for the benefit of a mortgage-backed security, trust, special purpose entity,
financial institution, investor, or other entity:
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(i) The United States’ capacity as an owner, purchaser, or
holder of whole loans, securities, derivatives, or other similar investments,
including without limitation, mortgage backed securities, collateralized debt
obligations, or structured investment vehicles.
(ii) The creation, formation, solicitation, marketing,
assignment, transfer, valuation, appraisal, underwriting, offer, sale, substitution,
of or issuance of any interest in such whole loans, mortgages, securities,
derivatives, or other similar investments.
(iii) Claims that the COMPANY or an affiliated entity made
false or misleading statements or omissions, or engaged in other misconduct in
connection with the sale, transfer or assignment of any interest in a loan,
mortgage, or security or in connection with investors or purchasers in or of such
loans, mortgages, or securities, including but not limited to conduct that affected a
federally insured financial institution or violated a legal duty to a mortgage-
backed security, trust, special purpose entity, financial institution, or investor
(including the United States), or governmental agency and/or that subjects the
COMPANY or an affiliated entity to a civil penalty or other remedy under 12
U.S.C. § 1833a.
(iv) Representations, warranties, certifications, statements, or
claims made regarding such whole loans, securities, derivatives or other similar
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investments, including representations, warranties, certifications or claims
regarding the eligibility, characteristics, or quality of mortgages or mortgagors;
(v) Activities related to the executing, notarizing, transferring
or recording of mortgages; the endorsement or transfer of a loan; and the
obtaining, executing, notarizing, transferring or recording of assignments;
(vi) Obtaining, securing, updating, transferring, or providing
promissory notes or endorsements of promissory notes through allonges or
otherwise;
(vii) Custodial and trustee functions;
(viii) Intentional or fraudulent failure to pay investors sums owed
with respect to any security, derivatives, or similar investment;
(ix) Contractual covenants, agreements, obligations and legal
duties to a mortgage-backed security, trust, special purpose entity, financial
institution, investor, or other entity (including the United States);
(x) Covered Origination Conduct (except to the extent such
conduct is released in Paragraphs 3.b, 4 or 5); and
(xi) Covered Servicing Conduct to the extent the COMPANY
or any affiliated entity engaged in the Covered Servicing Conduct in question not
in its capacity as servicer, subservicer or master servicer, but in its capacity as the
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originator of a mortgage loan or as seller, depositor, guarantor, sponsor,
securitization trustee, securities underwriter, document custodian or any other
capacity.
The exclusion set forth above in this Paragraph shall not apply to
Securitization/Investment Claims based on the following conduct, and such claims are included
in what is being released:
Securitization/Investment Claims based on Covered Servicing Conduct by the
COMPANY or any current or former affiliated entity where: (1) such conduct was
performed by the COMPANY or any affiliated entity in its capacity as the loan
servicer, master servicer or subservicer, whether conducted for its own account or
pursuant to a third party servicing agreement or similar agreement, and not in its
capacity as loan originator, seller, depositor, guarantor, sponsor, securitization
trustee, securities underwriter, or any other capacity; and (2) such conduct was not
in connection with (x) the creation, formation, solicitation, marketing, sale,
assignment, transfer, offer, sale, substitution, underwriting, or issuance of any
interest in securities, derivatives or other similar investments or (y) the sale or
transfer of mortgage loans. The claims addressed in this sub-paragraph include,
without limitation, Securitization and Investment Claims that the party seeking to
enforce a mortgage loan against a borrower and homeowner in respect of that
borrower’s default did not have a documented enforceable interest in the
promissory note and mortgage or deed of trust under applicable state law or is
otherwise not a proper party to the foreclosure or bankruptcy action or claims

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based on such party’s attempts to obtain such a documented enforceable interest
or become such a proper party.
(f) Any liability arising under Section 8 of the Real Estate Settlement
Procedures Act, 12 U.S.C. § 2607, relating to private mortgage insurance, with respect to claims
brought by the CFPB;
(g) Except with respect to claims related to the delivery of initial or
annual privacy notices, requirements with respect to the communication of non-public personal
information to non-affiliated third parties, or other conduct required by Sections 502 through 509
of the Gramm-Leach-Bliley Act (15 U.S.C. §§ 6802-6809), any claims or conduct involving the
obligation of a financial institution under Section 501(b) of the Gramm-Leach-Bliley Act (15
U.S.C. s. 6801(b)) and its implementing regulations to maintain administrative, technical, and
physical information security safeguards;
(h) Any liability arising under the Fair Housing Act; any provision of
the Equal Credit Opportunity Act that is not expressly released in Paragraph 2 of this Release,
including any provision prohibiting discriminatory conduct; the Home Mortgage Disclosure Act;
or any other statute or law that prohibits discrimination of persons based on race, color, national
origin, gender, disability, or any other protected status;
(i) Administrative claims, proceedings, or actions brought by HUD
against any current or former director, officer, or employee for suspension, debarment or
exclusion from any HUD program;
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(j) Any liability arising under the federal environmental laws;
(k) Any liability to or claims brought by (i) the Federal Housing
Finance Agency; (ii) any Government Sponsored Enterprise, including the Federal National
Mortgage Association and the Federal Home Loan Mortgage Corporation (except where the
Government Sponsored Enterprise seeks to impose such liability or pursue such claims in its
capacity as an administrator of the Making Home Affordable Program of Treasury); (iii) the
Federal Deposit Insurance Corporation (whether in its capacity as a Corporation, Receiver, or
Conservator); (iv) the Government National Mortgage Association (“Ginnie Mae”) arising out of
COMPANY’s contractual obligations related to serving as Master Subservicer on defaulted
Ginnie Mae portfolios, including claims for breach of such obligations; (v) the CFPB with respect
to claims within its authority as of the designated transfer date of July 21, 2011 that are not
expressly released in Paragraph 7; (vi) the National Credit Union Administration, whether in its
capacity as a Federal agency, Liquidating Agent, or Conservator; (vii) the Securities and
Exchange Commission; (viii) the Federal Reserve Board and its member institutions; (ix) Maiden
Lane LLC, Maiden Lane II LLC, Maiden Lane III LLC, entities that are consolidated for
accounting purposes on the financial statements of the Federal Reserve Bank of New York, and
the Federal Reserve Bank of New York; (x) the Office of the Comptroller of the Currency; (xi)
the USDA (except to the extent claims are released in Paragraph 5); (xii) the VA (except to the
extent claims are released in Paragraph 4); (xiii) the Commodity Futures Trading Commission;
and (xvi) the Inspectors General of such entities;
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(l) Any liability to the United States for the following claims alleged
against J.P. Morgan Chase & Company or any of its current or former subsidiaries, affiliates,
officers, directors, employees or agents, including but not limited to Chase Home Finance, LLC,
EMC Mortgage, and JPMorgan Chase Bank, National Association, or any other entity or person:
(i) All claims or allegations based on any conduct alleged in
United States ex rel. [Under Seal] v. [Under Seal], 2:11-cv-00535-RLH-RJJ (D.
Nev.); and
(ii) All claims or allegations based on any conduct alleged in
United States ex rel. Szymoniak v. [Under Seal], Civ. No. 0:10-cv-01465 (D.S.C.)
or in United States ex rel. Szymoniak v. [Under Seal], Civ. No. 3:10-cv-575
(W.D.N.C.), except any such claims that are encompassed by the releases
described in paragraphs 2 to 9, above, and not otherwise reserved from these
releases in this agreement.
(m) Any action that may be taken by the appropriate Federal Banking
Agency (FBA), as defined in 12 U.S.C. § 1813(q), against COMPANY, any of its affiliated
entities, and/or any institution-affiliated party of COMPANY, as defined in 12 U.S.C. § 1813(u),
pursuant to 12 U.S.C. § 1818, and any action by the FBA to enforce the Consent Order issued
against the COMPANY by the FBA on April 13, 2011;
(n) Any liability based upon obligations created by this Consent
Judgment;
F-36
Add. 36
Filing # 59196253 E-Filed 07/18/2017 10:13:06 PM
y,//d
Larry Schneider

Sent: Tuesday, July 14, 2015 4:58 PM
To: Milton W. Espinoza
Subject: RE: First American Bank (Bank of Coral Gables)
Importance: High
Milton,
I have been out of town . Can 1 send a wire for the payment? Please provide me the wiring information so it can be sent
the morning of Wednesday, July 15, 2015.
Sincerely,
Larry Schneider
2901 Clint Moore Road, Suite 410
Boca Raton, FL 33496
Tel : 305-710-4201
From: Milton W. Espinoza [mailto:[email protected]]

Sent: Monday, June 29, 2015 4:25 PM
To: Larry Schneider
Cc: Jennifer L. Anderson; James A Kielbasa
Mr. Schneider,
You are correct. The July 1st payment would be deemed late if payment is on or after July 16th.
In regards to the late charges, they will be removed and it will be reflected on the next statement.
Any other questions, please feel free to inquire with me. Again, my direct line is 305-400-3326. Thank you.
Milton Espinoza
First American Bank
Vice President Commercial Loan Relationship Manager
2295 Galiano Street
Voice/Fax (305) 400-3326
Cellular (786)562-50 12
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Sent: Monday, June 29, 2015 11:55 AM
Cc: Jennifer L. Anderson; James A Kielbasa
Importance: High
Milton,
Thank you for the information. The way the statement appears, it is extremely confusing. Just to re-confirm that the
July 1, 2015 bill which is attached, is deemed late pursuant to the loan documents on July 16, 2015?
The billing problems and thus late charges were caused due to my address and zip code for my billing the monthly
statements was boarded incorrectly, so I did not receive the billing statements. This was acknowledged by Jennifer
Anderson from First American Bank on June 5, 2015. It was attached as page two of the attachment. See attachment
again. Any late charge was to be removed .
Please remove the late charges, refund paid late charges and provide me proof of the adjustments.
Sincerely,
Larry Schneider
1199 S. Federal Hwy, #369
305-710-4201
2
Sent: Monday, June 29, 2015 10:15 AM
To: Larry Schneider
Good morning, Mr. Schneider.
Attached is the loan history for the last 12 months.

51
In regards to your email below, your payment is due on the 1 of each month. There is a 15 day grace period, so
any payments received after that will incur a late charge.
On the invoice due July 15\ 2015, the $179.23 late charge that was paid was due to no payment received for the
invoice due April 1st. The $205.78 late charge was assessed as the May 1st invoice was paid after May 15th (your
payment on May 28th paid both the April 1st and May 1st invoices).
Could you please re-state the billing problems you had and for which months?
Thank you in advance, and please let me know of any other questions. Also, please feel free to call me at 3005-
400-3326 (that is my direct line).
Milton Espinoza
First American Bank
2295 Galiano Street
Voice/Fax (305) 400-3326
Cellular (786)562-5012
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3
From: Larry Schneider [mailto:[email protected]
Sent: Saturday, June 27, 2015 11:38 AM
Cc: James A Kielbasa; Jennifer L. Anderson
Subject: RE: First American Bank {Bank of Coral Gables)
Importance: High
Milton,
Is my payment due on the 1st or the 15th of every month? I keep getting a late charge billed . The billing statements are
part of the confusion. It keeps showing me as being late and being charged a late charge. On this most recent
statement, the closing date says 6/15/15, payment due date is 7/1/15 and I am being charged an additional late charge
on June 15, 2015.
Please let me know if I need to get assistance from the Consumer Financial Protection Bureau to help resolve these
issues.
Sincerely,
Larry Schneider
305-710-4201

Sent: Friday, June 26, 2015 1:12PM
To: Larry Schneider
Mr. Schneider, attached is the promissory note and mortgage for your loan. I am still working on getting a year
to date history (once I receive it, I will send it to you as soon as possible).
Milton Espinoza
First American Bank
2295 Galiano Street
Voice/Fax (305) 400-3326
Cellular (786)562-5012
4
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From: Larry Schneider [mailto:[email protected] J

Importance: High
Milton,
I'll have more questions once I receive the year to date payment history. I continue to be billed late charges in advance
of my payment due date. This is part of the continuing problems that I am having with my account since the merger of
the data. As you are aware, the loan was boarded with numerous errors in my address which caused me to not receive
timely monthly billing statements.
Please send me copies of the note, mortgage and the year to date payment history.
Sincerely,
Larry Schneider
305-710-4201
From: Milton W. Espinoza [ mailto:[email protected]]

Sent: Friday, June 26, 2015 11:35 AM
To: Larry Schneider
Subject: FW: First American Bank (Bank of Coral Gables)
Good morning, Mr. Lawrence. I was informed of your request and will be working on providing you the
information. Let me know if you need anything else in the meantime.
Milton Espinoza
5
First American Bank
2295 Galiano Street
Voice/Fax (305) 400-3326
Cellular (786)562-5012
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lltlps.{:w\• .., f• ·st~moank CQD11Ge.JertltGtJ.:.:.L'JJ!o;P1Ya;,~c;;'.L,. ·
From: James A Kielbasa

Sent: Wednesday, June 24, 2015 4:44 PM
Milton,
Here is the email he sent me.
Thanks
From: Larry Schneider [mailto:[email protected] ]

Sent: Saturday, June 20, 2015 12:59 AM
To: James A Kielbasa
Jim,
I just received the July 1st statement. The mailing address is now correct.
Please send me a copy of the year to date charge/payment history and a copy of the promissory note as I want to make
sure that everything is correct going forward.
6
Sincerely,
Larry Schneider
Tel : 305-710-4201

Sent: Monday, June 08, 2015 1:20PM
Subject: Re: First American Bank (Bank of Coral Gables)
The payment went out on Friday.
Sent from my iPhone
On Jun 3, 2015, at 3:07PM, James A Kielbasa <[email protected]> wrote:
Sorry for the late response. The amount due for June is $4,427.64. Let me know if you do not
receive the statement again next month.
Thanks
From: larry Schneider [mailto:[email protected] 1

Sent: Monday, June 01, 2015 9:58 PM
James,
I have not yet received the invoice for the payment which is due on June 1, 2015, so I do not know how
much to pay( as the interest on the loan in calculated daily). Please provide me with the information to
that I can send the payment,
7
Also, 1received the notification about the insurance and forwarded to my insurance agent to change the
loss payee clause .
Sincerely,
Larry Schneider
Boca Raton, FL33496
Tel: 305-710-4201
From: James A Kielbasa [mailto:[email protected]]

Sent: Friday, May 29, 2015 10:25 AM
To: Larry Schneider
The payments were received and applied to your accotmt. It is now due for June. I have
submitted the request to correct your credit bureau.
Thanks
Thanks
-----Original Message-----
Sent: Thursday, May 28, 2015 11 :19 AM
Importance: High
James,
Please see attached wire confirmation. Please confirm when wire is received and applied.
Sincerely,
Larry Schneider
From: James A Kielbasa [[email protected]]

Sent: Thursday, May 28,2015 11:40 AM
To: Larry Schneider
It is going to your account here with First American Bank, so it would be your name and your
account number here (40000006).
8
For example:
ABA/Routing number: 071922777

Your account number: 40000006
Address: First American Bank

80 Stratford Drive
Bloomingdale, IL. 60108
Thanks
Jim Kielbasa
Collection Specialist
Phone/Fax 630-547-8965
-----Original Message-----
Sent: Thursday, May 28, 2015 10:21 AM
Importance: High
James,
Should the Account Name on the Wire be my name and the account#, my account number?
Again, I do not have a bank account with First American. My HELOC account# is 40000006. is
that what I am supposed to use as the account number or should the wire be going into a general
account within the bank and the monies then applied to my HELOC?
Please confirm so the wire isn't lost in cyberspace.
Larry Schneider
From: James A Kielbasa [[email protected]]

Sent: Thursday, May 28, 2015 9:55AM
To: Larry Schneider
Subject: First American Bank (Bank of Coral Gables)
This email contains images. Click

Here<https://www.firstambank.com/medialuploads/ad promos/im6/mktpromo.html> to view
this ad in a browser.
[https://www.firstambank.com/medialuploads/ad promos/im6/banner .gifl <https://www.firstamb
ank.corn!PersonalBanking/Borrowing/Mortgage/Rates>
Click Here for more
information<https://www.firstambank.com/PersonalBanking/Borrowing/Mortgage/Rates>
Larry,
Here are the wire instructions you had requested:

9
ABA!Routing number: 071922777
Your account number:
Address: 80 Stratford Drive

Bloomingdale, IL. 60108
The account is due for Aprillst and May 1st. The June payment will be due on the first. If you
have any questions please let me know.
Thanks
Jim Kielbasa
Collection Specialist
Phone/Fax 630-547-8965
[https://www.firstambank.com/med.ia/uploads!FAB-logo2.gifl <hrtps://www.firstambank.com/>
First American Bank
P.O. Box 0794
Elk Grove Village, IL 60009
Equal Housing Lender Member FDIC
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First American Bank will never ask you for your personal information, such as your login ID,
password, or answers to challenge questions, in an email or any web page directly linked to an e-
mail from us. For more information on how to protect yourself against online fraud, view our
Online Security page at https://www.firstambank.com/General/Generallnfo/OnlineSecurity/
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We do NOT disclose any information about you to anyone, except as permitted by law. For more
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11
Larry Schneider
From: BrianT. Hagan <[email protected]>

Sent: Thursday, July 30, 2015 2:32 PM
To: Larry Schneider
Subject: S & A Capital Partners I Ban k of Coral Gables
Mr. Schneider:
As First American Bank' s senior representative in Florida, I would like to meet with you to better understand
the circumstances surrounding your recent email to Milton Espinoza (and your borrower, Johnnie
Washington). I did leave a message for you yesterday but wanted to reach out via email as well.
Please let me know where and when you would be available to meet. Thank you.
Brian T. Hagan
Florida Market President
First American Bank
2295 Galiano Street
(305) 777-1027
First American Bank

P.O. Box 0794
Elk Grove Village, IL 60009
www.FirstAmBank.com
Online Security
First American Bank will never ask you for your personal information, such as your login ID, password, or answers to challenge questions, in an email or any web
page directly linked to an e-mail from us. For more information on how to protect yourself against online fraud, view our Online Security page at
https://www.firstambank.com/Generai/Generallnfo/OnlineSecurity/
Privacy Policy
We do NOT disclose any information about you to anyone, except as permitted by law. For more detailed information, view our Privacy Policy at
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1
Larry Schneider

Sent: Tuesday, August 09, 2016 7:15 PM
To: 'BrianT. Hagan'
Subject: 17685 Circle Pond Court
Attachments: S & A Capital v JPMC, Doc 111, Judge Francis Decision on motion to compel, July 14,
2016.pdf; Schneider v JPMorgan Chase, Doc 64, MOTION FOR COMPUANCE WITH
ORDER TO UNSEALCASE AND ENTIRE DOCKET-SC , August 4, 2016.pdf; Schneider v
JPMC 14-01047, Notice of Filing Doc 115, August 5, 2016.pdf
Brian,
I've sent in my financial information as you've requested. It's been well over a month and I have not heard from you or
the Bank.
I have been super busy with my litigation against JPMorgan Chase. We are now in three federal courts and I am going to
make JPMorgan Chase Bank suffer, as they have done so to me and my family. I've attached a recent filing from the
District Court for the Southern District of New York, District Court for the District of Columbia and District Court for the
District of South Carolina, so you can appreciate what I've been up against.
As you know, the cases against JPMorgan Chase Bank N.A. include breach, fraud in the inducement, torts, Civil RICO and
fraud under the Federal and State False Claims Acts.
With that said, my financial resources are limited and the First American Bank has caused me and my entities harms in
obtaining personal and business credit on multiple occasions due to the banks negligent servicing practices, amongst
other prohibited practices, which, as you know include the release and satisfaction of a loan owned by S & A Capital
Partners (similar to some of the same allegations against JPMorgan Chase Bank).
At this point, the harm being caused to my personal credit rating, which also affects my guarantor rating for my entities,
due to the Banks lack of communication and inaction, has brought things to a head. If I do not hear back from the bank
by the end of the week, I intend to file suit for numerous causes of action in the Southern District of Florida. As you
know, you had personally assured me that certain repeated servicing related issues were being resolved and that I
should only be dealing with you, as nobody in the Bank, including customer service could reconcile my account at any
time since the Bank acquired the Bank of Coral Gables. Despite those assurances, the harms continued immediately
despite my communication and cooperation. The harms caused to myself and my entities are calculated at a multiple of
the potential deficiency in the outstanding balance ofthe mortgage owed to the Bank, less the market value ofthe
above referenced property.
The one thing I have learned through the past four years of nonstop litigation, is that you do not get anywhere by being
the good guy and hoping things work out. I have no income and no significant assets owned in my name. As you are
aware, the note on the property is in my name only. Rather than work with me to limit the damage to the parties, the
Bank has decided to go a route to cause more harm and frustration. Although I do not have substantial financial
resources, I do have fulltime in house counsel dedicated to exposing fraud and injustice.
As such, I intend to name the Bank and you individually as a defendant in the forthcoming litigation.
Sincerely.
1
Larry Schneider
1•1 Fidelity Loan Servicing. LLC
2901 Clint Moore Road. Suite 410
Boca Raton. FL 33496
Cell (305) 710-4201
2
Larry Schneider

Sent: Friday, August 28, 2015 11:19 AM
To: Milton W. Espinoza (M [email protected])
Cc: Brian T. Hagan ([email protected])
Subject: HELOC #40000006- Laurence Schneider
Attachments: $4,297.83, Wire to First American Bank, Augu st 28, 201S.pdf
Milton,
Please confirm this wire has been received and credited towards the August 2015 payment of HELOC #40000006.
Sincerely,
Larry Schneider
51
1 Fidelity Loan Servicing
Tel : 305-710-4201
1
Larry Schneider

Sent: Friday, October 30, 201S 3:05 PM
To: Brian T. Hagan
Subject: RE: HELOC #40000006 - CONFIDENTIAL - FOR SETTLEMENT PURPOSES ONLY
Attachments: BankUnited Treasury Management (l).pdf
Brian,
I am out of town and do not have access to complete the financial statement and send back today. The amount you
claim is due for October is incorrect. I have wired the payment you are requesting so I can comply.
As I explained during our meeting, I have not filed 2013 or 2014 tax returns. I am in contact with the IRS and they are
aware of the JPMorgan litigation.
What are you going to do to immediately remediate the continued erroneous credit reporting of my account and the
harms it continues to cause me?
Please send me the complete payment history of my account since origination and a copy of the entire origination file
along with any and all prior billing statements, notices and other correspondences pertaining to the origination and
servicing of my mortgage since the date of origination. This communication should be deemed a Qualified Written
Request.
Sincerely,
Larry Schneider·
From: BrianT. Hagan [[email protected]]

Sent: Friday, October 30, 2015 12:43 PM
To: Larry Schneider
Subject: RE: HELOC #40000006- CONFIDENTIAL- FOR SETTLEMENT PURPOSES ONLY
Larry,
Thanks for your email. As I've said before, I am available whenever you have questions and can be reached almost any
time at my cell phone number, which is included below.
For the October 1 payment, the amount due is $4,646.05. The payment due November 1, if made on time, will be
$3,823.29. If you need any help in getting these payments made, please let me know.
As we discussed in our meeting, before First American Bank can consider a deed-in-lieu of foreclosure transaction like
the one you are proposing, we need to obtain from you the following documents and information:
• Personal tax returns for the most recent two years
1
• Personal Financial Statement (form attached)
I'll call you later today to discuss this.
Thanks,
Brian
BrianT. Hagan
First American Bank
2295 Galiano Street
Coral Gables, Fl33134
Office (305) 777-1027
Cell (786) 385-0348
[https://www.firstam bank.com/media/uploads/FAB-Iogo2.gif]<https://www. first a mbank.com/>
First American Bank
P.O. Box 0794
Elk Grove Village, ll60009
Equal Housing lender Member FDIC
www.FirstAmBank.com<https://www.firstambank.com/>
[https://www.firstambank.com/media/uploads/social_media/fb_button.png]<https://www.facebook.com/FirstAmBank
> [https:/ /www.fi rstambank.com/media/uploads/socia l_media/tw_button.png]
Online Security
First American Bank will never ask you for your personal information, such as your login 10, password, or answers to
challenge questions, in an email or any web page directly linked to an e-mail from us. For more information on how to
protect yourself against online fraud, view our Online Security page at
Privacy Policy
We do NOT disclose any information about you to anyone, except as permitted by law. For more detailed information,
view our Privacy Policy at https://www.firstambank.com/Generai/Generallnfo/PrivacyPolicy/
From: larry Schneider [mailto:[email protected]]

Sent: Tuesday, October 27, 2015 7:09 PM
To: BrianT. Hagan <[email protected]>
Subject: RE: HELOC #40000006- CONFIDENTIAL- FOR SETTLEMENT PURPOSES ONLY
CONFIDENTIAL- FOR SETTLEMENT PURPOSES ONLY
Brian,
2
I have been occupied 24/7 with the semi-confidential situation which we spoke about during our meeting. Thus, I have
not had a moment to address the continued problematic and abusive practices by First American Bank in its failure to
address and remediate its flawed system of records, which continues to erroneously report my HELOC account to the
major credit repositories as delinquent for the past six months (This report only shows September and October 2015, as
a letter correcting prior erroneous reporting's by the Bank, was sent to the credit repositories by Jennifer Anderson. In
fact, the bank has already reported my account as over 30 days past due for October 2015. (Attached is a confidential
copy of my credit report as of today, October 27, 2015). This has continually lowered my credit score and fraudulently
corrupted my credit worthiness in several attempts to get multi-million dollar financing for my FCA and RICO cases
against JPMorgan Chase and for other unrelated financing. As I notated in my email last month, the banks customer
service department can't tell me the last paid date and next due date of my mortgage loan. At 3:32 pm today, I once
again called the customer service number on my Periodic Billing Statement (847-952-3700) and once again I sat on hold
for 15 minutes while the representative tried to determine the accuracy and integrity of my account information, to no
avail.
You had personally assured me that the problem with my HEOLC billing was rectified during our meeting. I shared
honest and ·confidential information, as a professional, a customer and on a very personal level. I reasonably expected
that if you went out of your way to meet with me in person to discuss the matter, that you did so in good faith and that
the erroneous billing and credit reporting problems with my account were resolved as you represented to me.
Furthermore, in the subsequent email below, you claimed that you "will verify that it [the September payment] has been
applied properly." Once again, I took you at your word that you were personally ensuring that my account was being
handled properly. It was not and is still not being handled properly.
The banks unwillingness to address its corrupted system of records, despite over 20 documented requests, plus the
gross negligence shown by the bank in filing a release of lien and satisfaction of mortgage for a loan it did not own
(Johnnie Washington - S & A Capital Partners mortgage), shows the banks unwillingness to comply with federal and
state mortgage servicing and consumer protection laws.
I have been cooperative and accommodating with any of the banks requests. 1am now ready to make this a very long
and protracted litigated matter.
I offer this one offer and compromise as follows:

1/we will agree to provide the bank a special warranty deed for the transfer of the property in its "as-is" condition, which
is in the same material condition as it was at the time of the appraisal, in exchange for a full release of liability of the
debt, as a set off for the mortgage loan which the Bank released between S & A Capital Partners as Mortgagee and
Johnnie Washington as Mortgagor, and for other good and valuable consideration (harms). General releases to be
signed between the Bank and Laurence Schneider, individually and between the Bank and S & A Capital Partners.
As a professional courtesy, I did not copy anyone on this correspondence.
Please reply either way prior to 2:00p.m. on Friday October 30, 2015. A no reply will be interpreted as a disagreement
to the basic terms outlined and offered above.
Sincerely,
Larry Schneider
Tel: 305-710-4201
3
Sent: Wednesday, September 30, 2015 3:59 PM
To: BrianT. Hagan <[email protected]<mailto:[email protected]»
Cc: Milton W. Espinoza <[email protected]<mailto:[email protected]»; James A Kielbasa
<[email protected]<mailto:[email protected]»; Jennifer L. Anderson
<[email protected]<mailto:[email protected]>>
Subject: HELOC #40000006
Importance: High
Brian,
Please find the September 2015 payment on the HELOC account. Despite the flawed information in your servicing
system of records, my account is current (for the purposes of the Fair Debt Credit Reporting Act). Please apply the
payment accordingly. The bank has been and continues to make erroneous and derogatory reporting of my account to
the credit repositories, despite numerous requests to the bank to rectify the various boarding errors which has affected
my billing and subsequent payments. The bank continues to violate this and numerous other state and federal,
mortgage servicing and consumer protection laws.
Sincerely,
Larry Schneider
305-710-4201
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5
Larry Schneider

Sent: Wednesday, November 04, 2015 8:20 PM
To: Larry Schneider
Subject: Re: HELOC #40000006- CONFIDENTIAL- FOR SETTLEMENT PURPOSES ONLY
Larry:
Thanks for the reply. I have the payment history that you requested, and am told that the credit reporting is
accurate. I will double check to see what correspondence we have with the credit reporting agencies and will
get that to you as well.
Are you available to meet next week? I have appointments up near you and can bring the documents you've
requested.
Brian
Brian T. Hagan
First American Bank
2295 Galiano Street
(305) 777-1027
On Nov 4, 2015, at 1:48 PM, Larry Schneider <[email protected]> wrote:
Brian,
I just returned from Boston last night and will have the financial statement to you this weekend.
In the meantime, what steps have you taken to ensure that the erroneous reporting made by First
American Bank, to the major credit repositories have been expeditiously remediated and purged from
my credit file? I need financing for several things and thus require documentation from the Bank that it
acknowledges that my payment history has in fact been made on a timely basis, per the terms of the
loan documents as they relate to the Fair Debt Credit Reporting Act and that it takes responsibility for its
actions.
Please provide me a copy of the correspondence which the bank has sent to the credit repositories to
expeditiously remediate these ongoing harms, as a letter of explanation, although helpful, w ill not aid in
increasing my credit score. As you are aware, mortgage delinquencies reported to the credit
repositories have the most profound negative impact on their respective scoring models.
Lastly, has the flaws in the banks system of records been addressed such that my account is not still
erroneously reporting as delinquent?
I look forward to your prompt response to this matter.
1
Sincerly,
Larry Schneider
305-710-4201
From: BrianT. Hagan [mailto:[email protected]]

Sent: Friday, October 30, 2015 3:44PM
To: Larry Schneider
Subject: Re: HELOC #40000006- CONFIDENTIAL- FOR SETTLEMENT PURPOSES ONLY
Larry:
Thanks for the prompt reply. I'll get the information you're requesting, and am checking to see
how long that will take.
Brian
Sent from my iPhone
>On Oct 30, 2015, at 3:05PM, Larry Schneider <[email protected]> wrote:

>
>Brian,
>
> I am out of town and do not have access to complete the financial statement and send back
today. The amount you claim is due for October is incorrect. I have wired the payment you are
requesting so I can comply.
>
> As I explained during our meeting, I have not filed 2013 or 2014 tax returns. I am in contact
with the IRS and they are aware of the JPMorgan litigation.
>
> What are you going to do to immediately remediate the continued erroneous credit reporting of
my account and the harms it continues to cause me?
>
> Please send me the complete payment history of my account since origination and a copy of
the entire origination file along with any and all prior billing statements, notices and other
correspondences pertaining to the origination and servicing of my mortgage since the date of
origination. This communication should be deemed a Qualified Written Request.
>
>
> Sincerely,
>
>
> Larry Schneider
>
>
>
2
> -----------------------------------
>From: BrianT. Hagan [[email protected]
>Sent: Friday, October 30, 2015 12:43 PM
>To: Larry Schneider
> Subject: RE: HELOC #40000006 - CONFIDENTIAL - FOR SETTLEMENT PURPOSES
ONLY
>
>Larry,
>
> Thanks for your email. As I've said before, I am available whenever you have questions and
can be reached almost any time at my cell phone number, which is included below.
>
>For the October 1 payment, the amount due is $4,646.05. The payment due November 1, if
made on time, will be $3,823.29. If you need any help in getting these payments made, please let
me know.
>
> As we discussed in our meeting, before First American Bank can consider a deed-in-lieu of
foreclosure transaction like the one you are proposing, we need to obtain :from you the following
documents and information:
>
> • Personal tax returns for the most recent two years
>
> • Personal Financial Statement (form attached)
>
> I'll call you later today to discuss this.
>
>Thanks,
>
>Brian
>
> BrianT. Hagan
> Florida Market President
> First American Bank
> 2295 Galiano Street
> Coral Gables, FL 33134
>Office (305) 777-1027
> Cell (786) 385-0348
> [https://www.firstarnbank.com/media/uploads/FAB-
logo2.gif]<https :/ /www .frrstambank.com/>
>P.O. Box 0794
> Elk Grove Village, IL 60009
> Equal Housing Lender Member FDIC
> www .FirstAmBank.com<https://www.firstambank.com/>
>
[https ://www.firstambank.com/media/uploads/social medialfb button.png]<https :/ /www.facebo
ok.com/FirstAmBank>
[https://www.firstambank.com/medialuploads/social medialtw button.png]
>
---------------------------
> IMPORTANT INFORMATION
3
>
> Online Security
> First American Bank will never ask you for your personal information, such as your login ID,
Online Security page at https://www.firstambank.com/General/Generalinfo/OnlineSecurity/
>
> Privacy Policy
>We do NOT disclose any information about you to anyone, except as permitted by law. For
more detailed information, view our Privacy Policy at
https ://www.firstambank.com/General/Generalinfo/PrivacyPolicy/
>
>
>
>
>
> From: Larry Schneider [mailto:[email protected]]
>Sent: Tuesday, October 27, 2015 7:09PM
>To: BrianT. Hagan <[email protected]>
ONLY
>
> CONFIDENTIAL- FOR SETTLEMENT PURPOSES ONLY
>
>Brian,
>
> I have been occupied 24/7 with the semi-confidential situation which we spoke about during
our meeting. Thus, I have not had a moment to address the continued problematic and abusive
practices by First American Bank in its failure to address and remediate its flawed system of
records, which continues to erroneously report my HELOC account to the major credit
repositories as delinquent for the past six months (This report only shows September and
October 2015, as a letter correcting prior erroneous reporting's by the Bank, was sent to the
credit repositories by Jennifer Anderson. In fact, the bank has already reported my account as
over 30 days past due for October 2015. (Attached is a confidential copy of my credit report as
of today, October 27, 2015). This has continually lowered my credit score and fraudulently
corrupted my credit worthiness in several attempts to get multi-million dollar fmancing for my
FCA and RICO cases against JPMorgan Chase and for other unrelated financing. As I notated in
my email last month, the banks customer service department can't tell me the last paid date and
next due date of my mortgage loan. At 3:32pm today, I once again called the customer service
number on my Periodic Billing Statement (847-952-3700) and once again I sat on hold for 15
minutes while the representative tried to determine the accuracy and integrity of my account
information, to no avail.
>
> You had personally assured me that the problem with my HEOLC billing was rectified during
our meeting. I shared honest and confidential information, as a professional, a customer and on a
very personal level. I reasonably expected that if you went out of your way to meet with me in
person to discuss the matter, that you did so in good faith and that the erroneous billing and
credit reporting problems with my account were resolved as you represented to me.
>
>Furthermore, in the subsequent email below, you claimed that you "will verify that it [the
September payment] has been applied properly." Once again, I took you at your word that you
4
were personally ensuring that my account was being handled properly. It was not and is still not
being handled properly.
>
> The banks unwillingness to address its corrupted system of records, despite over 20
documented requests, plus the gross negligence shown by the bank in filing a release of lien and
satisfaction of mortgage for a loan it did not own (Johnnie Washington- S & A Capital Partners
mortgage), shows the banks unwillingness to comply with federal and state mortgage servicing
and consumer protection laws.
>
>I have been cooperative and accommodating with any of the banks requests. I am now ready to
make this a very long and protracted litigated matter.
>
> I offer this one offer and compromise as follows:
> I/we will agree to provide the bank a special warranty deed for the transfer of the property in
its "as-is" condition, which is in the same material condition as it was at the time of the appraisal,
in exchange for a full release of liability of the debt, as a set off for the mortgage loan which the
Bank released between S & A Capital Partners as Mortgagee and Johnnie Washington as
Mortgagor, and for other good and valuable consideration (harms). General releases to be signed
between the Bank and Laurence Schneider, individually and between the Bank and S & A
Capital Partners.
>
> As a professional courtesy, I did not copy anyone on this correspondence.
>
>Please reply either way prior to 2:00p.m. on Friday October 30, 2015. A no reply will be
interpreted as a disagreement to the basic terms outlined and offered above.
>
>
>Sincerely,
>
> Larry Schneider
> S & A Capital Partners
> 2901 Clint Moore Road, Suite 410
> Boca Raton, FL 33496
>Tel: 305-710-4201
>
>
>
> CONFIDENTIAL -FOR SETTLEMENT PURPOSES ONLY
>
>
> From: BrianT. Hagan [mailto:[email protected]]
>Sent: Thursday, October 01, 2015 8 :30AM
> Cc: Milton W. Espinoza; James A Kielbasa; Jennifer L. Anderson
> Subject: RE: HELOC #40000006
>
>Larry:
>
>I can confirm we have received your payment, and will verify that it has been applied properly.
>
> If you have any questions regarding your October payment, please contact me directly.
5
>
>Thanks,
>
>Brian
>
> Brian T. Hagan
> (305) 777-1027
>
> [cid:-WRDOOO.jpg]<https://www.firstambank.com/>
>P.O. Box 0794
> www.FirstA.mBank.com<https://www.firstambank.com/>
>
>
>
[cid:-WRDOOO.jpg]<https://www .facebook.com/FirstAmBank>[ cid:-WRDOOO .jpg]<https :/ /ww
w.twitter.com/FirstAmBank>
>
> _____________________________
>IMPORTANT INFORMATION
>
> Online Security
Online Security page at https://www.firstambank.com/General/Generalinfo/ OnlineSecuritv/
>
> Privacy Policy
>We do NOT disclose any information about you to anyone, except as permitted by law. For
https://www.firstambank.com/General/Generalinfo/PrivacyPolicy/
>
>
>
>
>
>From: Larry Schneider [mailto:[email protected]]
>Sent: Wednesday, September 30,2015 3:59PM
>To: BrianT. Hagan <[email protected]<mailto:[email protected]>>
> Cc: Milton W. Espinoza
<[email protected]<mailto:[email protected]>>; James A Kielbasa
<[email protected]<mailto:[email protected]>>; Jennifer L. Anderson
< [email protected]<mailto:[email protected]>>
> Subject: HELOC #40000006
> Importance: High
6
>
>
>Brian,
>
>Please find the September 2015 payment on the HELOC account. Despite the flawed
information in your servicing system of records, my account is current (for the purposes ofthe
Fair Debt Credit Reporting Act). Please apply the payment accordingly. The bank has been and
continues to make erroneous and derogatory reporting of my account to the credit repositories,
despite numerous requests to the bank to rectify the various boarding errors which has affected
my billing and subsequent payments. The bank continues to violate this and numerous other state
and federal, mortgage servicing and consumer protection laws.
>
>
>Sincerely,
>
> Larry Schneider
> 1199 S. Federal Hwy, #369
>Boca Raton, FL 33432
> 305-710-4201
>
>
>
>This email message has been delivered safely and archived online. This email system is
managed by DynamiCare
E2<http://dynamicsupport.com/dynamicare.php?utm source=Mimecast%2BStationary%2BLink
%2B-
%2BSACapita1Partners&utm medium=Mimecast%2BLink&utm campaign=Mimecast%2BLin
k%2B-%2BSACapitalPartners>.
> Powered by Mimecast
>
> <BankUnited Treasury Management (l).pdf>
7
Larry Schneider

Sent: Thursday, November OS, 2015 12:16 PM
To: Brian T. Hagan
Cc: Roberto DiMarco; Jennifer Walker
Subject: RE: HELOC #40000006- CONFIDENTIAL- FOR SETILEMENT PURPOSES ONLY
Attachments: RE: HELOC #40000006- CONFIDENTIAL- FOR SETILEMENT PURPOSES ONLY
Brian,
It is disturbing that you were told the " credit reporting is accurate" by staff. Despite the numerous conversations with
multiple employees at the bank over the past six months, my efforts and patience was to no avail.
Let me pose a few questions to you.

1. In your email below from last week, you personally state: " For the October 1 payment, the amount due is
$4,646.05. The payment due November 1, if made on time, w ill be $3,823.29." I paid the October payment via
wire transfer which you have received . I' ve attached it again , in the event your email from last night was based
on my account not being properly cred ited for your receipt of the October 1 payment. For the purposes of this
question, I am going to assume that you either did not receive the wire or that it was received but my account
was not credited on October 30th when the wire was received. If either of these scenarios explain why you were
told "the credit reporting was accurate" and that I am in fact delinquent, you can easily remedy the situation.
2. Assuming that you did receive the wire which 1 sent and the payment was credited on the day it was received,
then and subsequently applied for my October 1 st payment, then the information which you provided to me;
"For the October 1 payment, the amount due is $4,646.05. The payment due November 1, if made on time, will
be $3,823.29" was erroneous, as I did in fact make the payment as you directed . If you recall from earlier in the
ema il string, you specifically requested that I communicate directly with you for the October payment because
there is nobody in your organization, including the customer service department, who's contact number listed
on the Periodic Monthly Statement, that can provide me with timely or accurate information concerning my
account information. I have also left a message in July and August for Fred Snow, who is purportedly a customer
service supervisor. Those calls have not been returned.
Thus, in your own words, you have confirmed that my account is current and requested I only deal with you on
this matter. So I ask, if you have told me to deal directly with you and you have told me how much the monthly
payment was for October 1 and I made that payment within thirty days of its due date, how can you tell me the
payment is not current and how can you then claim that you are told that the "credit repo.rting is accurate" and
thus I am delinquent on the account? It can't be both ...
3. As I stated in the October 30th, 2015 email (attached), "t he amount you claim is due for October is incorrect.
have wired the payment you are requesting so I can comply.
Please explain the process used by which you determined the amount due for October 1, 2015 is $4,646.05.
would like a fully detailed breakdown of that payment billing period .
Case in point:
• There are 30 days in September and as we are both aware, my account is a HELOC based on a current
index and margin currently making the effective annual percentage rate 3.249% (daily periodic rate
.00890410%). This we agree upon.
1
• Let' s assume for the case of this argument, the outstanding principal is $1,500,000 ( I am only using that
figure for the simplicity in explaining my argument, as the bank does not actually know the exact
amount of my outstand ing principal balance due to its flawed boarding of my loan from the Bank of
Coral Gables, its flawed system of records and the inability of its employees to understand and
remediate this on-going problem.
• The daily finance charge should be $133.5615.
• Based on a 30 day billing cycle, the monthly billing statement for the month of September 2015 would
be $4,006.85(rounded}.
Again, how did you derive the payment due as $4,646,05?
In addition, please provide me a fully detailed explanation as to why your claim that the November 1, 2015 payment is
considerably lower despite the number of days in the billing cycle being greater than that for the October 1, 2015 billing.
lastly, please look at my October and November billing statements and provide me an explanation as to why the
information which you have provided to me below and represented to be accurate differ from the information
contained in the banks servicing system of records for these two periods.
Although I appreciate your willingness to meet with me next week, I do not feel as if any progress was made since the
original meeting and in fact, things have become progressively worse and more complicated for me, as you have not
even identified, no less rectify the continued harms caused by the banks erroneous billing statements and derogatory
reporting to the major credit repositories, which you had assured me would be resolved.
I will send you the financial information that you requested pursuant to my proposed settlement. If after you have
received the information which you requested from me and my proposal is not acceptable, we need to let the
regulators, attorneys and judicial system, intervene and resolve this situation and the other matt er with S & A Capital
Partners.
Sincerely,
larry Schneider
Boca Raton, Fl33432
305-710-4201

Sent: Wednesday, November 04, 2015 8:20PM
To: Larry Schneider
Subject: Re: HELOC #40000006 - CONFIDENTIAL - FOR SETTLEMENT PURPOSES ONLY
Larry:
Thanks for the reply. I have the payment history that you requested, and am told that the credit reporting is
accurate. I will double check to see what correspondence we have with the credit reporting agencies and will
get that to you as well.
Are you available to meet next week? I have appointments up near you and can bring the documents you've
requested.
2
Brian
BrianT. Hagan
First American Bank
2295 Galiano Street
(305) 777-1027
On Nov 4, 2015, at 1:48PM, Larry Schneider <[email protected]> wrote:
Brian,
I just returned from Boston last night and will have the financial statement to you this weekend.
In the meantime, what steps have you taken to ensure that the erroneous reporting made by First
American Bank, to the major credit repositories have been expeditiously remediated and purged from
my credit file? I need financing for several things and thus require documentation from the Bank that it
acknowledges that my payment history has in fact been made on a timely basis, per the terms of the
loan documents as they relate to the Fair Debt Credit Reporting Act and that it takes responsibility for its
actions.
Please provide me a copy of the correspondence which the bank has sent to the credit repositories to
expeditiously remediate these ongoing harms, as a letter of explanation, although helpful, will not aid in
increasing my credit score. As you are aware, mortgage delinquencies reported to the credit
repositories have the most profound negative impact on their respective scoring models.
Lastly, has the flaws in the banks system of records been addressed such that my account is not still
erroneously reporting as delinquent?
I look forward to your prompt response to this matter.
Sincerly,
Larry Schneider
305-710-4201

Sent: Friday, October 30, 2015 3:44 PM
To: larry Schneider
Subject: Re: HELOC #40000006 - CONFIDENTIAL - FOR SETTLEMENT PURPOSES ONLY
Larry:
Thanks for the prompt reply. I'll get the information you're requesting, and am checking to see
3
larry Schneider

Sent: Tuesday, November 17, 2015 2:35AM
To: Brian T. Hagan
Subject: RE: financial information
Attachments: Dep't of Treasury- Notice of Case Resolution, August 17, 2015- Copy.pdf; PFS - First
American Bank, November 9, 2015.pdf
Importance: High
Brian,
I have attached a limited PFS, as I have not been able to f ile business tax returns for three of my entities, 1st Fidelity, S &
A Capital or Mortgage Resolution for 2013 or 2014 due to information concerning the Government's ongoing
investigation concerning the pending the qui tam false claims case which I filed in March of 2013. The defendant
JPMorgan Chase began a massive whistleblower retaliation initiative in an attempt thwart my ability to fina ncially
continue the action upon the seal period expiration(although the government has not intervened in the case, it does not
mean that they are not going to in the future . Per the false claim act, the government can intervene at any time. By not
intervening, it can continue its investigation without being bound by the rules of civil procedure if they had intervened
during the seal period .
Due to the retaliation, the three entities listed above filed suit in federal court in the Southern District of New York for
numerous causes of action, including civil RICO.
I have made a request through my counsel to communicate with the proper U.S. Attorney with the Civil Fraud Division at
Main Justice coordinating the investigation with the numerous branches of the federal government and states, to
request some type of documentation from Treasury regarding the filing of my business tax returns, which in turn are
needed to file my personal tax returns. However, I have attached a document from the IRS/ Dep' t ofTreasury from a
local field office who was unaware of the sealed litigation at the time and requested information about my tax
returns. Upon providing certain information and her subsequent communications w ith the Office Bureau Chief, this
letter was provided to me acknowledging the Notice of Case Resolution . It furt her states in the last paragraph, " Please
note: I am closing my case for the time being, as you have pending lit igation and return is for informational purposes."
Also attached is the limited PFS. I have not taken a salary this year and continue to liquidate any business cash flow to
sustain the costly litigation, In which I have in excess of $500,000 in unpaid and deferred legal fees.
Please review and let me know what you decide, as my proposal has not changed . The harms caused by the bank are
significant. I have been more than reasonable, forthcoming and accommodating in this matter and I have taken all of
the proper and reasonable steps to resolve t his matter outside of formal litigation . I' m not looking for another legal
battle as I have my hands full taking on the nation's largest bank, however, I will litigate if necessary.
Sincerely,
Larry Schneider
305-710-4201
1
From: BrianT. Hagan fmailto:[email protected]]
Sent: Monday, November 16, 2015 7:51 PM
To: Larry Schneider
SUbject: Re: financial information
Larry:
Sorry for the late response but I have been in meetings all day.
Please send whatever you have and we can discuss it.
Thanks,
Brian
Brian T. Hagan
First American Bank
2295 Galiano Street
(305) 777-1027
On Nov 16,2015, at 12:03 PM, Larry Schneider <[email protected]> wrote:
Brian,
I've been struggling trying to complete the form, as I have not filed a tax return since 2012. I
request a letter from a contact at Treasury, who is familiar with the JPmorgan Chase litigation,
which is the primary division of the United States which was defrauded pursuant to the False
Claim Act case.
I'll send the PFS unsigned today so we can discuss. If you. Are comfortable with the answers
and why, I will then execute and return to you.
Thanks,
Larry
Sent from my iPhone
On Nov 12,2015, at 4:47PM, BrianT. Hagan <[email protected]> wrote:
Larry:
I have not seen the financial information you were planning to send. Please let me
know if you have already sent it, or when it can be expected.
2
Thanks,
Brian
Sent from my iPhone

This email message has been delivered safely and archived online. This email system is managed by DynamrCare E2
Powered by Mimecast
3
Larry Schneider

Sent Wednesday, November 18, 2015 11:29 AM
To: Larry Schneider
Subject: Re: financial information
Larry:
Thank you; this looks like what we needed. We'll review it promptly.
Are you available to meet on Friday?
Brian
Sent from my iPhone
On Nov 17,2015, at 2:35AM, Larry Schneider <[email protected]> wrote:
Brian,
I have attached a limited PFS, as I have not been able to file business tax returns for three of my entities,
1st Fidelity, 5 & A Capital or Mortgage Resolution for 2013 or 2014 due to information concerning the
Government's ongoing invest igation concerning the pending the qui tam false claims case which I filed in
March of 2013. The defendant JPMorgan Chase began a massive whistleblower retaliation initiative in
an attempt thwart my ability to financially continue the action upon the seal period expiration(although
the government has not intervened in the case, it does not mean that they are not going to in the
future. Per the false claim act, the government can intervene at any time. By not intervening, it can
continue its investigation without being bound by the rules of civil procedure if they had intervened
during the seal period.
Due to the retaliation, the three entities listed above filed suit in federal court in the Southern District of
New York for numerous causes of action, including civil RICO.
I have made a request through my counsel to communicate with the proper U.S. Attorney with the Civil
Fraud Division at Main Justice coordinating the investigat ion with the numerous branches of the federal
government and states, to request some type of documentation from Treasury regarding the filing of my
business tax returns, which in turn are needed to file my personal tax returns. However, I have attached
a document from the IRS/Dep't of Treasury from a local field office who was unaware of the sealed
litigation at the time and requested information about my tax returns. Upon providing certain
information and her subsequent communications with the Office Bureau Chief, this lett er was provided
to me acknowledging the Notice of Case Resolution . It further states in the last paragraph, "Please
note: I am closing my case for the time being, as you have pending litigation and return is for
informational purposes."
Also attached is the limited PFS. I have not taken a salary this year and continue to liquidate any
business cash flow to sustain the costly litigation, In which I have in excess of $500,000 in unpaid and
deferred legal fees.
Please review and let me know what you decide, as my proposal has not changed. The harms caused by
the bank are significant. I have been more than reasonable, forthcoming and accommodating in this
matter and I have taken all of the proper and reasonable steps to resolve this matter outside of formal
litigation . I' m not looking for another legal battle as I have my hands full taking on the nation's largest
bank, however, I will litigate if necessary.
Sincerely,
Larry Schneider
305-710-4201
From: BrianT. Hagan [mailto :[email protected]]

To: Larry Schneider
Subject: Re: financial Information
Larry:
Thanks,
Brian
BrianT. Hagan
First American Bank
2295 Galiano Street
(305) 777-1027
On Nov 16,2015, at 12:03 PM, Larry Schneider <[email protected]> wrote:
Brian,
I've been struggling trying to complete the form, as J have not filed a tax return
since 2012. I request a letter from a contact at Treasury, who is familiar with the
JPmorgan Chase litigation, which is the primary division of the United States
which was defrauded pursuant to the False Claim Act case.
l'll send the PFS unsigned today so we can discuss. If you. Are comfortable with
the answers and why, I will then execute and return to you.
Thanks,
2
Larry
Sent from my iPhone
On Nov 12,2015, at 4:47PM, BrianT. Hagan <[email protected]>

wrote:
Larry:
1 have not seen the financial information you were planning to

send. Please let me know if you have already sent it, or when it can
be expected.
Thanks,
Brian
Sent from my iPhone
Tbis email message has been delivered safely and archived online. This email system is managed by
DynamiCare E2
Powered by Mimecast
<Dep't of Treasury- Notice of Case Resolution, August 17,2015- Copy.pdf>

<PFS - First American Bank, November 9, 2015.pdf>
3
how long that will take.
Brian
Sent from my iPhone
>On Oct 30, 2015, at 3:05PM, Larry Schneider <[email protected]> wrote:

>
> Brian,
>
> I am out of town and do not have access to complete the fmancial statement and send back
today. The amount you claim is due for October is incorrect. I have wired the payment you are
requesting so I can comply.
>
> As I explained during our meeting, I have not filed 2013 or 2014 tax returns. I am in contact
with the IRS and they are aware of the JPMorgan litigation.
>
>What are you going to do to immediately remediate the continued erroneous credit reporting of
my account and the harms it continues to cause me?
>
> Please send me the complete payment history of my account since origination and a copy of
the entire origination file along with any and all prior billing statements, notices and other
correspondences pertaining to the origination and servicing of my mortgage since the date of
origination. This communication should be deemed a Qualified Written Request.
>
>
>Sincerely,
>
>
> Larry Schneider
>
>
>
>
------------------------------------
> From: BrianT. Hagan [[email protected]]
>Sent: Friday, October 30, 2015 12:43 PM
> Subject: RE: HELOC #40000006- CONFIDENTIAL - FOR SETTLEMENT PURPOSES
ONLY
>
> Larry,
>
> Thanks for your email. As I've said before, I am available whenever you have questions and
can be reached almost any time at my cell phone number, which is included below.
>
>For the October I payment, the amount due is $4,646.05. The payment due November 1, if
made on time, will be $3,823.29. If you need any help in getting these payments made, please let
me know.
>
> As we discussed in our meeting, before First American Bank can consider a deed-in-lieu of
foreclosure transaction like the one you are proposing, we need to obtain from you the following
4
docwnents and information:
>
> • Personal tax returns for the most recent two years
>
> • Personal Financial Statement (form attached)
>
> I'll call you later today to discuss this.
>
>Thanks,
>
>Brian
>
> Brian T. Hagan
>First American Bank
>Office (305) 777-1027
> Cell (786) 385-0348
> [https:l/www.firstambank.comlmedia/uploads/F AB-
logo2.gif]<https://www.firstambank.com/>
> P.O. Box 0794
> www.FirstAmBank.com<https://www.firstambank.com/>
>
[https:/ /www .frrstambank.corn/media/uploads/social med.ia/fb button.png] <https ://www .facebo
ok.com!FirstAmBank>
[https://www.firstambank.com/media/uploads/social media/tw button.png]
>
---------------------------
> IMPORTANT INFORMATION
>
> Online Security
Online Security page at https://www.firstambank.com/General/Generallnfo/OnlineSecurity/
>
> Privacy Policy
> We do NOT disclose any information about you to anyone, except as permitted by law. For
https://www.firstambank.com/General/Generallnfo/PrivacyPolicy/
>
>
>
>
>
> Sent: Tuesday, October 27, 2015 7:09PM
5
>To: BrianT. Hagan <[email protected]>
ONLY
>
> CONFIDENTIAL - FOR SETTLEMENT PURPOSES ONLY
>
>Brian,
>
> I have been occupied 24/7 with the semi-confidential situation which we spoke about during
our meeting. Thus, I have not had a moment to address the continued problematic and abusive
practices by First American Bank in its failure to address and remediate its flawed system of
records, which continues to erroneously report my HELOC account to the major credit
repositories as delinquent for the past six months (This report only shows September and
October 2015, as a letter correcting prior erroneous reporting's by the Bank, was sent to the
credit repositories by Jennifer Anderson. In fact, the bank has already reported my account as
over 30 days past due for October 2015. (Attached is a confidential copy of my credit report as
of today, October 27, 2015). This has continually lowered my credit score and fraudulently
corrupted my credit worthiness in several attempts to get multi-million dollar financing for my
FCA and RICO cases against JPMorgan Chase and for other unrelated financing. As I notated in
my email last month, the banks customer service department can't tell me the last paid date and
next due date of my mortgage loan. At 3:32pm today, I once again called the customer service
number on my Periodic Billing Statement (847-952-3700) and once again I sat on hold for 15
minutes while the representative tried to determine the accuracy and integrity of my account
information, to no avail.
>
> You had personally assured me that the problem with my HEOLC billing was rectified during
our meeting. I shared honest and confidential information, as a professional, a customer and on a
very personal level. I reasonably expected that if you went out of your way to meet with me in
person to discuss the matter, that you did so in good faith and that the erroneous billing and
credit reporting problems with my account were resolved as you represented to me.
>
>Furthermore, in the subsequent email below, you claimed that you "will verify that it [the
September payment] has been applied properly." Once again, I took you at your word that you
were personally ensuring that my account was being handled properly. It was not and is still not
being handled properly.
>
> The banks unwillingness to address its corrupted system of records, despite over 20
documented requests, plus the gross negligence shown by the bank in filing a release of lien and
satisfaction of mortgage for a loan it did not own (Johnnie Washington- S & A Capital Partners
mortgage), shows the banks unwillingness to comply with federal and state mortgage servicing
and consumer protection laws.
>
> I have been cooperative and accommodating with any of the banks requests. I am now ready to
make this a very long and protracted litigated matter.
>
> I offer this one offer and compromise as follows:
> 1/we will agree to provide the bank a special warranty deed for the transfer of the property in
its "as-is" condition, which is in the same material condition as it was at the time of the appraisal,
in exchange for a full release of liability ofthe debt, as a set off for the mortgage loan which the
Bank released between S & A Capital Partners as Mortgagee a..'l.d Johnnie Washington as
Mortgagor, and for other good and valuable consideration (harms). General releases to be signed
6
between the Bank and Laurence Schneider, individually and between the Bank and S & A
Capital Partners.
>
> As a professional courtesy, I did not copy anyone on this correspondence.
>
>Please reply either way prior to 2:00p.m. on Friday October 30, 2015. A no reply will be
interpreted as a disagreement to the basic terms outlined and offered above.
>
>
>Sincerely,
>
> Larry Schneider
> S & A Capital Partners
> 2901 Clint Moore Road, Suite 410
>Boca Raton, FL 33496
> Tel: 305-710-4201
>
>
>
> CONFIDENTIAL - FOR SETTLEMENT PURPOSES ONLY
>
>
> From: BrianT. Hagan (mailto:[email protected]]
> Sent: Thursday, October 01, 2015 8:30AM
> To: Larry Schneider
> Cc: Milton W. Espinoza; James A Kielbasa; Jennifer L. Anderson
> Subject: RE: HELOC #40000006
>
> Larry:
>
> I can confirm we have received your payment, and will verify that it has been applied properly.
>
> If you have any questions regarding your October payment, please contact me directly.
>
> Thanks,
>
>Brian
>
> Brian T. Hagan
> (305) 777-1027
>
> [cid :~WRDOOO.jpg]<https://www.firstambank.com/>
> P.O. Box 0794
> www.FirstAmBank.com<https://www.firstambank.com/>
7
>
>
>
[cid:- WRDOOO.jpg]<https://www.facebook.com/FirstAmBank.>[cid:-WRDOOO.jpg]<https://ww
w.twitter.com/FirstAmBank>
>
>
-----------------------------
>IMPORTANT INFORMATION
>
> Online Security
>First American Bank will never ask you for your personal information, such as your login ID,
Online Security page at https://WV~w.firstambank.corn/GeneraVGenerallnfo/OnlineSecurity/
>
> Privacy Policy
> We do NOT disclose any information about you to anyone, except as permitted by law. For
https://www.firstambank.corn/General/GeneraJinfo/PrivacyPolicy/
>
>
>
>
>
> Sent: Wednesday, September 30, 2015 3:59PM
> To: BrianT. Hagan <[email protected]<mailto:[email protected]>>
> Cc: Milton W. Espinoza
<[email protected] <mail to :[email protected]>> ; James A Kielbasa
<[email protected]<mailto:[email protected]>>; Jennifer L. Anderson
<[email protected]<mailto:[email protected]>>
> Subject: HELOC #40000006
> Importance: High
>
>
> Brian,
>
> Please fmd the September 2015 payment on the HELOC account. Despite the flawed
information in your servicing system of records, my account is current (for the purposes of the
Fair Debt Credit Reporting Act). Please apply the payment accordingly. The bank has been and
continues to make erroneous and derogatory reporting of my account to the credit repositories,
despite numerous requests to the bank to rectify the various boarding errors which has affected
my billing and subsequent payments. The bank continues to violate this and numerous other state
and federal, mortgage servicing and consumer protection laws.
>
>
> Sincerely,
>
> Larry Schneider
> 1199 S. Federal IJwy, #369
> Boca Raton, FL 33432
8
> 305-710-4201
>
>
>
>This email message has been delivered safely and archived online. This email system is
managed by DynamiCare
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%2B-
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k%2B-%2BSA CapitalPartners>.
> Powered by Mimecast
>
> <BankUnited Treasury Management (l).pd£>
9
Larry Schneider

To: BrianT. Hagan ([email protected])
Subject: FW: BankUnited-1st Fidelity Revolving LOC
Importance: High
Brian,
I want you to be aware that my banking relationship between 1st Fidelity Loan Servicing and Bank
United has now been affected by the fraudulent reporting of my HELOC by First American Bank. This
relationship with Bank United includes not only the operating account but also a revolving line of
credit which is the life line of the Company and the primary source of funding the RICO and False
Claim Cases against JPMorgan Chase, as the whistleblower retaliation to my entities by JPMorgan
Chase has significantly reduced my cash flow by interfering with the contractual relationships
between my entities and the borrowers whose loans are owned by my entities. The Justice
Department and numerous state attorney generals have been relying on my continued litigation and
progress in the FCA case while it decides whether and when to intervene in the case, which is largely
based on political factors.
However, due to the ongoing fraudulent reporting of my HELOC by First American Bank, Bank United
has suspended my business line of effective immediately due to negative reporting on my personal
credit report. As I have advised you and numerous other employees of First American Bank, over the
course of eight months, through scores of correspondences, the bank is fraudulently misrepresenting
my payment history to the credit repositories. As such, this ongoing fraud and misrepresentation has
now caused harms to me individually, to S & A Capital Partners regarding the Johnnie Washington
fraudulent satisfaction, and the now the freezing of 1st Fidelity Loan Servicing revolving line of credit
with Bank United. This is now causing indirect harm to the United States Treasury, every tax payer
and the treasuries of 19 States and the District of Columbia if I cannot fund the continuance of this
litigation.
Our counsel has already corresponded with general counsel for Bank United and with the Department
of Justice, concerning First American Banks gross negligence and potential criminal conduct in this
matter.
In addition, we will be filing complaints with every federal and state regulatory agency, in addition to
the temporary injunction which we will be filing in federal court for the cease and desist of the banks'
fraud. I will expose the banks fraud and your fraudulent misrepresentation in numerous these
litigations.
I have been instructed by counsel to cease all communications with you.
Sincerely,
Larry Schneider
1
1 st Fidelity Loan Servicing
Tel: 305-710-4201
From: Ivonne Cabrera

Sent: Wednesday, November 18, 2015 11:05 AM
To: [email protected]
Subject: BankUnited-1st Fidelity Revolving LOC
Hi Larry,
Per our conversation, as part of our loan conditions from time to time we review guarantors credit
and yours has been addressed. Please provide letter of explanation and supporting documentation of
resolution to credit report.
Please call me with any questions.
Thanks,
Ivonne
lvonne Cabrera
VP & Branch Manager
BankUnited
Miami 8th St Branch
3650 Southwest 8th Street
Miami Fl, 33135
P. (305) 476-3700
F. (305) 476-3725
c. {305) 495-5613
E. icabrera@ba nkunited.com
The information transmitted is intended only for the person or entity to which it is addressed and may contain
confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of
any action in reliance upon this information by persons or entities other than the intended recipient is prohibited.
If you received this in error, please contact the sender and delete the material from any computer.
This email message has been delivered safely and archived online. This email system is managed by DynamjCare E2
Powered by Mimecast
2
Larry Schneider
Sent: Friday, November 20, 2015 3:25 PM
To: Larry Schneider
Larry:
We can get you the payment history right away. Just let us know where to send it, and it will go out today. The
package will also include copies of the Mortgage, Credit Agreement and Disbursement Request.
As for S&A Capital, we will be filing updated releases of the prior assignments to protect against any future
confusion. As you had proposed in your offer, I am assuming that any settlement would incorporate the S&A
situation.
If you want to reach me over the weekend or next week, I'm available by cell (786-385-0348).
Brian
On Nov 20, 2015, at 1:05PM, Larry Schneider <[email protected]> wrote:
Brian,
Thank you for making the correction. I'll call customer service to verify that the billing and
payment history is now corrected.
What is the bank going to do about the S & A Capital Partners loan satisfaction situation? It's
been almost five months since it was brought to the bank's attention?
Also, please send me all of the documentation regarding the payment history of the loan since
origination and all executed loan documents(both sets).
Once I reviewed the requested documents, I'll decide my next course of action. Can I provide
you with my FedEx number so it can be expedited to me for Monday?
1
Thank you,
Larry Schneider
Sent from my iPhone
On Nov 20,2015, at 11:07 AM, BrianT. Hagan <[email protected]> wrote:
Larry:
I'm glad you reached out. When we met, one option we discussed was the bank's
willingness to finance a deficiency after the sale of the property, even
brainstorming several ideas for us to secure that deficiency and how it would get
repaid. I still believe that's your best option: you get the house listed and sold,
and we can work together on the deficiency.
As an alternative, given the current value of the property, we can only consider
your offer if it includes an additional, one-time payment of$250,000.
As an aside, we have submitted corrections to the credit reporting agencies and

we have verified by running a credit report that the account is showing no past
due payments and is reporting all payments made as agreed.
I will be traveling with family over Thanksgiving week as well, but can be
reached via email or my cell phone (786-385-0348) any time.
Brian
Brian T. Hagan
First American Bank
2295 Galiano Street
(305) 777-1027

Sent: Thursday, November 19, 2015 4:38 PM
To: BrianT. Hagan <[email protected] >
Brian,
While I have my composure and despite my attorney's advice, I want to reach out
to you one last time regarding the bank's fmal decision on handling this matter.
If we can quietly agree to my proposal and the bank will immediately remediate
the reporting errors and send any letters needed to rectify the harms, I would
prefer that course. I have bigger fish to fry. However, if not, you've effectively
put me into corner and I am forced to take legal actions proposed by counsel.
2
I need you answer ASAP, tomorrow.
Regardless, during a QWR, the bank is required to NOT make any negative
reporting to the credit repositories. Additionally, please confirm when and to
which address you've sent the complete payment history and copy of the entire
origination file.
Sincerely,
Larr Schneider
Sent from my iPhone
On Nov 18,2015, at 4:06PM, BrianT. Hagan <[email protected]>

wrote:
Larry:
Thanks for sending this. I hadn't seen these articles - interesting.
As for tomorrow, I am available in the morning. Is there

somewhere in Boca we can meet around 9:00 (or a little earlier or
later, if needed)?
Brian
Sent from my iPhone
On Nov 18,2015, at 11:55 AM, Larry Schneider

<[email protected]> wrote:
Brian,
Attached are a few of the tax returns that I was able to

complete for 2013, as well as my W-2' s for that year. I
hope this assists you .
Ironically, in my email to you yesterday I explained that

I will try to get my contact at the Civil Fraud Division at
the Justice Department to get you a letter from
Treasury. As it turns out, later in the day yesterday, it
was widely reported that the Civil Fraud Division is
working with the Criminal Division regarding the
prosecution of executives with JPMorgan Chase.
http:!/money.cnn.com/2014/11/04/investing/jpmorgan
-crim inal-probe-forex/index.html
http://www.reuters.com/article/2013/11/19/jpmorgan
chase-brief-
id USWENOOBM 120131119#LeFVS7skKhhwWHou.97
3
http:Uwww.housingwire.com/articles/35631-doj-
reportedly-pursuing-criminal-charges-against- jpmorgan-
chase-rbs-executives?eid=311688731&bid=1236786
I may have a small window to meet in Boca

tomorrow. We are headed out of town for
Thanksgiving week tomorrow evening.
Sincerely,
Larry Schneider
1st Fidelity Loan Servicing
Tel: 305-710-4201
From: Brian T. Hagan

[ mailto:[email protected]]
To: Larry Schneider
SUbject: Re: financial information
Larry:
Thank you; this looks like what we needed. We'll

review it promptly.
Brian
Sent from my iPhone
On Nov 17,2015, at 2:35AM, Larry Schneider

Brian,
I have attached a limited PFS, as I have

not been able to file business tax
returns for three of my entities, 1st
Fidelity, S & A Capital or Mortgage
Resolution for 2013 or 2014 due to
information concerning the
Government's ongoing investigation
concerning the pending the qui tam
false claims case which I filed in March
of 2013. The defendant JPMorgan
Chase began a massive whistleblower
4
retaliation initiative in an attempt
thwart my ability to financially continue
the action upon the seal period
expiration(although the government
has not intervened in the case, it does
not mean that they are not going to in
the future. Per the false claim act, the
government can intervene at any
time. By not intervening, it can
continue its investigation without being
bound by the rules of civil procedure if
they had intervened during the seal
period .
Due to the retaliation, the three entities

listed above filed suit in federal court in
the Southern District of New York for
numerous causes of action, including
civil RICO.
I have made a request through my

counsel to communicate with the
proper U.S. Attorney with the Civil
Fraud Division at Main Justice
coordinating the investigation with the
numerous branches of the federal
government and states, to request
some type of documentation from
Treasury regarding the filing of my
business tax returns, which in turn are
needed to file my personal tax
returns. However, I have attached a
document from the IRS/Dep't of
Treasury from a local field office who
was unaware of the sealed litigation at
the time and requested information
about my tax returns. Upon providing
certain information and her subsequent
communications with the Office Bureau
Chief, this letter was provided to me
acknowledging the Notice of Case
Resolution. It further states in the last
paragraph, " Please note: I am closing
my case for the time being, as you have
pending litigation and return is for
Also attached is the limited PFS. I have

not taken a salary this year and
continue to liquidate any business cash
flow to sustain the costly litigation, In
5
which I have in excess of $500,000 in
unpaid and deferred legal fees.
Please review and let me know what

you decide, as my proposal has not
changed. The harms caused by the
bank are significant. I have been more
than reasonable, forthcoming and
accommodating in this matter and I
have taken all of the proper and
reasonable steps to resolve this matter
outside of formal litigation. I'm not
looking for another legal battle as I have
my hands full taking on the nation' s
largest bank, however, I will litigate if
necessary.
Sincerely,
Larry Schneider
305-710-4201
From: BrianT. Hagan

[mailto:[email protected]]
Sent: Monday, November 16, 2015
7:51PM
To: Larry Schneider
Larry:
Sorry for the late response but I have

been in meetings all day.
Please send whatever you have and

we can discuss it.
Thanks,
Brian
BrianT. Hagan
First American Bank
2295 Galiano Street
(305) 777-1027
6
On Nov 16,2015, at 12:03 PM,
Larry Schneider
<Lan:[email protected]>
wrote:
Brian,
I've been struggling

trying to complete the
form, as I have not
filed a tax return since
2012. I request a
letter from a contact
at Treasury, who is
familiar with the
JPmorgan Chase
litigation, which is the
primary division of
the United States
which was defrauded
pursuant to the False
Claim Act case.
I'll send the PFS

unsigned today so we
can discuss. If you.
Are comfortable with
the answers and why,
I will then execute
and return to you.
Thanks,
Larry
Sent from my iPhone
On Nov 12, 2015, at

4:47PM, BrianT.
Hagan
<bhagan@firstamban
k.com> wrote:
Larry:
I have
not
7
seen
the
financi
al
inform
ation
you
were
plannin
g to
send.
Please
let me
know
if you
have
already
sent it,
or
when it
can be
expect
ed.
Thanks
Brian
Sent
from
my
iPhone
This email
message
has been
delivered
safely and
archived
onli.ne. This
email
system is
managed
by
DvnamiCar
~
Poweredby
Mimecast
<Dep't ofTreasury- Notice of Case

Resolution, August 17, 2015-
Copy.pd£>
<PFS - First American Bank,
November 9, 2015.pd£>
<2013 S & A Tax Return.pd£>
8
<LS- 2013 W-2's (l).pdf>
<2013 Real Estate & Finance Tax Retum.pdf>
9
Larry Schneider
From: Ivonne Cabrera <[email protected] >

To: Larry Schneider
Subject: FW: BankUnited
From: Ivonne Cabrera

Subject: BankUnited
Hi Larry,
Per our conversation, as part of our loan conditions from time to time we review guarantors credit
and yours has been addressed. Please provide letter of explanation and supporting documentation of
resolution to credit report.
Please call me with any questions.
Thanks,
Ivonne
lvonne Cabrera
VP & Branch Manager
BankUnited
Miami 8th St Branch
3650 Southwest 8th Street
Miami FL, 33135
P. (305) 476-3700
F. (305) 476-3725
c. (305) 495-5613
E. [email protected]
The information transmitted is intended only for the person or entity to which it is addressed and may contain
confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of
any action in reliance upon this information by persons or entities other than the intended recipient is prohibited.
If you received this in error, please contact the sender and delete the material from any computer.
This email message has been delivered safely and archived online. This email system is managed by DmarmCare E1.
Powered by Mimecast
BankUnited, N.A.
7815 NW 148th Street
M1am1 Lakes FL 3016
T 877 779 2265
www.bankun t d com
• BankUnited
'0\. ~mbl!r I. ~0 I6
I aurcncc ~dllll.!ltkr
co
I Fidel I\\ I oan ~en i~ing I LC
~90 Il hnt \ 1omc RJ ...,uitc.: #-II 0
Boca Rutl\11, I I B ~96
:
RL LOC" ~00086 lrorn Banl.l nited. N.A tl' I st f.iddit~ ll1an ~ln icing Ll C Credit I ine ,\grcl.!tnent
dated 1\.1arch 31 ·• 20 II in the Original P1 indpul Anwuntl)f I110.0110 00 I the "L uJil .. )
D..:ur \l r ...,chnc1der:
Plt!a-.1.! acc..:pt this kl1c.:r ""a •wtificati\lllthutthc l.inc ,\, ail.1bilit~ is cuncdkJ etli:ctl\..: immed iate!\ on the
abo' c-mcnt ion..:d loan.
Lill>R~f \1L '\I' LO CRI Dll ~r \ t1RI I_M '\I
!IllS I DOR~I \11'\T IOlRI DIJ LI~LAliRII ~IU\1 dli:cti\c,blll~ll\Cllll'l\:ri.~OI6cnteredin tl\b)

and bct\\1.!\!n BI\1\JJ...l f\.11 1 [) thcr..:maltcr th..: "I cnd\;•"l :mJ 1 1 riJ..:Jit~ ll'an ~cn1cing. LLC. a I lorida
l nrporatiun ( he•cin~ttier th!.! "Bllff\1\\cr"),
\\. Ill R1· \ ~ Bom)\\cr c~ccuted and Jd iH!rcJ Ill I cndcr that C\.'rtain C rcJu L.inc ,\ gn:..:ment \.1an:h 'I
20 II in the l)rlgina l princip,IJ amount of I 00,000 ( hcrcinalicr the "r\gn:crncnt '):and
I. Loan Prlldlh.:t I hl a\ ailaoilu~ on~ our Re\ oJ, in I! Line of C •·edit. t /36 mon th!} pa) ment
\\ jJJ be !1!1110\CU thcrcf()r\! ~1\11 \\ illrwt 01! uhJc Ill ma"c 'Ill) futun: athancc:. 011 the line, fhc
pa~ rn~?llls of the line \\ill •~·main <'11 a 1116 nwnthh prin-.ipal plus intcre'\t amort izat ion
-;~hcJulc until the llUhtanding. ill311 i-. raiJ in fidJ 'l t\U .11 311) p0i11t in time ab,o haH' the
''PIIt'll to pJ) the principal b.tlam:\; in tirll. t\11 ''tlll..r r~·rnb llfthc Crcc.lit Lin~. \g.reement arc
l1111.hangcd and arc muticJ und rcal t mn~.:d h~ rhe hl'rr,mcr.
Should ~ou require an~ aJJiti,,nal infonnation pka-.c Jo 11\lt hc ... itatc to C(lntact me at 305--n6-3700.
lo)inLcn:l).
h onnc Cabrera
Branch l.,ak:. Lcaucr
Ranl-.l ni tcd. "J.A
Larry Schneider

To: Brian T. Hagan
Subject Re: financial information
Brian,
While I have my composure and despite my attorney's advice, I want to reach out to you one last time regarding
the bank's fmal decision on handling this matter.
If we can quietly agree to my proposal and the bank will immediately remediate the reporting errors and send
any letters needed to rectify the harms, I would prefer that course. I have bigger fish to fry. However, if not,
you've effectively put me into comer and I am forced to take legal actions proposed by counsel.
Regardless, during a QWR, the bank is required to NOT make any negative reporting to the credit repositories.
Additionally, please confirm when and to which address you've sent the complete payment history and copy of
the entire origination file.
Sincerely,
Larr Schneider
Sent from my iPhone
On Nov 18,2015, at 4:06PM, Brian T. Hagan <[email protected]> wrote:
Larry:
Thanks for sending this. I hadn't seen these articles - interesting.
As for tomorrow, I am available in the morning. Is there somewhere in Boca we can meet around
9:00 (or a little earlier or later, if needed)?
Brian
Sent from my iPhone
On Nov 18,2015, at 11 :55 AM, Larry Schneider <[email protected]> wrote:
Brian,
Attached are a few of the tax returns that I was able to complete for 2013, as well
as my W-2's for that year. I hope this assists you.
Ironically, in my email to you yesterday I explained that I will try to get my
contact at the Civil Fraud Division at the Justice Department to get you a letter
from Treasury. As it turns out, later in the day yesterday, it was widely reported
that the Civil Fraud Division is working with the Criminal Division regarding the
http://money.cnn.com/20 14/ 11/04/ investingljpmorgan-criminal-probe-
forex/index.htrnl
http://www.reuters.com/article/20 13/ 11 / 19/ jpmorganchase-brief-
idUSWENOOBM 120 131119#LeFVS7skKhhwWHou.97
http://www .housingwire.com/articlcs/3 563 I -do j-reportedly-pursuing-criminal-
charges-against-jpmorgan-chase-rbs-executives?eid=311688731 &bid= 1236786
I may have a small window to meet in Boca tomorrow. We are headed out of
town for Thanksgiving week tomorrow evening.
Sincerely,
Larry Schneider
Tel: 305-710-4201
Sent: Wednesday, November 18, 2015 11 :29 AM
To: Larry Schneider
Larry:
Thank you; this looks like what we needed. We'll review it promptly.
Brian
Sent from my iPhone
On Nov 17, 2015, at 2:35AM, Larry Schneider <[email protected]>

wrote:
Brian,
I have attached a limited PFS, as I have not been able to file
business tax returns for three of my entities, 1st Fidelity, S & A
Capital or Mortgage Resolution for 2013 or 2014 due to
information concerning the Government's ongoing investigation
concerning the pending the qui tam false claims case which 1 filed
in March of2013. The defendant JPMorgan Chase began a
massive whistleblower retaliation initiative in an attempt thwart
my ability to financially continue the action upon the seal period
expiration(although the government has not intervened in the case,
it does not mean that they are not going to in the future. Per the
false claim act, the government can intervene at any time. By not
intervening, it can continue its investigation without being bound
by the rules of civil procedure if they had intervened during the
seal period.
Due to the retaliation, the three entities listed above filed suit in
federal court in the Southern District of New York for numerous
causes of action, including civil RICO.
I have made a request through my counsel to communicate with
the proper U.S. Attorney with the Civil Fraud Division at Main
Justice coordinating the investigation with the numerous branches
2
of the federal government and states, to request some type of
documentation from Treasury regarding the filing of my business
tax returns, which in turn are needed to file my personal tax
returns. However, I have attached a document from the IRS/Dep't
ofTreasury from a local field office who was unaware of the
sealed litigation at the time and requested information about my
tax returns. Upon providing certain information and her subsequent
communications with the Office Bureau Chief, this letter was
provided to me acknowledging the Notice of Case Resolution. It
further states in the last paragraph, "Please note: I am closing my
case for the time being, as you have pending litigation and return is
for informational purposes."
Also attached is the limited PFS. I have not taken a salary this year
and continue to liquidate any business cash flow to sustain the
costly litigation, In which I have in excess of $500,000 in unpaid
and deferred legal fees.
Please review and let me know what you decide, as my proposal
has not changed. The harms caused by the bank are significant. I
have been more than reasonable, forthcoming and accommodating
in this matter and I have taken all of the proper and reasonable
steps to resolve this matter outside of formal litigation. I'm not
looking for another legal battle as I have my hands full taking on
the nation's largest bank, however, I will litigate if necessary.
Sincerely,
Larry Schneider
305-710-4201
To: Larry Schneider
Larry:
Thanks,
Brian
Brian T. Hagan
First American Bank
2295 Galiano Street
(305) 777-1027
On Nov 16,2015, at 12:03 PM, Larry Schneider

Brian,
I've been struggling trying to complete the form, as
I have not filed a tax return since 2012. I iequest a
3
letter from a contact at Treasury, who is familiar
with the JPmorgan Chase litigation, which is the
primary division of the United States which was
defrauded pursuant to the False Claim Act case.
I'll send the PFS unsigned today so we can discuss.

If you. Are comfortable with the answers and why, 1
will then execute and return to you.
Thanks,
Larry
Sent from my iPhone
On Nov 12, 2015, at 4:47PM, BrianT. Hagan

Larry:
I have not seen the financial

information you were planning to
send. Please let me know if you have
already sent it, or when it can be
expected.
Thanks,
Brian
Sent from my iPhone
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Larry Schneider

Sent: Friday, November 20, 2015 3:25 PM
To: Larry Schneider
Larry:
We can get you the payment history right away. Just let us know where to send it, and it will go out today. The
package will also include copies of the Mortgage, Credit Agreement and Disbursement Request.
As for S&A Capital, we will be filing updated releases of the prior assignments to protect against any future
confusion. As you had proposed in your offer, I am assuming that any settlement would incorporate the S&A
situation.
If you want to reach me over the weekend or next week, I'm available by cell (786-385-0348).
Brian
On Nov 20, 2015, at 1:05 PM, Larry Schneider <[email protected]> wrote:
Brian,
Thank you for making the correction. I'll call customer service to verify that the billing and
payment history is now corrected.
What is the bank going to do about the S & A Capital Partners loan satisfaction situation? It's
been almost five months since it was brought to the bank's attention?
Also, please send me all of the documentation regarding the payment history of the loan since
origination and all executed loan documents(both sets).
Once I reviewed the requested documents, I'll decide my next course of action. Can I provide
you with my FedEx number so it can be expedited to me for Monday?
1
Thank you,
Larry Schneider
Sent from my iPhone
On Nov 20, 2015, at 11:07 AM, BrianT. Hagan <bhagan(a),firstambank.com> wrote:
Larry:
I'm glad you reached out. When we met, one option we discussed was the bank's
willingness to finance a deficiency after the sale of the property, even
brainstorming several ideas for us to secure that deficiency and how it would get
repaid. I still believe that's your best option: you get the house listed and sold,
and we can work together on the deficiency.
As an alternative, given the current value of the property, we can only consider
your offer if it includes an additional, one-time payment of $250,000.
As an aside, we have submitted corrections to the credit reporting agencies and

we have verified by running a credit report that the account is showing no past
due payments and is reporting all payments made as agreed.
I will be traveling with family over Thanksgiving week as well, but can be
reached via email or my cell phone (786-385-0348) any time.
Brian
Brian T. Hagan
First American Bank
2295 Galiano Street
(305) 777-1027

Brian,
While I have my composure and despite my attorney's advice, I want to reach out
to you one last time regarding the bank's final decision on handling this matter.
If we can quietly agree to my proposal and the bank will immediately remediate
the reporting errors and send any letters needed to rectify the harms, I would
prefer that course. I have bigger fish to fry. However, if not, you've effectively
put me into corner and I am forced to take legal actions proposed by counsel.
2
Regardless, during a QWR, the bank is required to NOT make any negative
reporting to the credit repositories. Additionally, please confirm when and to
which address you1ve sent the complete payment history and copy of the entire
origination file.
Sincerely,
Larr Schneider
Sent from my iPhone
On Nov 18, 2015, at 4:06PM, BrianT. Hagan <[email protected]>

wrote:
Larry:
Thanks for sending this. 1 hadn1t seen these articles- interesting.
As for tomorrow, I am available in the morning. Is there

somewhere in Boca we can meet around 9:00 (or a little earlier or
later, if needed)?
Brian
Sent from my iPhone
On Nov 18,2015, at 11 :55 AM, Larry Schneider

Brian,
Attached are a few of the tax returns that I was able to

complete for 2013, as well as my W-2's for that year. I
hope this assists you .
Ironically, in my email to you yesterday I explained that

I will try to get my contact at the Civil Fraud Division at
the Justice Department to get you a letter from
Treasury. As it turns out, later in the day yesterday, it
was widely reported that the Civil Fraud Division is
working w ith the Criminal Division regarding the
http:/lmoney.cnn.com/2014/11/04/investing/jpmorgan
-criminal-probe-forex/index.html
http://www.reuters.com/article/2013/11/19/jpmorgan
chase-brief-
idUSWENOOBM120131119#LeFVS7skKhhwWHou.97
3
http://www.housingwire.com/articles/35631-doj-
reportedly-pursuing-criminal-charges-against- jpmorgan-
chase-rbs-executives?eid==311688731&bid==1236786
I may have a small window to meet in Boca

tomorrow. We are headed out of town for
Thanksgiving week tomorrow evening.
Sincerely,
Larry Schneider
Tel: 305-710-4201
From: BrianT. Hagan

[mailto:[email protected] ]
To: Larry Schneider
Larry:
Thank you; this looks like what we needed. We'll

review it promptly.
Brian
Sent from my iPhone
On Nov 17,2015, at 2:35AM, Larry Schneider

Brian,
I have attached a limited PFS, as I have

not been able to file business tax
returns for three of my entities, 1'1
Fidelity, S & A Capital or Mortgage
Resolution for 2013 or 2014 due to
information concerning the
Government's ongoing investigation
concerning the pending the qui tam
false claims case which I filed in March
of 2013. The defendant JPMorgan
Chase began a massive whistleblower
4
retaliation initiative in an attempt
thwart my ability to financially continue
the action upon the seal period
expiration( although the government
has not intervened in the case, it does
not mean that they are not going to in
the future . Per the false claim act, the
government can intervene at any
time. By not intervening, it can
continue its investigation without being
bound by the rules of civil procedure if
they had intervened during the seal
period.
Due to the retaliation, the three entities

listed above filed suit in federal court in
the Southern District of New York for
numerous causes of action, including
civil RICO.
I have made a request through my

counsel to communicate with the
proper U.S. Attorney with the Civil
Fraud Division at Main Justice
coordinating the investigation with the
numerous branches of the federal
government and states, to request
some type of documentation from
Treasury regarding the filing of my
business tax returns, which in turn are
needed to file my personal tax
returns. However, I have attached a
document from the IRS/Dep't of
Treasury from a local field office who
was unaware of the sealed litigation at
the time and requested information
about my tax returns. Upon providing
certain information and her subsequent
communications with the Office Bureau
Chief, this letter was provided to me
acknowledging the Notice of Case
Resolution . It further states in the last
paragraph, "Please note: I am closing
my case for the time being, as you have
pending litigation and return is for
Also attached is the limited PFS. I have

not taken a salary this year and
continue to liquidate any business cash
flow to sustain the costly litigation, In
5
which I have in excess of $500,000 in
unpaid and deferred legal fees.
Please review and let me know what

you decide, as my proposal has not
changed. The harms caused by the
bank are significant. I have been more
than reasonable, forthcom ing and
accommodating in this matter and I
have taken all of the proper and
reasonable steps to resolve this matter
outside of formal litigation. I'm not
looking for another legal battle as I have
my hands full taking on the nation's
largest bank, however, I will litigate if
necessary.
Sincerely,
Larry Schneider
305-710-4201
From: Brian T. Hagan

[mailto:[email protected]]
Sent: Monday, November 16, 2015
7:51PM
To: Larry Schneider
Larry:
Sorry for the late response but I have

been in meetings all day.
Please send whatever you have and

we can discuss it.
Thanks,
Brian
Brian T. Hagan
First American Bank
2295 Galiano Street
(305) 777-1027
6
On Nov 16,2015, at 12:03 PM,
Larry Schneider
<[email protected]>
wrote:
Brian,
I've been struggling

trying to complete the
form, as I have not
filed a tax return since
20 12. I request a
letter from a contact
at Treasury, who is
familiar with the
JPmorgan Chase
litigation, which is the
primary division of
the United States
which was defrauded
pursuant to the False
Claim Act case.
I'll send the PFS

unsigned today so we
can discuss. If you.
Are comfortable with
the answers and why.
I will then execute
and return to you.
Thanks,
Larry
Sent from my iPhone
On Nov 12,2015, at
4:47PM, BrianT.
Hagan
<bhagan@firstamban
k.com> wrote:
Larry:
I have
not
7
seen
the
financi
al
inform
ation
you
were
plannin
g to
send.
Please
let me
know
if you
have
already
sent it,
or
when it
can be
expect
ed.
Thanks
Brian
Sent
from
my
iPhone
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<Dep't of Treasury -Notice of Case

Resolution, August 17, 2015 -
Copy.pdf>
<PFS - First American Bank,
November 9, 2015.pdf>
<2013 S & A Tax Return.pdf>
8
<LS - 2013 W-2's (l).pdf>
<2013 Real Estate & Finance Tax Return.pdf.>
9
Larry Schneider
From: Henry Bolz <[email protected] >

To: Larry Schneider
Cc: Garry Smith ([email protected]); James Berton [email protected]);
Brian Hagan ([email protected]); Frederick M. Snow ([email protected])
Subject: First American Bank HELOC Loan (FCRA)
Attachments: L2 Schneider 11-30-15 FCRA.pdf
Please see attached correspondence of even date.
Regards,
Henry H. Bolz, III

Keller & Bolz, LLP
121 Majorca A venue, #200
Telephone: (305) 529-8500
Telefax: (305) 529-0228
E-mail: hbolz@kellerbo lz.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 T HE E-MAIL TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPYING OF
THIS COMMUN ICATION 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.
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1
KELLER & BoLz
Limited Liability Partnership
JOHN W. KELLER, III* 12 1 MAJORCA AVENUE TELEPHONE (305) 529-8500

HENRY H. BOLZ, III SUITE 200 TELEFAX (305) 529-0228
CORAL GABLES, FL 33 134
SHEYLA MESA WWW.KELLERBOLZ.COM
EMAIL: [email protected]
*Board Certified in
Admiralty & Mariti me Law
November 30, 2015
VIA EMAIL and U.S. MAIL
Laurence Schneider
360 East Coconut Palm Road
Re: First American Bank

October 30, 2015 Email Directed to Brian Hagan (FCRA)
$1 ,500,000.00 HELOC Loan- July 28, 2006
Dear Mr. Schneider:
Keller & Bolz, LLP represents First American Bank ("FAB"). As you know, Bank
of Coral Gables LLC merged into and became FAB in December 2014.
This letter responds to that email which you sent to Brian Hagan at 3:05p.m. on
Friday, October 30, 2015. That email can arguably be viewed as an attempt by you to
dispute directly with FAB, in accordance with 15 U.S.C. § 1681s-2(a)(8) of the
Consumer Credit Protection Part of the Fair Credit Reporting Act ("FCRA"), information
that FAB provided to credit reporting agencies earlier th is year.
In accordance with the FCRA, FAB has conducted an investigation and reviewed
that information in which you provided with respect to the disputed late payment
information you identified. After completing its investigation, FAB communicated with all
of the major/national credit reporting agencies and advised them that all of your past
due payment notices have been reversed, and that you had been making all payments
as agreed. This letter is being timely sent to you in accordance with 15 U.S.C. § 1681 i.
Your November 18, 2015 (7:48 p.m. EST) and November 19, 2015 (4:37 p.m.
EST) emails to Brian Hagan indicate that in addition to "immediately remediating the
reporting errors" (done), FAB needs to "send any letters needed to rectify the harms"
and identifies the Bank United-1 st Fidelity revolving Line of Credit as having been
Mr. Laurence Schneider
November 30, 2015
Page2
Accordingly, FAB considers your inquiry to be overbroad. Pursuant to 12 C.F.R. §

1024.35(g)(1 )(ii), FAB has no obligation to provide you with the information or
documents you request nor with a formal response .
Despite the above-outlined objections, and despite the fact that your October 30,
2015 email was not submitted in conformity with 12 U.S.C. § 2605, and without waiving
its objections, FAB has cond ucted a search for the information wh ich you have
requested. The following documents regarding your referenced account are enclosed:
1. July 28, 2006 Credit Agreement.
2. July 28, 2006 Mortgage (covering the real property located at 17685 Circle
Pond Ct., Boca Raton, FL 33496).
3. July 28, 2006 Disbursement Request and Authorizatio n.
4. Statement of Account for your Home Equity Line of Credit (HELOC)

(encompassing the entire period that Bank of Coral Gables/FAB serviced
your loan) .
The above-referenced Mortgage was duly recorded in the Official Records of Palm
Beach County on July 31, 2006. The original' Mortgage and the original Credit
Agreement are being securely maintained by FAB.
The foregoing documents also reflect that on July 28, 2006, you obtained a
$1 ,500,000.00 HELOC loan which was fully drawn down to its $1 ,500.000.00 limit by
November 21, 2008. The loan has essentially remained ful ly drawn down since
November 21, 2008. You have only been making interest payments on this loan for the
past seven years. The July 28, 2006 Disbursement Request, Credit Agreement and
Mortgage all make it clear that your HELOC has a ten-year term which expires on July
28, 2016 (approximately nine months from now) at which time the attached documents
call for a balloon payment of about $1,500,000.00 (specifically, the outstanding
principal, interest and any changes then due).
To the extent that any statements in your October 30, 2015 email to Brian Hagan
consist of any allegations of wrongdoing of any type or nature by FAB, Bank of Coral
Gables, LLC or otherwise, all such allegations are denied. In providing the above
response, FAB is not limiting or waiving any rights or remedies it may now or hereafter
have whether arising under the loan documents attached, at law or in equity, and all
such rights and remedies are expressly reserved .
November 30, 2015
Page 3
In accordance with 12 U.S.C . § 2505(e)(3), since receipt of your October 30,

2015 QWR, FAB has not provided information regarding any overdue payment owed by
you to any consumer reporting agency.
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 .
HHB/Amh
Encls.
cc: First American Bank
Larry Schneider
From: Henry Bolz <hbolz@ kellerbolz.com>

To: Larry Schneider
Subject: First American Bank HELOC Loan (RESPA)
Attachments: L2 Schneider 11-30-15 RESPA (reduced).pdf
Please see attached correspondence of even date. (This is a second attempt - first email bounced
for being too large).
Regards ,
Henry H. Bo lz, III

Keller & Bolz, LLP
12 1 Maj orca A venue, #200
Telephone: (305) 529-8500
Telefax: (305) 529-0228
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 INT ENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPYING OF
THIS COMMUN ICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS E-MAIL IN ERROR, PLEASE IMMEDIATELY NOTIFY THE SENDER BY
E-MAIL OR TELEPHON E (IF CONTACT INFORMATION IS PROVIDED) AND PERMANENTLY DELETE THE ORIGINAL OR ANY PRINTOUT THEREOF.
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1
KELLER & BoLz
Limired Llabilil:y Partnership
JOHl\ W. KELLER. III' 121 MAJORCA AVENUE TELEPHONE (30.5) .529-8500

HENRY H. BOLl, J[J SUITE 200 TELEPAX (305) 529-0228
CORAL OIIBLES, FL331 34
SIIEYLA MESA WWW.KELLERBOLZ.COM
EMAIL: hbo l 7.@kellc ~bo lz. com
•Bollrd Certified in
Admiralty & Maritime Law
November 30, 2015
VIA EMAIL and U.S. MAIL
Laurence Schneider
360 East Coconut Palm Road
Re: First American Bank

October 30, 2015 Email Directed to Brian Hagan (RESPA)
$1,500,000.00 HELOC Loan- July 28, 2006
Dear Mr. Schneider:
Keller & Bolz, LLP represents First American Bank ("FAB"). As you know, Bank
of Coral Gables, LLC merged into and became FAB in December 2014.
This letter responds to that email which you sent to Brian Hagan at 3:05 p.m. on
Friday, October 30, 2015. Brian Hagan acknowledged the receipt of your October 30,
2015 email with his email back to you at 3:44 p.m. on that same date. This
correspondence constitutes a timely response to your October 30, 2015 email which
purports to constitute a "Qualified Written Request" ("QWR") under the Real Estate
Settlement Procedures Act, 12 U.S.C. §2605.
Your October 30, 2015 email seeks information and documents beyond what is
available through a QWR. No specific date, amount or category of charges are
identified as grounds for your claim that "The amount you [FAB] claim is due for October
is incorrect." Under the applicable law, a servicer must provide information (not
necessarily documents) "relating to the servicing of a loan." 12 U.S.C. § 2605(e){1)(A).
"Servicing" in turn is defined as "receiving any scheduled periodic payments from a
borrower pursuant to the terms of any loan." 12 U.S.C. § 2605(i)(3).
Your requests reach far beyond this statutory scope. Your October 30, 2015
email, for instance, seeks information relating to the origination and validity of the loan
which does not fall within the term "servicing" as defined by 12 U.S.C. § 2605(i)(3).
November 30, 2015
Page 2
affected. Do you still want/need FAB to write to Bank United (or might such a letter now
be unnecessary)? Please let me know.
All further requests for information for documents in any fashion relate to any
complaints or disputes that you might have pursuant to the FCRA should be addressed
to the undersigned at the address on this correspondence.
HHB/cp
cc: First American Bank

Larry Schneider

Sent Wednesday, January 27, 2016 8:37 AM
To: Brian T. Hagan ([email protected])
Subject HELOC
Attachments: Wire to First American $4,500, Janu 25, 2016.pdf
Brian,
I am waiting to get particular information from BSI regarding investor relations and lock box set up.
I had sent a wire on Monday for $4,500 as you requested.
Regards.
Larry Schneider
1st Fidelity Loan Servicing. LLC
Cell (305) 710- 4201
1
Larry Schneider

Sent Monday, January 18, 2016 5:53 PM
To: 'Henry Bolz'
Cc: Garry Smith ([email protected]); James Berton [email protected]); Brian
Hagan ([email protected]); Frederick M. Snow ([email protected]);
Jennifer Walker; Jenn Foster; Helen Chaitman ([email protected]); Lance
Gotthoffer ([email protected])
Subject: RE: First American Bank HELOC Loan (FCRA)
Hey folks,
Here we go again .... I am once again in a predicament regarding obtaining financing due to the ongoing and erroneous
servicing incompetency issues caused by the lack of quality control since First American took over the Bank of Coral
Gables over a year ago . I finally figured out why you continuously send incorrect billing statements and falsely report my
account as delinquent to the credit repositories. I still can't understand why nobody at the bank would take the time to
investigate the account history and review the loan documents. This is despite over thirty (30) communications with
numerous employees and management of the bank regarding the reporting my my HELOC account as late, prior to a
payment actually being due.
My loan was originated on the 281h of a month with a payment due the following month. You are continuing to falsely
and repeatedly report my account as over 30 days late after the 151 of the month.
I was recently made aware ofthese derogatory reporting's
• January 9, 2016
FIRST AMERICAN BANK has flagged your account as Not more than two payments past due (2}.
Alert Date 1/9/2016
Source EQUIFAX
Company FIRST AMERICAN BANK
Payment Status Not more than two payments past due (2)
Status Date 1/1/2016
Balance $1A98,138.00
Balance Date 12/1/2015
Address PO Box 794Eik Grove Village, IL 60009-0794
• January 7, 2016
Alert Date 1/7/2016
Source EXPERIAN
Payment Status 30 Days Past Due
Balance $1,498,138.00
Balance Date N/A
Address 700 BUSSE RDELK GROVE VLG, ll60007-2137
You have caused me some substantial financial problems over the past year, now you've put me in a terrible financial
predicament driven by a February 12, 2016, line in the sand deadline, as I have a balloon mortgage due on my primary
1
residence and this false reporting is the reason for my inability to obtain conventional refinancing. As you are aware,
there is not a blemish on my credit, with the exception of First American' s continued reporting.
Prior to First American acquiring the Bank of Coral Gables, I had a stellar banking relationship with them from the time it
opened its doors in 2006, over eight years.
Once again... I demand that you immediately retract the false reporting of my account from all credit repositories.
I am speaking w ith Brian, in an attempt workout some sort of deal structure, to rectify several issues including the
mortgage referenced above, the problem with the balloon mortgage on my property, which cannot not be rectified in
time to appease the private lender who owns the balloon mortgage on my home (due to the torturous timelines and
verifications pursuant to the new Dodd-Frank provisions) and the collateralized loan from Bank of Coral Gables to S & A
Capital Partners, an entity of mine which also had a great banking relationship with the Bank of Coral Gables including a
collateralized business loan. As you are aware, the collateralized business loan with S & A Capital had been long since
paid off but the Bank of Coral Gables never released the collateral assignment on the Johnnie Washington mortgage. A
title company called First American Bank, and since the First American representative did not recognize the borrowers
name in your system of records, and didn't bother to further research the situation by even looking at the "collateral
Assignment" which provided our company contact info, the First American employee executed a satisfaction ofthe
mortgage and underlying promissory note. The owner walked away from the property without having to pay the
mortgage, which was owned by S & A Capital.
Hopefully, Brian and I can work something out regarding a collateralized business loan, so that we can clean the slate
and start a fresh banking relationship. I'd rather not contemplate the alternative !
Regards,
Larry Schneider
1$'Fidelity Loan Servicing. LLC
290 1 Clint Moore Road, Su ite 4 10
Boca Raton. fL 33496
Cell (305) 710-4 201

Sent: Monday, November 30, 2015 1:40PM
To: Larry Schneider
Cc: Garry Smith ([email protected]); James Berton ([email protected]); Brian Hagan
([email protected]); Frederick M. Snow ([email protected])
Subject: First American Bank HELOC Loan (FCRA)
Please see attached correspondence of even date.
Regards ,
2
Henry H. Bolz, III
Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
IMPORTANT: THIS E·MAIL AND ANY ATTACHMENTS THERETO. IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS
AQDRESSED AND MAY CONTAIN INFORMATION THAT IS LEGALLY PRIVILEGED. CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER
APPLICABLE LAW. IE 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
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3
Larry Schneider

Sent: Tuesday, August 09, 2016 7:15 PM
To: 'BrianT. Hagan'
Subject: 17685 Circle Pond Court
Attachments: S & A Capital v JPMC, Doc 111, Judge Francis Decision on motion to compel, July 14,
2016.pdf; Schneider v JPMorgan Chase, Doc 64, MOTION FOR COMPUANCE WITH
ORDER TO UNSEALCASE AND ENTIRE DOCKET-SC, August 4, 2016.pdf; Schneider v
JPMC 14-01047, Notice of Filing Doc 115, August 5, 2016.pdf
Brian,
I've sent in my financial information as you've requested. It's been well over a month and I have not heard from you or
the Bank.
I have been super busy with my litigation against JPMorgan Chase. We are now in three federal courts and I am going to
make JPMorgan Chase Bank suffer, as they have done so to me and my family. I've attached a recent filing from the
District Court for the Southern District of New York, District Court for the District of Columbia and District Court for the
District of South Carolina, so you can appreciate what I've been up against.
As you know, the cases against JPMorgan Chase Bank N.A. include breach, fraud in the inducement, torts, Civil RICO and
fraud under the Federal and State False Claims Acts.
With that said, my financial resources are limited and the First American Bank has caused me and my entities harms in
obtaining personal and business credit on multiple occasions due to the banks negligent servicing practices, amongst
other prohibited practices, which, as you know include the release and satisfaction of a loan owned by S & A Capital
Partners (similar to some of the same allegations against JPMorgan Chase Bank).
At this point, the harm being caused to my personal credit rating, which also affects my guarantor rating for my entities,
due to the Banks lack of communication and inaction, has brought things to a head. If I do not hear back from the bank
by the end of the week, I intend to file suit for numerous causes of action in the Southern District of Florida. As you
know, you had personally assured me that certain repeated servicing related issues were being resolved and that I
should only be dealing with you, as nobody in the Bank, including customer service could reconcile my account at any
time since the Bank acquired the Bank of Coral Gables. Despite those assurances, the harms continued immediately
despite my communication and cooperation. The harms caused to myself and my entities are calculated at a multiple of
the potential deficiency in the outstanding balance of the mortgage owed to the Bank, less the market value of the
above referenced property.
The one thing I have learned through the past four years of nonstop litigation, is that you do not get anywhere by being
the good guy and hoping things work out. I have no income and no significant assets owned in my name. As you are
aware, the note on the property is in my name only. Rather than work with me to limit the damage to the parties, the
Bank has decided to go a route to cause more harm and frustration. Although I do not have substantial financial
resources, I do have fulltime in house counsel dedicated to exposing fraud and injustice.
As such, I intend to name the Bank and you individually as a defendant in the forthcoming litigation.
Sincerely.
1
Larry Schneider
Cell(305)710-4201
2
Larry Schneider

To: Brian T. Hagan
Subject: RE: 17685 Circle Pond Court, Boca Raton FL
Attachments: Notice From IRS re. 2013 Tax Return, June 20, 2016.pdf; Notice From IRS re. 2014 Tax
Returns.pdf; 2015 S & A Capital Partners W-2 Laurence Schneider.pdf; 2015 W-2 Real
Estate & Finance - Laurence Schneider.pdf; Email With Ms. Goldberg re. No 2016 payroll
year to date, June 30, 2016.pdf; Email With Ms. Paz of PayChex re. No 1st Fidelity
Payroll, June 29, 2016.pdf
Hi Brian,
My apologies for not getting back to you sooner. We've been bombarded with litigation and filings in the ICO case
against JPMorgan Bank N.A.. They have continued to stall and not provide any discovery. We've filed a Motion to
Compel, they filed a Cross Claim Protective Order, we opposed the Protective Order, they filed another reply, without
the courts approval, the court allowed us to file a two page sur reply. Around 1,000 pages of documents in total. We' ll
see how the SDNY Federal Judge rules. I'll send you a few links tomorrow along with the PFS.
As to the PFS, let me first provide you with the following documentation.
1. Proof my 2013 Tax Returns have not been filed.

See Notice From IRS re. 2013 Tax Return, June 20, 2016
2. Proof my 2014 Tax Returns have not been filed.

See Notice From IRS re. 2014 Tax Returns
In regards to my 2015 income, I have attached the following;
1. Attached is my W-2 payroll from S & A Capital Partners showing $40,000 Gross Pay. Note that all of the money
went to taxes. I received $0 cash in pocket. So far year to date 2016 is $0 payroll.
See 2015 S & A Capital Partners W-2 Laurence Schneider

See Email With Ms. Goldberg re. No 2016 payroll year to date, June 30, 2016
2. Attached is my W-2 from Real Estate and Finance Inc showing gross pay of $26,250. So far year to date 2016 is
$0 payroll.
See 2015 W-2 Real Estate & Finance - Laurence Schneider
3. Attached is an email from Sylvia Paz of Paychex, who handles payroll for 1' 1 Fidelity Loan Servicing. I did not
receive any payroll for 2015 and have $0 payroll for year to date 2016. In 2013 and 2014,
See Email With Ms. Paz of PayChex re. No 1st Fidelity Payroll, June 29, 2016,
Thus, my salary for 2015 was $66,250, almost all of which went to federal taxes. I haven't been able to take any salary
this year. In 2013 and 2014, 1 was able to take $250,000 salary in 1st Fidelity alone .. .
1
JPMC has destroyed my business and my life. In confidence, I told you the factors which compelled me to take on this
case against JPMC. I' ll stop at nothing to take them down .... I hope we can amicably part ways so I can direct all of my
efforts towards the pending litigation at hand.
I' ll send you the rest of the info tomorrow.
Regards,
Larry Schneider
1st Fidelity Loan Servicing, LLC
29 0 1 Clint Moore Road, Suite 41 0
Boca Raton. FL 334 96
Cell (305) 710-4201

Sent: Monday, June 13, 2016 2:17PM
To: larry Schneider
Subject: FW: 17685 Circle Pond Court, Boca Raton FL
Larry:
As we understand your tax situation, we will not need tax returns to complete our review. But our folks are
requesting a current Personal Financial Statement. ·
Please complete the attached to the best of your ability and return it to me. Thanks,
Brian
From: Garry Smith

Sent: Monday, June 13,2016 2:09PM
Subject: Personal Financial Statement
Brian,
Here is our personal financial statement.
Thanks,
Garry S. Smith
Senior Vice President

80 Stratford Drive
Bloomingdale, IL 601 08-2219
Phone and Fax (630) 547-8970
2
First American Bank
P.O. Box 0794
Elk Grove Village. IL 60009
www.FirstAmBank.com
lt.iPORTAI'!T INFORMATION
Online Security
First American Bank will never ask you for your personal information. such as your login 10. password, or answers to challenge questions, in an email or any web
page directly linked to an e-mail from us. For more information on how to protect yourself agarnst online fraud, view our Online Security page at
https:J/www.firstambank.com/Generai/Generalln[O/OollneSecurtlv/
Privacy Policy
We do NOT disclose any information about you to anyone, except as permitted by law For more detailed information, view our Privacy Policy at
https://www.firstambank.com/Generai/Generallnfo/PrivacyPolicy/
3
Larry Schneider

Sent Thursday, May 26, 2016 3:32 PM
To: Brian T. Hagan
Subject Re: HELOC
Brian,
I just left you a voice message. Please give me a call so we can determine if there are any avenues of resolution outside
of litigation.
Thanks,
Larry
305-710-4201
Sent from my iPhone
On Feb 19, 2016, at 8:23AM, BrianT. Hagan <[email protected]> wrote:
Larry:
Any news?
Brian
From: Larry Schneider [mailto:[email protected])

Sent: Wednesday, January 27, 2016 8:37AM
To: BrianT. Hagan <[email protected] >
Subject: HELOC
Brian,
I am waiting to get particular information from BSI regarding investor relations and lock box set up.
I had sent a wire on Monday for $4,500 as you requested .
Regards,
Larry Schneider
ln Fidelity Loan Servicing, LLC
Cell (305} 710-4201
1
This email message has been delivered safely and archived online. This email system is managed by DynamiCare E2
Powered by Mimecast
2
Filing # 59196253 E-Filed 07/18/2017 10:13:06 PM
IN THE CIRCUIT COURT OF
THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 502016-CA-009292
DIVISIONAW
FIRST AMERICAN BANK, as

successor by merger to Bank of
Coral Gables, LLC,
Plaintiff,
v.
LAURENCE S. SCHNEIDER,
STEPHANIE L. SCHNEIDER, et al.,
Defendants.
------------------------~'
FINAL JUDGMENT
THIS CAUSE came on before this Court upon the Motion for Summary Judgment
filed by First American Bank which was heard by the Court at a 45-minute specially set
hearing on Monday, June 26, 2017, and the Court, having heard and considered
argument from First American Bank, it is
ORDERED AND ADJUDGED THAT:
1. Judgment is GRANTED in favor of Plaintiff, FIRST AMERICAN BANK, and against
Defendants, LAURENCE S. SCHNEIDER, STEPHANIE L. SCHNEIDER and THE OAKS
AT BOCA RATON PROPERTY OWNERS' ASSOCIATION , INC.
2. Amounts Due. Plaintiff, FIRST AMERICAN BANK, 2295 Galiano Street, Coral
Gables, Florida 33134, is due:
Principal ... ...... .. ... . .... .. ....... .... ..... ... ... ... ... .... .. .. ......... ...... .... . .. ....... ...... . $1,488,554.76
Interest from March 16, 2016 to date of this Judgment .... ... ... . .. .. .. .. .. $69,646.52
Florida Ad Valorem/real property taxes for 2014, 2015 and 2016 .. ... $66,870.93
Total .................................................................................................. $1,625,072.21
That shall bear interest at the rate of 5.05% per year.
3. Lien of Property. Plaintiff, FIRST AMERICAN BANK, holds a lien for the total
sum superior to all claims or estates of Defendants, on the following described property
in Palm Beach County, Florida:
"Lot 37 of the Fox Hill Estates of Boca Raton, according to the Plat thereof,
as recorded in Plat Book 87, Page 4, of the Public Records of Palm Beach
County, Florida."
Commonly known as 17685 Circle Pond Court, Boca Raton , Florida 33496-1002
("Property").
4. Sale of Property. If the total sum with interest at the rate described in Paragraph
2 and all costs accrued subsequent to this Judgment are not paid, the Clerk of this Court
shall sell the Property at public sale on ~~ \ \1 (

2{)11-to the highest bidder for
cash, except as prescribed in Paragraph 5, at the Courthouse located at 205 N. Dixie
Highway in Palm Beach County in West Palm Beach, Florida, in accordance with section
45.031, Florida Statutes (2013), using the following method: By electronic sale beginning
at 10 ·. OONf\ at the prescribed date at https://mypalmbeachclerk.clerkauction.com.

5. Costs. Plaintiff, FIRST AMERICAN BANK, shall advance all subsequent costs of
this action and shall be reimbursed for them by the Clerk if Plaintiff, FIRST AMERICAN
BANK, is not the purchaser of the Property for sale, provided that the purchaser of the
Property for sale shall be responsible for the documentary stamps payable on the
certificate of title. If Plaintiff, FIRST AMERICAN BANK, is the purchaser, the Clerk shall
Page 2 of 4
credit Plaintiffs bid with the total sum with interest and costs accruing subsequent to this
Judgment, or such part of it as is necessary to pay the bid in full.
6. Distribution of Proceeds. On filing the certificate of title the Clerk shall distribute
the proceeds of the sale, so far as they are sufficient, by paying: first, all of Plaintiff's
costs; second, documentary stamps affixed to the certificate; third, Plaintiff's attorneys'
fees; fourth , the total sum due to plaintiff, less the items paid, plus interest at the rate
prescribed in Paragraph 2 from this date to the date of the sale; and by retaining any
remaining amount pending further order of this Court.
7. Right of Redemption/Right of Possession . On filing the certificate of sale,
Defendants and all persons claiming under or against Defendants since the filing of the
Notice of Lis Pendens shall be foreclosed of all estate or claim in the Property and
Defendants' right of redemption as prescribed by section 45.0315, Florida Statutes (2013)
shall be terminated, except as to claims or rights under chapter 718 or chapter 720,
Florida Statutes, if any. Upon the filing of the certificate of title, the persona named on
the certificate of title shall be let into possession of the Property.
8. Attorneys' Fees. The Court finds that Plaintiff, FIRST AMERICAN BANK, is
entitled to reasonable attorneys' fees , costs and expenses incurred in connection with
this action. The Court will retain jurisdiction to determine the total amounts of attorneys'
fees, costs and expenses to which Plaintiff is entitled.
9. Jurisdiction Retained. Jurisdiction of this action is retained to enter further
orders that are proper including , without limitation, a deficiency judgment.
IF THIS PROPERTY IS SOLD AT PUBLIC AUCTION , THERE MAY BE
ADDITIONAL MONEY FROM THE SALE AFTER PAYMENT OF PERSONS WHO ARE
Page 3 of 4
ENTITLED TO BE PAID FROM THE SALE PROCEEDS PURSUANT TO THE FINAL
JUDGMENT.
IF YOU ARE A SUBORDINATE LIENHOLDER CLAIMING A RIGHT TO FUNDS
REMAINING AFTER THE SALE, YOU MUST FILE A CLAIM WITH THE CLERK NO
LATER THAN 60 DAYS AFTER THE SALE. IF YOU FAIL TO FILE A CLAIM, YOU WILL
NOT BE ENTITLED TO ANY REMAINING FUNDS.
DONE AND ORDERED in Chambers in Palm Beach County, Florida on this __
day of_ _ _ _ _ , 2017.
Copies furnished to:
Henry H. Bolz, Ill , Esq.

Keller & Bolz, LLP
Attorneys for First American Bank
Laurence S. Schneider
360 E Coconut Palm Road
Stephanie L. Schneider
JayS. Levin, Esq .

Sachs, Sax, Caplan
Attorneys for The Oaks at Boca Raton Property Owners' Association, Inc.
6111 Broken Sound Parkway, N.W ., #200,
Page 4 of 4
II
t
~
;
~
CASE NO.: 502016-CA-009292
DIVISIONAW
l
i
t
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~~ ;
t
f
~
cc
Coral Gables, LLC, f
Plaintiff, ..~
l
!
~.
v. '~
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STEPHANIE L. SCHNEIDER, et al., l
t'
-
0 Defendants. ~
FINI'' I ~ENT rI
THIS CAUSE came on bef,~ourt upon the Motion for Summary Judgment l
filed by First American Bant"~s heard by the Court at a 45-minute speciallk~t
.., I
,.....,
hearing on Monday, .• ~2017, and the Court, having heard and considi!>rea __,
::::t: :::<.l
~
nm o <-
c::
r-
argument from Fir' n Bank, it is ~~~ :z:
N
e n·
~::X: -;:'J -.J
AJDGED THAT: ~g~ .., m

:X
'
< .....
_..,._"
1~
.1 .. is GRANTED in favor of Plaintiff, FIRST AMERICAN BANK, and ag~t c.a 0
..,:::o 0
r:;J:: en
Defer. ->,LAURENCE S. SCHNEIDER, STEPHANIE L. SCHNEIDER and THE OAKS
AT BOCA RATON PROPERTY OWNERS' ASSOCIATION, INC.

t
~
t·
r
(

t
Principal .... .. ... ............. ..................... ............................................. ..... $1 ,488,554.76
{
!
It
I
t
I
Interest from March 16, 2016 to date of th is Judgment .... .. ............... $69,646.52
Florida Ad Valorem/real property taxes for 2014, 2015 and 2016 ..... $66,870.93
Total .................................................................................................. $1,625,072.21
3. Lien of Property. Plaintiff, FIRST AMERICAN BANK, holds a lien f?L.._"'\ ' total
sum superior to all claims or estates of Defendants, on the following des~.-~erty

in Palm Beach County, Florida: C
"Lot 37 of the Fox Hill Estates of Boca Raton, according •
as recorded in Plat Book 87, Page 4, of the
r ~
Public~ ~aim
.:.d thereof,
Beach
County, Florida." ~ Y
Commonly known as 17685 Circle Pond Cou~~ .aton, Florida 33496-1002
("Property"). ~:~
,.t
4. Sale of Property. If the total su~ ~ est at the rate described in Paragraph f
t
2 and all costs accrued subsequen!.. ~,-'gment are not paid, the Clerk of this Court ~
shall sell the Property at
cash, except as prescribP

public~~
G
~~
Y rap2tlhe
\D Q-C\1, to the highest bidder for
C~urthouse located at 205 N. Dixie

I
t
t
Highway in Palm Be~ ~ .cy in West Palm Beach, Florida, in accordance with section f.
45.031 , FloridK : ~;013}, using the following method: By electronic sale beginning t
r
at\c·.~roe 3 prescribed date at https://mypalmbeachclerk.clerkauction.com.
r
t
this actll:ln and shall be reimbursed for them by the Clerk if Plaintiff, FIRST AMERICAN 1-
l
r
I
Page 2 of 4
I
l

l
6. Distribution of Proceeds. On filing the certificate of title the Clerk shall distribute I
the proceeds of the sale, so far as they are sufficient, by paying: first, all of Plaintiffs
costs; second, documentary stamps affixed to the certificate; third, Plaintiff'~eys'

It
r
fees; fourth, the total sum due to plaintiff, less the items paid, plus inte~ .a rate
fr
prescribed in Paragraph 2 from this date to the date of the sale; p · C .<aining any ~
remaining amount pending further order of this Court. G t
7. Right of Redemption/Right of Possession. ..1e certificate of sale, I

['
Defendants and all persons claiming under or aga~~ants since the filing of the
Notice of Lis Pendens shall be foreclosed
Defendants' right of redemption as presc~ "'~~~~

o~' or claim in the Property and
.. ction 45.0315, Florida Statutes (2013)

I
shall be terminated, except as to ~' ghts under chapter 718 or chapter 720,
Florida Statutes, if any. Upon~~ the certificate of title, the persona named on
the certificate of title shall' ( J ' Y assession of the Property.
8. Attorneys' Fr .c Court finds that Plaintiff, FIRST AMERICAN BANK, is

entttled to rea~ · .•tomeys' fees, costs and expenses incurred in connection with
this actionc ~urt will retain jurisdiction to determine the total amounts of attorneys'
fees .a expenses to which Plaintiff is entitled.
9. ~urisdiction Retained. Jurisdiction of this action is retained to enter further
orders that are proper including, without limitation, a deficiency judgment.
IF THIS PROPERTY IS SOLD AT PUBLIC AUCTION, THERE MAY BE
Page 3 of 4
JUDGMENT.
LATER THAN 60 DAYS AFTER THE SALE. IF YOU FAIL TO FILE A CLAIM, Y/ '.VILL
Laurence S. Schneid',· '·.·;.i'i.;tY.

360 E Coconut Pa' ~~--«; ·
Boca Raton, F~ ~ £· •
.::Jder
aim Road
L 33432
Jay S. L ·vin, Esq.

Sachs, Sax, Caplan
Boca Raton , FL 33487
Page4of4
IN THE CIRCU IT COURT OF
CASE NO. : 502016-CA-009292
DIVISIONAW

Coral Gables, LLC,
Plaintiff,
v.
STEPHANIE L. SCHNEIDER, et al. ,
__________________________
Defendants.
,/
AMENDED FINAL JUDGMENT
THIS CAUSE came before this Court on June 26, 2017 upon Plaintiff's, FIRST
AMERICAN BANK, Motion for Summary Judgment (bearing a Certificate of Service dated
May 25, 2017) and the Court having granted the aforementioned Motion,
IT IS ADJUDGED that:
1. Judgment is GRANTED in favor of Plaintiff, FIRST AMERICAN BANK, and against
Defendant, LAURENCE S. SCHNEIDER.
2. Plaintiff, FIRST AMERICAN BANK, 2295 Galiano Street, Coral Gables, Florida
33134, recover from Defendant, LAURENCE S. SCHNEIDER, 360 E Coconut Palm Road
Boca Raton, FL 33432, Social Security No. XXX-XX-1358, the sum of $1 ,625,072.21 ,
which shall bear interest at the rate of 5.05% per year, for which let execution issue.
3. The Court finds that Plaintiff, FIRST AMERICAN BANK, is entitled to reasonable
attorneys' fees, costs and expenses incurred in connection with this action. The Court
will retain jurisdiction to determine the total amounts of attorneys' fees, costs and
expenses to which Plaintiff is entitled.
ORDERED in Chambers in Palm Beach County, Florida on this so day of_ _
r Circuit CourtJu
Henry H. Bolz, Ill, Esq.

Keller & Bolz, LLP
Attorneys for First American Bank
Jay S. Levin, Esq.

Sachs, Sax, Caplan
Attorneys for The Oaks at Boca Raton Property Owners' Association , Inc.
Page 2 of 2
Filing # 59196253 E-Filed 07/18/2017 10:13:06 PM
EXHIBIT D
II
t
~
;
~
CASE NO.: 502016-CA-009292
DIVISIONAW
l
i
t
l
~~ ;
t
f
~
cc
Coral Gables, LLC, f
Plaintiff, ..~
l
!
~.
v. '~
t
t
STEPHANIE L. SCHNEIDER, et al., l
t'
-
0 Defendants. ~
FINI'' I ~ENT rI
THIS CAUSE came on bef,~ourt upon the Motion for Summary Judgment l
filed by First American Bant"~s heard by the Court at a 45-minute speciallk~t
.., I
,.....,
hearing on Monday, .• ~2017, and the Court, having heard and considi!>rea __,
::::t: :::<.l
~
nm o <-
c::
r-
argument from Fir' n Bank, it is ~~~ :z:
N
e n·
~::X: -;:'J -.J
AJDGED THAT: ~g~ .., m

:X
'
< .....
_..,._"
1~
.1 .. is GRANTED in favor of Plaintiff, FIRST AMERICAN BANK, and ag~t c.a 0
..,:::o 0
r:;J:: en
Defer. ->,LAURENCE S. SCHNEIDER, STEPHANIE L. SCHNEIDER and THE OAKS
AT BOCA RATON PROPERTY OWNERS' ASSOCIATION, INC.

t
~
t·
r
(

t
Principal .... .. ... ............. ..................... ............................................. ..... $1 ,488,554.76
{
!
It
I
t
I
Interest from March 16, 2016 to date of th is Judgment .... .. ............... $69,646.52
Florida Ad Valorem/real property taxes for 2014, 2015 and 2016 ..... $66,870.93
Total .................................................................................................. $1,625,072.21
3. Lien of Property. Plaintiff, FIRST AMERICAN BANK, holds a lien f?L.._"'\ ' total
sum superior to all claims or estates of Defendants, on the following des~.-~erty

in Palm Beach County, Florida: C
"Lot 37 of the Fox Hill Estates of Boca Raton, according •
as recorded in Plat Book 87, Page 4, of the
r ~
Public~ ~aim
.:.d thereof,
Beach
County, Florida." ~ Y
Commonly known as 17685 Circle Pond Cou~~ .aton, Florida 33496-1002
("Property"). ~:~
,.t
4. Sale of Property. If the total su~ ~ est at the rate described in Paragraph f
t
2 and all costs accrued subsequen!.. ~,-'gment are not paid, the Clerk of this Court ~
shall sell the Property at
cash, except as prescribP

public~~
G
~~
Y rap2tlhe
\D Q-C\1, to the highest bidder for
C~urthouse located at 205 N. Dixie

I
t
t
Highway in Palm Be~ ~ .cy in West Palm Beach, Florida, in accordance with section f.
45.031 , FloridK : ~;013}, using the following method: By electronic sale beginning t
r
at\c·.~roe 3 prescribed date at https://mypalmbeachclerk.clerkauction.com.
r
t
this actll:ln and shall be reimbursed for them by the Clerk if Plaintiff, FIRST AMERICAN 1-
l
r
I
Page 2 of 4
I
l

l
6. Distribution of Proceeds. On filing the certificate of title the Clerk shall distribute I
the proceeds of the sale, so far as they are sufficient, by paying: first, all of Plaintiffs
costs; second, documentary stamps affixed to the certificate; third, Plaintiff'~eys'

It
r
fees; fourth, the total sum due to plaintiff, less the items paid, plus inte~ .a rate
fr
prescribed in Paragraph 2 from this date to the date of the sale; p · C .<aining any ~
remaining amount pending further order of this Court. G t
7. Right of Redemption/Right of Possession. ..1e certificate of sale, I

['
Defendants and all persons claiming under or aga~~ants since the filing of the
Notice of Lis Pendens shall be foreclosed
Defendants' right of redemption as presc~ "'~~~~

o~' or claim in the Property and
.. ction 45.0315, Florida Statutes (2013)

I
shall be terminated, except as to ~' ghts under chapter 718 or chapter 720,
Florida Statutes, if any. Upon~~ the certificate of title, the persona named on
the certificate of title shall' ( J ' Y assession of the Property.
8. Attorneys' Fr .c Court finds that Plaintiff, FIRST AMERICAN BANK, is

entttled to rea~ · .•tomeys' fees, costs and expenses incurred in connection with
this actionc ~urt will retain jurisdiction to determine the total amounts of attorneys'
fees .a expenses to which Plaintiff is entitled.
9. ~urisdiction Retained. Jurisdiction of this action is retained to enter further
orders that are proper including, without limitation, a deficiency judgment.
IF THIS PROPERTY IS SOLD AT PUBLIC AUCTION, THERE MAY BE
Page 3 of 4
JUDGMENT.
LATER THAN 60 DAYS AFTER THE SALE. IF YOU FAIL TO FILE A CLAIM, Y/ '.VILL
Laurence S. Schneid',· '·.·;.i'i.;tY.

360 E Coconut Pa' ~~--«; ·
Boca Raton, F~ ~ £· •
.::Jder
aim Road
L 33432
Jay S. L ·vin, Esq.

Sachs, Sax, Caplan
Boca Raton , FL 33487
Page4of4
Filing # 59196253 E-Filed 07/18/2017 10:13:06 PM
EXHIBITE
-- - - TFolnier AdchM
- ___ _L _ -·- - -- -- 1
650
Crcd1t H1story
Summary
PMI Due 1'8jt!MIIl
$3,882 $2,617
Bllln:e
$481,182
111111108
$70,078
Paymsnt (1111.) llllaiiCIII

$302 $18,630
II .
~ experian
•
Credit Report Prepared For.
LALRE~C:: S SC...,NEIDER
Experian Report As Of Apr 3, 2017
Personal & Confidential

LAURENCE S SCHNEIDER Experian
Date of Report: Apr 3, 2017
...
~experian.
COl
FIRST AMERJCAN BANK

Open
ACCOUNT DETAILS CREDIT USAGE
e
Account Name FIRST AMERICAN BANK High Credit Usage
Keeping your account balances as low as possible can
Account # 4000XXXX
have a positive impact on your credit.
Account Status Open
Last Updated Mar3, 2017

CONTACT INFORMATION
Account Type Home Equity Line Of Credit - Revolving Terms
700 BUSSERD
Date Opened Jul1 , 2006 ELK GROVE VLG, IL 60007
{847} 228-9300
Balance $1,708,894
PAYMENT HISTORY
Credit Limit $1,500,000
2ln7 2116 20'15
Monthly Payment $4,698 Jan Feb Mar Apr Jan Feb Mar Apr Jan Feb Mar Apr
Past Due Amount $1,680,998 ~~~D G2)~~~ ~~~~

May Jun Jul Aug May Jun Jul Aug May Jun Jul Aug
Payment Status Past due 180 days DODO

Sep Oct Nov Dec
~~~~ ~~~~
Sep Oct Nov Dec Sep Oct Nov Dec
Highest Balance $1,708,894 DODO ~~~~ ~~~~

2114 2011 21112
Terms Revolving Jan Feb Mar Apr Jan Feb Mar Apr Jan Feb Mar Apr
Responsibility Individual ~~~~ ~~~~ ~~~~

May Jun Jul Aug May Jun Jul Aug May Jun Jul Aug
Comments [i)~~~ li]G!)~~ ~~li]~

Sep Oct Nov Dec Sep Oct Nov Dec 5ep Oct Nov Dec
~~~~ ~~~~ ~~~~

20'11 21110
Jan Feb Mar Apr Jan Feb Mar Apr
~~~~ ODD~
May Jun Jul Aug May Jun Jul Aug
~~~~ ~~~~
Sep Oct Nov Dec Sep Oct Nov Dec
~~~~ ~~~~
sumn1ary Accounts (Open) Collections Inquiries Public Records Credit Score

Credit Report Prepared For:
LAWRENCE S SCHNEIDER
Equifax Report As Of: Apr 3, 2017
Personal & Confidential

lAWRENCE S SCHNEIDER - Equifax
Date of Report Apr 3, 2017
FIRST AMERICAN BANK

A 4l'AIOXXXX
Open
ACCOUNT DETAILS CREDIT USAGE
Account Name FIRST AMERICAN BANK
8
High Credit Usage
Keeping your account balances as low as possible can
Account# 4000XXXX
have a positive impact on your credit.
Account Status Open
Last Updated Mar3, 2017

CONTACT INFORMATION
Account Type
700 BUSSE HIGHWAY
Date Opened Jul 28, 2006 ELK GROVE VILLAGE, IL 60007
(847) 952-3700
Balance $1,708,894
...
PAYMENT HISTORY
Credit Umit $1,500,000
21117 2111i
Monthly Payment $4,698 Jan Feb Mar Apt Jan Feb Mar Apt Jan Feb Mar l>f>r
Past Due Amount $1,680,998 ~~DO ~~~H~~ ~~~[2;)

May Jun Jut Aug May Jun Jul Aug May Jun Jul Aug
Payment Status At least 120 days or more than four payments past due DODO
Dec
Sep Oct Nov
~~~~ ~~~~
scp Oct Nov Dec Sep Oct Nov Dec
Highest Balance
Terms
$1,539,165
M
DODO
21n4
Jan Feb Mar Apr
~§)§)§) DO~~
...
~~~~ ~~~~
Jan Feb Mar Apr
Responsibility Individual Account

May Jun Jut Aug May Jun Jul Aug
Comments ,VARIABLE RATE ~~~~ ~~~~

sep Oct Nov Dec sep Oct Nov Dec
~~~~ ~ ~~~
Summary Accounts (Open) Collections Inquiries Public Records Credit Score

• •
•
•• •
To ensure
security of your Experian Credit Tracker5111 account, some of your personal information below
cannot be updated through the Edit Profile page. If you would like to make updates to any of the
information, please contact customer care.
Personal Information
Name
Laurence Schneider
Mother's maiden name
*********
Membership ID #
340909994
Please have your Membership ID# number handy when you call customer support.
Username
Your username should be between 6-35 characters and may not contain spaces.
Username:
11arryschneider1
Update
Password
Please choose a password that is 8 to 35 characters. Your Password may not contain spaces and the
following characters: < > " ' · %
Current Password* Update
New Password*
Security Question
Balance $1,496,266.00
Balance N/A
Date
Address 700 BUSSE RDELK GROVE VLG, IL
60007-2137
May 23, 2015

FIRST AMERICAN BANK has flagged your
account as 30 Days Past Due.
Alert Date 5/23/2015

Source EXPERIAN
Payment 30 Days Past Due
Status
Status 5/4/2015
Date
Balance $1 ,498,729.00
Balance N/A
Date
Address 700 BUSSE RDELK GROVE VLG , IL
60007-2137
May 9, 2015
account as Not more than two payments
past due (2).
Alert Date 5/9/2015

Source EQUIFAX
Payment Not more than two payments past
Status due (2)
Balance $1,498,729.00
Balance 5/ 1/2015
Date
Address PO Box 794Eik Grove Village, IL
60009-0794
Balance $1,498,138.00
Balance 12/1/2015
Date

60009-0794
January 7, 2016
Alert Date 1/7/2016

Source EXPERIAN
Status
Status 1/4/2016
Date
Balance $1,498,138.00
Balance N/A
Date
60007-2137
September 11 , 2015
past due (2).

Source EQUIFAX
Status due (2}
Balance $1 ,496,266.00
Balance 8/1/2015
Date
60009-0794
September 10, 2015

AlertDate 9/10/2015
Source EXPERIAN
Status
Status 9/4/2015
Date
August 9, 2016

Alert Date 8/9/2016

Source EXPERIAN
Status
Status 8/4/2016
Date
Balance $1,552,984.00
Balance N/A
Date
60007-2137
July 14, 2016

account as Not more than three payments
past due (3).

Source EQUIFAX
Payment Not more than three payments past
Status due (3)
Balance $1,548,229.00
Balance 5/1/2016
Date
60009-0794
January 9, 2016
past due (2).
Alert Date 1/9/2016

Source EQUIFAX
Status due (2)
Your security question and answer will give
• •• J an added layer of protection in
• ::essing your Experian Credit Tracker
•• • :ount. If you'd like to change your
--..lHity question and answer, please select
from below.
Current Question:
What street did you grow up on?
Update
©20 7C
Ov w Ab tU c tU
1i &C dt Pv y P iy
Ad i gtgP i y G y FAQ
~
~
.
EC{UIFAX
CREDIT FILE : May 18, 2017
Confirmation # _ . 6 5 8 CJwr-oo ~:u
OCI>t»08
nO:E"'g
D> ITl.,j;\ Ol ~0
::0 w O>._
U ':: ,\1 L.::.wrence S Schneider:
:uo;oo ~ ~OJ
cg~~~ C>~
v'v·": cW~ pl&ascd to let you kno\'\' that the resu~ts of the disput1:1 you recently filed with Equifax are complete. Here are a )>-
1·,_,-.. tl'fn!JS to know about the process: ?Q<nCfg
-n =(/)
0., 6
,--n > ~~
c.,.;o<r-
...e~s~ ~ A-
Were changes made to my credit report and what actions were taken? r;r-CXl
~~
c.>='Cl.
"' ::j
Pleas.e see the following page(s) for more detailed information on your specific re::ults. :\) ::0 (1) -
~Q_""" ~
<0 c.>
II we were able to make changes to your credit report based oP the information you provided, we have done so
Otherwrse. we contacted the company reporting the infonnation to Equifax for thc11 to in•.'estlgatc your dispute.
~
01
0
In Uus situation: =:
We request that the reporting company verify the accuracy cf the information you disputed: ~
0
0
We provide them with any relevant information and supporting documentation you provided us with the
dispute to consrder as part of the inve$1iga1ion: and
We request that they send Equifax a response to your dispute and update their records and systems.
as necessary.
If your dispute involves a public record item. Equifax contacts a third party vendor to obtain the most recent status of
the public record.
How do I know that all of this is happening?

When the reporting company replies to us, they certitJ that they have followed Equitax's instructions and the law:
considered all information and documentation provided: and updated your rnformation. as necessary
What should I do If! do not agree with the results of the investigation?
You have a few options:
You may add a statement of up to 100 words (200 words for Maine residents) to your credit report. If you orovide a consumer statement that contains
medical information related to sel\lices provided or medical procedures, then you expressly consent to including this informatton in every credit report we
issue about you.
You may contact the company that reports the information to us and dispute it directly with them. If you would like written proof about your accounts (such
as the original agreement). please contact you,r creditors directly.
You may provide us additional information or documents (such as an identity theft report or a letter from the reporting company) about your dispute to help
us resclve it by visiting our website https://www.ai.equitax.com/Creditlnvestigation/home.action. You may also ma!l yoUI documents to PO Box 740256.
Atlanta GA 30348 or contact us by calling a Customer Representative at ~888) 425-7961 from 9:00a.m . to 5:00p.m. Mor.day ·Friday in your time zone.
You may contact tht Consumer Fman cial Protection Bureau or your State Attorney General's office about your issue or co!71pla•nt against Equitax or the
company re;portlng the tl\fomlatlon.
1 Continued On '<e):! Page ) Page 1 of 6 7131056658ADPLADM·002568653- 4074 · 11461
- --
What else should I know?
11 there lias be1:1n a change to your credit report based on your dispute. or if you add a consumer statement. you may request that Equifax send an updated report to
compe~nies who received your credit report within the last two years for employment purposes. or within the last six months for any other purpose (the past 12
n·,<~rnt. s lor residents of California, Colorado, Maryland. New York and New Jersey restdent:>}.
At'::.(,. cf you are interested. you may request a description of how the reinvestigation was conducted along with the business name, address and telephone number
· ·' 'E:C'l':>Oth"\bly avatlable) of the furnisher of your disputed information . •
i="or tlequenlly asked questions about your credit report and the dispute process, please vi sit Equifax at https://help.equifax.com/
As always. we thank you for contacting Equifax and the results of your dispute a~ on the pages following this letter
i Continued On Next Page ) Page 2 of 6 7131056658APPLADM·002568653- 4074 - 1146i ·

iow should I read my dispute results'?
·o bettt?r asstst you with understanding the results of your dispute. plea se review the infonnation below:
• <
.
If an ttem states "Deleted". we have removed it from your credit report and taken steps so it does not reappea r.
If an atem states '' Verified as Reported". the repo rting company has certifed it is repo rting accurately.
II an ttem states "Updated". we have updated one or more fields on the item based on informatton rece ived from the reporting c~mpany .
fil6 ·Results Of Our Reinvestigation

·>> We have reviewed your concerns and our conclusions are:
\t thts ttme. no creditor received your Equifax credit file in the past 6 month~: ther(;fore . a revised credit file Can not be sent.
Credit Account lnfonnation

(Fer your 110curity, the 111111 4 digts of .ccount numbM(s) have been rsplaced by 1 (Tht. section incJude5 open and clostJd accounts reported by credit grantors)
Account History 1 : 30·59 Days Past Due 5 : 150-179 Days Past Due J Voluntary Surrender
2 : 60-89 Days Past Due 6 · 180 N More Days Past Due K Repossession
Status Code 3 : 90-1 19 Days Past Due G : Collection Accoun t L Charge Off
Descriptions 4 : 120-149 Days Past Due H : Foredosure
·>> We have researched the credit account Account# - 40oo• The results are: Historical account information was updated on thrs account. This account has
·e en updated. The p rior paying history on this account has been updated. If you have additronal questions about this item please contaci: First American Bank,
'0 Box 794, Elk Grove Village IL 60009-0794
First American Bank PO Box 794 Elk Grove Viliago IL 60009-0794
~ttlu """" Oone~ened H.qn .:aeom1 C'.t~'lt.,. l : etl1':~ ;:t.:ralt'ln Teur. s Fre::JUeMy Month~ Mevd At.!t\'11)' Ue~t~o:d.,. Cfecit:r- Cias!.i1Jc<lt.-or
ooo· 0710112006 $1.549.143 $1.500.000 Mon :~h' 49
!nl"- A~ o' ti&:.Jru:v Atr.a.nt ::kite- :or A.!r... c1- .&~edulrl ;.ll :e :>t h ! r...,:! : • n.~tr ~l:.. . :;...,:.=~ C tt l:"'k:H4<1 F., ea1 •.,.,.. : "' B.>r:~:r. !;'.v~
l1f• Rf:nr t~ Am~ ·,• Pl\'!:! W e t..~t~J ~cr..oMnl J..;wrr;r..l A'Oo;.::: f ' 1t&V"Nit A...,o .., r t , lef.., ..J\It r :v l m l A.c!N1tv Del. H: ~ td A1't\:;vr ' St,"f tO(I.t't" An aOlll'l' fJ<N i:.ure Ct".Jt.ed
5 118 '21)17 51 .756.754 $1 .7~8 .596 04/201'.:' S>v S29.i02 05/201€ SO $0
w:.;~~ · Over 120 Days Pa~t !)uer: TypEr of Account · Lmo:: ot CreCiit. Type of Loan · Hc•me Equity L1nt: 01 Credit: Wnose: Ac;;ount - lndivtdual Account: ADD ITIONAL INFORMATJO'..; -
~ " . .~• •~': U !'}' Lean : 180 Davs or ~ ore Past Due: Variable 'Adjustable Rate :
.-.count Hictorv rl4'20l i OJI20 t .' 0~211 11 0 1'2rt1? 12 :>t.J ii 11 '2<.111; 102111·: <.9'2016 08·'201 6 r;;· ,'()16 00((116 05.'~!11 5 01'2016
11h Status Codes 6 6 €. 6 6 6 6 5 4 3 2 1 1
i l!\l')r1ca1 Account rn1o•m.;,t o,., J
:it
l ·'
Ij
Amour.!
Past
i 1ype o f
ILoa"\
1
1Acti\ity
De:s:gnator
I
.
1 Due ! I
~:,71 $ 1.73a .s9E> I$4.698 i 1 4. 1 ;20 ~ 6 i $ 1 .543 .sq~ 1$1.soo .ooo
----~--------~------------------------------~--------~
31171 $1 .70&.894 $.4 698
?11 7 I $1 .680 .998 $4 .1398 i 4/1/20t6 I51.534 .3G3 !$1.500.0CO I$() !Home Equa~y L1nEj Of Cred!l I --·- 1
=====T======~================- . - ~
ii171 $1.1>55.163 I$4 .698 I 14!1.'20 16 j S1.52B.251 j ~ 1~5(•0.000
; i O ~ !"iome Eqlllty Line: 0! Crea:1 1 I
:::o!'ltlnued Of' Ne xt Page 1 Page 3 of 6 7131056658APPLADM-002568653- 4074 • 1 •
H1sturical Account Information I
Balance Scheduled Actual Date of H1gh Credit Amount Type of Activity
Payment Payment Last Credit Limit Past Loan Designator
Amount Amount Payment Due
' 12 lE' $1 .603.916 $4.698 4/1/2016 $1.524.760 $1.500.000 $0 Home Equity Line Of Credit
'----
G -:-~6 ~ s1 .597.4?6 $4 .698 ( 411 /2016 $1,!'20.268 $ 1,500.000 $0 Home Equity Lin& Of Credit .
I_ .,_
r,o.," 1st.650.437 i S4.698 I
4/1 /20 16 $1 .590.314 I $1.50C,OOO $0 Home EqUity Lme Of Credit
r~ ...... . . ·- -
! O!.l H) S.1 .55 7 .3&3 $4,698 4•1/2016 !$1.511.23!:> S1 .500.000 so ~ome Equ1ty Line Of Credit
$~
1
.552.984 I $4.698 1 1 1
51.506.8~~13 f'S1.5<'0.ooo ls;o Irome Eq~;1ty Line 01 Credit 1 ==1
$4,698 $1 .502.977 $1 .50C .OOO lso I Home Equity ~ine Of Crer.i1t
I
r=-:-;-r;:--
06t16 $1.543.581 1$4.69s I 14/1 /2016 1$1.502 .977 l$1 ,500 .000 I
I I Home Equity Line Of Credit l'

-
05/16,$1.493.446 ,$4.698 : $4.500 14/112016 1$1 .502.977 1s1 .soc .ooo I IHome Equitv L1ne a. Cred1t
I I -
04/16l $1.493.248 l$4 .277 1$4.Soo 13,1i2C 16 1$1.502.977 1s i.E>Oo .ouo I IHor.e E~uity Line Of Credit I
031161$1 .493.470 1$2.647 1211/2016 J$1.502.977 I $1 .soo .ooo I !Home Eauity Line Of Credit J
1$4 .5oo
-
02/161$1 .493.853 l $3.029 J$9.300 jt /1.'20 16 l $1.502.977 1s· .soo ooo J IHome Equity Line 0! Credit i
.0 1 '161 $1.498.138 J$3.731) I 11111/2015 1$1 .502.977 i$1.500.000 J$0 JHome Equity Line Of Credrt l
:~ 2 151$1.494.554 1$3.730 1$4.soo 111 /1/2015 I$1.502.977 IS1 .500.0GO j IHome Equity line Of Cred1t I
11 i1 51 $1.494.646 1$3.823 1$4.646 j t Otl/2015 1$1.502.977 1s1.5o~.ooo i IHome Equity Line Of Credit I
10/151 $1 .495.469 1$2.517 I $3.983 ,, 0/1/2015 1s1 .so2.9n 1s1.soo.ooo !so IHome Equity Line Of Credit 1
o9i15 1$1.496.266 l $3.982 J s4.298 [at112o 15 1$1.502.977 ' $1 .500 .000 1$0 jH ome Equity line 01 Credit
I
08/151 51,494 .806 1$3.982 1$4.ose J711/2015 J$1.502,977 1$1 .soo.ooo I .lHome Equtty line Of Credit I
- - - - -- - --~ · -
\ Continued On Next Page 1 Page 4 of 6 713 ',056658APPLADM-002568653- 4074 - >1461 ·

~
~
CREDIT FILE: May 18,2017 Confirmation# 7131056658
. ~
I 1-l >tor,ca! Account informabon
i i S.?!orce
I
I Sched~;led
1 Payment
\Actual
Payment
Date of
Last
H1gt1
Credit
ICredit
Limit
1Amou:1t
PaH
I Type ot
! Loan
ActJvity
Oestgnator
I I Amou!"t Al':'lount Payment Due I
l • l 1~ i$1.4~4.879 1$4.oss 1$4.248 6t1120t5 $t.50~ .977 IS1 .500.000 I !Home Equity Line Of Credit
IS1.50J.00(! -
i •.it · '5 ~ S 1 .4SI~ 4S6 1s.4.42' ! $7.700
I
15 11 /2015 1$1.503.157 ! [ Home Equity Line Of Cred1t L_.__ I
·--.,..--
(•'i ·!, 1 s: 49e.729 $3.584 [3.1/?.015 l$1.499.733 ! S~.501,0Cl0 SO Home Equity Lir.e Of Credit
Notice to Consumers
You may request a description of the procedure used to determine the accu~nd completeness of the infonnation, inclUding the business name and address of
the fumrsher of information contacted. and it reasonably available the telephone number.
If the reinvestigation does not resot11e your dispute. you have the right to add a statement to vour credit file disputing the accuracy or completeness of the
infonnation: the statement should be bnef and may be limited to not more than one hundred ·words {two hundred words for Maine reSidents) explaining the nature of
your d1spute.
If the reinvestigation results in the deletion of disputed infonnation. or you submit a statement in accordance with the preceding paragraph, you have the right to
reauest that we send your revised credit file to any company specifican~· designated by you that received your credit report in the past SIX months (twelve months for
California. Colorado. Maryland. New Jersey and New York reSiden!s) for any purpose or in th(; past two years for employment purposes.
t Coo11nued On Next Page ., Page 5 of 6 7131056658APPLADM-Q02568653· 4074 11461

..::0
Q.
£
0
~
c
lLJ
Name(&) assoCiated with your 'redlt
Name ldentillc:atlon number
I.AUfU:NCE S SCHNEIDER 20512
l.AUREHCE SCHNEIDER 4718
Sc.INEIDER LAURENCE 26213
LAWU:Na: S SCHNEIDER
LARRY 6 SCHIEDER 13043
I.AUREHCf C SC~EIDER 19183
LAUREHCE SCHNELDER
LARRY SCHNEIDER 28838
LAURENCE 6 SHNEUER 4783
Addr-(ea) .ssoclated With your cradlt

Adclt-
ldenUftciUon Rea*nce IYI'I GeogfllphiCal code
number
2901 CUNT MOORE RD t410 SOCA RATON Fl 0610766210 AparitMnt eomplu 0-7006~880
:s:MIIW041
360 E COCONUT PALM RD BOCA RATON FL 00742741)23 Single famrly 0-750340-&8-Si&O
33432-7818
Sl.t.moly G-750340-8N880
Smgle famly G-750340-&W960
S1ngle famoly G-77<4310-9Ntll0
Single ramify ~20-ee.&IIIIO
Multlr-lly 0-700S1~
2101 NN CORPORATE BLVD STE320 IOCA 00742421113 Mul1lltmiiY G-70081CHI&-eaaD

RATON A. :s:M$1-7311
FL 0074208113 Singlllfamil)l G-778030-BNMO
21 G1 ~·FL 00762SS.67 MuldtlmUy 0-700111~

35431-~
007J202378 Poet office box 0-~
0072.988104 S~{amily o-&702~
Stngletamoly 0-9702~
Mulll*nUy G-1111o.aa-
Single fwnlly l)o0().0.5000
Apartmenl ccmpi6X o-, 21).18 5000

Multit8mliy 0.11120-M-
~="
2300 GIRAI.JlA E CIR APT2.04 PALM BEACH 007402$083

GARDENS FL 33410<5349
2101106lA SAUNAS ctR BOCA RATON Fl 058311114079 Single family Oo004-
3a428
Other per.onal anformatlon a..ociated with your CRdit
SOGIII Stcu~ numbtr Vlrllllon(l)
XXX·XX-1358
Yearofbhth
STEPHANIE
SA CAPITAL PARTNERS
SA CAPITAL PARTNeRS
HEAVENLY f'ROPERTIESGRAN
HEAVEI'LY PROPERTIES INC
Notieea
This 8ddrt$t 11M l*t8inld to a buslnoN. 3eO E COCONUT PAW RD BOCA AATOl<l FL 3M32
Account nlml
BANK OF AMERICA, tt.A
4801 SAVAReSE CIR

'!).MPA, FL ms.
800888M07
Add,... identlflcai!IICI number
-~tp;;;;~ Stl'lfillt:IOLR"- - -- -- - --- - - - - -- - - , -
a/IIOI.Wit
No! .-.ported
Account history
.201t 1011 2011
~~--~-~~~~~~---~M~~~~-~~~~
2010 2009
-~-~~-~-~~~~----~~~~~~-~·
~nt1111110 Account number Rec:ant .,.nc. Date opened

FIRST AMERICAN BANI< -4000 -· $1,110,998 .. of 07/2008
021D3/2017
700BUSSERO 'J'ipt c..dit ti..lt or Daet of tta!UJ

Ell( GROVE VLG, IL 110007 Home E(lUity original amount 1012018
.-.
&472.218300
Aclctr... identiflc:.don lllltllbef
Tlllfml
NA
11,500 000
High bllanc.
l1,11e0.81111
llomhly ptyment
$4.891
~tpqment
Flnt reportld
0812008
Responsibility
ln~cMI
amount
so
AccountlllltDIY
.... ...,
2017
-....
2011
o.c ,.... Ocl a.,
.... """ ..., ...
...... .1<11 Jt.ll Uoy
..
""'
.... ....
-- ..
~ .on Doc
....
2ct11
'low Oct So p • ..;
...... ..., .....

""'
...,
J• n
- -
u.., Apr
,.,
1'411 .w>
....
- --
1014
J.... ~ ,, , 201~
coo o.a eo, Apr Jon
l~12
:lee
Doc Ocl
""'' ,... ,.., ,.,
~ Aut ~ .IIIII Mlf IW ~... J:<l
2011
Doc ~ .a.; ~ :an Dot
21110
Nil• Oc' Sep
...... .ad .bl ...1 AP' ....

180 cllya pat u aa of Oct 201e to Fib 2011
1!0 - · PMt clue aa of Sep 2016
120 dllya paat due aa of Aug2018
eo days put due- of JIJI 2016, Jun 2018
30 dtye put due • of May 2018. Jen 2011
.....,..hi•IIIHy
The fol~ dlla will...-., lnl falo'Mng fcxmlll·
Olle. e=ount t.lenoe/ dMe payment raceived I scheduled ~ymtlll emount /actual smauntl)llld
Jen 2017; $1 ,114!, 113 I A(Jif 0$. 2014/ $4,«1111 No dlla
0.0 2011 11.403.911 I Afll 08. 2016 I 14,8981 No dll8
New 2018. 11,517,428/ Atx OS. 2018/ 14,e88 I No dlta
Oet 2016; $1,660,417 I Atx 08, 2018 I 14,1188/ No dl&a
IMp 201e. 11,557,3M/. OS. 2016/S.UNI Nodlta
Aug 2016: $1,U2..8M/ Nit OS, 2018 I 14,&1181 No elite
Jlll2018. $1,542211 I . 01, ~18 I I4,8NI No dllta
Jun 2016. $1,$43,561/ A(Jif 0$, 2018/14,081/ No datil
- 2015: 11.8,448/ Nit 011, 2018/14,888114,500
A(Jif 2018: $1,483,W I Ma' 16. 2011 /S.U77/14,SOO
M.- 2018. $1,413,470 I Feb 17, 2016 I Q.M7 I $4.500
Feb 2018: SU83,16S I Jen 25, 2018 I t3.02S I S8,300
Jen 201G: 11.41N1,1311 Nov %7,2015/18,7301 Ha dala
Dec 2015; ~1.-4M,6S41 Nov %7. 201! 113,730/14.600
Nov 2:015 S1,4M,6415 I Oct 50, 20\5113,123/14,846
Oct 2015: S1,41S,41i I Oct 01, .2015 I 12,$17/SUU
8ep lll01fi: 11.486,285 I Au; 31, 20151 $3,882/ 14,298
Aug lll015' $1,414,1011/ J .. 15. 20,5/$3,182114.0118
J" 2015. S1,48U7i/ Jwa 10, 2018 I 14,0&6114.248
Jun 2015: 11,495.457 I Mlri 28, 2015/13,5&4/ No data
/liJI2015: IUM.813/ M• 08. 1015/ 515&41 $4.24&
u. 2015: S1,485,m 1Jan 30, 2015/ M.24e 1No data
Feb 2015· S1,4111,02SII Jen SO, 2015 I $U50 I $7,985
8etw~en Fib 2015 and J1111 211!7, vaur e..clit limit/high blltnc:e WM $1,500,000
Filing # 59196253 E-Filed 07/18/2017 10:13:06 PM
EXHIBIT F
jJBK09 {LN2300 )M~~,
F!~ American Bank
P.O Boll 0794, Elk Grove Village, Illinois 60009·Q794
Customer Service· 1-847-952-3700 5/01/2015
Toll Free. 1-855-690-2~10
£mall. Ciel\[email protected]
NOTICE OF PAYMENT 30 DAYS PAST DUE
Laurence Schneider
1199 South Federal Highway Suite 36
Boca Raton FL 33496
Your account is past due for the Total Amount Due shown below. In
accordance with your loan a~eement, your accuont may be subject to a
delinquent interest rate . Please rem~t your payment as soon as possible .
PRINCIPAL DUE INTEREST DUE CHARGES DUE TOTAL AMOUNT DUE

0.00 3,584.60 0.00 3,584.60
The bank may report information about your account to credit bureaus.
Late paymentsL missed paymentsL or other defaults on your account
may be reflec~ed in your credi~ report.
If you are havinq difficulty meeting your real estate +oan obliq~tions,
call 1-800-994-3328 ext 141 to rece1ve budget and cred~t counsel~ng at
no cost . Or you may call 1-800-569-4287 to obtain a list of
HOD-Approved credit counseling organizations in your area.
Servicemembers on "active duty 11 or "active service 11 .,._ or their dependents,

may be entitled to certain legal ~rotections and deot relief pursuant
to the Se1~icernembers Civil Relier Act (SO USC App . 501-596) {SCRA} •
In some instances the protections of the act may extend to co-makers,
endorsers, guarantor~i or others who may be obligated on the l9an along
with the person in m~ itary s~rvice. Please see the reverse s~de of
this notice for more informat~on.
NOTICE OF PAST DUE PAYMENT 5/01/2015

Laurence Schneider
DUE DATE: 4/01/2015 ACCOUNT:

AMOUNT DUE: 3,564.60
Making Multiple Payments? {Y/N) ______
SEND PAYMENT TO:
Extra Prin:
First American Bank
P. 0. BOX 7983 Extra Escrow:
Elk Grove Village, IL 70007-7963 --------
TOTAL PAID
•= s 55 55 5 s 5 5•: 025
~ LN6240P)
Customer Serv1ce 847-952-3700 Ptriodk Rllhng
Statement
Mail Payments: F1rst Amer).can Ba11k
P o Box 7983
Elk Grove \';;..llag~: IL 600:)7- 7983
Laurence GchneJ.d.;oz
360 E COCONUT PALM ROAD 7/01/lS 4,055 91
BOC'.A RA'!'ON li'L 33432
025
PLEASE RfTUI-IN lOP POHioON STI\1 ~MFJir WJTI~ 'I'OtJ~ I'I'IYMENT • "'-YAEIU: 10 ARST AMERICAN BANK
ACCOUNT NUMBER . ~~" , -c~~orr tM~-~ l.~~tL;;_~ ·~~

·-- ···-- ~--· ........- ..·--· -
- -~ -·- --
l
--------·-----,
fiiA'YMDIT
DUE DAT_E. _ _ •
40000006 L; 6/15/1!:> I 1,500,000. 8,970 77 1 7/0l/15 4 , 055 <Jl

_L. _____ .... -·-·-- ..... l ____ ... -· . -· --..
. -·. -- ·- ·-·-·L . ·-· ---·---·- --- - ... J~. --- -
- __----- - L_
--ci£1c--r .. ... _. ~ ·-~- ~-·
POSTING DATE
NUMBER ' -· .. ~~CRIP110N OF TRANSACTIONS :~ RUNNING BALANCE
I· .... - .. 'i ·-
I' 1
I CUrrP~t Intere~~ Rate 3.2500
DAILY RATF:-See Reverse .0089
correspond1ng APR * 3 . 2SOO
5/28/lS Payment - Finance Charge 3,.:;84.60 1,4~9,572.52
5t28/15 Payment. - F1nance Chaz·ge 4 , l 15.65 1,495,456.8'1
6/:!..0/1'5 Payment - Finane~ Cha.t"ge 4,2·16.41 l,Bl,208.46
6/10/15 Payment Late C'ha.rge 179.23 1,491,029 2J
6/lS/15 Billed - Late Charges 205 ..,8 1,491, 2.35.01
6/15115 I Bll1ed Finar-:.cc Char.·ge 3,850.::0..3 1. 495' 085 14
--- · . _ _l_ .
+ FiNANcE OTHER NEW

CHARGE C~ARGE<; BALANCE
1 , 503 , 1:07.12 00 ;
I 12,127.89 ; 3,850.13; 205 78
_ _ _ .--. _ - r - - - -
J., 495' 085. 14
ANNUAL ~·-~ 0~1-l
A..(RAG( OAVS
PERCENTAGE PEF!IOOC.
RATE _ , .BJ<TF
OAILY BALANCE
,-
1
IN CVCtt
3 .2:0\ .uo~so.n3% \ 1,491,029.;~3 : 29 ;.,

;_
·,~ ·:~.,. ·:=h~ onn~~::'lerct..iot..19cf:.itt:t' c::-ldD;t:yPc~~:e R:~t~ ;nay va.:Y- ~
S. f\evarst ~·do ~."r tn1pr,,~ ~~r.t tn•o,tr.elHC:r .
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IWire Transfer ,. I Import Input . Multiple

Entry Reports:
TPmnWP WirP
LAURENCE SCHNBD~ Accepted on: Jul15, 2015 at 12:23:14 PM

Send Date: Jul15, 2015
2901 CLINT MOORE RD SUITE #41 0
BOCA RATON, FL 33496
Debit Bank: Bank United- Bank United Credit Bank: 071922n7- ARST
AMERICAN BANK
Debit Account: Credit ·Laurence
9852376502 - Account: Schneider
2295 Galiano Street
Debit Currency: USO- US Dollar Credit USD- US Dollar

Currency:
Debi t Amount: , _ Credit 4 055.91
4 055 91
Amount: '
Template ID: Free Form - 0 Approvers
Originator-to- line 1 -Laurence Schneider
Beneficiary: line 2- July 2015 Pm t. no. 40000006
Entry Cust/User: 1STFIOELITY • LSCHNBDER
Entry
Datetrime: Jul15, 2015 -12:23:14 PM
Bank Trace#: 2015196000230 Cust Trace#: 000279
Please press the print button on your browser to generate a hard copy of this
w ire transfer request.
This transaction is subject to bank rules and regulations governing such electronic
transactions as described in our services agreement. Please keep these numbers
handy in case you have any questions regarding this transaction.
If any portion of the above is incorrect, or you have further questions. please
contact customer serv1ce Thank You.
MEMBER
FDII
(LN6240P)
CUstomer Service 347-952-3700 Periodic Billina
Statement
Mail Payments: First Ameri can Bank
P 0 Box 7983
Elk Grove Vil lage IL 60007-7983
Payment Minimum
Due Date PaymantOua
Laurence Schneider
360 E COCONUT PALM ROAD 8/01/15 6 , 280.69
BOCA RATON FL 33432
0 i! 5
.. P\.EABE REIURN TOP PORTION OF STATEMENT WITH 'lOUR Pl'VtAENT • F\IIYASLE TO FIRST AMERICAN BANK
l ACCOUNT NUMBER S1JI1'DIENT

CI.OIIHQ QjQ'I CR!OfT UMJT AY.AILABL£ CREDIT
Pi\VIIINT
OW !WI.
.....
Mv.MUfiDU£
I 40000006 L B/16 / 15 1,500,000 9,176.55 8/01/15 8, 2 80.69
~~~t=
DESCRIPTION OF TRANSACTIONS TllANUtr10it
AMOUNT RUNNING IIAI.ANCEl
7 / 15 / 15 CUr rent Interest Rate 3 . 2500
I
I DAILY RATE-See Reverse
Cor responding APR *
As sess Annual Fee
.0089
3.2500
50 . 00 1 , 494,806.31
I 7/28/15 I
I
I 8/14/15 Billed - Annual Fee 50 . 00 1,494,856 . 31
B/ 14/15 Billed - F~nance Charge 4, 247.83 1,499,104 . 14
..I
~-PREViOL1S ~ CHECKS .A.NO PAYMENTS + FINANCe + OiHEP.~---: - NEW

BAL~NCE ......,.---'~.=.:.:..:lt.NC:..:.";:;.;E::::S::...-.__ __,_ _ NCJ CREDITS CHARGE CH.~AGES ~l:.~.E=-----4
I~-
___
1 _,4_9_4_ ,_a_o_6_._3_l___ L __ _ _ _ _ __ ___ . o_o~~-----r-~~~--~--4~·~2~4~7_._a_3-+----~!-~ i ooa
DAILY
PEHIOOIC I
AVERAGE
DAILY BALANCE
1 , 4 99 , 1 04 . 1 4
I !N CYCLe
1
1
1-------!.:~IL-~---i---.-OO.. t8x9w01i.4-:;r~~4~~~--- 3~
~ : '!'lw Aranuel PwcentaP ~Mel Dllltv PModlc RAM! nta\1 Yllr".
e.. Rfterw Sid. iollml)ortllnt 1nfonnlllon. .
IWire Transfer Imp or! Multiple

Entry Reports
LAU~E SCtN3DER Accepted on: Aug 28, 2015 at11:14:41 AM

Send Date: Aug 28, 2015
2901 CLINHIIOORERD SUITE#410
Debit Bank: Bank United- Bank United Credit Bank: 071922777 - FIRST
AM ERIC AN BANK
Debit Account: Credit l06- Laurence
9852376502 • Account: Schneider
2295 Galiano Street
Debit Currency: USD- US Dollar Credit USD- US Dollar

Currency:
Debit Amount: • . Credit 4 297.83
4 297 83
Amount: '
Template ID: Free Form • 0 Approvers
Originator-to- line 1 106-Laurence Schne ider
Beneficiary: line 2- HB...OC-17685 Circle Pond Ct.,
line 3- Boca Raton, FL 33496
Entry Cust/User: 1STFIDB.ITY • LSCHNBDER
Entry
Date/Time: Aug 28, 2015- 11:14:41 AM
handy in case you have any questions regarding this transaction .
If any portion of the above is incorrect, or you have further questions, please
contact customer service. Thank You .
MEMBER
FDMI
ILN6240Pl
Customer Service 84.,-952--3700 Penndlc BlUing
Statement
Mail Payments: First Amer1can Ba.nk.
P 0 Box ?9a3
Elk Grove V:~.llage IL 60007 · 79e·~
-· - - - - - r - · -··- -- -···- . --,

Payme•n M111imum :
La~rence Schneider
[
-----·-__;____l___--·----·--. ·-···--··l
Due Date Payment Oue
J60 E COC'ONUT PAl.!\~ ROAD B/01/'15 10,997.17

BOCA RATON FL 33.032
025
I I FIRST AMERICAN BANK

r
- - -nA-miei-i"··· T ... -··

ACCOUNT HUMBER
· · -- - •. - - ,8 _____ -
CI.CIUtQ DttTE
_ __ ,..... - - · - ··-·· ...
· CREDfT LIMIT AVAilABLE CREDIT "''""·!tiM
.. ~r~!f!.'"'
~ooooov6 r, 9 / 15 / 15 1 , soo,ooo
I 12,014.19 a/ol 1 1s : 10,997 17
-'·
DESCAIPllOH OF TRANSACllONS RUNNING BALANCE
8/"J 4-/lS 1 Cu:t:rent Inr.erest Rate 3.2500

! DAlLY RATE·See Re •:erse .0089
I Corresponding APR * 3.2500
Win~ T'xansf~l.
I
1!.'~8,]5 LJ.ne Advance - -1,297 . 83 1,503 , 401 97
8 128 · 15 Pt·tnd.pal Deb1 t Feversal 4 , 297 . e3 1 , 499 , 10-1 . 14
8 / 2B / !5 · Payment - Intere::t. 1,460 J.9 1.499,104 H
S i 2e ' 15 Payment - Principal 2,837.64 1,4.96,266 so
9 / 15/l"i Billed - Late Charges 199 14 1,496,465 '54
9 ( 15 /15 Billed - Fin~nce Charge 2 , 517 . 34 1,498,982 98
1, 4951,10 4 . 14 co 3,<.:7"1 53 199.14

---1,...498,982.98
·D.C.~ _,
.. Cl.iLi i
' ' l:HIOIX" 1:4:_;rW.
f.l~rJ·
~riodic RIIUnK
~1atrmmt
Customer Serv1ce 847-952-3700
Mail payments· First Amencan Bank

P .O. Box 7983
Elk Grove VIllage. ll 60007-7983
Laurence Schneidef 9/1/2015 $8.628.91

360 COCONUT PALM ROAD
BOCA RATON FL 33432
025
FIRST AMERICAN BANK
Corrected Statement
CAEOfT LIMIT AVAllA

!
Ir··~ ~-;;-=-.,_.1~=~·
40000006 9/20i2015 $1,500,000.00 $9.176 55 9/1/2015
I
l.. $8,628.91 __
_...;;;,.__
1
-;::..-:;,;.·-...;....;-_OUCFltPTiON
L OFTRANSAC; IO;S RlJNNII'+G 84LANCE
~ 8/14i2015 CURR;N~~NT;REST RATE ---- 3 2500%

i• DAILY RATE • SEE REVERSE 0.0089
e CORRESPONDING APR 32500%
8/28i2015 L•ne Advance - W1re Transfer $4,297 83 :s1 .so3.4o1 97
8.'28/2015 Pnnc1pal Debit Reversal $4,297 83 i$1,499, 104.1 4
8/28/2015 Payment - Interest $1,460.19 ~$1.499,104.14
8/28/2015 Payment - Pnncipal $2,837 64 '$1,496,266 50
8/28i2015 Reverse Payment - Interest $1,460 19 $1,496,266.50
8/2812015 Reverse Payment • Princ1pal $2.83"/64 .$1.499,1 04 14
8/2812015 Payment Finance Charge $.3,982 86 j$1.495,121.28
8/28/2015 Payment Finance Charge $314.97 $1.494,806.31
9/15/2015 B11led - Late Charges $199.14 $1.495,005 45
9/1512015 Reverse Bill - Late Charge $199 14 $1.494,806 31
9/15/2015 Billed - Finance Charge $2,517 34 $1,497,323.65
9/18!2015 Billed • F1nance Charge $2,128.71 $1,499,452.36
9/16/2015 Wa!ve Late Charge $199.14 $1.499,452.36
9/17/2015 Wa1ve Late Charge $212.39 $1.499.452 36
PREVIOUS CHECKS ~0 FIN ANCE

L.
B A W~e
_ _:::::::
--, A~ANC
':!:E;:::
S_ _....-~.:..;;.:: CHARGE
1.499.104 14 $2.837.64 $8,794.79 $6,106 24 $19914 ~ $1,499.452.36

A!:anlll lnitArl
Import Input Mul~ Reports
Entry
TPnllllittP WII'P
LAURENCE SCHNEIDER Accepted on: Sep 30, 2015 at 03:43:28 PM

Send Date: Se p 30, 201 5
2901 CLNT M:>ORE RD SUITE #41 0
Debit Bank: Bank United- Bank United Credit Bank: 071922777- ARST
AM~CANBANK
Debit Account: Credh 106- Laurence
9852376502 - Account: Schneider
2295 Galiano Street

Currency:
Debit Amount: , _ Credit _
3 977 53 3 977 53
Amount: '
Template ID: 12- 0 Approvers
Originator-to- line 1 - ·- 1006- Laurence
Beneficiary: Schneider
line 2- HB..OC-17685 Circle Pond Ct
Entry Cust!User: 1STFIDB.ITY- LSCHNBDER
Entry
Date/Time: Sep 30, 2015- 03:43 :27 PM
Bank Trace # : 2015273000525 Cus t Trace # : 000301
wire transfer request.
contact customer service. Thank You .
MEMBER
FDMI
(LN6240P)
CUstomer Service 8•7-952-3700 Periodic BUUng
Statement
Mail Payments : First American Bank
P 0 Box 7983
Elk Grove Village IL 60007-7983
Payment Minimum
Due Date Payment Due
Laurence Schneider
360 B COCONUT PALM ROAD 10/01/15 8,46~.34
BOCA RATON FL 33432
025
PLEASE RET\JRN lOP PORTION C)i'" STATEMEf\IT WITH 'VOIJR PAYMENT· fii.YI\SLE 'TO FIRST AMERICAN BANK
·--- --- - ---
ACCOUNT NUMBER
40000006 :t.
ln'ATIMINT
CLOtiNQD#tta
10/18/15
CREDIT LIMIT
1,500,000
AVAILABLE CREDIT
9,176.55
MYIIINT
DUID«M
10/01/15
-
Pl\'l...-r Due
8,469 . 34
I
I
POSTING DATE OHIQ( - DESCRIPT10N OF TRANSACTIONS TRANUCnON
RIJNHIHQ 8ALANCE
~ AMOUNT
9/18/J5 CUrrent Interest Rate 3.2500

DAILY RATE-See Reverse . 0089
Corresponding P~R * 3 . 2500
9/30/15 Payment-Principal Paydown-Wire 3,977.53 1,495,474.83
9/30/15 Principal Payment Reversal 3,977 . 53 1,49~,452 . 36
9/30/15 Payment - F.l.Ilailce Charge 3,932.86 1 , 495 ,519.50
9/30/15 Payment - Annual Pee 44.67 1,495,474.83
9/30/15 Payment - Annual Fee 5 . 33 1,495,469.50
10/H/15 Billed - Late Charges 106.44 1,495,575.94
10/16/15 Billed - Finance Charge 3,716.85 1,499,292.79
I 'I
I
I
t
!
l - _j
PREVIOUS CHECKS AND - PAYMENTS FINANCE OTHER NEW
BALANCE + ADVANCES
··~·
AND CREDITS +
CHARGE
·-·
+
. CHARGES "' BALANCE
1,499,452.36 . 00 i 3 , 982.86 3,716.85 1 106 . 44 1,499,292.79

ANNUAL DAJL:i AVERAGE twS
~AGE PERIODIC
-!WE OAIL.Y BAlANCE IN CYClE
·-···
3.250\ i .00890412% 1,490,823 . 45 28
IWire Transfer Import Inpu t Multiple

Entry Reports Template
Groups
Wire
LAURENCE SCHNEIDER Accepted on: Oct 30, 2015 at 02:41 :56 PM

.," . . Send Date: Oct 30, 2015
2901 CLINT MOORE RD SUITE #410
Debit Bank: BankUnited • BankUnited Credit Bank: 071922777 • FIRST AMERICAN

BANK
Debit Account: • •_ Credit Account: )0006 • Laurence Schneider
9852376602
2295 Galiano Street
Debit Currency: USD • US Dollar Credit Currency: USD • US Dollar
Debit Amount: 4,646.05 Credit Amount: 4,646.05
Template ID: 12 • 0 Approvers
Originator-to- line 1 . :)()006 • Laurence Schneider
Beneficiary: line 2- HELOC-17685 Circle Pond Ct
line 3 - Boca Raton, FL 33496
Entry Cust/User: 1STFIDEUTY • LSCHNEIDER
Entry
Date/Time: Oct 30, 2015-02:41:55 PM
Bank Trace#: 2015303000515 Gust Trace # : 000309
Please press the print button on your browser to generate a hard copy of this wire transfer request.
This transaction is subject to bank rules and regulations governing suCh electronic transactions as
described in our services agreement. Please keep these numbers handy in case you have any
questions regarding this transaction.
If any portion of the above is incorrect, or you have further questions, please contact customer service
Thank You.
MEMBER G)
About Us I Legal I Security I Privacy I Terms & Conditions I Branch Locator FDIIe
(LN6240P)
Customer Sexvice 847-952-3700 Periodic: Billing
Statement
Mail Payments : First America n Bank
P o Box 7983
Elk Grove Village IL 60007 - 7 983
Payment Minimum
Laurence Schneider
360 E COCONUT PALM ROAD 11/01/15 8,230.65
BOCA RATON FL 33432
025
PlEASE RETURN lOP PORTlON OF STATEMENT WITH VOUR

.------------------- - ---------- -- - --- ---- FIRST
• PAYABLE TO
----AMERICAN BANK
~YMENT
-- - - --·---------,
ACCOUNT NUMBER CREDIT LIMIT I AVAILABLE CREDIT PAYioiEHT

DUE Do\TI!
40000006 L ll/18/15 II 1,500,000 9 , 176.55 ll/01/15 8,230 . 65
l
r~-POSn
___. _N_B_~_
· _·r_·E·--r~~~:~~~~~~-r-------DE
__SC
__R_IPnO
___"__OF ___~
__TRA ______NB________;-----m~~~~------+-·--
A_UN_N_wo ___E__~~
____BA_LANC
10/16/15 Cur rent Inte rest Rate 3.2500

DAILY RATE-See Reverse . 0089
Corresponding APR * 3.2500
1 0/30/15 Payment - Finance Charge 2,517 . 34 f 1,496 , 775.45
10/30/15 Payment - Fi nance Charge 2 , 128 . 71 i 1,494 ,646. 74
11/18/15 Billed - Late Charges 185.84 1,494 , 832.58
11/18/15 Billed - Late Charges 1 06 . 44 1,494,939 . 02
11/18/15 Billed - Finance Charge 4,11 5 . 08 1 ,499,054 . 10
I
II
I
1
I
~~-=----·--..______:___ •
I ------- -
PREVK.lUS + CHECKS AND
BAi...A.NCE
- - -·---=-PA:-:-Y-::-M-:=E:::-NT=s -· -·-.---==FlN
··-_
_ _...:..A=
· W,;.:.;_:;
A.N
~AHC~-:-:-=E·--;- Oi HE:H
:..:.C;::;.E=::S=----r----"-A.:.:.N"-=O"-C=RE,
=
"'
D'-'ITS..;;;..__~--'C:;;,;HAR
NEW
-l
=~G;;.:E;;..____,.-2tiAI=I<?_F_L-.------=e=-t\l..A!=.;NC~;::;;'E=-
·
~
,___
1_,_4_9_9_,_2_92__. _7_9_ __,].__ _ .00 ~,646 . 05 \ 4 , 115.08 1 292.2 8 \ 1, 499,0~
ANNUAL DAILY AVERAGE DAYS
PERCENTAGE PERIODIC C-AllY BALANCE IN CYCLE
,___~R"-"~:.:.:TE
=---+---'-'
M '-":'r--"E'----I-- --
I 3.249" .00890411\ 1, 490 , 823 . 4 5 31 1
~tk:e: The Annual l>«centa!lO Rata and Dally Periodic Rate may v•ry.
See Rallerse Side fo r lmoort•nl Information
(LN6240P)
Customer Service 847-952-3700 Periodic BilllDg
Statement
Mail Payments: First American Bank
P 0 Box 7983
Elk Grove Village IL 60007- 7983
Payment Minimum
Cue Dale Payment Due
Laurence Schneider
360 E COCONUT PALM ROAD 12/01/15 7,314 . 75
BOCA RATON FL 33432
0 25
PLEASE RETURN TOP PORTION OF ST.6.TENENT WITH YO!.ir! PAYMENT · PAYABLE TO FIRST AMERICAN BANK
~~~ I IA~LABLE -=~ ~ ~--~~~DUe-

7,314.75~
I
ACCOUNT NUM8ER CREDIT UMIT CREDIT
I
I
POSTING DATE
40000006
CHt!Ck
JMIIIER
I
L l
12/15/15\ 1 , 5oo , oo o
DESCRIPTION OFTRANSACTIOHS
I 9 ,176 . 55
} __
1 2/01/ 15 1
TR.t.Nt.IIICTION
,\MOUNT
I --
RUNNING BALANCE
I
ll/~8/15 Cllrrent IntArest Rate 3 . 2500
DAILY RATE-See Reverse .0089
11/27/15
Corresponding APR *
Payment - Finance Charge
Payment - Late Charge
I 3.2500
3,716. 85
10 6 .44
1,495,337 . 25
1,495,230 . 81
ll/27/15
11/27/J.S Payment - Finance Charge 676.71 1 1 4 94 1 554 . 10 '
12/15/15 Billed - Finance Charge 3 ,584 .10 1,498,138.20 i
I Ii
I
'
!
I
I
~:;::;::;:;;;;;=::===~;;:;;::;;;;:=====~;;=::===;;;
_j~--:-;.= _I ___ ______.
PREVIOUS
BALANCE
+ CHECKS AND
ADVANCES
PAYMENTS
AND CREDITS
+ FtHANCE
CHARGE
+-- OTHER
CHARG_§._ __
,., NEW
__.::;BA;.:::LAN
...:--~
1,499,054.10 . 00
---'-----r---:c
AHNOA
4,500 . 00
=::~L-+--DAil:'l'
, nRC!NTAGE
1 ,584 . 10
Pf::1-IIODIC
00 1 1, 498 , 118 . 20
.1 ---'RA=iTE,.___+-- Me ....
1/1412016 BankUnited Treasury Management
IWire Transfer Import Input Multiple

Entry Reports
WirP
LAURENCESCHN8DER Accepted on: Jan 14, 2016 at 02:42 :11 PM

Send Date: Jan 14, 2016
Debit Bank: Bank United- Bank United Credit Bank: 071922777 - FIRST
AMERICAN BANK
Debit Account: Credr \l06- Laurence
9852376502 - . -- - -- Account: Schneider
2295 Galiano Street
Coral Gables , FL 33134
Deb it Currency: USD- US Dollar Credit USD- US Dollar

Currency:
Debit Amount: 4 ,800.00 Credit 4 800.00
Amount: '
Template /D : 12- 0 Approvers
Originator-to- line 1 - 40000006- Laurence
Beneficiary: Schne ider
line 2- HELOC-17685 Circle Pond Ct
line 3 - Boca Raton, FL 33496
Entry Gust/User: 1 STFIDELITY- LSCHNBDER
Entry ..
. Jan 14, 2016- 02.42.11 PM
t IT1me:
Dae
Bank Trace#: 2016014000283 Cust Trace #: 000331
This transaction is subject to bank rules and reg ulations governing such electronic
contact customer service. Thank You.
MEMBER
FDIG
https://wmJ.banl<unitedbusinessonli nebanking .com'bi:>Wcmser-..erfl nterface/defa~Vframes.cfm 1/2
1/2512016 BankUnited Treasury Managem3flt
A~nlll lnitoli
IWire Transfer ~I Import Input Multiple
Entry Reports
'II
Temolate Wire
LAURENCE SCHNEIDER Accepted on: Jan 25, 2016 at 03:43:33 PM

L.C Send Date: Jan 25, 2016
Deb it Bank: Bank United- Bank United Credit Bank: 071922777- FIRST
AM ERIC AN BANK
Debit Account: Credi1 06- Laurence
A t.l
9852376502 - • -- • I""\
Account: Schneider
2295 Galiano Street

Currency:
Debit Amount: 4 , 500.00 Credit 4 500.00
Amount: '
Template /D: 12- 0 Approvers
Originator-to- line 1 - 40000006- Laurence
Beneficiary: Schneider
line 2 - HELOC-17685 Circle Pond Ct
Entry Gust/User: 1STFIDELITY- LSCHNEIDER
Entry
rr· Jan 25, 2016- 03:43:33 PM
Da te,,tme:
Rease press the print button on your browser to generate a hard copy of th is
wire transfer request.
transactions as described in our services agreement. Rease keep these numbers
If any portion of the above is incorrect, or you have f urther questions , please
contact customer serv ice. Thank You.
MEMBER
·FDIG
https :/fvww./.banl<unitedbusi nessonl inebanl<i ng .corrlbbW'cmsen.erfl nterfaceJdefauiVfr ames .cfm 1/2
(LN6240P )
Customer Service 84'/-952 - 3700 Periodic Billing
Statement
Mail Payments: First American Bank
P 0 Box 7993
Elk Grove Village IL 6000""~-7983
Laurence Schr.eide r
r--- - -
Payment
Due Date
Minimum
Payment Due
360 E COCONUT PALM RD 5/ 01/16 7 56 , 754.72

BOCA RATON FL 33432-7916
025
PlEASE RETURN TOP PORTION OF STATEMENT WllH YOUR PAYMENi PAYI\fiLE TO FIRST AMERICAN BANK
I
I
AccouNT•:::::-~- ~:, CRE~=~!~~ua_L~~~o:J-_::11:L-::;~~J
- PO"_!'NG DAl£
9 /C 7 / "l.6
1 L ___
j
~· ~~SCRI;oo..OFTRA.SACTtOHS - -==-~l-~~~~-~~=-
P...ssess L-::><~n Expense Fee I 13 , 974.9R
- ;,; . . ~-....w.:...-~1
1 , 54 3, 65>3 29
1 0 / 05 / 16 Assess Loan Expense Fee 17 , 034.77 1 , 543.693.29
11/ 09 / 16 I Assess Loan Expense Fee I 1,998.27 1 , 543 , 693.29
11 / 30!16
12 / 14 / 15
1 Assess Loan Fxpenee Fee
i Asses!J Loan Expense Fee
I 30,249.56
16 , 507.06
1 , 543 , 693 . 29
1,543 , 693 . 29
l / 18 / 1 7 Assess Loan Exp~1se Fee 25 . 00 1,543 , 693.29
2 / "l.0/17 Assess Loan Expense Fee 23,069.12 , 1 ,543,693.29
3/0 6 / :; Assess Loan Expense Fee 2S , 174.40 1 , 543 , 693.29
3 ; :5! 17 CUrrent Interest Rate 3.7500
Corresponding APR ~ 3 . 7500
3 / 16 / 17 Current Interesc Rate 4.0000
Corresponding APR * 4 . 0000
4. / 06 / 17
4 / 14 / 17
I Assess Loan Expense Fee
1 Billed - Late Charges
12 , 708 . 10
229 . 43
1 , 543,693 29
1 , 543,922 . 72
4 / 14 / 17 Billed - Finance Charge 5 , 220 . 81 1,549,143.53
Current Fees / Other Charges not in

"New Balance" S".lmmary 12 , 708.10
~ ~~~-~ ; ::::o.'~Jt =~- ._.r,,V~~Q~~~-~~···=· ~~ ·.- ·~ =-~~~~~i ~ -~:;t~~--~:~--

' l 543,6 93 : 9 : .0 0 . 00 5 ,2 :! 0 81 ! 229 . 43 1 1 , 549 , 143.53
-·. - - ~- . .. . --···· ··-- -r- -
ANNUM. _LV.i~i . . ; AVERAGE I DAYS I
~-E~,J~AGE - f'L·~~'VY(, l ?_All:~ 8~!:~~~
i
-r~. c_v.~.
I
·i
3.999% . ol -:~:-:~89\ l l . 488,74B . os , 3'2
-.,..,..-,--:=-·-:-'-··-·· A ·-- • - • - · - - .I
1
Notic:e. TM Al'nuat Pel't"C'f\UW,. Rate a11d Daily Pertodlc Rat• may nry.
C:.Aa R-v•,.,. c;~ tor l,oortapt Information.
(LN6240P)
customer Service 847-952-3700 Periodic Billing
Statement
Mail Payments: Fi rst Amer~can Bank
P 0 Box 7 983
Elk Grove Village IL 60007-7983
Payment Minimum
Laurence Schneider
360 E COCONUT PALM RD 5 / 01 / 16 708,894.38
BOCA ~~TON FL 33432-7916
025
r --- PLEASE RETUPN TOP ronnoN OF STATEMENT WITH YOUR PAYMENT PAYABLE TO FIRST AMERICAN BANK
~-A-C-~0-U_NT
__N_U_M_B_E_R·--·---;-
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I POSTING DATE ~ DESCRIPTION OFTRANSAC110NS ·==r !

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i Assess Loan Expense
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· Assess Loan Expense Fee
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30 , 248 . 56 1. , 534, 363 . 53
12 / 14 / 16
1 /1 3/17
!
Assess Loan Expense Fee
Current Interest Rate II 16 , 507.06
3 . 7500
1 , 534 , 363.53
i
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1
DAILY RATE-See Reverse
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.0102
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!
I
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2/10/17
2 / 15 / 17
Assess Loan Expense Fee
Billed - Late Charges
I 23,069.1.2
213 . 55
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I 1 ,539 ,165.69
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I 23 , 094.12
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CHECKS AND PAYMENTS AHANCE
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ANNUAl o.&.ILY AVERAGE
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E_ _ _ _ _ _ _ . • _ __ .....__ _ _,
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...
Filing # 59196253 E-Filed 07/18/2017 10:13:06 PM
EXHIBIT G
Larry Schneider
From: Henry Bolz <[email protected]>

To: Larry Schneider
Subject: First American Bank v. Schneider
Mr. Schneider,
It looks like we have missed each other's telephone conference windows this afternoon. Please call
me tomorrow, any time after 9:00a.m.
Regards,
Henry H. Bolz, III

Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
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
1
Larry Schneider

To: Larry Schneider
Subject: RE: Fi rst American Bank v. Schneider - Property Inspection
Can you call me here at the office at 2:30p.m.?
Henry H. Bolz, III

Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
IMPORTANT· THIS E-MAIL. AND ANY ATTACHMENTS THERETO . IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS
E-MAIL OR TELEPHONE (IF CONTACT INFORMATION IS PROVIDED) AND PERMANENTLY DELETE THE ORIGINAL OR ANY PRINTOUT THEREOF .
From: Larry Schneider [mailto:[email protected] ]

Subject: Re: First American Bank v. Schneider- Property Inspection
Mr. Bolz,
Can I call you at 3:00p.m. give or take a few minutes?
I'd like to discuss the inspection, which we may need to schedule at a date earlier than your proposed dates, as I will be
unavailable that week. Perhaps later t his week.
I'd also like to discus a related piece of housekeeping in the pending fore closure case which may help resolve the "global
disputes" between the parties.
If 3:00pm is not convenient for you, please provide me a time which would be more convenient.
Thank you,
Larry Schneider
Sent from my iPhone
On Jul18, 2017, at 1:41 PM, Henry Bolz <[email protected]> wrote:
Mr. Schneider,
1
On Wednesday, Ju ly 12, 2017, I sent you an email requesting that you provide First American Bank with
a time/date convenient to you next week to inspect the property being foreclosed. A copy of our earlier
email is attached for ease of reference. We have not yet heard back from you.
We would greatly appreciate it if you would provide us with an inspection time/date for next week by
the close of business tomorrow.
Regards,
Henry H. Bolz, III

Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
IMPORTANT: THIS E-MAIL. AND ANY ATIACHMENTS 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
<mime-attachment>
2
Filing # 59196320 E-Filed 07/18/2017 10:27:51 PM
EXHIBIT H
KELLER & BoLz
Limi1ed Liabilicy Pannership
JOHN W. KELLER, Ill* 121 MAJORCA AVENUE TELEPHONE (305) 529-8500

HENRY H. BOLZ. Ill SUITE 200 TELEFAX (305) 529-0228
CORAL GABLES. FL 33134
SHEYLA MESA WWW.KELLERBOLZ.COM
· EMAIL: hbolz@;kellcrbolz.com
*Board Certified in
Admiralty & Maritime Law
March 30, 2017
VIA FEDEX DELIVERY
Judge James T. Ferrara

Circuit Court Judge
Palm Beach County Courthouse
205 N. Dixie Highway, Rm. 10.1208
West Palm Beach, FL 33401
Re: First American Bank v. Schneider, et al.; Palm Beach County

Circuit Court Case No. 502016-CA-009292
Dear Honorable Judge Ferrara:
In accordance with this Court's March 22, 2017 Order Special Setting Hearing (30
Minutes at 1:30 p.m. on Friday, April 7, 2017), the Plaintiff, First American Bank, hereby
provides hard copies of the following motions (and other pleadings addressed by those
motions), along with highlighted case authority.
The two motions scheduled to be heard on Friday, April 7, 2017, are:
1. First American Bank's Motion to Dismiss Schneider's Amended Counterclaim;

and
2. First American Bank's Motion to Strike the Schneiders' Amended Affirmative
Defenses.
In addition, for the Court's reference with regard to these specially-set motions, we
enclose copies of First American Bank's Verified Foreclosure Complaint and the Answer,
Amended Affirmative Defenses and Amended Counterclaim filed by Laurence S.
Schneider and Stephanie L. Schneider.
Finally, First American Bank encloses highlighted copies of those Florida Statutes,
Florida Rules of Civil. Procedure and case law set out on Appendices "A" and "B" attached
hereto.
Judge James T. Ferrara
March 30, 2017
Page 2
It is anticipated that both of the above-identified motions can be fully considered

and ruled upon by the Court during the course of Friday's specially-set 30 minute hearing.
~~~ ~r
)reff,yi; Bolz, Ill
HHB/Amh
Encls.
cc: Kenneth Eric Trent, Esq .

StuartS. Mermelstein, Esq.
Jay S. Levin, Esq.
(Via Email w/o encls.)
IV. Schneider has Failed to State a Cause of Action for Defamation.
22. Granda-Centeno v. Lara, 489 So. 2d 142 (Fla. 3d DCA 1986)

23. Jews for Jesus, Inc. v. Rapp, 997 So. 2d 1098 (Fla. 2008)
24. Morse v. Ripken, 707 So. 2d 921 (Fla. 4th DCA 1998)
V. Schneider has Failed to State a Cause of Action for Violation of FDUTPA
25. Merrill Lynch Bus. Fin. Servs., Inc. v. Performance Mach. Sys. U.S.A., Inc.,
2005 U.S. Dist. LEXIS 7309 (S.D. FLA. March 4, 2005)
VI. Schneider has Failed to State a Cause of Action for Breach of the Implied
Covenant of Good Faith and Fair Dealing
1. Ament v. One Las Olas, Ltd., 898 So. 2d 147 (Fla. 4th DCA 2005)
2. Hosp. Corp. of Am. V. Florida Med. Ctr., Inc., 710 So. 2d 573 (Fla. 4th DCA
1998)
3. Ins. Concepts & Design, Inc. v. Healthplan Servs., Inc., 785 So. 2d 1232
(Fla. 4th DCA 2001)
4. Meruelo v. The Mark Andrew of The Palm Beaches, Ltd. , 12 So. 3d 247
(Fla. 4th DCA 2009)
Schneider has Failed to State a Cause of Action for Negligence
5. Ewing v. Sellinger, 758 So. 2d 1196 (Fla. 4th DCA 2000).

Larry Schneider

Sent: Monday, May 01, 2017 2:54 PM
To: Larry Schneider
Cc: Kenneth Eric Trent, P.A.
Subject: FAB v Laurence and Stephanie Schneider Foreclosure Lit igation
Attachments: 2017-05-01 Docs Produced by Schneiders (Bates-stamped).pdf
Mr. and Ms. Schneider:
I expect that Atty Trent has by now advised you that Judge Ferrara granted Atty Trent's Motion to Withdraw as your
legal counsel in the referenced foreclosure litigation.
We take this opportunity to provide you with a complete set of those documents that Atty Trent handed to me this
morning and which constitute the initial Production of Documents made by you to FAB in response to FAB' s First
Request for Production of Documents. Please note that your documents were scanned into our firm ' s computer-
completely, unabridged and without review. In that process, we Bates-stamped your documents using Bates-stamp #'s
SCHNEIDERS 00001 through SCHNEIDERS 00253 . A complete copy of those documents, with Bates-stamp #'s are
attached to this email for your records/file. In an abundance of caution, and for the sake of good order, we are also
sending this email and a copy of your Bates-stamped documents to your former attorney.
Regards.
Henry H. Bolz, III

Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
E-mail : [email protected]
E-MAIL OR TELEPHONE (IF CONTACT INFORMATION IS PROVIDED) AND PERMANENTLY DELETE TH E ORIGINAL OR ANY PRINTOUT THEREOF.
1
Larry Schneider

To: Larry Schneider
Subject: First American Bank v. Laurence and Stephanie Schneid er - Foreclosure
Attachments: E2 Trent 04-17-17.pdf
Follow Up Flag: Follow up

Due By: Friday, May OS, 2017 1:30 PM
Flag Status: Flagged
This email follows up on our email to Attorney Kenneth Eric Trent, dated April 17, 2017 (attached),
and the Court's May 15\ 2017 Order granting Attorney Trent's Motion to Withdraw. We are seeking
both of your cooperation and assistance in the following :
(1) Depositions. We want to schedule and take your depositions in the middle of June 2017, in
West Palm Beach. We expect that Mr. Schneider's deposition will take a fu ll day; Mrs.
Schneider's deposition should only take about half a day. Please provide some dates on which
the depositions can be scheduled and taken.
(2) Trial Date. We are going to notice the case for trial. We anticipate that the trial will last about
a day or a day and half. In accordance with the applicable Palm Beach County Foreclosure
Court rules , please provide the number of witnesses you intend to call and the amount time
you expect the trial will last.
Regards,
Henry H. Bolz, Ill

Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
IMPORTANT: THIS E-MAIL, AND ANY ATIACHMENTS THERETO. IS INTENDED FOR THE USE
INFORMATION THAT IS LEGALLY PRIVILEGED. CONFIDENTIAL AND EXEMPT FROM
DISSEMINATION, DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY
1
2
From: Henry Bolz
Sent: Monday, April 17, 2017 4:32PM
To: Kenneth Trent Esq. ([email protected])
Subject: First American Bank v. Schneiders - Foreclosure
Attorney Trent,
This email follows up on our conversation of earlier this afternoon , the two Orders that were entered
by Palm Beach County Circuit Court Judge Breger on April 7, 2017 and the Order Granting Ex Parte
Motion to Compel entered by Judge Barkdull on March 23, 2017. Specifically, and despite your
advices of your intention to withdraw (which Motion you are going to set down for hearing at 0845 on
Monday, May 1, 2017), our office wants to continue to move this litigation along .
Specifically, we are seeking your cooperation and assistance in:
Discovery responses served on April 3, 2017. In response to 24 separate and distinct Requests
for Production of documents, you did not interpose any objections but stated only that the
documents "will be provided ." When we talked this afternoon, you indicated you had the
documents. I agree to reimburse you for the reasonable copying costs to get the documents. We
would like to receive all of the documents responsive to our discovery by no later than week's end
(April 21, 2017).
Although you advised that you are no longer regularly in touch with your clients , we also need to
"keep moving" on:
Depositions of Laurence S. Schneider and Stephanie L. Schneider. We anticipate that the

deposition of Laurence Schneider will take a full day; we expect that Stephanie Schneider's
deposition will only take about a half day. We want to schedule and take those depositions before
the middle of May 2017, either in West Palm Beach or Boca Raton. We would like some dates on
which their respective depositions can be scheduled and taken?
Trial date. Our foreclosure litigation is now "at issue." In accordance with the Florida Rules of
Civil Procedure and the Palm Beach Circuit Court's foreclosure division rules , we are required to
coordinate with you with respect to the number of witnesses the Defendants intend to call and the
amount of time needed for trial. Although we do not yet know what the court's practice or
schedule might be vis-a-vis setting foreclosure trials, we are amenable to scheduling that trial at
any time between the beginning of June and the end of September, 2017. We anticipate that the
trial will last between a day and a half - two days.
Please forward this email on to your clients to give them a "head's up" that we will be contacting them
(or their new/replacement counsel) to schedule their depositions and trial.
Regards,
Henry H. Bolz, 111

Keller & Bolz, LLP
1
Telephone: (305) 529-8500
Telefax: (305) 529-0228
E-mai l: [email protected]
IMPORTANT: THIS E-MAIL AND ANY ATTACHMENTS THERETO. IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS
DELIVERING THE E-MAIL TO THE INTENDED REC IPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION , DISTRIBUTION OR COPYING OF
2
From: Henry Bolz
Sent: Monday, April17, 2017 4:32 PM
To: Kenneth Trent Esq. (trentlawoffi [email protected])
Subject: First American Bank v. Schneiders - Foreclosure
Attorney Trent,
This email follows up on our conversation of earlier this afternoon , the two Orders that were entered
by Palm Beach County Circuit Court Judge Breger on April 7, 2017 and the Order Granting Ex Parte
Motion to Compel entered by Judge Barkdull on March 23, 2017. Specifically, and despite your
advices of your intention to withdraw (which Motion you are going to set down for hearing at 0845 on
Monday, May 1, 2017) , our office wants to continue to move this litigation along.
Specifically, we are seeking your cooperation and assistance in:
Discovery responses served on April 3, 2017. In response to 24 separate and distinct Requests
for Production of documents, you did not interpose any objections but stated only that the
documents "will be provided." When we talked this afternoon, you indicated you had the
documents. I agree to reimburse you for the reasonable copying costs to get the documents. We
would like to receive all of the documents responsive to our discovery by no later than week's end
(April 21 , 2017).
Although you advised that you are no longer regularly in touch with your cl ients, we also need to
"keep moving" on:
Depositions of Laurence S. Schneider and Stephanie L. Schneider. We anticipate that the

deposition of Laurence Schneider will take a full day; we expect that Stephanie Schneider's
deposition will only take about a half day. We want to schedule and take those depositions before
the middle of May 2017, either in West Palm Beach or Boca Raton. We would like some dates on
which their respective depositions can be scheduled and taken?
Trial date. Our foreclosure litigation is now "at issue." In accordance with the Florida Rules of
Civil Procedure and the Palm Beach Circuit Court's foreclosure division rules , we are requ ired to
coordinate with you with respect to the number of witnesses the Defendants intend to call and the
amount of time needed for trial. Although we do not yet know what the court's practice or
schedule might be vis-a-vis setting foreclosure trials, we are amenable to scheduling that trial at
any time between the beginning of June and the end of September, 2017. We anticipate that the
trial will last between a day and a half- two days.
Please forward this email on to your clients to give them a "head's up" that we will be contacting them
(or their new/replacement counsel) to schedule their depositions and trial.
Regards,
Henry H. Bolz, Ill

Ke ller & Bolz, LLP
1
Telephone: (305) 529-8500
Telefax: (305) 529-0228
IMPORTANT: THIS E-MAIL. AND ANY ATIACHMENTS THERETO. IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS
E-MAIL OR TELEPHONE (IF CONTACT INFORMATION IS PROVIDED) AND PERMANENTLY DELETE T HE ORIGINAL OR ANY PRINTOUT THEREOF.
2
Larry Schneider

Sent: Tuesday, May 09, 2017 1:32PM
To: Larry Schneider
Subject: First American Bank v. Laurence and Stephanie Schneider
Attachments: NTD - Laurence Schneider.pdf; NTD - Stephanie Schneider.pdf
This email follows up on our email to Attorney Kenneth Eric Trent, dated April17 , 2017, and our email
to you, dated May 4, 2017. We have not rece ived a response to our April 17, 2017 or our May 4,
2017 emails requesting dates to schedule and take your depositions. As a result, we have scheduled
Mr. Schneider's deposition for June 13, 2017 at 9:30 a.m. and Mrs. Schneider's deposition for June
14, 2017 at 9:30a.m. Attached please find a copy of both Notices of Taking Deposition.
Regards,
Henry H. Bolz, Ill

Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
1
Filing# 56183453 E-Filed 05/09/2017 01:19:07 PM

CASE NO.: 502016-CA-009292
DIVISION AW

Coral Gables, LLC,
Plaintiff,
v.
Defendants.
--------------------------~/
NOTICE OF TAKING DEPOSITION
TO: All Counsel Listed on the Attached Certificate of Service
PLEASE TAKE NOTICE that the undersigned attorneys will take the deposition of:
NAME: The Defendant

DATE AND TIME: Tuesday, June 13, 2017

9:30a.m.
PLACE: Law Office of Michael P. Walsh , P.A.

501 South Flagler Drive, Suite 306
West Palm Beach, FL 33401
upon examination before Julio A. Mocega & Associates, Inc. , Court Reporter, Notaries
Public, or any other notary public or officer authorized by law to take depositions in the State
of Florida. The oral examination will continue from day to day until completed . The deposi-
tion is being taken for the purpose of discovery, for use at trial, or for such other purposes
as are permitted under rules of court.
KELLER & BOLZ, LLP

Attorneys for Plaintiff
121 Majorca Avenue , #200
Telephone: (305) 529-8500
Telefax: (305) 529-0228
Email: [email protected]
By: s/Henrv H. Bolz, Ill

Henry H. Bolz, Ill
Florida Bar No. 260071
WE HEREBY CERTIFY that a true and correct copy of the foregoing Notice of
Taking Deposition was delivered to: LAURENCE S. SCHNEIDER and STEPHANIE L.
SCHNEIDER ([email protected]) , 360 E. Coconut Palm Road , Boca Raton ,
FL 33432; and JAY S. LEVIN, ESQ. (foreclosures@ssclawfirm .com), Sachs, Sax,
Caplan, Attorneys for Oaks at Boca Raton, 6111 Broken Sound Parkway, N.W., #200,
Boca Raton, FL 33487 via theE-filing Portal on this 91h day of May, 2017.
KELLER & BOLZ, LLP
By: s! Henry H. Bolz. Ill

Henry H. Bolz, Ill
Page 2 of 2
Filing# 56183453 E-Filed 05/09/2017 01:19:07 PM

CASE NO.: 502016-CA-009292
DIVISION AW

Coral Gables, LLC,
Plaintiff,
v.
Defendants.
--------------------------~'
NOTICE OF TAKING DEPOSITION
TO: All Counsel Listed on the Attached Certificate of Service
PLEASE TAKE NOTICE that the undersigned attorneys will take the deposition of:
NAME: The Defendant

DATE AND TIME: Wednesday , June 14, 2017

9:30a.m.
PLACE: Law Office of Michael P. Walsh , P.A.

501 South Flagler Drive, Suite 306
West Palm Beach , FL 33401
upon examination before Julio A. Mocega & Associates , Inc., Court Reporter, Notaries
Public, or any other notary public or officer authorized by law to take depositions in the State
of Florida. The oral examination will continue from day to day until completed. The deposi-
tion is being taken for the purpose of discovery, for use at trial, or for such other purposes
as are permitted under rules of court.
KELLER & BOLZ, LLP

Telephone: (305) 529-8500
T elefax: (305) 529-0228
By: s!Henrv H. Bolz, Ill

Henry H. Bolz, Ill
Taking Deposition was delivered to: LAURENCE S. SCHNEIDER and STEPHANIE L.
SCHNEIDER ([email protected]), 360 E. Coconut Palm Road , Boca Raton ,
FL 33432; and JAY S. LEVIN , ESQ. ([email protected]) , Sachs, Sax,
Caplan , Attorneys for Oaks at Boca Raton , 6111 Broken Sound Parkway, N.W., #200,
Boca Raton , FL 33487 via theE-filing Portal on this 91h day of May, 2017.
KELLER & BOLZ, LLP
By: s!Henrv H. Bolz. Ill

Henry H. Bolz, Ill
Page 2 of 2
Filing# 56200409 E-Filed 05/09/2017 03:36:24 PM

CASE NO.: 502016-CA-009292
DIVISIONAW

Coral Gables, LLC,
Plaintiff,
v.
Defendants.
____________________________./
NOTICE FOR TRIAL
COMES NOW the Plaintiff, FIRST AMERICAN BANK, by and through its
undersigned counsel , and pursuant to Fla. R. Civ. P. 1.440(b) and this Court's Divisional
Instructions, hereby gives notice that this case is an original action wh ich is at issue and
is ready to be set for a non -jury trial. The specific matters to be tried are Plaintiff's
foreclosure action against all Defendants and breach of contract action against
Defendant, LAURENCE S. SCHNEIDER.
Plaintiff intends to call three witnesses and estimates that the time needed for trial
will be a day and half.
In accordance with this Court's Divisional Instructions, on May 4, 2017,
undersigned counsel contacted the Defendants, LAURENCE S. SCHNEIDER and
STEPHANIE L. SCHNEIDER, via email, requesting each Defendant provide the number
of witnesses he/she intends to call and the amount of time needed for trial. Defendants
have not responded to undersigned's May 4, 2017 email. 1
On May 9, 2017, undersigned counsel spoke with JayS. Levin, Esq., counsel for
Defendant, THE OAKS AT BOCA RATON PROPERTY OWNERS' ASSOCIATION , INC
("Association"). Attorney Levin advised that the Association will not attend the trial.
KELLER & BOLZ, LLP

Telephone: (305) 529-8500
Telefax: (305) 529-0228
By: s! Henry H. Bo/z, Ill

Henry H. Bolz, Ill
On April1 7, 2017, undersigned contacted Defendants' former counsel, via email, requesting the
same information. Former counsel for the Defendants did not respond to undersigned's email.
Page 2 of 3
WE HEREBY CERTIFY that a true and correct copy of the foregoing , Notice for
Trial, was delivered to: LAURENCE S. SCHNEIDER and STEPHANIE L. SCHNEIDER
([email protected]), 360 E. Coconut Palm Road , Boca Raton , FL 33432; and
JAYS. LEVIN , ESQ. (foreclosures@ssclawfirm .com), Sachs, Sax, Caplan, Attorneys for
Oaks at Boca Raton, 611 1 Broken Sound Parkway, N.W ., #200 , Boca Raton , FL 33487
via theE-filing Portal on this g th day of May, 2017.
KELLER & BOLZ, LLP
By: s!Henrv H. Bo/z. Ill

Henry H. Bolz, Ill
Page 3 of 3
Filing # 56245558 E-Filed 05/10/2017 01:17 :21 PM

CASE NO.: 502016-CA-009292
DIVISION AW

Coral Gables, LLC,
Plaintiff,
v.
Defendants.
--------------------------~'
NOTICE OF UNAVAILABILITY
COMES NOW, Henry H. Bolz, Ill, counsel of record for the Plaintiff, FIRST
AMERICAN BANK, in the captioned litigation and hereby files this his Notice to the Court,
all parties, and all counsel of record of the fact that he has long-standing plans to be away
from Miami/out of the country on vacation beginning on Wednesday, October 11 , 2017
and returning to the office on Monday, November 6, 2017. Although other attorneys at
Keller & Bolz, LLP will be able to cover ministerial matters in my absence, the undersigned
would request the forbearance of all counsel and the Court from scheduling any
significant hearings, trials, or deadlines during my absence.

KELLER & BOLZ, LLP

Telephone: (305) 529-8500
Telefax: (305) 529-0228
By: s/Henry H. Bolz, Ill

Henry H. Bolz, Ill
Unavailability was delivered to: LAURENCE S. SCHNEIDER and STEPHANIE L.
SCHNEIDER ([email protected]), 360 E. Coconut Palm Road, Boca Raton,
FL 33432; and JAY S. LEVIN, ESQ. ([email protected]), Sachs, Sax,
Caplan, Attorneys for Oaks at Boca Raton, 6111 Broken Sound Parkway, N.W. , #200,
Boca Raton, FL 33487 via theE-filing Portal on this 10th day of May, 2017.
KELLER & BOLZ, LLP

Henry H. Bolz, Ill
Page 2 of 2
Larry Schneider

Sent: Monday, May 15, 2017 2:43PM
To: 'Henry Bolz'
Cc: Garry Smith (gsmith@firstamba nk.com); Carlos Molestina
([email protected])
Subject: RE: FAB v. Schneider- Property Inspect ion: 17685 Circle Pond Court, Boca Raton, FL
33496-1002
Dear Mr. Bolz,
I just wanted to reply and confirm that we are in agreement with the inspection time and date. I also wanted to state
for the record, per our cal l, that I had expected to receive a notification of some type from the Bank last month, in
accordance with the Circuit Court's March 28, 2017 Order. I have been and continue to act in accordance of such.
For my protection and based on our history with prior counsel, can you please advise me if you sent a notification to my
prior counsel concerning the April2017 inspection. If so, please forward me a copy of the notification fo r my records so
I can send a letter of explanation to the court.
Regards.
Larry Schneider
2901 Clint Moore Road, Suite 4 10
Cell (305) 710-4201

Sent: Monday, May 15, 2017 2:04PM
To: Larry Schneider
Cc: Garry Smith ([email protected]); Carlos Molestina ([email protected])
Subject: FAB v. Schneider- Property Inspection: 17685 Circle Pond Court, Boca Raton, FL 33496-1002
Dear Mr. Schneider,
This email follows up on that telephone conversation you and I had earlier today wherein you advised
that you would make the above-referenced property being foreclosed available for inspection by First
American Bank's representative at 2:00p.m. on Wednesday, May 24, 2017. Next week's inspection
will be conducted in accordance with the Circuit Court's March 28, 2017 Order.
In the event that it becomes necessary for you to change the time/date for the inspection of your
property, please give me a call or send me an email a day or two in advance.
1
Regards,
Henry H. Bolz, III

Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
DELIVERING THE E-MAIL TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEM INATION, DISTRIBUTION OR COPYING OF
E-MAIL OR TELEPHONE {IF CONTACT INFORMATION IS PROVIDED) AND PERMANENTLY DELETE THE ORIGINAL OR ANY PRINTOUT THEREOF.
2
Larry Schneider

Sent: Tuesday, May 16, 2017 2:47PM
To: Larry Schneider
Subject: RE: Defendants First Request For Documents
Mr. Schneider,
We are in receipt of the email that you sent at 1:17 p.m. yesterday afternoon which had attached to it
an unsigned request for production of documents dated April14, 2017 which had Attorney Kenneth
Trent's address and name. Until you sent what appears to be a draft/proposed "Defendant's First
Request for Production of Document" yesterday, we had never seen it, nor have we seen any
documents or correspondence seeking discovery from First American Bank.
To answer the question in your email of yesterday, First American Bank does not consider that the
attachment to your email, Defendant's First Request for Production of Document, satisfies the
necessary requirements to constitute bona fide service of it. Among the deficiencies in the
"Defendant's First Request for Production of Document" are:
A. It appears that this document was drafted by Attorney Kenneth Trent. Attorney Trent is no
longer your counsel of record since he was allowed to withdraw on May 1, 2017.
B. The Certificate of Service states that the document was "electronically served ... via the e-
filing portal." We did not receive any version of the Defendant's First Request for
Production of Document until yesterday- more than one month after it was supposedly
dated by Attorney Trent.
C. The document is not signed by Attorney Trent or anyone else.
D. The document does not appear to be anything more than a draft/proposed version of a
Request for Production.
E. The above-referenced litigation has been "at issue" since April 7, 2017 when all of your
Amended Affirmative Defenses and all of your Amended Counterclaim were
stricken/dismissed with prejudice.
Shortly stated , it is the position of First American Bank that the Defendant's First Request for
Production of Documents sent to me yesterday does not satisfy the necessary requirements so as to
start any time frames running or require any action/response by First American Bank.
Although I do not intend to provide you with legal advice or tell you how to proceed , in the event that
proper discovery is generated in any Florida Circuit Court, it does not have to be sent via certified
mail. Electronic service via email is sufficient.
Regards,
Henry H. Bolz, Ill

Keller & Bolz, LLP
1
Telephone: (305) 529-8500
T elefax: (305) 529-0228
INFORMATION THAT IS LEGALLY PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM
From: Larry Schneider [mailto:larry@sacapita lpartners.com]

Sent: Monday, M ay 15, 2017 1:17PM
To: Henry Bolz <hbolz@ke llerbolz.com>
Subject: Defend ants First Request For Documents
Dea r. M r. Bolz,
I just left a message for Mr. Trent, for co nfirmation as t o whether this document was or was not properly
se rved. Rega rdless, does this email f rom me, satisfy the necessa ry requirements or do I need to have the documents
dat ed again today. Al so, please let me know if this email is considered as serving t he documents or do I need to have
them delivered via certified mail?
Again, thank you for taking the tim e to spea k with me today.
Regards.
Larry Schneider
151 Fidelity Loan Servicing. LLC
2901 Clint Moore Road. Su ite 4 10
Cell (30 5) 710-4201
2
Filing# 56793353 E-Filed 05/23/2017 11:28:09 AM

CASE NO.: 502016-CA-009292
DIVISIONAW

Coral Gables, LLC ,
Plaintiff,
v.
Defendants.
--------------------------~'
COMES NOW, Henry H. Bolz, Ill , counsel of record for the Plaintiff, FIRST
AMERICAN BANK, in the captioned litigation and hereby files th is his Notice to the Court,
all parties, and all counsel of record of the fact that counsel for FIRST AMERICAN BANK
has long-standing out-of-state vacation plans beginning on Friday, July 14, 2017, to
Wednesday, July 26, 2017, inclusive. Although other attorneys at Keller & Bolz, LLP will
be able to cover ministerial matters, the undersigned would respectfully request the
forbearance of all counsel and the Court from scheduling any significant hearings, trials ,
or deadlines during my absence.

KELLER & BOLZ, LLP

Telephone: (305) 529-8500
Telefax: (305) 529-0228
By: s! Henrv H. Bolz, Ill

Henry H. Bolz, Ill
Unavailability was delivered to : LAURENCE S. SCHNEIDER and STEPHANIE L.
SCHNEIDER ([email protected]) , 360 E. Coconut Palm Road , Boca Raton ,
FL 33432; and JAY S. LEVIN, ESQ. ([email protected]) , Sachs, Sax,
Caplan, Attorneys for Oaks at Boca Raton , 6111 Broken Sound Parkway, N.W ., #200,
Boca Raton , FL 33487 via the E-filing Portal on this 23rd day of May, 2017.
KELLER & BOLZ, LLP

Henry H. Bolz, Ill
Page 2 of 2
Filing# 56793353 E-Filed 05/23/2017 11:28:09 AM

CASE NO. : 502016-CA-009292
DIVISIONAW

Coral Gables, LLC,
Plaintiff,
v.
____________________________
Defendants.
/
MOTION FOR SPECIALLY-SET

TRIAL DATE
undersigned counsel , and in accordance with the applicable Florida Rules of Civil
Procedure and this Court's May 16, 2017 Order Setting Residential Foreclosure Non-Jury
Trial and Directing Pretrial Procedures, hereby advises the Court that the primary First
American Bank witness who will be testifying on behalf of First American Bank resides
and works in Chicago, Illinois. In addition , the undersigned has long-standing out-of-state
vacation plans from Friday, July 14, 2017 through Wednesday , July 26, 2017.
Accordingly, FIRST AMERICAN BANK and the undersigned respectfully request that the
trial in the above-styled litigation be specially scheduled for a date certain between July
3, 2017 and July 13, 2017.

It is further respectfully requested that the Court determine at trial only Plaintiffs
entitlement to attorneys' fees, costs and expenses, and schedule a future hearing at
which evidence is taken to establish the quantum of attorneys' fees , cost and expenses
to which Plaintiff is entitled. At the second hearing , Plaintiff will prepare and submit the
relevant evidence, including expert testimony, in order for the Court to determine
reasonableness and amount of the fees, costs and expenses that should be awarded
Plaintiff.
WHEREFORE, Plaintiff, FIRST AMERICAN BANK, respectfully requests that this
Court enter an Order:
(a) setting a date certain (and also a time, if possible) for trial between July 3, 2017
and July 13, 2017 during the non-jury trial calendar wh ich runs from 9:00a.m. on
Wednesday, June 28, 2017 , until July 26, 2017; and
(b) that at trial the Court will only determine Plaintiffs entitlement to attorneys' fees,
costs and expenses, and , if Plaintiff is entitled to fees, the Court will retain
jurisdiction to determine the total amounts of attorneys' fees , costs and expenses
to which Plaintiff is entitled .
KELLER & BOLZ, LLP

Telephone: (305) 529-8500
Telefax: (305) 529-0228
By: s/Henry H. Bolz. Ill

Henry H. Bolz, Ill
Page 2 of 3
WE HEREBY CERTIFY that a true and correct copy of the foregoing Motion for
Specially Set Trial was delivered to: LAURENCE S. SCHNEIDER and STEPHANIE L.
SCHNEIDER ([email protected]) , 360 E. Coconut Pa lm Road , Boca Raton ,
FL 33432; and JAY S. LEVIN, ESQ. ([email protected]) , Sachs, Sax,
Caplan, Attorneys for Oaks at Boca Raton , 6111 Broken Sound Parkway, N.W ., #200,
Boca Raton , FL 33487 via theE-filing Portal on this 23rct day of May, 2017.
KELLER & BOLZ, LLP
By: s!Henrv H. Bo/z. Ill

Henry H. Bolz, Ill
Page 3 of 3
Filing# 56863923 E-Filed 05/24/2017 12:50:00 PM

CASE NO.: 502016-CA-009292
DIVISION AW

Coral Gables, LLC,
Plaintiff,
v.
STEPHANIE L. SCHNEIDER,
JEFFREY MARC HERMAN ,
UNKNOWN TENANT #1 , UNKNOWN
TENANT #2 and THE
OAKS AT BOCA RATON PROPERTY
OWNERS' ASSOCIATION, INC .,
Defendants.
--------------------------~/
NOTICE OF HEARING
Uniform Motion Calendar
TO: All Addressees Listed Below
YOU ARE HEREBY NOTIFIED that the undersigned will call up for hearing , before
the Honorable James Ferrara , one of the Judges of the above-styled Court, in his
Chambers at the Palm Beach County Courthouse, 205 N. Dixie Highway, #11A (please
check white board on 41h floor for courtroom designation for this hearing), West Palm
Beach , FL 33401 on Monday, June 12, 2017 at 8:45a.m., or as soon thereafter as same
can be heard ,
Plaintiff's Motion for Specially Set
Trial Date
Dated May 23, 2017
Plaintiff's Notice of Unavailability

Dated May 23, 2017
In accordance with the Americans with Disabilities Act, persons with disabilities needing a special
accommodation to participate in this proceeding should contact Court Administration at the Miami-Dade County
Courthouse, no later than seven days prior to the proceeding.
The undersigned certifies that a bona fide effort to agree to or narrow the issues
has been made or will be made prior to the hearing in this cause.
PLEASE GOVERN YOURSELF ACCORD INGLY.
KELLER & BOLZ, LLP

Telephone: (305) 529-8500
Telefax: (305) 529-0228
By: s/Henrv H. Bolz. Ill

Henry H. Bolz, Ill
Page 2 of 3
Hearing was delivered to: LAURENCE S. SCHNEIDER, ([email protected]),
360 E. Coconut Palm Road , Boca Raton, FL 33432; STEPHANIE L. SCHNEIDER
([email protected]), 360 E. Coconut Palm Road, Boca Raton , FL 33432; and
JAYS. LEVIN , ESQ. ([email protected]) , Sachs, Sax, Caplan, Attorneys for
Oaks at Boca Raton, 6111 Broken Sound Parkway, N.W. , #200 , Boca Raton, FL 33487
via the E-filing Portal on this 241h day of May, 2017.
KELLER & BOLZ, LLP

Henry H. Bolz, Ill
Page 3 of 3
Larry Schneider

Sent: Tuesday, May 23, 2017 3:16 PM
To: 'Henry Bolz'
Subject: RE: First American Bank v. Schneider
Mr. Bolz,
I have been out of the office due to a family illness. My father is 92 and is suddenly not well. We have an urgent
appointment with his Urologist tomorrow. Thus, I do not know if I will be back in time for the inspection. As such,
please postpone the inspection for Wednesday, June 24, 2017. I'll get back to you tomorrow and hopefully reschedule
for later in the week.
Regards,
Larry Schneider
Cell(305)710-4201

Sent: Tuesday, May 23, 2017 11:49 AM
To: Larry Schneider
Mr. Schneider:
I need to speak with you briefly about (1) conf irm ing tomorrow's inspection of the property in foreclosure and (2)
coordinating a hea ring date for those two pleadings I sent to you earlier today. Tim e is of the essence . Please call me
when you get a minute.
Regards.
Henry H. Bolz, III

Keller & Bolz, LLP
I 21 Majorca Avenue, #200
Telephone: (305) 529-8500
Telefax: (305) 529-0228
IMPORTANT: THIS E-MAIL AND ANY ATIACHMENTS 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
1
2
Filing# 56793353 E-Filed 05/23/2017 11:28:09 AM

CASE NO.: 502016-CA-009292
DIVISION AW

Coral Gables, LLC,
Plaintiff,
v.
Defendants.
----------------------------'
COMES NOW, Henry H. Bolz, Ill, counsel of record for the Plaintiff, FIRST
AMERICAN BANK, in the captioned litigation and hereby files this his Notice to the Court,
all parties, and all counsel of record of the fact that counsel for FIRST AMERICAN BANK
has long-standing out-of-state vacation plans beginning on Friday, July 14, 2017, to
Wednesday, July 26, 2017, inclusive. Although other attorneys at Keller & Bolz, LLP will
be able to cover ministerial matters, the undersigned would respectfully request the
forbearance of all counsel and the Court from scheduling any significant hearings, trials,
or deadlines during my absence.

KELLER & BOLZ, LLP

Telephone: (305) 529-8500
Telefax: (305) 529-0228
By: s/Henrv H. Bo/z. Ill

Henry H. Bolz, Ill
Unavailability was delivered to: LAURENCE S. SCHNEIDER and STEPHANIE L.
SCHNEIDER ([email protected]), 360 E. Coconut Palm Road, Boca Raton ,
FL 33432; and JAY S. LEVIN , ESQ. ([email protected]) , Sachs, Sax,
Caplan , Attorneys for Oaks at Boca Raton , 6111 Broken Sound Parkway, N.W., #200,
Boca Raton , FL 33487 via the E-filing Portal on this 23rct day of May, 2017.
KELLER & BOLZ, LLP

Henry H. Bolz, Ill
Page 2 of 2
Filing# 56955784 E-Filed 05/25/2017 04:50:27 PM

CASE NO.: 502016-CA-009292
DIVISIONAW

Coral Gables, LLC,
Plaintiff,
v.
Defendants.
__________________________ ./
FIRST AMERICAN'S MOTION FOR SUMMARY

JUDGMENT AND INCORPORATED MEMORANDUM OF LAW
COMES NOW the Plaintiff, FIRST AMERICAN BANK (hereinafter "FIRST
AMERICAN"), by and through its undersigned counsel, and pursuant to Fla. R. Civ. P.
1.510, hereby files this Motion for Summary Judgment, and in support thereof states:
I. INTRODUCTION/BACKGROUND
FIRST AMERICAN instituted this foreclosure action on August 17, 2016 [D.E. 2].
FIRST AMERICAN seeks, among other things, to foreclose a Mortgage on the residential
property located at 17685 Circle Pond Court, Boca Raton , Florida 33496-1002
(hereinafter the "Property"). On November 16, 2016, the Defendants, LAURENCE S.
SCHNEIDER and STEPHANIE L. SCHNEIDER (collectively "the SCHNEIDERS" or
"Defendants") filed their Answer and Affirmative Defenses to FIRST AMERICAN's

Verified Foreclosure Complaint, which included two Affirmative Defenses [D.E. 32]. On
January 26, 2017, this Court entered an Order Striking the SCHNEIDERS' Affirmative
Defenses (hereinafter "January 26 Order") [D.E. 49]. The SCHNEIDERS were granted
20 days from the entry of the Court's January 26 Order to file amended affirmative
defenses.
On March 6, 2017- 39 days after entry of this Court's January 26 Order- the
SCHNEIDERS filed their Amended Affirmative Defenses [D.E. 61].1 The SCHNEIDERS
asserted the following three Amended Affirmative Defenses: (1) Anticipatory Breach/Prior
Breach ; (2) Usury and (3) Set-off. As all three Amended Affirmative Defenses were legally
insufficient and immaterial to this foreclosure proceeding, FIRST AMERICAN requested
the Court strike each Amended Affirmative Defense [D.E. 67]. On April7 , 2017, this Court
entered an Order striking all three Amended Affirmative Defenses with prejudice
(hereinafter "April 7 Order") [D. E. 85]. This Court specifically denied the SCHNEIDERS
motion for leave to file second amended affirmative defenses.
As will be demonstrated below, the Defendants have admitted : (a) that they
executed the Note and/or Mortgage and (b) that they have defaulted under the terms of
the Note and/or Mortgage by: (i) failing to pay the monthly interest payment due on May
1, 2016 and all subsequent months, (ii) failing to pay the entire balance owing in a single
balloon payment on July 28, 2016 and (iii) failing to pay the Florida Ad Valorem property
taxes on the Property for 2014, 2015 and 2016. Furthermore, Defendants have no
As detailed in FIRST AMERICAN 's Motion to Compel Defendants to Comply with this Court's Order
(bearing a Certificate of Service date of March 1, 2016), the SCHNEIDERS and their former counsel have
interposed numerous extension requests primarily, if not solely, for the purpose of delay [D.E. 60].
Page 2 of 19
affirmative defenses. Thus, there is no genuine issue of material fact and FIRST
AMERICAN is entitled to judgment as a matter of law.
II. STATEMENT OF UNDISPUTED FACTS
1. On July 28, 2006, Defendant, LAURENCE S. SCHNEIDER, executed and
delivered a Credit Agreement for a 10-year Home Equity Line of Credit (HELOC) with a
credit limit of $1 ,500,000.00 and promised to pay any and all amounts borrowed from the
$1 ,500,000.00 Credit Agreement (hereinafter "Credit Agreement" or "Note") by making a
single balloon payment on July 28 , 2016. A true and correct copy of the Credit
Agreement, which constitutes the Note with respect to this credit transaction, is attached
hereto and fully incorporated herein as Exhibit "1." Defendant, in his Answer, admitted
the allegations stated in Paragraph 10 of FIRST AMERICAN 's Verified Foreclosure
Complaint that he executed the Note and promised to pay and any and all amounts
borrowed from the $1,500,000.00 Note by making a single balloon payment on July 28,
2016 [D.E. 32, 1(10 and D.E. 61 , 1(10]. Furthermore, during an evidentiary hearing on
March 28, 2017, Defendants stipulated to the authenticity of the Credit Agreement and
that Defendant, LAURENCE S. SCHNEIDER, executed the Credit Agreement. A true
and correct copy of the Transcript of the March 28, 2017 Evidentiary Hearing is attached
hereto as Exhibit "2," at p. 10.
2. On January 28, 2006, Defendant, LAURENCE S. SCHNEIDER, joined by
his wife, Defendant, STEPHANIE L. SCHNEIDER , executed and delivered a Mortgage
securing payment of the Note (Exhibit "1")to FIRST AMERICAN's predecessor in interest,
Bank of Coral Gables. A true and correct copy of the Mortgage is attached hereto and
fully incorporated herein as Exhibit "3." Defendants, in their Answer, admitted the
Page 3 of 19
allegations stated in Paragraph 11 of FIRST AMERICAN's Verified Foreclosure
Complaint that they executed the Mortgage and that the Mortgage secured payment of
the Note [D.E. 32, 1J11 and D.E. 61 , 1J 11 ]. See also Ex. "2" at p. 10 (during the March 28,
2017 evidentiary hearing, Defendants stipulated to the authenticity of the Mortgage and
that Defendant, LAURENCE S. SCHNEIDER, executed the Mortgage). The Mortgage
was recorded on July 31 , 2006 in Official Records Book 20662 at Page 0250 of the Public
Records of Palm Beach County, Florida. The legal description of the Property is:
"Lot 37 of the Fox Hill Estates of Boca Raton, according to the

Plat thereof, as recorded in Plat Book 87, Page 4, of the Public
Records of Palm Beach County, Florida."
3. FIRST AMERICAN is the entity entitled to enforce the Note and Mortgage
under applicable law because of FIRST AMERICAN 's merger with Bank of Coral Gables,
which was effective on December 5, 2014. See Ex. "2" at p. 9. See also Affidavit of Garry
S. Smith attached hereto as Exhibit "4," 1J 10.
4. FIRST AMERICAN is the current owner and holder of the Note and
Mortgage and has possession of the original Note and Mortgage. See Ex. "2" at p. 12
and Ex. "4," 1J 10. The original Note and Mortgage will be filed with the Court prior to the
hearing on this Motion.
5. The terms of the Note and Mortgage provided that Defendant, LAURENCE
S. SCHNEIDER, would make 119 monthly payments equaling the amount of his accrued
interest charges, "plus any amount due and other charges," and the entire principal
balance in a single balloon payment on or before July 28, 2016. Ex. "1" at p. 1 & Ex. "3"
at p. 1. Defendant, LAURENCE S. SCHNEIDER, and/or Defendant, STEPHANIE L.
SCHNEIDER, defaulted under the Note and/or Mortgage by, among other things:
Page 4 of 19
(a) Failing to pay the monthly interest payment due on May 1, 2016 and all
subsequent monthly payments. Defendants, in their Answer to FIRST
AMERICAN's Verified Foreclosure Complaint, admitted "that all payments have
not been made and/or that one or more payments was not timely made." [D.E.
32, 1{14 and D.E. 61 , 1{14]. See a/so Ex. "2" at p. 13-14 (during the March 28,
2017 evidentiary hearing, Defendant stipulated that they have not made any
monthly payments since April 2016) and Ex. "4 ," 1{11.
(b) Failing to pay the entire balance owing in a single balloon payment on July 28,
2016. See [D.E. 32 1l1f10 & 14 and D.E. 61, 1{1{10 (Defendants admit that
Defendant, LAURENCE S. SCHNEIDER, "promised to pay any and all
amounts borrowed from the $1,500,000.00 Credit Agreement by making a
single balloon payment on July 28, 2016.") & 14 ("Defendants admit that all
payments have not been made")]. See a/so Ex. "2" at p. 17 (during the March
28, 2017 evidentiary hearing, Defendants stipulated that the balloon payment
"has not been made") and Ex. "4," 1{11 .
(c) Failing to pay the Florida Ad Valorem/real property taxes on the Property for
2014, 2015 and 2016 (on or about March 31 , 2016, FIRST AMERICAN
advanced and paid the Florida Ad Valorem/real property taxes on the Property
for 2014 and 2015 in the amount of $46,148.17, and , on or about January 4 ,
2017, FIRST AMERICAN advanced and paid the Florida Ad Valorem/real
property taxes on the Property for 2016 in the amount of $20,722.76) .
Defendant, LAURENCE S. SCHNEIDER, in his Objections and Responses to
FIRST AMERICAN's First Set of Interrogatories, specifically Interrogatory No.
Page 5 of 19
4, stated "I did not pay the taxes before First American paid them." A true and
correct copy of Defendant's Objections and Responses to Plaintiff First
American Bank's First Set of Interrogatories is attached hereto as Exhibit "5."
Furthermore, Defendants, in their Response to First American's Request for
Admissions (specifically Request for Admission Nos. 4 & 5), admitted that they
failed to pay the Property's Ad Valorem/Real Property Taxes for 2014 and
2015. A true and correct copy of First American 's First Request for Admissions
and Defendants' Response to First American 's Request for Admissions is
attached hereto as Composite Exhibit "6." See also Ex. "2" at pp. 15 & 25
(during the March 28, 2017 evidentiary hearing, Defendants stipulated that they
did not pay the property taxes) and Ex. "4," 1f1l11 & 12.
6. On numerous occasions FIRST AMERICAN notified Defendant,
LAURENCE S. SCHNEIDER, in writing , of his material defaults/breaches of the Note and
Mortgage. Specifically,
(a) By letter dated March 18, 2016, FIRST AMERICAN demanded that Defendant,
LAURENCE S. SCHNEIDER, pay the Florida Ad Valorem/real property taxes
on the Property for 2014 and 2015. The demand letter further warned
Defendant, LAURENCE S. SCHNEIDER, that: "Under the terms of your
HELOC mortgage and loan agreement, failure to pay your property taxes when
due puts your loan into default." A true and correct copy of the March 18, 2016
letter FIRST AMERICAN sent Defendant, LAURENCE S. SCHNEIDER, is
attached hereto as Exhibit "7 ." See also Ex. "4," 1J13.
Page 6 of 19
(b) By letter dated April 22, 2016, FIRST AMERICAN notified Defendant,
LAURENCE S. SCHNEIDER, that: (1) the Florida Ad Valorem/real property
taxes on the Property for 2014 and 2015 were delinquent, (2) FIRST
AMERICAN paid the Florida Ad Valorem/real property taxes on the Property
for 2014 and 2015 in the amount of $46,148.17 and (3) if Defendant,
LAURENCE S. SCHNEIDER, did not repay the $46,148.17 paid by FIRST
AMERICAN his account "will be in default." A true and correct copy of the April
22, 2016 letter FIRST AMERICAN sent Defendant, LAURENCE S.
SCHNEIDER, is attached hereto as Exhibit "8." See a/so Ex. "4 ," 1J 13.
(c) By letter dated July 7, 2016, FIRST AMERICAN notified Defendant,
LAURENCE S. SCHNEIDER, that his "loan was delinquent for failure to make
the monthly payment(s)" and that "failure to make payments when due is a
material breach under the terms of [his] loan ." The notice further provided that
"If the loan default is not cured on or before July 17, 2016, the Bank reserves
its right to demand payment of [his] loan balance in full and take whatever legal
action is necessary to protect [its] interest." A true and correct copy of the July
7, 2016 letter FIRST AMERICAN sent to Defendant, LAURENCE S.
SCHNEIDER, is attached hereto as Exhibit "9." See a/so Ex. "4," 1J 13.
(d) By letter dated August 16, 2016, FIRST AMERICAN notified Defendants,
LAURENCE S. SCHNEIDER and STEPHANIE L. SCHNEIDER, that they had
defaulted under the terms of the Note and Mortgage by failing "to pay the entire
principal balloon payment on the ten-year HELOC Line of Credit which was due
on July 28, 2016." A true and correct copy of the August 16, 2016 letter FIRST
Page 7 of 19
AMERICAN sent to Defendant, LAURENCE S. SCHNEIDER, is attached
hereto as Exhibit "1 0." See also Ex. "4," ~ 13.
7. To date, Defendants have failed to tender or attempt to tender the amounts
owed under the Note and Mortgage, including the Florida Ad Valorem/real property taxes
on the Property for 2014, 2015 and 2016. See Ex. "4," ~ 14. See also Exhibit "2" at pp.
13, 14, 15, 17 & 25.
8. The Defendant, LAURENCE S. SCHNEIDER, owes FIRST AMERICAN
$1 ,488,554.76 in unpaid principal,2 interest thereon , unpaid Florida Ad Valorem/real
property taxes on the Property for 2014, 2015 and 2016 in the amount of $66,870.93,
interest thereon , along with expenses that have been incurred by FIRST AMERICAN,
costs and reasonable attorneys' fees. 3 See Ex. "4" at~ 14.
9. As a result of Defendants' defaults, FIRST AMERICAN instituted this
foreclosure action on August 17, 2016.
10. On March 6, 2017, Defendants filed their Answer and Amended Affirmative
Defenses [D.E. 61]. On April 7, 2017, this Court entered an Order striking all three
Amended Affirmative Defenses with prejudice, as all three of Defendants' Amended
Affirmative Defenses were legally insufficient and immaterial to this foreclosure
2 In its Verified Foreclosure Complaint, FIRST AMERICAN alleged that Defendant, LAURENCE S.
SCHNEIDER, owed FIRST AMERICAN the unpaid principal balance of $1,488,748.05 [D.E. 2]. On April
17, 2017, FIRST AMERICAN received a Qualified Written Request ("QWR") from Defendant, LAURENCE
S. SCHNEIDER (dated April 10, 2017) . In preparing its response to the Defendant's QWR, FIRST
AMERICAN reviewed the entire loan history of the HELOC account. That investigation revealed that there
were two clerical errors made (an $0.80 clerical error in June 2012 and another of $192.49 in August 2011 ).
The aggregate amount of those two clerical errors, totaling $193.29, has been credited to Defendant's loan
history. See Ex. "4," ~16 . Accordingly, the actual unpaid principal balance under the HELOC is
$1 ,488,554.76.
3 Defendant, LAURENCE S. SCHNEIDER, incurred $732.84 in late fees from March 2015 to April
2016, and $2,679.29 in late fees from May 2016 to the present. FIRST AMERICAN is not seeking to recover
any late fees incurred by Defendant, LAURENCE S. SCHNEIDER, from March 2015 to the present.
Page 8 of 19
proceeding [D.E. 85]. Accordingly, Defendants have no affirmative defenses to FIRST
AMERICAN's Verified Foreclosure Complaint.
Ill. MEMORANDUM OF LAW
A. Summary Judgment Standard.
In Florida, summary judgment "must be rendered immediately if the pleadings and
summary judgment evidence" (affidavits, answers to interrogatories, admissions and
other materials as would be admissible in evidence) "on file show that there is no genuine
issue as to any material fact and that the moving party is entitled to judgment as a matter
of law." Fla. R. Civ. P. 1.510(c). The moving party bears the initial burden to show the
nonexistence of any disputed issue of material fact. 770 PPR, LLC v. TJCV Land Trust,
30 So. 3d 613, 618 (Fla. 41h DCA 201 0) . The party moving for summary judgment must
factually refute or disprove the affirmative defenses raised , or establish that the defenses
are insufficient as a matter of law." !d. Once the moving party meets its burden of
demonstrating through "competent evidence" that no genuine issues of material facts
exist, the burden shifts to the non-moving party to "come forward with counterevidence
sufficient to reveal" that a genuine issue of material fact exists. /d. "It is not enough for
the opposing party merely to assert that an issue does exist." !d. citing Landers v. Milton,
370 So. 2d 368, 370 (Fla. 1979).
B. Count I - Foreclosure of Mortgage.
(1) There is no genuine issue of material fact and FIRST AMERICAN is entitled to
judgment as a matter of law.
The Mortgage states that it is
Page 9 of 19
"GIVEN TO SECURE (A) PAYMENT OF THE INDEBTEDNESS4 AND (B)
PERFORMANCE OF EACH OF [Defendants'] AGREEMENTS AND
OBLIGATIONS UNDER THE CREDIT AGREEMENT WITH THE CREDIT
LIMIT OF $1 ,500,000.00, THE RELATED DOCUMENTS, AND THIS
MORTGAGE."
Ex. "3" at p. 1 (emphasis in original). The Mortgage provides that Defendants "shall pay
to Lender all lndebtedness 5 secured by this Mortgage as it becomes due" and "shall pay
when due (and in all events prior to delinquency) all taxes ... levied against or on account
of the Property." Ex. "3" at pp. 1 & 2. Further, the Mortgage provides:
"EVENTS OF DEFAULT. [Defendants] will be in default under the Mortgage

if any of the following happen: . . . (B) [Defendant, LAURENCE S.
SCHNEIDER] does not meet the repayment terms of the Credit Agreement.
(C) [Defendants] action or inaction adversely affects the collateral or
Lender's rights in the collateral. This can include ... failure to pay taxes. "
Ex. "3" at p. 4. Further, the Mortgage provides that FIRST AMERICAN may exercise the
following rights and remedies in the event of a default:
"Judicial Foreclosure. Lender may obtain a judicial decree foreclosing

[Defendants'] interest in all or any part of the Property."
"Deficiency Judgment. If permitted by applicable law, Lender may obtain

judgment for any deficiency remaining in the lndebtedness6 due to Lender
after application of all amounts received from the exercise of the rights
provided in this section."
"Attorneys' Fees; Expenses. If the Lender institutes any suit or action to

enforce any of the terms of this Mortgage, Lender shall be entitled to recover
such sum as the court may adjudge reasonable as attorneys' fees at trial
end upon any appeal. Whether or not any court action is involved, and to
the extent not prohibited by law, all reasonable expenses Lender incurs that
in Lender's opinion are necessary at any time for the protection of its interest
4 The Mortgage defines "Indebtedness" as "all principal, interest, and other amounts, costs and
expenses payable under the Credit Agreement or Related Documents together with ... any amounts
expended or advanced by Lender to discharge [Defendants] obligations or expenses incurred by Lender to
enforce [Defendants] obligations under this Mortgage, together with interest on such amounts as provided
in this Mortgage." Ex. "3" at p. 5.
5 See n. 4 , supra.
6 See n. 4, supra.
Page 10 of 19
or the enforcement of its rights shall become a part of the lndebtedness 7
payable on demand and shall bear interest at the Credit Agreement rate
from the date of expiration until repaid . Expenses cove red by this
paragraph include, without limitation ... Lender's reasonable attorneys' fees
and Lender's legal expenses . . . [and] surveyors' reports, to the extent
permitted by law. [Defendants] also will pay any court costs, in addition to
all other sums provided by law."
Ex. "3" at p. 4 .
Here, Defendants admitted "that all payments have not been made and/or that one
or more payments was not timely made," see [D.E. 32, 11 14 and D.E. 61 , 1114], and that
they did not pay the Florida Ad Valorem/real property taxes on the Property, see Ex. "6,"
Admis. Nos. 4 & 5. Accordingly , it is undisputed that Defendants, LAURENCE S.
SCHNEIDER and/or STEPHANIE L. SCHNEIDER,: (a) failed to pay the monthly interest
payment due on May 1, 2016 and all subsequent monthly payments; (b) failed to pay the
entire balance owing in a single balloon payment on July 28, 2016; and (c) failed to pay
the Florida Ad Valorem/real property taxes on the Property for 2014, 2015 and 2016. See
[D.E. 32111110 & 14 and D.E. 61 , 111110 & 14], Ex. "2" at pp. 13-14, 15, 17 & 25, Ex. "4,"
1111 11 , 12 & 14, Ex. "5," Interrogatory No. 4 and Ex. "6," Admissions Nos. 4 & 5.
Furthermore, under Florida law "failure to pay real estate taxes in accordance with
the terms of the mortgage, standing alone, is a sufficient basis for the trial court to grant
foreclosure ." Siahpoosh v. NOR Properties, Inc., 666 So. 2d 988, 989 (Fla. 4th DCA
1996). See also Lunn Woods v. Lowery, 577 So. 2d 705, 707 (Fla. 2d DCA 1991) and
Heimerv. Albion Realty& Mortg. Inc., 300 So. 2d 31 , 33 (Fla. 3d DCA 1974) (same).
As discussed supra, all of Defendants' affirmative defenses have been stricken.
Accordingly, FIRST AMERICAN is entitled to summary judgment as to Count I as there
7 See n. 4, supra.
Page 11 of 19
is no genuine issue of material fact as to FIRST AMERICAN 's claim for Foreclosure of
Mortgage. The Court should grant FIRST AMERICAN 's Motion for Summary Judgment
as to Count I of the Verified Foreclosure Complaint.
(2) Rebuttal of The Oaks at Boca Raton Property Owners' Association, Inc.'s
Affirmative Defenses.
Defendant, THE OAKS AT BOCA RATON PROPERTY OWNERS'
ASSOCIATION , INC. (hereinafter "the ASSOCIATION"), administers a residential real
estate project known as Fox Hill Estates, which includes the residential property located
at 17685 Circle Pond Court, Boca Raton, Florida 33496-1002, which property is the
subject matter of this foreclosure action. The ASSOCIATION asserted three Affirmative
Defenses in its Answer and Affirmative Defenses [D.E. 12].
The ASSOCIATION 's First Affirmative Defense simply quotes Fla. Stat.
720.3085(2)(c), discussed in more detail infra. and is not a true affirmative defense. At
best, the ASSOCIATION's First Affirmative Defense attempts to set out a statement of
Florida law. That law, while it may ultimately prove to be applicable, simply does not, in
and of itself, constitute a cognizable affirmative defense. See Black's Law Dictionary 482
(91h ed . 2009) (An affirmative defense is "a defendant's assertion of facts and arguments
that, if true, will defeat the plaintiff's ... claims, even if all the allegations in the complaint
are true.").
In its Second Affirmative Defense, the ASSOCIATION states that it is entitled to
"judgment to the extent of its lien , plus accrued but unpaid assessments, interest, costs,
and attorneys' fees." However, Fla. Stat. §720.3085(2)(c) places a cap on the liability of
a foreclosing mortgagee. The safe harbor provision of Section 720.3085(2)(c), as it
concerns a first mortgagee ... who acquires title to a parcel by foreclosure" states that
Page 12 of 19
"the liability of the first mortgagee ... shall be the lesser of' either "unpaid common
expenses and regular periodic or special assessments that accrued or came due during
the 12 months immediately preceding the acquisition of title" or "one percent of the original
mortgage debt." Fla. Stat. §720.3085(2)(c)1-2. Given the plain language of Section
720.3085(2)(c) (and the fact that FIRST AMERICAN joined the ASSOCIATION as a
Defendant in this action), the ASSOCIATION is not entitled to interest, late fees,
attorney's fees and costs because the safe harbor provision of Section 720.3085 (2)(c)
applies. See Catalina W Homeowners Ass'n. Inc. v. Fannie Mae , 188 So. 3d 76, 81 (Fla.
3d DCA 2016).
The ASSOCIATION 's Third Affirmative Defense states that the ASSOCIATION
"may have an interest superior to that of Plaintiff pursuant to a special equity in the event
that the Plaintiff fails to timely foreclose, thereby prejudicing the rights of the
ASSOCIATION." Here, the ASSOCIATION is attempting to invoke a contingent
affirmative defense, dependent upon FIRST AMERICAN 's conduct in this action. In other
words, the ASSOCIATION is uncertain whether it "may have" the right to assert its
interest. Simply stated , like its First Affirmative Defense, the ASSOCIATION 's Third
Affirmative Defense is not a true affirmative defense.
Furthermore, pursuant to Section 5.10 of the ASSOCIATION 's Amended and
Restated Declaration of Covenants and Restrictions for The Oaks at Boca Raton
(hereinafter "Declaration"),
5.10 Subordination of the Lien . The lien of the Assessments provided for in
this Article shall be subordinate to ... the lien of any first mortgage held by
a Mortgage Lender ....
Page 13 of 19
Due to the voluminous nature of the Declaration, the pertinent portion of the Declaration
to this action is attached hereto as Exhibit "11." The Declaration was recorded on October
25, 2004 in Official Records Book 17679 at Page 0883 of the Public Records of Palm
Beach County, Florida. Accordingly, any lien asserted by the ASSOCIATION is
subordinate to FIRST AMERICAN 's Mortgage.
* * *
Court:
(a) adjudicate that FIRST AMERICAN has a valid lien on the Property that is
superior to any right, title, interest or claim of all Defendants and all persons
and entities claiming by, through or under them ;
(b) enter Final Judgment in favor of Plaintiff, FIRST AMERICAN BANK, and
against Defendant, LAURENCE S. SCHNEIDER,
a. for $1,488,554.76 in unpaid principal;
b. for $66,870.93 consisting of the Florida Ad Valorem/real property taxes
on the Property for 2014, 2015 and 2016;
c. for $64,304.08 in interest from March 16, 2016 through May 25, 2017;
and
d. post-judgment interest.
(c) enter Final Judgment foreclosing the Mortgage and determine that the rights ,
title and interest of any Defendant (or any party claiming by, through , under or
against any Defendant) be forever barred and foreclosed ;
Page 14 of 19
(d) direct the Clerk of Court to sell the Property which is the subject matter of this
foreclosure to satisfy FIRST AMERICAN's Mortgage lien in accordance with
the provisions of Fla. Stat. §45.031;
(e) direct the Clerk of Court that the proceeds of the sale, the amounts due and
owing to FIRST AMERICAN be paid in full, including reasonable attorneys'
fees, costs, expenses and pre-judgment and post-judgment interest;
(f) establish, if the proceeds of the sale of the Property being foreclosed are
insufficient to pay FIRST AMERICAN 's claim, a Deficiency Judgment against
the Defendant, LAURENCE S. SCHNEIDER;
(g) determine that FIRST AMERICAN is entitled to attorneys' fees, costs and
expenses incurred in connection with enforcing the terms, covenants,
conditions and agreements contained in the Mortgage; and
(h) retain jurisdiction to determine the total amounts of attorneys' fees , costs and
expenses to which FIRST AMERICAN is entitled.
C. Count II - Breach of Contract Against Defendant, Laurence 5. Schneider.
To establish a prima facie case for a breach of contract action, a plaintiff must
show: (1) a valid contract, (2) a material breach and (3) damages. J.J. Gumberg Co. v.
Janis Servs., Inc., 847 So. 2d 1048, 1049 (Fla. 41h DCA 2003). The Credit Agreement
states in pertinent part:
"Promise to Pay. [Defendant, LAURENCE S. SCHNEIDER] promise[s] to

pay [FIRST AMERICAN], or order, the total of all credit advances and
FINANCE CHARGES. Together with all costs and expenses for which you
are responsible under this Agreement or under the 'Mortgage' which
secures your Credit Line."
Page 15 of 19
"Credit Limit. This Agreement covers a revolving line of credit for the
principal amount of One Million Five Hundred Thousand & 00/100 Dollars
($1 ,500,000.00) , which will be your 'Credit Limit' under this Agreement."
Ex. "1" at p. 1. The Credit Agreement and the admissions made by Defendants in their
Answer to the Verified Foreclosure Complaint and Responses to FIRST AMERICAN's
Request for Admissions establish the undisputed facts that: (1) the Parties entered into a
valid contract, (2) Defendant, LAURENCE S. SCHNEIDER, defaulted under the Credit
Agreement and thereby breached the Credit Agreement by, inter alia,
(a) failing to pay the monthly interest payment due on May 1, 2016 and all
subsequent monthly payments;8
(b) failing to pay the entire balance owing in a single balloon payment on July 28,
2016·,9 and
(c) failing to pay the Florida Ad Valorem/real property taxes on the Property for
2014, 2015 and 2016 (on or about March 31, 2016, FIRST AMERICAN
advanced and paid the Florida Ad Valorem/real property taxes on the Property
for 2014 and 2015 in the amount of $46,148.17, and on or about January 4,
2017, FIRST AMERICAN advanced and paid the Florida Ad Valorem/real
property taxes on the Property for 2016 in the amount of $20,722.76). 10
8 See Ex. "1" at p. 1 ("Minimum Payment. Your 'Regular Payment' will equal the amount of your
accrued FINANCE CHARGES. You will make 119 of these payments . You will then be required to pay the
entire balance owing in a single balloon payment."). See also [D.E. 32, 111110 & 14 and D.E. 61 , 111110 &
14), Ex. "2" at pp. 13-14 and Ex. "4 ," 1111 .
9 See Ex. "1" at p. 1 ("Balloon Payment. Your Credit Line Account is payable, in full upon maturity
in a single balloon payment. You must pay the entire outstanding principal, interest and any other charges
then due."). Pursuant to the Credit Agreement, the "Maturity Date" was July 28, 2016. See also [D.E. 32,
111110 & 14 and 61 , 111110 & 14], Ex. "2 ," at p. 17 and Ex. "4 ," 1111 .
10 See Ex. "1" at p. 1 ("Charges to your Credit Line. We may charge your Credit Line to pay other
fees and costs that you are obligated to pay under this Agreement, the Mortgage or any other document
related to your Credit Line. .. . We may also, at our option, charge your Credit Line to pay any costs or
expenses to protect or perfect our security interest in your principal dwelling .... If you do not pay your
Page 16 of 19
and (3) that said breaches caused FIRST AMERICAN the following damages:
(a) $1 ,488,554.76 in unpaid principal;
(b) $66,870.93 in Florida Ad Valorem/real property taxes on the Property for 2014,
2015 and 2016;
(c) $64,304.08 in interest from March 16, 2016 through May 25, 2017; and
(d) post-judgment interest; and
(e) all costs , expenses and reasonable attorneys' fees incurred in connection with
enforcing the covenant, conditions and agreements contained in the Credit
Agreement;11
Thus, there is no genuine issue of material fact as to FIRST AMERICAN 's claim for breach
of contract against Defendant, LAURENCE S. SCHNEIDER. Accordingly, the Court
should grant FIRST AMERICAN's Motion for Summary Judgment as to Count II of the
Verified Foreclosure Complaint.
Court to enter Final Summary Judgment in favor of Plaintiff, FIRST AMERICAN BANK,
and against Defendant, LAURENCE S. SCHNEIDER:
(a) for $1 ,488,554.76 in unpaid principal;
(b) for $66,870.93 consisting of the Florida Ad Valorem/real property taxes on the
Property for 2014, 2015 and 2016;
(c) for $64,304.08 in interest from March 16, 2016 through May 25, 2017; and
property taxes, we may charge your Credit Line and pay the delinquent taxes."). See also Ex. "2," at pp.
15 & 25, Ex. "4," 1l1l11 &12, Ex."5," lnterrog. No. 4 and Ex. "6," Admissions Nos. 4 & 5.
11 See Ex. "1" at p. 4 (Collection Costs. "You will pay us the amount of these costs and expenses,
which include, subject to any limits under applicable law, our reasonable attorneys' fees and our legal
expenses ... . If not prohibited by applicable law, you also will pay any court costs, in addition to other sums
provided by law."). See also Ex. "4," 1f8.
Page 17 of 19
(d) post-judgment interest;
(e) determine that FIRST AMERICAN is entitled to attorneys' fees, costs and
expenses incurred in connection with enforcing the terms, covenants,
conditions and agreements contained in the Mortgage; and
(f) retain jurisdiction to determine the total amounts of attorneys' fees, costs and
expenses to which FIRST AMERICAN is entitled .
Page 18 of 19
WE HEREBY CERTIFY that a true and correct copy of the foregoing, First
American's Motion for Summary Judgment and Incorporated Memorandum of Law, was
delivered to: LAURENCE S. SCHNEIDER, ([email protected]), 360 E.
Coconut Palm Road, Boca Raton, FL 33432; STEPHANIE L. SCHNEIDER
([email protected]), 360 E. Coconut Palm Road, Boca Raton, FL 33432; and
JAYS. LEVIN , ESQ. ([email protected]) , Sachs, Sax, Caplan, Attorneys for
Oaks at Boca Raton, 6111 Broken Sound Parkway, N.W., #200, Boca Raton, FL 33487
via theE-filing Portal on this 251h day of May, 2017.
Page 19 of 19
Larry Schneider
From: Henry Bolz <h [email protected]>

Sent: Wednesday, May 24, 2017 11:22 AM
To: Larry Schneider
Cc: Carlos Molestina ([email protected])
Mr. Schneider,
I received your email of 3:16p.m. yesterday afternoon . I also received your email of this morning.
am happy to hear that your father's illness issues resolved favorably .
With respect to the inspection of the property being foreclosed , unfortunately, Mr. Molestina, upon
receiving your email yesterday, made other plans for this afternoon and cannot be available for
inspection this afternoon. Mr. Molestina advises, however, that he can be available at any
reasonable time tomorrow or Friday. Please let me know.
In the meantime, and as I stated in the telephone message that I have left for your earlier today, and
as I stated in my telephone messages yesterday (before sending you an email yesterday), it is
incumbent that you and I speak to agree on a hearing date for those pre-trial pleadings that we filed
yesterday.
In that regard , all of the Court's motion calendar slots for 8:45a.m. on June 8, 2017 that I mentioned
in my telephone messages to you yesterday are gone. The earliest possible hearing date that we can
now get is 8:45a.m. on Monday, June 12, 2017. Be advised that if I do not hear from you in
response to this email , my earlier emails and my series of unanswered telephone messages by noon,
it is my intention to unilaterally schedule our pleadings for hearing at 8:45a.m. on Monday, June 12,
2017.
Again, time is of the essence.
Regards,
Henry H. Bolz, III

Keller & Bolz, LLP
12 1 Majorca Avenue, #200
Telephone: (305) 529-8500
Telefax: (305) 529-0228
E-mail: hbolz{a)kellerbolz.com
IMPORTANT: THIS E-MAIL. AND ANY ATTACHMENTS THERETO. IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY TO W HICH IT IS
DELIVERING THE E-MA IL TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPYING OF
1
From: Larry Schneider [mailto:larrv@sacapita lpartners.com ]
Sent: Wednesday, May 24, 2017 10:47 AM
Subject: Fwd: First American Bank v. Schneider
Dear Mr. Bolz,
Things went as good as planned with my fathers medical issues. Thus, let's keep the inspection as planned for today.
Thank you,
Larry Schneider
Sent from my iPhone
Begin forwarded message:
From: Larry Schneider <larrv @sacapitalpartners.com>

Date: May 23, 2017 at 3:15:55 PM EDT
To: Henry Bolz <[email protected] >
Mr. Bolz,
I have been out of the office due to a family illness. My father is 92 and is suddenly not we ll. We have
an urgent appointment with his Urologist tomorrow. Thus, I do not know if I will be back in time for the
inspection. As such, please postpone the inspection fo r Wednesday, June 24, 2017. I'll get back to you
tomorrow and hopefully reschedule for later in the week.
Regards.
Lany Schneider
Cell (305) 7 10-4.201

Sent: Tuesday, May 23, 2017 11:49 AM
To: Larry Schneider
Mr. Schneider:
I need to speak with you briefly about (1) confirming tomorrow's inspection of the property in
foreclosure and (2) coordinating a hearing date for those two pleadings I sent to you earlier today. Time
is of the essence. Please call me when you get a minute.
Regards.
2
Henry H. Bolz, III
Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
IMPORTANT. THIS E-MAIL. AND ANY ATIACHMENTS THERETO. IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY TO
THIS E-MAIL IN ERROR. PLEASE IMMEDIATELY NOTIFY THE SENDER BY E-MAIL OR TELEPHONE (IF CONTACT INFORMATION IS
3
Larry Schneider

Sent: Wednesday, May 24, 2017 2:58 PM
To: Larry Schneider
Subject: RE: SERVICE OF COURT DOCUMENT- CASE NUMBER 502016CA009292XXXXMB
Attachments: 2017-05-01 Order Granting Trent's M2 Withd raw.pdf; 2017-03-22 M2 Withdraw .pdf;
2017-03-28 Order re M2 Inspect Property.pdf
Mr. Schneider,
I write this email to you in response to your four emails sent to me earlier today (at 11 :59 a.m., 12:21
p.m. , 12:43 p.m. and 1:20 p.m., respectively). Specifically, I want to provide you with those
documents and information that you requested . This email will also address the series of
mischaracterizations of that conversation that you and I had on Monday, May 15, 2017.
You are correct in identifying the Motion and Notice that our office filed yesterday and which we
noticed for hearing at 12:50 p.m. today. I would point out, however, that it was only after you ignored
my repeated telephone messages and emails seeking to coordinate the hearing (and after your wife
noticed her Motion to Drop Party and/or Dismiss Case on June 12, 2017) that we set the hearing.
In accordance with your request, I attach a copy of Judge Ferrara 's May 1, 2017 Order Granting
Attorney Trent's Motion to Withdraw. I also attach a copy of Attorney Trent's Motion for Withdraw
which was dated/served on March 22, 2017.
I have no idea what, if anything, Attorney Trent might have told you about what occurred at the May
1, 2017 hearing. The statement in your 12:01 p.m . email from earlier today indicates " ... that there
were to be no filings for 20 days to allow me to obtain new counsel. " Your understanding is
51
incorrect. Language in the proposed Order that Attorney Trent presented to Judge Ferrara on May 1
allowed you 20 days to obtain new counsel. Judge Ferrara specifically and unequivocally struck that
paragraph from Attorney Trent's proposed Order. Towards the end of the May 1, 2017 hearing,
Judge Ferrara asked me if, as a matter of courtesy, First American Bank would refrain from
scheduling any hearings for 20 days (through Sunday, May 21 , 2017). I agreed with that request
from the Court. First American Bank had a Court Reporter attend the hearing and you should feel
free to order the transcript of the hearing . At no time during the May 1, 2017 hearing (or thereafter)
did I ever agree to refrain from filing any additional pleadings, motions, etc. So that there is
absolutely no doubt, since May 1, 2017, both you and your wife have been representing yourselves
prose.
When you and I spoke on May 15, 2017, you did mention to me that you were continuing to attempt
to locate counsel to replace Attorney Trent. In response, I made it perfectly clear to you that you
were welcome to obtain replacement counsel or not, in accordance with your wishes and that you
could take as much time as you desired . I also pointed out that until and unless replacement counsel
appeared, First American Bank/Keller & Bolz, LLP had no choice but to deal with you directly. At no
time during our conversation did I agree to stay any aspect of this case while you seek out
replacement counsel.
Shortly stated , you are welcome to take as much time as you like in interviewing and engaging
replacement counsel. Do not, however, expect that this office or our client are going to allow this
1
case to be placed "on hold" while you go through that exercise. While the statement in your 11 :59
a.m. email to me "... you seemed to be receptive in allowing me to engage counsel" is correct (a
competent/professional attorney representing an adversary in litigation is invariably helpful), you
have known since March 22, 2017 that Attorney Trent was withdrawing as your legal counsel
in this litigation. While you have elected to allow two months to transpire without undertaking
any efforts to obtain replacement counsel, do not attempt to visit that inaction on your part on
our client.
We are scheduled to have a series of pre-trial matters heard/considered by Circuit Court Judge
Ferrara at 8:45 a.m. on Monday, June 12, 2017. Your deposition is scheduled for Tuesday, June 13,
2017, beginning at 9:30a.m. Your wife's, Stephanie Schneider, deposition is scheduled for
Wednesday, June 14, 2017, beginning at 9:30a.m. This foreclosure case is sched uled for trial
beginning on June 28, 2017. Insofar as our office is concerned , all of these events will go forward as
scheduled .
When can you arrange for Carlos Molestina to inspect the property being foreclosed? A copy of the
Court's March 28, 2017 Order in this regard is attached .
Finally, I take this opportunity to advise that any and all future communications between us
(pending your retention and the appearance of new counsel) must occur only in writing. I will
not be speaking with you further on the telephone.
Govern yourself accordingly.
Henry H. Bolz, III

Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
IMPORTANT· THIS E-MAIL. AND ANY ATTACHMENTS THERETO. IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS
APPLICABLE LAW. IF T HE READER OF THIS E-MAIL IS NOT THE INTENDED RECIPIENT, OR THE EMPLOYEE OR AGENT RESPONSIBLE FOR
E-MAIL OR TELEPHONE (IF CONTACT INFORMATION IS PROVIDED} AND PERMANENTLY DELETE THE ORIGINAL OR ANY PRINTOUT T HEREOF.
From: Larry Schneider [mailto: la rry@sa capitalpartners.com]

Sent: Wednesday, M ay 24, 2017 1:20PM
To: Henry Bolz <hbolz@ kellerbolz.com>
Subject: FW: SERVICE OF COURT DOCU M ENT - CASE NUMBER 502016CA009292XXXXM B
Importance: High
Mr. Bolz,
Did you just file this motion for a hearing, after I responded to your email, in writing, within the narrow 38 minute
window of opportunity to respond(attached) . I need these answers in writing, as I do not understand what is happening
and need to provide communications to new counsel upon engagement, so that they can understand everything that is
transpiring. It seems like you are purposely taking these actions and filing this flurry of activity while you were aware
that I was obtaining counsel by the end of this week and you agreed to allow me the time to do such .
2
Please confirm that this is a motion that you filed at 12:50 p.m . today. Although you did not provide me with a read
receipt of the email, Carlos Molina did . I have attached this for your records.
Once again, I stress the urgency in your responding to my emails, so I can engage counsel and receive proper
representation under the law. This is very frustrating.
Regards.
Larry Schneider
Boca Raton. FL 334 96
Cell (30 5) 71 0-4201
From: [email protected] [ mailto :[email protected]]

Subject: SERVICE OF COURT DOCUMENT - CASE NUMBER 502016CA009292XXXXMB
Notice of Service of Court Documents
Filing Information
Filing#: 56863923
Filing Time: 05/24/2017 12:50:00 PM ET
Filer: Henry H Bolz III 305-529-8500
Court: Fifteenth Judicial Circuit in and for Palm Beach County, Florida
Case#: 5020 16CA009292XXXXMB
Court Case#: 50-20 16-CA-009292-XXXX-MB

Case Style: FIRST AMERICAN BANK - SCHNEIDER, LAURENCE S
Documents
Title File
!Notice Of Hearing 2017-05-24 NOH - M4 Spec Set Trial-N-Unav:
E-service recipients selected for service:
!Email Address
3
Name Email Address
Henry H Bolz III hbolz(@kellerbolz.com
[email protected]
Laurence and Stephanie Schneider [email protected]
Jay Samuel Levin [email protected]
[email protected]
[email protected]
Brent Tantillo [email protected]
Stephanie L Schneider steffschneider 13@!lmail.com
E-service recipients deselected for service:
Name Email Address

Kenneth E Trent [email protected]
Stuart S. Mermelstein smermelstein_@hermanlaw .com
mconnor@hermanlaw .com
This is an automatic email message generated by the Florida Courts E-Filing Portal. This
email address does not receive email.
Thank you,
The Florida Courts E-Filing Portal
request_ id#: 56863923;Audit#: 194179666;UCN#: 502016CA009292XXXXMB;
4
Larry Schneider

To: Larry Schneider
Subject: RE: SERVICE OF COURT DOCUMENT - CASE NUM BER 502016CA009292XXXXMB
Attachments: 2017-05-01 Order Granting Trent's M2 Wit hdraw.pdf; 2017-03-22 M2 W ithdraw.pdf;
2017-03-28 Order re M2 I nspect Property.pdf
Mr. Schneider,
I write this email to you in response to your four emails sent to me earlier today (at 11 :59 a.m., 12:21
p.m. , 12:43 p.m. and 1:20 p.m., re~pectively). Specifically, I want to provide you with those
documents and information that you requested. This email will also address the series of
You are correct in identifying the Motion and Notice that our office filed yesterday and wh ich we
my repeated telephone. messages and emails seeking to coordinate the hearing (and after your wife
In accordance with your request, I attach a copy of Judge Ferrara's May 1, 2017 Order Granting
which was dated/served on March 22, 2017.
.. I have no idea what, if anything, Attorney Trent might have told you about what occurred at the May
1, 2017 hearing . The statement in your 12:01 p.m. email from earlier today indicates " ... that there
were to be no filings for 20 days to allow me to obtain new counsel. " You r understanding is
incorrect. Language in the proposed Order that Attorney Trent presented to Judge Ferrara on May 1 st
paragraph from Attorney Trent's proposed Order. Towards the end of the May 1, 2017 hearing ,
Judge Ferrara asked me if, as a matter of courtesy, First American Bank ~ou ld refrain from
scheduling any hearings for 20 days (through Sunday, May 21 , 2017). I agreed with that request
free to order the transcript of the hearing. At no time during the May 1, 2017 hearing (or thereafter)
absolutely no doubt, since May 1, 2017, both you and your wife have been representing you rselves
prose.
When you and I spoke on May 15, 2017, you did mention to me that you were continu ing to attempt
to locate counsel to replace Attorney Trent. In response, I made it perfectly clear to you that you
could take as much time as you desired. I also pointed out that until and unless replacement counsel
appeared , First American Bank/Keller & Bolz, LLP had no choice but to deal with you directly. At no
replacement counseL
Shortly stated , you are welcome to take as much time as you like in interviewing and engaging
replacement counsel. Do not, however, expect that this office or our client are going· to allow this
1
a.m. email to me " ... you seemed to be receptive in allowing me to engage counsel" is correct (a
any e.fforts to obtain replacement counsel, do not attempt to visit that inaction on your part on
our client.
Ferrara at 8:45a.m. on Monday, June 12, 2017 . Your deposition is scheduled for Tuesday, June 13,
Wednesday, June 14, 2017, beginning at 9:30a.m. This foreclosure case is scheduled for trial
beginning on June 28, 2017. Insofar as our office is concerned , all of these events will go forward as
scheduled.
Henry H. Bolz, III

Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
IMPORTANT: THIS E-MAIL. A ND ANY ATTACHMENTS THERETO IS INTENDED FOR THE USE OF THE INDIVI DUAL OR ENTITY TO W HICH IT IS
ADDRESSED AND MAY CONTAIN INFORMATION THAT IS LEGALLY PRIVILEGED. CONFIDENT IAL A ND EXEMPT FROM DISCLOSURE UNDER
APPLICABLE LAW. IF THE READER OF THIS E-MAIL IS NOT THE INTENDED RECIPIENT, OR THE EMPLOYEE O R AGENT RESPONSIBLE FOR
DELIVERING THE E-MA IL 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-MAI L IN ERROR. PLEASE IMMEDIAT ELY NOTIFY THE SENDER BY
E-MA IL OR TELEPHONE (IF CONTACT INFORMATIO N IS PROVIDED) AND PERMANENTLY DELETE THE ORIGINAL OR ANY PRINTOUT THEREOF.

Sent: Wednesday, May 24, 2017 1:20PM
Subject: FW : SERVICE OF COURT DOCUMENT - CASE NUMBER 502016CA009292XXXXMB
Importance: High
Mr. Bolz,
window of opportunity to respond(attached). I need these answers in writing, as I do not understand what is happening
that I was obtaining counsel by the end of this week and you agreed to allow me the time to do such.
2
Larry Schneider

To: 'Henry Bolz'
Subject: RE: First American Bank v. Laurence and Stephanie Schneider - Foreclosure
Attachments: First American Bank v. Laurence and Stephanie Schneider- Foreclosure
M r. Bolz,
I am gathering the remainder of our communications for my new counsel, as we've previously discussed. In the email
below, you refer to the Court's May 1st, 2015 order granting Mr. Trent's withdrawal. Please provide me with a copy of
that order, as you acknowledge in your May 4th, 2017 email below, that Mr. Trent was no longer my counsel as of May 1,
2017.
Regards.
Larry Schneider
Cell (305) 710-4201
From: Henry Bolz [ mailto:[email protected]]

To: Larry Schneider
Subject: First American Bank v. Laurence and Stephanie Schneider- Foreclosure
This email follows up on our email to Attorney Kenneth Eric Trent, dated April17, 2017 (attached),
and the Court's May 15 \ 2017 Order granting Attorney Trent's Motion to Withdraw. We are seeking
both of your cooperation and assistance in the following :
(1) Depositions. We want to schedule and take your depositions in the middle of June 2017, in
West Palm Beach. We expect that Mr. Schneider's deposition will take a full day; Mrs.
Schneider's deposition should only take about half a day. Please provide some dates on which
the depositions can be scheduled and taken.
(2) Trial Date. We are going to notice the case for trial. We anticipate that the trial will last about
a day or a day and half. In accordance with the applicable Palm Beach County Foreclosure
Court rules, please provide the number of witnesses you intend to call and the amount time
you expect the trial will last.
Regards,
1
Henry H. Bolz, Ill
Keller & Bolz, LLP
Telephone: (305) 529-8500
T elefax: (305) 529-0228
IMPORTANT: THIS E-MAIL, AND ANY ATIACHMENTS THERETO. IS INTENDED FOR THE USE
2
Larry Schneider

Subject: FW: SERVICE OF COURT DOCUMENT- CASE NUMBER 502016CA009292XXXXMB
Attachments: Notice Of Unavailability.pdf; Motion.pdf
Mr. Bolz,
Is this the motion that you we re refe rring to in your email today, in which you gave me 38 minutes to reply? I just need
to understand what' s goi ng on, as I certainly do not. You've filed a lot of stuff in the past couple weeks .. . Especially
given that we had spoken about my being in Phoenix all last week and that you agreed to allow me time to obtain
counsel by the end of this week.
Regardless, please confirm that these are the motion that you are referring to.
Regards.
Larry Sclmeider
2901 Clint Moore Road. Suite 4 10
Cell (30 5) 710-420 1
From: [email protected] [mailto:[email protected]]

Sent: Tuesday, May 231 2017 11 :28 AM
Filing Information
Filing #: 56793353
F iling Time: 05/23/2017 11:28:09 AM ET
Filer: Henry H Bolz Ill 305-529-8500
Case # : 5020 16CA009292XXXXMB
Court Case # : 50-20 16-CA-009292-XXXX-MB
Case Style: FlRST AMERICAN BANK- SCHNEIDER, LAURENCE S
Documents
Title File
!Notice Of Unavai lability 20 17-05-23 N-Unavailability.pdf
Motion 2017-05-23 M4 Special Set Trial Date.pdf
Name Email Address
Henry H Bolz III hbolz(a),kellerbolz.com

ahart@,kellerbolz.com
Laurence and Stephanie Schneider larrv@,sacaoitaloartners.com
Jay Samuel Levin ·levin(a),ssclawfirm.com
foreclosures(a),ssclawfirm.com
·avlevin.esq(a),gmail.com
INa me Email Address

Kenneth E Trent trentlawoffice(a),yahoo.com
Stuart S. Mermelstein smermelstein(a),hermanlaw .com
mconnor@,herman law.com
This is an automatic email message generated by the Florida Courts E-Filing Portal. This
email address does not receive email.
Thank you,
request_ id#: 56793353;Audit#: 193944313;UCN#: 502016CA009292XXXXMB;
2
Larry Schneider

Subject: FW: SERVICE OF COURT DOCUMENT - CASE NUMBER 502016CA009292XXXXMB
Attachments: Notice Of Hearing.pdf; RE: First American Bank v. Schneider; Read: RE: First American
Bank v. Schneider
Importance: High
Follow Up Flag: Follow up

Flag Status: Flagged
Mr. Bolz,
Did you just file this motion for a hearing, after I responded to your email, in writing, w ithin the narrow 38 minute
window of opportunity to respond(attached). I need these answers in writing, as I do not understand what is happening
transpiring. It seems like you are purposely taking th ese actions and filing this flurry of activity while you were aware
Please confirm that this is a motion that you filed at 12:50 p.m. today. Although you did not provide me w ith a read
receipt of the email, Carlos Molina did . I have attached this for your records.
Once again, I stress the urgency in your responding to my emails, so I can engage counsel and receive proper
representation under the law. This is very frustrating.
Regards.
Larry Sclmcider
2901 Clint Moore Road, Suite 4 10
Cell (30 5) 7 10 - 4201

Filing Information
Filing #: 56863923
1
Filing Time: 05/24/2017 12:50:00 PM ET
Case #: 502016CA009292XXXXMB
Court Case #: 50-20 16-CA-009292-XXXX-MB
Case Style: FIRST AMERJCAN BANK - SCHNEIDER, LAURENCE S
Documents
Title File
[Notice OfHearing 2017-05-24 NOH- M4 Spec Set Trial-N-Unavail
Name Email Address
Henry H Bolz III hbolz(a)kellerbolz.com
ahart(a)kellerbo lz.com
Larry Schneider

Sent: Thursday, May 25, 2017 5:45 PM
To: 'Henry Bolz'
Mr. Bolz,
As I reiterate, I am not an attorney and I plan to engage counsel as I've repeatedly indicated . However, I cannot
understand what the difference is between " scheduling a hearing" and "filing any additional pleadings, motions, etc."
" Towards the end of the May 1, 2017 hearing, Judge Ferrara asked me if, as a matter of courtesy, First American
Bank would refrain from scheduling any hearings for 20 days {through Sunday, May 21, 2017}. I agreed with that
request from the Court. 11
"At no time during the May 1, 2017 hearing (or thereafter) did I ever agree to refrain from filing any additional
pleadings, motions, etc.II
It seems very deceptive and unethical, as I believe a motion for trial is scheduling a hearing. I would think the Judge
Ferrara specifically requested the 20 day courtesy for the exact type of conduct which you've displayed in this matter.
Please govern yourself accordingly.
Regards,
Larry Schneider
2901 Clint Moore Road , Suite 4 10
Cell (30 5) 710- 4 201

To: Larry Schneider
Mr. Schneider,
I write this email to you in response to your four emails sent to me earlier today (at 11:59 a.m. , 12:21
p.m., 12:43 p.m. and 1:20 p.m., respectively). Specifically, I want to provide you with those
1
documents and information that you requested . This email will also address the series of
You are correct in identifying the Motion and Notice that our office filed yesterday and which we
my repeated telephone messages and emails seeking to coordinate the hearing (and after your wife
In accordance with your request, I attach a copy of Judge Ferrara's May 1, 2017 Order Granting
which was dated/served on March 22 , 2017.
I have no idea what, if anything, Attorney Trent might have told you about what occurred at the May
1, 2017 hearing. The statement in your 12:01 p.m . email from earlier today indicates " ... that there
were to be no filings for 20 days to allow me to obtain new counsel. " Your understanding is
51
incorrect. Language in the proposed Order that Attorney Trent presented to Judge Ferrara on May 1
paragraph from Attorney Trent's proposed Order. Towards the end of the May 1, 2017 hearing,
Judge Ferrara asked me if, as a matter of courtesy, First American Bank would refrain from
scheduling any hearings for 20 days (through Sunday, May 21 , 2017) . I agreed with that request
free to order the transcript of the hearing . At no time during the May 1, 2017 hearing (or thereafter)
absolutely no doubt, since May 1, 2017, both you and your wife have been representing yourselves
prose.
When you and I spoke on May 15, 2017, you did mention to me that you were continuing to attempt
to locate counsel to replace Attorney Trent. In response , I made it perfectly clear to you that you
could take as much time as you desired . I also pointed out that until and unless replacement counsel
appeared , First American Bank/Keller & Bolz, LLP had no choice but to deal with you directly. At no
replacement counsel.
Shortly stated, you are welcome to take as much time as you like in interviewing and engaging
replacement counsel. Do not, however, expect that this office or our client are going to allow this
a.m. email to me " ... you seemed to be receptive in allowing me to engage counsel" is correct (a
any efforts to obtain replacement counsel, do not attempt to visit that inaction on your part on
our client.
Ferrara at 8:45a.m. on Monday, June 12, 2017. Your deposition is scheduled for Tuesday, June 13,
Wednesday, June 14, 2017, beginning at 9:30a.m . This foreclosure case is scheduled for trial
beginning on June 28, 2017. Insofar as our office is concerned, all of these events will go forward as
scheduled .
2
Henry H. Bolz, III

Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
From: Larry Schneider [mailto :larry@saca pitalpartners.com]

Subject: FW: SERVICE OF COURT DOCUMENT- CASE NUMBER 502016CA009292XXXXMB
Importance: High
Mr. Bolz,
window of opportunity to respond( attached). I need these answers in writing, as I do not understand what is happening
and need to provide communications to new counsel upon engagement, so that they can understand everything tha t is
Please confirm that this is a motion that you filed at 12:50 p.m. today. Although you did not provide me with a read
receipt of the email, Carlos Molina did. I have attached this for your records.
Once agai n, I stress the urgency in your responding to my emails, so I can engage counsel and receive proper
representation under the law. This is very f rustrating.
Regards,
Larry Schneider
Cell(305)710-4201
3
Filing Information
Filing#: 56863923
Filing Time: 05/24/2017 12:50:00 PM ET
Case#: 5020 16CA009292XXXXMB
Court Case #: 50-20 16-CA-009292-X:XXX-MB
Case Style: FIRST AMERICAN BANK- SCHNEIDER, LAURENCE S
Documents
Title File
Notice Of Hearing 20 17-05-24 NOH - M4 Spec Set Trial-N-Unav:
Name Email Address
Henry H Bolz III [email protected]
[email protected]
Laurence and Stephanie Schneider [email protected]
Jay Samuel Levin "[email protected]
forecl osures@ssclawfirm. com
·avlevin.esa fa2!!mail.com
Stephanie L Schneider [email protected]

4
Name Email Address
Kenneth E Trent [email protected]
StuartS. Mermelstein [email protected]
[email protected]
This is an automatic ema il message generated by the Florida Cou rts E-Filing Portal. Th is
email address does not rece ive email.
Than k you,
request_ id#: 56863923 ;Audit#: 194179666;UCN # : 502016CA009292XXXXMB;
5
Larry Schneider

To: Larry Schneider; Stephanie Schneider (steffschneider13 @gma il.com)
Subject: First American Bank v. Schneider et al.
In accordance with the Court's procedures, we are attempting to coordinate a hearing on the Motion
for Summary Judgment (filed yesterday). The earliest possible hearing date that we can now get is
1:30 p.m. or 2:30p.m. on Monday, June 26, 2017. Please let us know (by noon) if you can attend the
hearing on June 26, 2016 and at what time.
Regards.
Henry H. Bolz, Ill

Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
IMPORTANT: THIS E-MAIL. AND ANY ATTACHMENTS THERETO. IS INTENDED FOR THE USE
1
Larry Schneider

To: Larry Schneider; Stephanie Schneider ([email protected])
Subj ect: First American Bank v. Schneiders - Compliance with Trial Order
Attachments: 2017-05- 16 Order Setting Trial.pdf
Palm Beach County Circuit Court Judge James Ferrara's May 16, 2017 Trial Order (copy attached for ease of reference)
requ ires that by no later than t he 201h business day prior to trial, "the parties shall confer" to discuss settl ement, simplify
the issues and discuss objections to t rial exhibits.
It is my intent ion t o set up a conference call by and bet w een the three of us at 10:00 a.m. today. We would greatly
appreciate it if you would attempt to make you rselves available to participate in a short conference call at that time.
Regards,
Henry H . Bolz, III

Keller & Bolz, LLP
A!to~J -r;-;~ \
Telephone: (305) 529-8500
~;~~~
Telefax: (305) 529-0228
IMPORTANT: THIS E-MAIL, AND ANY ATIACHMEN"

ADDRESSED AND MAY CONTAIN INFORMATION T
r~-r-~ OR ENTITY TO WHICH IT IS
ROM DISCLOSURE UNDER
APPLICABLE LAW.I F THE READER OF THIS E-MA \GENT RESPONSIBLE FOR
DELIVERING THE E-MAIL TO T HE INTENDED RECI 1N, DISTRIBUTION OR COPYING OF
THIS COMMUNICATION IS STRICTLY PROHIBITEC AEDIATELY NOTIFY THE SENDER BY
E-MAIL OR T ELEPHONE (IF CONTACT INFORMATI • OR ANY PRINTOUT THEREOF.
1
Larry Schneider

To: Henry Bolz
Subject: RE: First American Bank v. Schneider et al.
Mr. Bolz,
I am unavailable from between June 26, 2017 and July 5, 2017.
As you are aware, your unrelenting actions and filings in this matter, especially in the past month, while I have been
attempting to retain counsel in this matter, continues to prejudice my ability to engage competent counsel. As such, I
request that you not file any additional actions in this matter for ten business days, so that I can get proper legal
representation in this matter.
Furthermore, as you are aware, my prior counsel in this matter, Mr. Trent has been problematic in my representation
and has specifically NOT informed me of the numerous communications and gyrations in this litigation. I have
requested that Mr. Trent immediately provide me with all communications between him/his office and you/your firm in
this matter. Several attorneys who I have spoken to, are weary of taking this case due to the circumstances which had
occurred in the past with prior counsel and the rate in which you are fast tracking this foreclosure action. Mr. Trent has
provided me with what I believe is a fraction of the communications between your firms.
As such, please send me a copy of all communications, correspondences or otherwise between you and or your office,
both to and from my formal counsel Mr. Trent. Let me know if there is a fee you will charge for this and how much the
total cost wi ll be, prior to providing me with the communications. For the above mentioned reasons, I request that you
please refrain from making any unnecessary addition filings, pleadings, hearings or otherwise for five business days from
being provided with the totality of the communications between you and your firm and Mr. Trent and his
firm. Likewise, I have made a request to Mr. Trent for a complete copy of my entire case file including all
communications with opposing counsel. I have not yet received a reply from him.
If you are unable or unwilling to assist me in providing the communications, please let me know immed iate ly. Without
the communications, I am not able to obtain competent counsel, as they have concerns of communications which I am
not aware of, which may have adversely affected my representation in this matter.
Again, for the above mentioned reasons, I do not agree to the proposed hearing for the Motion for Summary
Judgment. Please confirm that you are in receipt of the First Request For Production which I sent on April 24, 2017, and
when we can expect to receive FAB's responses to these requests.
Sincerely,
Larry Schneider
305-710-4201
[email protected]
1
Sent: Friday, May 26, 2017 9:53AM
To: Larry Schneider <larry@sacapita lpartners.com>; Stephanie Schneider ([email protected] )
<[email protected]>
Subject: First American Bank v. Schneider et al.
In accordance with the Court's procedures, we are attempting to coordinate a hearing on the Motion
for Summary Judgment (filed yesterday). The earliest possible hearing date that we can now get is
1:30 p.m . or 2:30p.m. on Monday, June 26, 2017. Please let us know (by noon) if you can attend the
hearing on June 26, 2016 and at what time.
Regards.
Henry H. Bolz, Ill

Keller & Bolz, LLP
Telephone: (305) 529-8500
T elefax: (305) 529-0228
IMPORTANT: THIS E-MAIL. AND ANY ATIACHMENTS THERETO. IS INTENDED FOR THE USE
2
Larry Schneider

Sent: Tuesday, June 13, 2017 1:58 PM
To: Henry Bolz
Subject: Schneider/ FAB
Mr. Bolz,
I hope that you had a productive trip to Newark last week and returned safely.
Wearing my hat as the borrower in this matter, please provide me with detailed payoff figures for the HELOC, which
specifically breaks out the outstanding principal balance, interest rate, per diem, late charges, corporate advances, legal
fees, costs and any other line items utilized in calculating the payoff figures. Also, please break down the nature and
scope of each, billing increment periods by which you billed, along with the hourly rates which you command and in
which any of the other attorney's, paralegals and anyone else who aided you in the prosecution have billed. Also, please
notate as whether any of the costs or fees are not recoverable per the terms of the HELOC between Schneider and FAB.
Additionally, we have not received the history of billing statements sent by FAB in this matter between January 2015
through June 2017.
We look forward to your cooperation so we can bring this litigation to a timely and efficient resolution ofthe matters
involved.
Larry Schneider
305-710-4201
[email protected]
1
Larry Schneider

To: Henry Bolz
Cc: Stephanie Schneider ([email protected]); Jay Levin, Esq.; Jay Levin Esq.
([email protected])
Subject: Re: First American Bank v. Schneider, et al. - Palm Beach Circuit Court Case No.
2016-009292
Mr. Bolz,
As I had explained to you, I am in Phoenix doing depositions and will not be back in town until Thursday of next week.
Please note that I will be filing a notice with the court.
Additionally, you have refused to produce any billing statement or any Request for Production.
Sincerely,
Late Schneider
Sent from my iPhone
On Jun 23, 2017, at 7:25AM, Henry Bolz <[email protected]> wrote:
Although you may have already seen it, we attach a copy of United States District Court Judge Donald
Middlebrooks' June 22, 2017 Order remanding the Foreclosure Litigation back to Circuit Court.
The Order Remanding Case to State Court has been filed with the Circuit Court and the Circuit Court
again has jurisdiction over the Foreclosure Litigation .
We are advised by the Circuit Court that First American Bank's Motion for Summary Judgment (bearing a
Certificate of Service date of May 25, 2017) remains scheduled to be heard by the Circuit Court at 2:30
p.m. on Monday, June 26, 2017. 45 minutes has been set aside for this hearing. A copy of Judge
Ferrara's June 2, 2017 Order Special Setting Hearing is attached for ease of reference .
Regards,
Henry H. Bolz, III

Keller & Bolz, LLP
Telephone: (305) 529-8500
Telefax: (305) 529-0228
1
IMPORTANT: THIS E-MAI L. AND ANY ATTACHM ENTS THERETO. IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY TO
<#9 Order of Remand 06-22-17.pdf>

<2017-06-02 Order Spc Set Hrg- MSJ.pdf>
2
Filing # 59196320 E-Filed 07/18/2017 10:27:51 PM
EXHIBIT I
Larry Schneider
From: Kenneth Eric Trent, P.A. <[email protected] >

Sent: Thursday, March 09, 2017 11:49 AM
To: Larry Schneider; ,
Subject: Fw: First America n Bank v. Schneider
Attachments: 2017-02 -23 N-of Filing Aff.pdf
Kenneth Eric Trent, P.A.

831 E. Oakland Park Blvd .
Ft. Lauderdale, FL 33334
(954) 567-5877-phone
(954) 567-5872 fax
[email protected]
www.foreclosuredestroyer.com
----- Forwarded Message -----

To: "Kenneth Trent Esq . ([email protected])" <[email protected]>
Sent: Thursday, March 9, 2017 9:36 A M
Attorney Trent,
Carlos Molestina is First American Bank's Brokers Sales Manager. His January 19, 2017 inspection
of the Schneider's residence at 17685 Circle Pond Road was informal.
His hand-written notes and communications with me constitute either work product or attorney-client
privilege and will not be produced. Carlos Molestina's Affidavit dated February 23, 2016 which we
filed with the Court on that same date (you were provided with a copy) , constitutes his inspection
report. In an abundance of caution, our Notice of Filing, his Affidavit (and his photographs) are
attached for your ease of reference.
At this point in time, we are intending to call Mr. Molestina as a witness at the March 28, 2017
hearing. In order for Mr. Molestina's testimony to be meaningful, it will be necessary for him to revisit
the property. Again , can you provide us with a time and date between Monday, March 20, 2017, and
Thursday, March 23, 2017 when Mr. Molestina can revisit the residence?
Regards,
Henry H. Bolz, III

Keller & Bolz, LLP
12 1 Maj orca A venue, #200
Telephone: (305) 529-8500
Telefax: (305) 529-0228
1
Filing # 52905246 E-Filed 02/23/2017 03:45:47 PM

CASE NO.: 502016-CA-009292
DIVISION AW

Coral Gables, LLC ,
Plaintiff,
v.
JEFFREY MARC HERMAN ,
TENANT #2 and THE
OAKS AT BOCA RATON PROPERTY
OWNERS' ASSOCIATION, INC .,
Defendants.
__________________________./
NOTICE OF FILING
AFFIDAVIT
undersigned counsel, and in accordance with the applicable Florida Rules of Civil
Procedure, hereby gives notice to the Court and all counsel of the filing of the Affidavit of
Carlos Molestina in support of Plaintiffs Renewed Verified Petition for Appointment of
Receiver which is scheduled be to heard before this Court on March 28, 2017 at 1:00
o'clock p.m.
KELLER & BOLZ, LLP

Telephone: (305) 529-8500
Telefax: (305) 529-0228

Henry H. Bolz, Ill
Filing Affidavit was delivered to: KENNETH ERIC TRENT, ESQ.
([email protected]) , Trent Law Office, Attorneys for Laurence and Stephanie
Schneider, 831 East Oakland Park Blvd., Fort Lauderdale, FL 33334; STUART S.
MERMELSTEIN , ESQ. ([email protected] , [email protected]),
Herman Law, Attorneys for Jeffrey Herman, 3351 NW Boca Raton Blvd., Boca Raton, FL
33431 ; and JAYS. LEVIN , ESQ. ([email protected]) , Sachs, Sax, Caplan ,
Attorneys for Oaks at Boca Raton, 6111 Broken Sound Parkway, N.W., #200, Boca
Raton, FL 33487 via the E-filing Portal on this 23rd day of February, 2017.
KELLER & BOLZ, LLP

Henry H. Bolz, Ill
2
AFFIDAVIT
STATE OF FLORIDA
: SS
COUNTY OF MIAMI-DADE
BEFORE ME, the undersigned authority, personally appeared Carlos E. Molestina,
who being duly sworn does depose and state as follows:
1. I am over the age of 21 years old , sui juris and competent to make this
Affidavit.
2. I am presently employed by First American Bank's Coral Gables, Florida
branch where I work as the Brokers Sales Manager. Among my job duties are the
physical inspection of properties in which First American Bank has an interest or is
considering obtaining an interest in.
3. The matters set forth in this Affidavit are based on my personal knowledge.
4. I make this Affidavit based on that physical inspection that I made of the
residential premises located at 17685 Circle Pond Court, Boca Raton, Florida 33496
("Property" or "Residence") on January 19, 2017.
5. In the early .afternoon of Thursday, January 19, 2017, I was escorted into
the gated community in which the Property to be inspected is located by an individual
who identified himself to me as Laurence Schneider.
6. When Mr. Schneider attempted to gain access to the Residence through
the garage, it was determined that the garage door was inoperable. After we got into the
Residence through the front door, it was determined that the electrical power had been
shut off to the Residence (for reasons unknown to the undersigned).

7. As a result of the power being off, there was no air conditioning or air
circulating within in the Residence. Because of loss of electrical service to the Property,
I could not determine whether any of the appliances or light fixtures in the residence
worked .
8. There was no personal property or furniture in the Residence and it was
clear that the Property had been unoccupied for some months.
9. On the initial approach to the Property, it was noted that the exterior of the
Property was not being maintained. Specifically, the grass on the Property was not
properly mowed and grass was non-existent where it should have been.
10. There were a lot of bushy/overgrown/dried out plants which included
bougainvillea, palm trees and unclipped shrubbery. See illustrative photographs attached
as Composite Exhibit "A".
11. The exterior swimming pool of the Residence was fairly clear but had a good
number of leaves and debris in it. It was evident that because the electricity to the
Property had been turned off, the pool's pump/filtration system/cleaning/straining system
was not operating. See illustrative photographs attached as Composite Exhibit "8".
12. On a number of walls on the exterior of the Residence, there were large
areas of cracked and peeling paint which was falling off. In addition, there were numerous
areas where the exterior paint on the Residence where mold and/or mildew had grown
as a result of inattention. In a number of areas of the exterior of the house, the paint was
marred by water stains, dripping water and/or debris. See illustrative photographs
attached as Composite Exhibit "C".
2
SWORN TO AND SUBSCRIBED befor
My Comm(s ·on Expires:
SEAL
Personally known to me
Produced
---------------------- as identification
Took an Oath
Did not take an Oath
3
CoM P.
;.A~~
e._ X.r-1 .
C.o ,u r . [__¥- .f-J .
''b''
, I ,, II' '
I ,,
. I
\
\
C Q (v\. ? ·t._'i H .
if c \1
, ,.,.
,
.
)
/
Filing# 54066120 E-Filed 03/22/2017 01:44:17 PM
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN

AND FOR PALM BEACH COUNTY, FLORIDA

Coral Gables, LLC, Case No. 50-2016-CA-009292
Division AW
Plaintiff,
V.
JEFFREY MARC HERMAN,
UNKNOWN TENANT #1, UNKNOWN
TENANT #2 and THE OAKS AT BOCA
RATON PROPERTY
OWNERS' ASSOCIATION, INC.,
Defendants.
______________________________/
MOTION TO WITHDRAW
Kenneth Eric Trent seeks leave of Court to withdraw as counsel for Defendants Laurence
Schneider and Stephanie Schneider. This request is necessary because the undersigned does not
have sufficient time to properly represent the interests of the Defendants in this cause.
WHEREFORE, the undersigned seeks leave to withdraw, and asks that Defendants be
given time to obtain replacement counsel.
Respectfully submitted this 22nd day of March, 2017.
KENNETH ERIC TRENT, ESQ.

Attorney for Defendant(s)
831 East Oakland Park Blvd.
Fort Lauderdale, FL 33334
(954)567-5877; (954)533-9571 [fax]
[email protected]
By:/s/ Kenneth Eric Trent

Fla. Bar No. 693601
Certificate of Service
I hereby certify that on this 22nd day of March, 2017 true and correct copies of the
foregoing were served upon all counsel of record via the clerk's e-filing portal, and upon
Defendants c/o Laurence Schneider via email to [email protected] .
KENNETH ERIC TRENT, ESQ.

Counsel for Defendant(s)
831 East Oakland Park Blvd.
Fort Lauderdale, FL 33334
(954)567-5877; (954)533-9571 [fax]
[email protected]
By:/s/ Kenneth Eric Trent

Fla. Bar No. 693601
2
Larry Schneider
From: [email protected]
Sent: Thursday, March 23, 2017 12:16 PM
To: Larry Schneider
Cc:
Subject: Re: Orders compelling property inspection and discovery responses.
Larry please come to the hearing on the 28th that way I can make sure that I'm your mouthpiece and make every argument that u want
made
Sent from my MetroPCS 4G LTE Android device
------ Original message------

Date: Thu, Mar 23, 20 17 II :20 AM
To: 1n·[email protected];
Cc: ... ..,,
Subject: RE: Orders compelling property inspection and discovery responses.
Ken,
Did you raise the fact they Plaintiff's would not provide a copy of the inspection report?
I' ll get back to you before 1:00pm re. the inspection time and date.
Regards.
Larry Schn eider
1 st Fidelity Loan Servicing , LLC
Cell (305) 710-4201
1
Sent: Thursday, March 23, 2017 11:10 AM
To: Larry Schneider
Cc:
Subject: Re: Orders compelling property inspection and discovery responses.
!nothing. there is not a written inspection report as indicated in the email from the opposing counsel that I fo rwarded to you and we
also don't have a motion to compel them to turn over any such report. When can they inspect the place?
Sent ji·om my MetroPCS 4G LTE Android device
------ Original message------
Date: Thu, Mar 23, 2017 9:32 AM
To: [email protected];
Ce
Subject:Re: Orders compelling property inspection and discovery responses.
Ken,
What did the judge say about our access to the prior inspection report by whi ch served as part of the banks new allegations for a new
receiver.
Thanks,
Larry
Sent from my iPhone
On Mar 23, 2017, at 9:05AM, "[email protected]" <[email protected]> wrote:
2
Larry Schneider

Sent: Monday, March 27, 2017 3:37PM
To: '[email protected]'
Cc:
Subject: FW: Appraisal Attached - 17685 Circle Pond Court
Attachments: 17865 CIRCLE POND CT.pdf
I' ll be at the hearing. Attached is a copy of the appraisal for the property, w hich w as ordered by First American Bank
back in August 2015 . The house is in exactly the same condition as w hen the appraisal was done. I was as cooperative
then as I am now.
Larry
From: Alan Krauss [mailto:[email protected]]

Sent: Thursday, August 27, 2015 2:05 PM
To: Larry Schneider
Cc: Brian T. Hagan
Subject: Appraisal Attached - 17685 Circle Pond Court
This email contains images. Click Here to view this ad in a browser.
2.
Spoclal lntr
tor
After that, va
Mr. Schneider,
Brian Hagan asked that I email you a copy of the appraisal for 17685 Circle Pond Court for your review.
If you would like us to provide you with a physical copy of the report, please supply Brian with your mailing
address and we will place it in the mail to you right away.
Sincerely,
Alan
Alan S. Krauss
Senior Vice President
1
First American Bank
80 Stratford Drive, Bloomingdale, IL 60108-2219
Phone/Fax: 630-547-8990
Mobile: 224-805-6523
fiRS I
AMERICAN
BANK
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First American Bank
P.O. Box 0794
Elk Grove Village. IL 60009
www.FirstAmBank.com
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Appraisal First (305) 47().2100 IMain File No. 1851821 Page #1 1
um'form Rest'denta
t' I A1ppra1saIReport File# 185182
The purpose of this summary apJXllisal repoll is to prtWide the lender/cieflt with an accurate, and adequately suPIJ(Xted, opilioo of the matket value of the subject property.
I Property Address 17685 Circle Pond Ct City Boca Raton State FL Zip Code 33496
Borrower Laurence S Schneider Owner of Public Record Laurence s Schneider Stephanie L Schneid•• County Palm Beach
Legal Description FOX HILL ESTATES OF BOCA RATON L T 3 7
Assessor's Parcel # 00-42-46-31-01-000-0370 Tax Year 2014 R.E. Taxes S 18 691
Neighballood Name Fox Hill Estates Map Reference 46-42-31 Census Tract 0077.43
Occupant [] Owner [] Tenant ~ Vacellt Special Assessments S 0 ~ PIJO HOAS 704 [ I per year ~ per month
" Property Rights Appraised ~ Fee Simple [] Leasehold [] Other (describe)
Assignment Type [] Purchase Transaction [] Refinance Transaction ~ Other (describe) Loan underwritinq & or credit decisions
Lender/Client First American Bank Address P .O. Box 0794 Elk Grove Villaae II 60009
Is the subject property currently ofiered for sale or has it been ofiered for sale in the twelve months prior to the effective date of this appraisal? [8J Yes [] No
Report data source(s) used ofierilll Plice(s). and dale(s). DOM 365·Accordina to local MLS #R10027091 was listed for sale on 0312412014 at S1 850 000 reduced
to $1 ,699.000 on 0511612014 and to $1,649,000 on 0811612014. expired on 03124/2015, and in acceptinq back up contracts on 0312512015.
I 0 did [8J did not analyze the contract for sale for the subject purchase transactioo. Explain the results of the analysis of the contract foc sale or why the analysis was not
oortormed. A contract was not available for review.
: Contract PriceS Date of Contract Is the property seflelthe owner of public record? [J Yes lJ No Data Source(s)
Is there any financial assistance (loan charges, sale concessioos, gift oc downpayment assistillce. etc.) to be paid by any party on behaH of the borrower? D Yes 0 No
• 11 Yes, ~port the total d(jiar amount and describe the items to be oaid.
Note: Race and the racial composition of the neighborhood are not appraisal factors.
Neighbortoood Characteristics One-Unit Housin Trends One-Unit Housing Present Land Use %
Location [] Urban IZJ Suburban [] Rural Property values I l increasin_g_ . ~ Stable [] Declining PRICE AGE One-Un~ 65 %
• BuiH-Up ~ Over 75% [] 25-75% [] Under 25% Demand/Supply [] Shortage [8 In Balance [] Over Supply s (000) (yrs) 2-4 Untt 5%
: Growth LJ Rapid ~ Stable LJ Siow Matketing Time [] Under 3 mths [8 3-6 mths [] Over 6 mths
125 Low 1 Mulli·Famlty %
, Neighborhood Boundaries The sub 'eel's marl<et area is bounded on the north by Addison Reserve on the south b 3 000 High 50 Commercial 15 %
~ Yamato Rd on the east by the Turnpike and on the west by the Loxahatchee Wildlife Refuge. 550 Pred. 21 Other 15 '1(,
Neighballood Description The sub 'eel properly is located in northwestern Boca Raton in southern Palm Beach County. The area is primarily composed of PUD
communities of sinale-familv medium-sized to estate homes. The neiqhborflood has qood linkage to shotJpinq and service facilities which have followed the
I arowth of the area and mav be found alona 441 and Yamato Road. The turnpike mav be accessed to the southeast at Glades Road.
Matket Conditioos [ltlcluding support for the aboYe conclusioos) Marl<et conditions are mos/Jy stab/a as supply and demand are close to balance and marketinq times
are oenerallv runnino inside of 180-<favs but /onaer for Iaroe estate homes. Prices have been mostlv level the last few auarlers after recoverinq from the lows of
the recession at the end of the 2000's. Mortgage rates remain historically .tow and conventional financina and cash transactions are found.
Dimensioos -119 X 136 X 136 X 75' Area 13 142 sf Shaoe Narrows to lake VIeW BWtr
Spec~ic Zoning Class~ication PUD ZoningDescription Planned Unit Development
Zoning Compliance ~ Legal [] legal Nonconlonning (Grandlalhered Use) [] No Zoning [] ntegal (describe)
Is the highest and best use of subject property as improved (oc as proposed per plans illd specifications) the present use? ~ Yes 0 No If No. describe
Utilities Public Other (describe) Public Other (describe) Off-site Improvements - Type Public Private
Electricity [81 [] Water ~ [] Street All Weather Asphalt fl IX1
Gas [8J [] Sanitary Sewer [8] [l Alley None fl fl
FEMA Special FOOd Hazard Area [] Yes [X] No FEMA Fklod Zone B FEMAMap # 1201920215A FEMA Map Date 0210111979
Are the utlities and ofi-sile imprtWernents typical foc the matket area? ~ Yes [] No HNo, describe
ke there any adverse site conditions or external factors (easements, encroachments, environmental conditions. land uses, etc.)? [] Yes !XI No HYes, describe
The su~ct ha s about 75' of frontaae on a small lake and about 119' of frontaae on a auiet interior block of Circle Pond Court. A survev of the lot
has not been provided. Lot size and dimensions are subject to a survev. The all-weather asphalt roads are adequately-maintained Qy_the HOA.
General DescnDtlon Foundation Exterior Description materials/condition Interior materials/condition

Units ~ One [ ] One wtth AcceSSCI'Y Unit 181 Concrete Slab [ ] Crawl Space Foundation Walls Concretelavg Floors Marble tile crptlgoo
#of Stories 2 l Fun Basement [ l Partial Basement Exterior Walls CBS/avo Walls DrvwaiVaood
Tvoe IX1 Det. fl Att. fl S-Det/End Unit Basement Area 0 SQ.ft. Roof Surtace Tiles/avo TMIIV'Finish Woodloaint/aood
IX1 Existillg fl Prooosed fl Under Const. Basement Finish 0 % Gutters &DownsPOUts MetaVavo Bath Floor Tile Marble/aood
. ~n(Stvlel Mediterranean 0 Outside Enl!y/Exil LJ Sump Pump Window Type lmoact/aood Bath Waitscot Tile M arble/aood
Year Buitt 2006 Evidence of [] Infestation Stocm Sash/Insulated Yeslaood Car Stocaoe L J None
Effective Age (Yrs) 5 0 Dampness 0 Settlement Screens Aluminum/a ood ~Driveway #of Cars 4
Attic L J None Healna L FWA ILJ HWBB ILJ Radiant Amenities LJ Woodstove(s) # o Driveway Surtace Pavers
I Droo Stair [] Stairs 1!Xl Other CAC IFuel Electric ~ Fireplace(s) # 1 [X] Fence Aluminum 11:8J Garage #of Cars 3
l Floor 15<:1 Scuttle Cooino lXI Cenltal Air Condiionino lXI Pati~k ooen lXI Porch Porches l Carport #of~ 0
0 Fillshed 0 Heated 0 lndivi:fual I[] Other [8J Pool Open [8J Other Sprinkler ] Att. 0 Det. rgJ Buitt·il
IAppliances ~ Refrigerator [8J RangP/Oven [8J Dishwasher !XI Disposal ~ Microwave [8J Washer/Dryer ~ Other (describe) Central Vacuum
Fmished area above grade contains: 11 Rooms 5 Bedrooms 6.2 Bath(s) 6 519 Square Feet of Gross Uving Area Above Grade
~ Additional features (soeclal enerav efficient items etc.l. Central ale imPact windows and doors cherrv wood cabinets. granite tops gas stove and tgg_of
the line appliances wet bar crown moldings Jacuzzi tub bidet dual shower his & her bathrooms gas fireplace
Describe the condition of the property OnckJding needed repairs. deterioration. renovations, remodelilg, etc.).
C2'No updates in the prior 15 years· The subject is in
mostly averaae condition with no deferred maintenance noted. The improvements and finish are of hiqher aualitv and less than ten years old.
Are there any physical deficiencies or adverse conditioos that affect the livabiilv. soundness, oc structural in!egrity of the ll11l001tv? [ ] Yes [8J No HYes, describe
Does the property geneta:IY confocm to the nelg~ballood (functional utiity, style, cooditioo, use. constructioo, etc.)? ~ Yes [ ] No If No. describe
Freddie Mac Form 70 March 2005 UAD Version 9/2011 Page 1 of 6 Fannie Mae Form 1004 March 2005
Focm 1004UAD- W1nTOTAL' appraisal software by aIa mode, inc. - 1·800-ALAMODE

IMain File No 1851821 !'aae #21
um'form ReSI'den1a
t' I A1ppra1saIReport File# 185182
There are 4 comoarable properties currently offered for sale in the subiect neighborhood ranaina in price from S 1 499 999 to$ 1 799 999
There are 5 comparable sales in the subject n_eighborllood wnhil the past twelve months ranging in sale price from S 1149 999 to$ 1 465 000
FEATURE SUBJECT COMPARABLE SALE# 1 COMPARABLE SALE # 2 COMPARABLE SALE # 3
Address 17685 Circle Pond Ct 17918 Monte Vista Dr 17646 Cadena Dr 17837 Key Vista Way
Boca Raton FL 33496 Boca Raton FL 33496 Boca Raton FL 33496 Boca Raton FL 33496
Proxinitv to Subiect o. 76 miles SE 0.86milesE 0.33 miles SE
Sale Price s $ 1 149 000 $ 1 465 000 IS 1306 250
Sale Price/Gross Uv. Area s ~.ft.S 183.40 sq.ft.L $ 219.34 sq.ft. 228.85 sq.ft. s
Data Source(s) MLS#R10050940DOM 280 MLS#R10108502DOM 34 MLS#R9973068DOM 440
Verification Source(s) Deed Bk 27573/Pg 842 Deed 8k 27661/Pf1213 Deed Bk 27325/PfJ 865
VAWE ADJUSTMHlTS DESCRIPTION DESCRIPTION +(-) SAdjustment DESCRIPTION +1-l SAdjustment DESCRIPTION +(-) sAd~stment
s~ I)" Filancing ArmLth ArmLth ArmLth
Concessions Cash·O Conv·o Conv·o
Date of Salellime s05/15 ·c03115 s05/15·c03115 s02115·c11114
Location N R es· N;Res; NRes· N;Res·
Leasehoi!VFee Simple Fee Simple Fee Simple Fee Simple Fee Simple
Site 13 142 sf 10 654 sf o 11 481 sf 0 11 346 sf 0
VieW BWtr BWtr N·Res· +50.000 BWtr
Design (SMel DT2·Mediter DT2·Mediter DT2·Mediter DT2·Mediter
Oualitv of Construction 03 03 Q3 03
Actual Age 9 9 1 09
Condnion C2 C2 C1 -100 000 C2
Above Grade Trul IBdrms.l Baths TOialiBdrms.l Baths Trui IBdrms. Baths 0 Tota1 I Bdrms.l Baths
RQI)"O Count 11 I 5 I 6.2 11 I 6 I 6.2 0 10 I 5 5.2 0 10 I 5 I 5.1 0
Gross Living flJea 6 519 SQ.ft. 6 265 SQ.ft. +25 000 6 679 SQ.ft. -15 000 5 708 SQ.ft. +80000
Basement & finished Osf Osf Osf Osf
RQI)"OS Below Grade
Functional Utilitv Satisfactorv Satisfactorv Satisfactorv Satisfactorv
HeatilgJCooling CentraiA/C Centrai AIC CentraiAIC CentraiAIC
Enerav Efficient Items Standard Standard Standard Standard
Garage/Carport 3abi4dw 3abi4dw 3Qb/4dw 3Qbi4dw
PmM'atio'Deck Porch balconv Porch balconv Porch balconv Porch balconv
• Pool fence Pool fence Pool fence Pool fence Pool fence
• Net Adjustment (Total) [81 + [] - $ 25000 [] + [81 - $ -65 DOG [81 + [] - $ 80000
Adjusted Sale Price Net Adj. 2.2% Net Adj. 4.4% Net Adj. 6.1%
of Comparables Gross Adi. 2.2% s 1 174,000 Gross Adj. 11.3% s 1 40000G Gross Adj. 6.1 % $ 1 386 250
I 1:8] did [] did not research the sale ll" lrcrlsfer histtJY of the subject property and com~~. Hnot, explain
I Mv research [ J did 1:><1 did not reveal anv orior sales ll" transfers of the sublect property for the three vears Prior to the effective date of this appraisal.
Data Source(sl Realist (county records). countv clerk
I Mv research [] did Xl did not reveal anv orior sales ll" transfers ot the comparable saies for the vear orior to the date of sale ot the CI)"Oparable sale.
Data Source(s) Realist {COU!Jiy records). countv clerk
Repat the resuHs of the research and analysis of the prior sale ll" transfer history of the subject property and comparable sales (repat additional prior sales on page 3).
ITEM SUBJECT COMPARABLE SALE #1 COMPARABLE SALE #2 COMPARABLE SALE #3
Dateof Prior Sale/Transfer
Price of Pfil)" Sale/Transfer
Data Source(s) County Records County Records Countv Records Countv Records
Effective Date of Data Source(s) 0812012015 0812012015 0812012015 0812012015
Analysis of prior sale or transfer histOfY of the subject property and comparable sates Neither the subject nor any of the comparables have anv recent
transfer histories.
Summary of Sales Comparison Approach The market analysis focused on the most recent sales and listinas of prooerties that are similar to the subiect
and would attract the same market audience in this neiahborhood. As verv few recent sales of larae homes ware found the research extended in
time. Comoarable one is a similar Prooertv in mosl/v similar condition with similar finishes views and amenities. It was reduced various time since
it was offered for sale as the seller was very motivated. Comparable two is a new construction that was offered on MLS with similar amenities
and finish it Is on a dry lot that backs Lyons Road a four lane traffic road however the propertv line is buffed by about 60 feet of landscapina
and a wall makina the noise a non factor. Comparable three Is a smaller home in similar condition with similar amenities finish and similar water
view. It was on the market since 0812812013 and was reduced from $1 799 999 various times. Even thouah more than six months old is one of
the most recent sales available and its older sale date do not affect its viability as a market indicator. See additional comparables.
Indicated Value by Sales Co11111arison Approach S 1300000
Indicated Value by: Sales Comparison Approach$ 1300000 Cost Approach (ff developed) S 1 405 286 IncomeApproach Of developed) S
The sales comparison approach has been given primary consideration toward the opinion of value. The cost approach is less reliable when
• applied to PUD development. Limited rental data discounts the use of the income approach to value.
This appraisal is made 181 'as is', 0 subject to completion per plans and specifications on the basis of a hypothetical condttton that the improvements have been
completed, 0 subject to the foliowing repairs or alterations on the basis of a hypothetical condttlon that the repairs or alterations have been completed, or 0 subject to the
• following reaured inspection based on the extraocdinary assumption that the cond~ion or defiCiency does not reaure atteration or repair: Appraised in "as Is" condition.
Based on a complete visual inspection of the interior and exterior areas of the subject prope~ defined scope of work, statement of assumptions and limiting
conditions, and appraiser's certification, my (our) opinion of the market value, as defined, of e real property that is the subject of this report is
$ 1,300,000 8$01 08120/2015 which is the date of inspection and the effective date of this appraisal.
Fll"ffi 1004UAO- W10TOTAL' applaisal software by a Ia mode, inc. - 1-800-Al.AMODE

IMajn Ale No 1851821 Page #31
um"form R8SI"denf1alA~ppra1saIR eport File# 185182

Intended user:
The intended user of this appraisal report is First American Bank
Intended use:
The intended use of the appraisal reoort is for loan underwriting and/or credit decisions
Additional comments:
See paqe 4 of the 1004 for the description of the scope of work followed toward the completion and deliverv of this aPPraisal rePort.
A reasonable exposure time for the subiect property is 6·12 months.
The definition of market value on oaae 4 is from FNMA oer lnteraaency Guidelines f2010J.
The hlahest and best use Is as imoroved with a sinale-famiiY house in accordance with local zonina reauirements. The orooertv is in a PUD
community of sinale-family homes.
The aooraiser certifies and aarees that this aooraisal was oreoared in accordance with the reauirements of Title XI of the Financial Institutions
Reform Recoverv. and Enforcement Act fFIRREAJ of 1989 as amended f12 U.S. C. 3331 et sea.). and anv aoDiicabte imp/ementiogregulations
• in effect at the time the aooraiser signs the @P£8isal certification.
.. Althouoh the opinion of value is hioher than the predominant value the subiect is not considered to be an overimorovement. The ooinion falls
. within the neiahborhood ranae.
This aooraisal assianment was not made nor was the aooraisal rendered on the basis of a reauested minimum valuation specific valuation or an
amount which would result in approval of a loan.
Though vacant on the effective date the utilities had been on end in workino order.
Other land use includes golf courses.
Because the comparables are in a private aated communityL and access would not be granted the front photo of the comparables come from third
I oartv sources. However adequate data has been found to properly identify and analyze the comparablas.
Additional comments:
Richmond American Homes builder has started to build the last available lots in the develooment at this time is offerina sixteen homes of which
two are similar to the subiect. The Redonde model a 6 679/sf home is offered at $1 599 950 and the Westaate model also e 6 679/sf home
offered as pre construction at $1 269 950 without upgrades.
COST APPROACH TO VALUE not required by Fannie Mae)

Provide adeauate lnf0011ation for the lender/client to reolicate the below cost fiaures and calculatilns.
SuDoort for the ODinion or s~e value (summaJV of comparable land sales or other methods for estimatno stte value) Site value is based on the extraction method
because of the absence of buildable lot sales in this fully-developed communitv.
ESTIMATED [] REPRODUCTION OR [X] REPLACEMENT COST NEW OPINION OF SIT£ VALUE .. .... ·-·· --····················· ······ =S 200000
; Source of cost data Local contractor estimates & M & S Handbook DWEWNG 6519 Sq.ft.@S 180.00 ............. =S 1 173 420
Quality rating from cost service Good Effective date Gcost data 07/2015 o SQ.ft.@ S .... =S
: Comments on Cost Approach (gross living area calculations, depreciation, etc.) Pchs 498sf @J. $40.00 ............. =$ 19 920
The ooinion of replacement cost is intended only for mortaaoe loan GaragP/Caroort 760 Sa.Ft.@ s 45.00 .......... .. =S 34 200
• purposes as part of a value of the whole property. It is not intended for Total Estimate of Cost-New .... =S 1 227 540
end the appraiser is not responsible for any other use. Less Physical !Functional !External
Depreciation 102 2541 I =S( 102 254)
Physical depreciation is based on the age/life method. Depreciated Cost of Improvements ....... ....... ---- --······················· =S 1 125 286
'As-is' Value of Site Improvements ........ ···········--------···················· =S 80000
Esijmated Remaining Economic Ufe (HUD i¥1d VA only) 55 Years INDICATED VALUE BY COST APPROACH .... ····· .............................. =$ 1,405 286
INCOME APPROACH TO VALUE (net required by Fannie Mae)
• Estimated MonthlY Miiket Rent S X Gross Rent MultlDiier =S Indicated VakJe.tli Income ~h
Summal}' of Income Awrooch [llcluding suooat for marltet rent and GRMI
PROJECT INFORMATION FOR PUDs (H applicable)

Is the developer/builder In control of the Homeowners' Association (HOA}? lJ Yes I:8J No Untt type(s) [8J Detached [ ] Attached
Provide the following information for PUDs ONLY Hthe develooerlbuilder is n control of the HOA and the subiect property is an attached dwellng unit.
I Legal Name of Project
• T~al number of phases T~al number of un~s T~al number of units sold
Tctal number of un~s rented Tctal number of units foc sale Data soorce(s)
Was the project created by the conversion of existing building(s) nto a PUD? [] Yes ] No If Yes, date of conversion.
~ Does the project contain any mutt~dwelfing un~s? [] Yes [] No Data Source
. Are the un~s. common elements, and recreation facilities complete? [ ] Yes [ ] No If No, describe the status of completkln.
Are the common elements leased to or by the Homeowners' Association? [] Yes [] No If Yes, descrile the renlaltesms <lld options.
Describe coovnon elements and recreational facilities.
F00111004UAD - W111TOTAL' appraisal software by a Ia mode, inc. -1-800-ALAMOOE

!Main Ale No. 1851821 Page #41
Uniform Residential Appraisal Re_Qort File# 185182
This report form is designed to report an appraisal of a one-unit property or a one-unit property with an accessory unit;
including a unit in a planned unit development (PUD). This report form is not designed to report an appraisal of a
manufactured home or a unit in a condominium or cooperative project.
This appraisal report is subject to the following scope of work, intended use, intended user, definition of market value,
statement of assumptions and limiting conditions, and certifications. Modifications, additions, or deletions to the intended
use, intended user, definition of market value, or assumptions and limiting conditions are not permitted. The appraiser may
expand the scope of work to include any additional research or analysis necessary based on the complexity of this appraisal
assignment. Modifications or deletions to the certifications are also not permitted. However, additional certifications that do
not constitute material alterations to this appraisal report, such as those required by law or those related to the appraiser's
continuing education or membership in an appraisal organization. are permitted.
SCOPE OF WORK: The scope of work for this appraisal is defined by the complexity of this appraisal assignment and the
reporting requirements of this appraisal report form, including the following definition of market value, statement of
assumptions and limiting conditions, and certifications. The appraiser must, at a minimum: (1) perform a complete visual
inspection of the interior and exterior areas of the subject property, (2) inspect the neighborhood, (3) inspect each of the
comparable sales from at least the street, (4) research, verify, and analyze data from reliable public and/or private sources,
and (5) report his or her analysis, opinions, and conclusions in this appraisal report.
INTENDED USE: The intended use of this appraisal report is for the lender/client to evaluate the property that is the
subject of this appraisal for a mortgage finance transaction .
INTENDED USER: The intended user of this appraisal report is the lender/client.
DEFINITION OF MARKET VALUE: The most probable price which a property should bring in a competitive and open
market under all conditions requisite to a fair sale, the buyer and seller, each acting prudently, knowledgeably and assuming
the price is not affected by undue stimulus. Implicit in this definition is the consummation of a sale as of a specified date and
the passing of title from seller to buyer under conditions whereby: (1) buyer and seller are typically motivated; (2) both
parties are well informed or well advised, and each acting in what he or she considers his or her own best interest; (3) a
reasonable time is allowed for exposure in the open market; (4) payment is made in terms of cash in U. S. dollars or in terms
of financial arrangements comparable thereto; and (5) the price represents the normal consideration for the property sold
unaffected by special or creative financing or sales concessions* granted by anyone associated with the sale.
*Adjustments to the comparables must be made for special or creative financing or sales concessions. No adjustments are
necessary for those costs which are normally paid by sellers as a result of tradition or law in a market area; these costs are
readily identifiable since the seller pays these costs in virtually all sales transactions. Special or creative financing
adjustments can be made to the comparable property by comparisons to financing terms offered by a third party institutional
lender that is not already involved in the property or transaction. Any adjustment should not be calculated on a mechanical
dollar for dollar cost of the financing or concession but the dollar amount of any adjustment should approximate the market's
reaction to the financing or concessions based on the appraiser's judgment.
STATEMENT OF ASSUMPTIONS AND LIMITING CONDITIONS: The appraiser's certification in this report is
subject to the following assumptions and limiting conditions:
1. The appraiser will not be responsible for matters of a legal nature that affect either the property being appraised or the title
to it, except for infonmation that he or she became aware of during the research involved in performing this appraisal. The
appraiser assumes that the title is good and marketable and will not render any opinions about the title.
2. The appraiser has provided a sketch in this appraisal report to show the approximate dimensions of the improvements.
The sketch is included only to assist the reader in visualizing the property and understanding the appraiser's determination
of its size.
3. The appraiser has examined the available flood maps that are provided by the Federal Emergency Management Agency
(or other data sources) and has noted in this appraisal report whether any portion of the subject site is located in an
identified Special Flood Hazard Area. Because the appraiser is not a surveyor, he or she makes no guarantees, express or
implied, regarding this determination.
4. The appraiser will not give testimony or appear in court because he or she made an appraisal of the property in question,
unless specific arrangements to do so have been made beforehand , or as otherwise required by law.
5. The appraiser has noted in this appraisal report any adverse conditions (such as needed repairs, deterioration, the
presence of hazardous wastes, toxic substances, etc.) observed during the inspection of the subject property or that he or
she became aware of during the research involved in performing the appraisal. Unless otherwise stated in this appraisal
report, the appraiser has no knowledge of any hidden or unapparent physical deficiencies or adverse conditions of the
property (such as, but not limited to, needed repairs, deterioration, the presence of hazardous wastes, toxic substances,
adverse environmental conditions, etc.) that would make the property less valuable, and has assumed that there are no such
conditions and makes no guarantees or warranties, express or implied. The appraiser will not be responsible for any such
conditions that do exist or for any engineering or testing that might be required to discover whether such conditions exist.
Because the appraiser is not an expert in the field of environmental hazards, this appraisal report must not be considered as
an environmental assessment of the property.
6. The appraiser has based his or her appraisal report and valuation conclusion for an appraisal that is subject to satisfactory
completion, repairs, or alterations on the assumption that the completion, repairs, or alterations of the subject property will
be performed in a professional manner.
Freddie Mac Form 70 March 2005 UAD Version 9/201 1 Page 4 of 6 Fannie Mae Form 1004 March 2005
Form 1004UAO - 'WinTOTAl' appraisal software by a Ia mode, inc. - 1-800-ALAMODE

!Main f ile No. 1851821 Page #Sl
Uniform Residential Appraisal Report File# 185182
APPRAISER'S CERTIFICATION: The Appraiser certifies and agrees that:

1. I have, at a minimum, developed and reported this appraisal in accordance with the scope of work requirements stated in
this appraisal report.
2. I performed a complete visual inspection of the interior and exterior areas of the subject property. I reported the condition
of the improvements in factual, specific terms. I identified and reported the physical deficiencies that could affect the
livability, soundness, or structural integrity of the property.
3. I performed this appraisal In accordance with the requirements of the Uniform Standards of Professional Appraisal
Practice that were adopted and promulgated by the Appraisal Standards Board of The Appraisal Foundation and that were in
place at the time this appraisal report was prepared .
4. I developed my opinion of the market value of the real property that is the subject of this report based on the sales
comparison approach to value. I have adequate comparable market data to develop a reliable sales comparison approach
for this appraisal assignment. I further certify that I considered the cost and income approaches to value but did not develop
them, unless otherwise indicated in this report.
5. I researched, verified, analyzed, and reported on any current agreement for sale for the subject property, any offering for
sale of the subject property in the twelve months prior to the effective date of this appraisal, and the prior sales of the subject
property for a minimum of three years prior to the effective date of this appraisal, unless otherwise indicated in this report.
6. I researched, verified, analyzed, and reported on the prior sales of the comparable sales for a minimum of one year prior
to the date of sale of the comparable sale, unless otherwise indicated in this report.
7. I selected and used comparable sales that are locationally, physically, and functionally the most similar to the subject property.
8. I have not used comparable sales that were the result of combining a land sale with the contract purchase price of a home that
has been built or will be built on the land.
9. I have reported adjustments to the comparable sales that reflect the market's reaction to the differences between the subject
property and the comparable sales.
10. I verified, from a disinterested source, all information in this report that was provided by parties who have a financial interest in
the sale or financing of the subject property.
11 . I have knowledge and experience in appraising this type of property in this market area.
12. I am aware of, and have access to, the necessary and appropriate public and private data sources, such as multiple listing
services, tax assessment records, public land records and other such data sources for the area in which the property is located.
13. I obtained the information, estimates, and opinions furnished by other parties and expressed in this appraisal report from
reliable sources that I believe to be true and correct.
14. I have taken into consideration the factors that have an impact on value with respect to the subject neighborhood, subject
property, and the proximity of the subject property to adverse influences in the development of my opinion of market value. I
have noted in this appraisal report any adverse conditions (such as, but not limited to, needed repairs, deterioration, the
presence of hazardous wastes, toxic substances, adverse environmental conditions, etc.) observed during the inspection of the
subject property or that I became aware of during the research involved in performing this appraisal. I have considered these
adverse conditions in my analysis of the property value, and have reported on the effect of the conditions on the value and
marketability of the subject property.
15. I have not knowingly withheld any significant information from this appraisal report and, to the best of my knowledge, all
statements and information in this appraisal report are true and correct.
16. I stated in this appraisal report my own personal, unbiased, and professional analysis, opinions, and conclusions, which
are subject only to the assumptions and limiting conditions in this appraisal report.
17. I have no present or prospective interest in the property that is the subject of this report, and I have no present or
prospective personal interest or bias with respect to the participants in the transaction . I did not base, either partially or
completely, my analysis and/or opinion of market value in this appraisal report on the race, color, religion, sex, age, marital
status, handicap, familial status, or national origin of either the prospective owners or occupants of the subject property or of the
present owners or occupants of the properties in the vicinity of the subject property or on any other basis prohibited by law.
18. My employment and/or compensation for performing this appraisal or any future or anticipated appraisals was not
conditioned on any agreement or understanding, written or otherwise, that I would report (or present analysis supporting) a
predetermined specific value, a predetermined minimum value, a range or direction in value, a value that favors the cause of
any party, or the attainment of a specific result or occurrence of a specific subsequent event (such as approval of a pending
mortgage loan application).
19. I personally prepared all conclusions and opinions about the real estate that were set forth in this appraisal report. If I
relied on significant real property appraisal assistance from any individual or individuals in the performance of this appraisal
or the preparation of this appraisal report, I have named such individual(s) and disclosed the specific tasks performed in this
appraisal report. I certify that any individual so named is qualified to perform the tasks. I have not authorized anyone to make
a change to any item in this appraisal report: therefore, any change made to this appraisal is unauthorized and I will take no
responsibility for it.
20. I identified the lender/client in this appraisal report who is the individual, organization, or agent for the organization that
ordered and will receive this appraisal report.
Foon 1004UAO - WnTOTAL' appraisal software by aIa mode, inc. -1-80Q.ALAMOOE

IMain Ale No 1851821Page #61
Uniform Residential A File# 185182
21. The lender/client may disclose or distribute this appraisal report to: the borrower: another lender at the request of the
borrower: the mortgagee or its successors and assigns: mortgage insurers: government sponsored enterprises: other
secondary market participants: data collection or reporting services: professional appraisal organizations: any department,
agency, or instrumentality of the United States; and any state. the District of Columbia, or other jurisdictions: without having to
obtain the appraiser's or supervisory appraiser's (if applicable) consent. Such consent must be obtained before this appraisal
report may be disclosed or distributed to any other party (including, but not limited to, the public through advertising, public
relations, news, sales, or other media).
22. I am aware that any disclosure or distribution of this appraisal report by me or the lender/client may be subject to certain
laws and regulations. Further, I am also subject to the provisions of the Uniform Standards of Professional Appraisal Practice
that pertain to disclosure or distribution by me.
23. The borrower, another lender at the request of the borrower, the mortgagee or its successors and assigns, mortgage
insurers. government sponsored enterprises, and other secondary market participants may rely on this appraisal report as part
of any mortgage finance transaction that involves any one or more of these parties.
24. If this appraisal report was transmitted as an "electronic record" containing my "electronic signature," as those terms are
defined in applicable federal and/or state laws (excluding audio and video recordings), or a facsimile transmission of this
appraisal report containing a copy or representation of my signature, the appraisal report shall be as effective, enforceable and
valid as if a paper version of this appraisal report were delivered containing my original hand written signature.
25. Any intentional or negligent misrepresentation(s) contained in this appraisal report may result in civil liability and/or
1~
THE CiRCU IT COURT OF
THE 1-'IFTI:.I.:f''fH JUDICV\l CIRCUIT
1~ AND roR PAu\t OP.ACH COUNTY, FLOIUDA
fiRST AMERICAN RANK, as

!.Ut:ces.sor by merger In Rank of
Cural Gableo; , LLC,
l'laintiff,
\' , Ca:>~ Nu . .5020 l6-CA-OO
LAURENCE S. SCIINEIDER,
STEPHAl\1F. L. SCHNEIDER,
l)NKNOW TENANT #I , UNKNO\VN
TENANT #2 and THE OAKS AT BOCA
RATO PROPERT Y 0\VNERS'
AS SOCIATJON ,
Oetk·
Dcfcndancs. Please UPdate
OrActd
Attomey
I ress Information
----------------------~----·
ORDER GRANTING M
c fuHy advised in the premis.es. hereby ORDERS £hat:
I. The Motion to \'1 raw is GRANTED.
2. 1~~•1•olf<or ,~;o,.. io ••.-.lcuu P'""i' flcfl:>tolonu

;1;9 b ...toio ,.,loo01118ol
nles~ llnd until repl.acemc:nt coun!id .appeaTS em thei r behalf, aH nlt\lre pl~dmgs.,
OO~E ANO ORJ)EREn at \'le: ·t· Pl) lm .Beach, t>.alm Bcgch County, Flonda., on this 1''day
ofMay, 2017. ~~~~~::::::::=--

.. cuit oun Judg:z,?
Copies. to·
!Main File No 1851821 Page #101
Mar ket Cond'f

11ons Addendurn toth e A1ppra1saIR e~>_ort FileNo. 185182
The Jllrpose of this addendum is to provXIe the lender/client with aclear and accurate understanding of the market trends and conditions prevalent In the subject
nel!lhbcrtlood. This is a reQuired addendum for aDappraisal lePOI1s with an effective date on or alter AJri 1, 2009.
Property Address 17685 Circle Pond Ct City Boca Raton State FL ZIP Code 33496
Borrower Laurence S Schneider
Instructions: The appraiser must use the information required on this form as the basis for hiS/her cooclusions, and must provide support for those cooclusions, regarding
housing trends and overa.U market conditions as reported In the Neighbcrtlood section of the appraisal report form. The appraiser must fit in al the information to the extent
~ is available and rwable and must provide 1r1atysis as indicated below. Hirly required data is unavailable or is considered unreliable, the appraiser must prMie 1r1
ex~allon. tt is recognized that not an data sources wit be able to provide data for the shaded areas below; WHis available, however, the appraiser must ilclude the data
in the analysis. Hdata sources JXWide the required information as an average instead of the median, the appraiser should report the available fl!lure and identify ~as an
average. Sales and listings must be properties that compete w~h the subject property, detennined by applying the crrtena that would be used by a prospective buyer of the
subject property. The appraiser must explain any anomalies In the data, such as seasonal markets, new construction, foreclosures, etc.
Inventory Analysis Pr1or 7-12 Months Pr1or 4-1l Months Current - 3 Months Overal Trend
Totai # of Cllflll3r3ble Sates (Set11ed) 2 2 1 Increasing ~ Stable Declining
Absor!Xion Rate (Total Sales/Months) 0.33 0.67 0.33 0 Increasing 12':] Stable Declining
Total# of Comparable Active Ustings 4 Declining I ~ Stable Increasing
Months of Housing Suoo!v (Total UstinoS/Ab.Ratel 12.1 Declining I ~ Stable Increasing
Median Sale & Ust Price, DOll, Sale/Ust% Prior 7-12 Months Prior 4-1l Months Current- 3 Months Overallrend
Median Compasable Sale Price 1,287, 125 1,199,500 1 465 000 0 Increasing I!XJ Stable Declining
Median Compasable Sales Days oo Market 308.5 315.5 34 Declining [8] Stable Increasing
Median Comparable Ust Pnce 1,697,000 Increasing Stable Declining
Median Compasable Ustlngs Days oo Market 48.5 Declining Stable Increasing
Median Sale Price as %of Ust Price 93.6% 97.9% 93.55% 0 Increasing Stable Dec filing
.". Seler·(developer, builder, etc.)paid financial assistance prevalent? l i Ves ()<] No Oeclini~g Stable Increasing
Explain in detai the seller concessions trends for the past 12 months (e.g., seller cootribulions ilcreased from 3% 1o 5%, increasing use of buydowns, closing costs, condo
fees, options, etc.). There is no trend of seller concessions in the market area. Some may be found but there is not a consistent pattern from
any particular seller.
Ale foreclosure sales (REO sales) a factor In the market? ll Yes l:x:i No Hves, extiain finctudlna the trends in listinas and saes of foreclosed orooertiesl.
REOs are not a sianificant factor in the sub ·eel's market seamen! nor in the aeneral market neiahborhood. however some REO and short
sale mav be still found.
cne data sources for above information. MLS Brokers Office files County Clerk
Summarize the above information as sUJ)pOO for your conclusions i1 the Neighbcrtlood section of the appraisal report form. Hyou used any additional information, such as
an analysis d oendila sales and/or eXIlired and wtlhdrawn 6stlnas, to formulate your conclusions, orovide both an exolanation and suooort for your conclusions.
The above arid is reflective of trends associated with the sub ·eel's market seamen! of Iaroe estate homes from the Fox Hill Estates
devetooment. The arid shows mosttv stable orices for the seamen! for the 12-months prior to the effective date however more quarters are
needed to establish a trend. Markelina times mav be skewed bv locallislina services that do not count orior expired or cancelled in their
runnirrg total. New construction beirrg_ offered bv the devetooer are not included.
An attemot was made to como/ate the shaded areas however due to the inconsistent listing hisiOtY and historical data from the toea/listing
services those boxes could not be reliablv comoleted.
If the subject is a unit in acondominium or cooperative project , complete the following: Project Name:
SubJect Project Data Prior7-12 Mooths Prior 4-1l Months Current- 3 Months OveraU Trend
Total # of Comparable Sales (Settled) Increasing Stable Declining
Absorption Rate (Total Sales/Months) Increasing Stabile Declining
Tdal # of Active Comparable listilgs Declining Stable Increasing
Months of Uri! Supply (Total Uslings,/Ab.Rate) Declining Stable Increasing
Ale foreclosure sales (REO sales) afactor In the project? U Yes 0 No If yes. indicate the number of RED listings and explain the trends in listings and sales of
foreclosed properties.
.
..
.
.
• Summarize the above trends and address the Impact on the subject untl and project.
(\ .....
Signature l l -l)_-+- Signature / / / Y /~.:;.c.
• Appraiser Name Paolo Lanata Supervisor;' AI>Draiser Natte-r William K Griffith SRA
Company Name APoraisatFirst Company Name Aooraisa/First
Company Address 1444 Biscayne Blvd, Suite 211 Miami FL 33132 Company Address 1411 Biscayne Blvd, Suite 211, Miami FL 33132
State Ucense/Cerlification # Cert Res RD7611 Stale FL State Ucense/Certificatioo# Cart Res RD 1480 State FL
Email Address J)[email protected] E~Address bi/[email protected]
Freddie Mac Form 71 March 2009 Page 1 of 1 Fann1e Mae Form 1004MC March 2009
Form 1004MC2 -W11TOTAL' appraisal sottware by a Ia mode. inc. - 1-BQQ.ALAMODE

IMain File No. 1851821 Page #111
Subject Photo Page

Client First American Bank
Property Address 17685 Circle Pond Ct
Citv Boca Raton Countv Palm Beach State FL Zi2_Code 33496
Subject Front
17685 Circle Pond Ct
Sales Price
Gross Living Area 6,519
Total Rooms 11
Total Bedrooms 5
Total Bathrooms 6.2
Location N;Res;
View B;Wtr;
Site 13,142 sf
Quality 03
Age 9
Subject Rear
Subject Street
F0011 PICPDCSR - 'WinTOTAL' appraisal software by a Ia mode, inc. -1-BOIJ.ALAMOOE

!Main File No. 1851821 Page # 121
Interior Photos
Prooertv Address 17685 Circle Pond Ct
Qty. Boca Raton County Palm Beach State FL Zip Code 33496
Interior Interior Interior
Interior Interior Garage

FOIITI P1CINT15 - 'WinTOTAL' appraisal software by a Ia mode. ilc. - 1·800-ALAMOOE
!Main Fife No. 1851821 Page # 131
Interior Photos
Prooenv Address 17685 Circle Pond Ct
City Boca Raton Coonty Palm Beach Stale FL Zip Code 33496
Interior Interior Garage

Form PICINT15- 'W11TOTAL' appraisal software by a Ia mode, nc. - 1-800-ALAMODE
IMain File No. 1851821 Page # 141
Interior Photos
Property Address 17685 Circle Pond Ct
Citv Boca Raton County Palm Beach State FL Zip Code 33496
Interior Interior Balcony
Lake view from balcony Balcony Pool area
Side Side Rear

Foon PICINT15- 'WinTOTAL' appraisal software by a Ia mode, inc. -1·800-ALAMODE
Larry Schneider
From: Kenneth Eric Trent, P.A. <[email protected]>

Sent: Thursday, March 23, 2017 12:57 PM
To: Henry Bolz
Cc: Larry Schneider
Subject: I nspection
Mr. Bolz :
Good afternoon. The second inspection will be permitted at 1:00 p.m. on Friday, March
24th. Please advise as to the name of your attendee so my client can call ahead and
authorize his or her admittance at the gate.
Please also forward me any emails from March 14th, and the email in which you
informed me that there was/is no written report of the January inspection.
Finally, this is a request for advance disclosures regarding your exhibits to be presented
on March 28th; please provide me with copies of such items as soon as practicable via
email.
Thank you.
KET

831 E. Oakland Park Blvd .
(954) 567-5877-phone
(954) 567-5872 fax
[email protected]
1
Larry Schneider

Sent: Monday, March 27, 2017 3:42PM
To: 'Kenneth Eric Trent, P.A.'
Cc:
Subject: RE: Pies
Attachments: FPL- 17685 Circle Pond Ct., Boca Raton, FL 33496- March 23, 2.pdf; PBCWUS- 17685
Circle Pond Ct., Boca Raton FL 33432 - March 201.pdf; Florida Public Utility - March
2017 Invoice (EFn 17685 Circle .pdf; FPL March 2017 Billing - 17685 Circle Pond Ct,
Boca Raton, FL.pdf; Invoice Green Island Maintenance-Oaks, March 3, 2017.pdf;
PBCWUS- 17685 Circle Pond Ct., Boca Raton FL 33432- March 201.pdf
Ken,
I w ill be t here. The house is in perfect condition and I will attest to it. I pay the following bills every mont hs
I pay roughly $1,000 per month to maintain the propert y.
Larry
From: Kenneth Eric Trent, P.A. [mailto:[email protected]]

Sent: Monday, March 27, 2017 6:15AM
To: Brent Tantillo; Larry Schneider
Subject: Re: Pies
Never mind, I found them. I was able to file the pictures, but not in color. In any event,
the affidavit is hearsay, so the landscaper should be at the hearing, and should have
printed, color photos with him, if you want this evidence to be utilized at tomorrow's
hearing. It starts at 1:00, and Larry should be there as well.

831 E. Oakland Park Blvd.
(954) 567-5877-phone
(954) 567-5872 fax
[email protected]
I 27 4116220340056527411400000
Please request changes on t he bac~. The amount enclosed tncludes the tollowmg donation:
Notes on the fr ont Wtll not be detected. FPL Care To Share $ _ _ _ __
STEP HANI E SCHNEIDER

360 E COCONUT PALM RD
3,4,7,8
BOCA RATON fl 3343 2 -7916

AUTO **CO 3222
41 16 2
1 079287
-- Ma~ e chec~ payable to FPL 1n U.S. funds
and mail along wtth thiS coupon to:
FPL
·1 1t11 ·•·· 111alt1·ul 11··· 11··11·t1•1·1'tlll •. ,ltllltllu·ll h1.1 GENERAL MAIL FACILITY
MIAMI FL 33188-0001
Account number Amoont enclosed

22034-00565 $
Your electric statement Account number: 22034-00565

For: Feb 21 l017 to M.Jr 22 2017 (29 days
Customer namt:: STEPHANIE SCHNEIDER Statement date: Mar 22 2017
Servtce address· 17685 CIRCLE POND CT NeXI meter readmg: Apr 21 2017
T
Amount Balance · · . Total NeW'
of your Addttlonal before New a~nt cnarg~
last 0111 Payments acuvtty new charges char~es you owe due by
1·1 t +or ) (=) (+ (=)
269.05 269.05 CR 0.00

L 0.00 411 .47 $411 .47 Apr 12 2017
Meter reading · Metar .ACD4835

Current readmg 53949 Amount of your last btll 269.05
Prevtous reaomg - 50699 Payment recetved - Tnanl. you 269.0SCR
~Wh usea 3250
Balance before new charges $0.00
Energy usage
New charges (Rate: RS-1 RESIDENTIAL SERVICE)
~ W n thts month 3250
Serv1ce days 29 Electnc servtce amount 346.16"
~ Wh per day 112 Storm charge 4.07
Gross rece1pts tax 9.03
••The electric serv1ce amount Franch,se charge 21.68
includes the following charges Utl tty tax 28.51
Cu~tonu:u· rn-:arng,· SJP.J C' A1'l A7
Fuel:
(flf!
(Ovo LAURENCE SCHNEIDER
Non-tu STEPHANIE SCHN EIDER
tfrn 1199 S FEDERAL HWY SUITE 369
(0>< BOCA RA-o, FL 33" j : : p ,
NORTHERNTRUSTANCHORACCOUNT
/7~ C<·(~ ~ ~ <;}~---==~=>::~~-=--

•: 0 b b 0 0 9 b 50 a: ~ ? ~0 3 5 ?9 ~ 3 u• 0 (; ~ 3 ~
Please have your accoon1 number ready when contacting FPL

Customer serv1ce. (561) 994·8227
Outstde Flonda 1-800-226-3545
To report power outdges· 1·800-40UTAGE (468-8243)
Heanng/speech n pa.rcd 711 (Relay Servtce)
Online at: www FPLcom
Palm Beach County Customer Service
Water Utilities Department Central County: (561) 740-4600
9045 Jog Road Boca Raton: (561) 278-5135
Boynton Beach, Florida 33472 Toll Free: (877) 477-1305
www .pbcwater.com
ACCOUNT NUMBER ID # SERVICE ADDRESS STATEMENT DATE DUE DATE

1000739959 6152 176 5 CIRCLE POND CT BOCA RATON 02/23/201 7 03/16/2017
SERVICE !I OF READ METER READINGS (OOO's Gallons) USAGE
METER NUMBER CLASS FROM TO DAYS TYPE CURRENT PREVIOUS (OOO's Gallons)
0065239761 R 01/19/2017 02/ 16/20!7 28 ACTUAL -l974 4974 0

BALANCE LAST BILL $ 29 .05
ONE YEAR AGO ' PAYMENT (29.05)
BASE FACI LITY FEE - WATER 13.69

LAST MONTH BASE FACI LITY FEE· WASTEWATER 15.36
0
12 MONTH AVERAGE
PAY THIS AMOUNT ===> S 29.05
A Customer May Request That The Water Meter Serving Their Property Be Re-Read For A $35 Service Fee
In The Event That It Is Determined That The Initial Reading Was Incorrect, This Fee Will Be Waived
~------------------
6:-li 904 altemate fonnal.
BIT OR CREDIT CARD

JVISA DISC vu
,,
p AMOUNT NOW DUE
29.05
AMOUNT ENCLOSED
BOCA RATO FL 33432-7335
000 000 2905 10 00739959

FLORID~ PU!!LIC~ Account#: 0251809·0 Page: Page 1 of 1
Service Period: 01 / 16-02/14 Billing Date: 02/1512017
Route : 001021 Service Location:

Florida Public Utrlilles STEPHANIE SCHNEIDER
P.O . Box 610
Mananna. FL 32447·0610 17685 CIRCLE POND CT
Customer Care: 1-800-427-77 12 BOCA RATON , FL 33496
www.fpuc.com
711 for TTY I Relay Servrce
Current ' A Late Payment Fee will apply 1f amount due 1S

Previous Account Past Due Or Current Total NOW greater than $5 00 and IS nor pa1d b~ due date
Balance Less Payments Credit Balance Charges Due
Charges Due
On • Past due balances are due 1mmed•ately
and subrect ro prev1ous d1scoMect dates
S20.27 S20.27CR so 00 $20.44 03108/2017 $20 .44
·The APR for •nstallmenl contracrs IS 18°.,
Meter Information - meter# 74304W Current Account Activity
Current Reading 0005329
Billing For RS GRS31
PreVIous Read1ng 0005325
CCF's Usee 4 Natural Gas Servrce Amount .. 18.69
Mul!lply1ng Factor X 1.0563 Florida Gross Receipts Tax 0 .19
Total Therms Used 4 22 PB County Municipal Tax 1.56
TOTAL NATURAL GAS CHARGES 20.44
Energy Usage Last Year Thrs Year
Total Current Charges $20.44
Therms This Month 41 4
Therms Day 1 0
Sel"\l1ce Days 29 29
**Amount Includes the following charges**

Customer Charge 11 00
Base Energy per therm 0.9731 4
PGA per therm 0.85000
THIS IS NOT A BILL. The amount due on th~s

b~ll w~ll be drafted from your account
7 - 10 days from the b~ll da te .
To ensure proper credw Please return rh1s portiOn With payment make
check money order payaole to FPU ar>d 1ndrcate account number
Flonda Public Utilities
FLORID~ PUBLIC~U L T •C
P.O. Box 610 Current Charges Due On: 03/08/2017
Mananna. FL 32447-0610 Account Number: 0251809-0
711 for TTY I Relay Service Amount Due: EFT, Do Not Pay $20.44
Address Sei"\IICe Requested Check Numbe r : - - - - - - - - - - - - -
Amount Enclosed: - -- - - - - - - - - -
Please check box to ind1cate address I phone changes
3335 000000150 and EFT enrollment on the reverse s1de
Route· 001021
'll.llallllllll•llll•ltll ll lllllllll'lll'll'l•th 'ltl•l•'t"lll
STEPHANIE SCHNEIDER
1199 S FEDERAL HWY # 369
1 1
w.. t• 111 1'1111'' 1'·11'1111tl1•1·''··tl't•ltll''''''tllltl'lllllll''
Flonda Public Utilities
P.O. Box 2 137
BOCA RATOII. FL 33432-7335
Salisbury. MD 21802-2 137
0251 8090 00000000020444

I 27 4116220340056595096200000
Please request changes on the back. The amount enclosed includes the following donation:
Notes on the front w ill not be detected.
FPL Care To Share s ____
•
B 4316 9
AUTO **CO 3222
085786
STEPHANIE SCHNEIDER
360 E COCONUT PALM RD Make check payable to FPL in U.S. funds
BOCA RATON fl 33432-7916 and mail along with this coupon to:
FPL
GENERAL MAIL FACIUlV
MIAMI FL 33188-0001
Account number
22034-00565
'four electric statement Account number· - - iS
(
P.
~
kWI
ser·
kWh
$269.05
-Payments received after March 14, 2017 are considered late; a late payment
cli<~ rge , the greater of $5.00 or 1.5% of ycui p.:;:;t due ba:ance wil: app:y. Your
account may also be billed a deposit adjustment.
- This btlling period 1s less than a month; bill factors are available upon request.
- We' ve installed a smart meter on your property and it's ready to give you
mformation-by the month, day and hour-about your energy use. For more
information about the benefits, including how the smart meter will be read
remotely, VIS i t www.FPLcom/smartmeter.
-The Service/Initial Charge is a one-time charge to defray administrative costs
required to start your electric service or to make a change to your account at
your request.
- The Florida Public service Commission is reviewing a routine storm charge
adjustment as well as a hurricane recovery cost surcharge that would apply to
your bill beginning in March. To learn more about your energy bill, visit
FPL.cornlrates.
Please have your account number ready when contacting FPL

Customer service: (561) 994-8227
Outside Flonda: 1-800-226-3545
To r eport power outages: 1-800-40UTAGE (468-8243)
Hearing/speech 1mpa1red: 711 (Relay Servtce)
Online at: www.FPL.com
.J .l..J 0
c_
~.) ' \ v
(•
- t Sc ~ -
LAURENCE SCHNEIDER
STEPHANIE SCHNEIDER
1199 S FEDERAL HWY. SUITE 36;1
BOCA RATON FL 33432
rth n 1 1
/7 c~5 ( i ), '{c ('

I: 0 b b 0 0 q b 50 I: ~ 7 ~ 0 3 5 7 q ~ 3 II' 0 b ~ 2 •
KEEP THIS SLIP FOR REFERENCE

Water Utilities Department Central County: (561) 740-4600
9045 Jog Road Boca Raton: (561) 278-5135
Palm liNCh County www.pbcwater.com
Water UtHitles

1000739959 6152 17685 CIRCLE POND CT BOCA AAT0:-1 02/23/2017 03/16/20 17
SERVICE # OF READ METER READINGS (OOO's Gallons) USAGE
METER NUMBER CLASS FROM TO DAYS TYPE CURRENT PREVIOUS (OOO's Gallons)
0065239761 R 01/19/2017 02/ 16/20 17 28 ACTUAL -l-97-l 4974 0

BALANCE LAST BILL $ 29.05
ONE YEAR AGO PAYME T (29.05)
BASE FACILITY FEE- WATER 13.69

LAST MONTH BASE FACI LITY FEE- \VASTE\VATER 15.36
0
12 MONTH AVERAGE
PAY THIS AMOUNT ~ S 29.05

H
:v
LAURENCE SCHNEIDER
STEPHANIE SCHNEIDER
11 99 S. FEDERAL HWY SUITE 369
BOCA RATON. FL 33432
_I !;?:/)[).L-u L'j)
s·
/
'*
~t,.,
904
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r3
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~
7
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1ocg
6123 a lterna te fonnat.
BIT OR CREDIT CARD

J\liSA DISC . ; ;
r
p G5/': t-". / • )' AMOUNT NOW DUE
\\ _.<. . 1 ?t..,.. "l..{' )
29 .05
"E NO~ST CO>I~v NORTHERN TRUST ANCHOR ACCOUNT
·~
AMOUNT ENCLOSED
/C 7
r:t' 7 ~ LJ f s· 'l
BOCA RATON FL 33432·7335
0000002905 10 00 73 9959
Water Utilities Department Central County: (561) 740·4600
9045 Jog Road Boca Raton: (561) 278·5135
Palm Beach County www .pbcwater.com
WOlter Utilities
1000739959 6152 17685 CIRCLE POND CT 130CA RATON 02/23/20 17 03/16/2017

SERVICE #OF READ METER READINGS (OOO's Gallons) USAGE
METERNUMBER CLASS FROM TO DAYS TYPE CURRENT PREVIOUS (OOO's Gallons)
0065239761 R 01/19/2017 02 /16/20 17 28 ACTUAL 4974 4974 0

BALANCE lAST BILL $ 29.05
ONE YEAR AGO • PAYMENT (29.05)
BASE FACILITY FEE- \VATER 13.69

LAST MONTH BASE FACILI1Y FEE - WASTEWATER 15.36
0
12 MONTH AVERAGE
PAY THIS AMOUNT => S 29.05

alternate format.
BIT OR CREDIT CARD

J'1/ISA ~ vet
r
p AMOUNT NOW DUE
\I
29.05
AMOUNT ENCLOSED
BOCA RATON F_ 33432·7335
000 0002 905 1000739959

AFFIDAVIT
STATE OF FLORIDA
COUNTY OF PALM BEACH
BEFORE ME, the undersigned authority, personally appeared Sergio Lemus who being first duly
sworn, on oath, deposes and says:
1. My name is SERGIO LEMUS. I am a resident of the State ofFlorida, Palm Beach County,
and am over the age of 18. I make this affidavit on my own personal knowledge.
2. I am the principal of Green Island Maintenance and Landscaping Corp at 9055 Brandy Ln,
Lake Worth, FL 33467 and in that capacity my company maintains the grounds at 17685
Circle Pond Court, Boca Raton, Florida 33496.
3. Green Island Maintenance services 17685 Circle Pond Court on a scheduled cycle providing
landscaping services as follows:
Lawn Mowing: November to March: twice a month; April- October: every week
Hedge Trimming: 3 times a year
Pick up dead Palm Fronds and branches: every visit
Twice a Year: Tree Trimming: Coconut and one layer from Coconut Palms
Bougainvilleas: trim as needed every visit.
4. Green Island Maintenance and Landscaping Corporation has serviced the property for more
than five years.

5. The Bougainvillea on the photos submitted are healthy, alive, and part of the landscape
design. The Bougainvilleas on the photographs shown are trimmed once a month and
naturally lose leaves periodically especially in the winter months.
6. All shrubbery and palm trees have also been maintained to specifications. See photographs
enclosed.
7. The design of the layout includes areas around the trees and bushes where mulch is placed
and therefore no grass is planted. See photographs enclosed.
8. The landscaping for 17685 Circle Pond Court, Boca Raton, Florida 33496 complies with the
requirements of Palm Beach County, Boca Raton and the Association.
9. During the maintenance of the grounds, we have noted that the sound of the pool pump
running.
FURTHER AFFIANT SA YETH NAUGHT.
h~us,~
Green Island Maintenance and Landscaping
SWORN TO AND SUBSCRIBED before me on this d

{ day of March 2017 by SERGIO
LEMUS who has submitted 0 t'i \l(r i / ,r f.tlt f t> , as identification and did/aittnot
take an oath.
Notary Public, State of Florida

My Commission Expires:
SEAL
Personally known to me ~"f!:";·~ CAROLINE IACINO

Produced as identification. ~w MY COMMISSION tl GG 17456
----------------- ·., .,ff,... EXPIRES May 07.2021
.,
--- ·- -
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./
Filing# 49129118 E-Filed 11/2112016 10:28:22 AM
-· · --- - --- --- -- ..... --- -- -- -- ~- ---·· ----- - ---· -·- -~--- --- , -- ·
AND FOR PAIM BEACH COUNTY, FLORIDA

Coral Gables, LLC, Case No. 50-2016-CA-009292
DiW>ionAW
Plaintiff,
v.
TENANT#2 and THE OAKS AT BOCA
RATON PROPERTY
OWNERS ' ASSOCIATION, INC.,
Defendants.
----------------- I
NOTICE OF ABSENCE
PLEASE TAKE NOTE that due to a consent judgment upon a Bar grievance against him,
the tmdersigned attomey will be suspended from practice and therefore tmavailable from December
12, 2016 through J anuary 11 ,20 17. This notice should be construed as a motion to continue any
events scheduled, and toll any time periods set to elapse, dming said 30-day suspension.
Respectfully submitted this 2Pl day ofNovember, 2016.
KENNETH ERIC TRENT

Attomey for Defendant(s)
83 1 East Oakland Park Blvd.
Fort Lauderdale, FL 3 3 3 34
(954)567-5877; (954)567-5872 [fax]
[email protected]
By:ls/Kenneth Eric Trent

Fla. BarNo. 693601
Certificate of Service
I hereby certify that hue and conect copies of the foregoing were served via thee-filing
portal upon all counsel of record on this 2 1st day ofNovember, 2016.
By:ls/ Kenneth Eric Trent

Fla. BarNo. 69360 1
~upreme (!Court of jflortba
Office of the Clerk
500 South Duval Street
Tallahassee, Florida 32399-1927
JOHN A. T OMASINO PHONE NUMBER: (850) 488-0 125
CLERK www.floridasupremecourt.org
MARK CLAYTON
CHIEF D EPUTY CLERK
KRI STINA SAMUELS
STAFF ATTORNEY
ACKNOWLEDGMENT OF NEW CASE
October 25, 2016
RE: THE FLORIDA BAR vs. KENNETH ERIC TRENT
CASE NUMBER: SC16-1893

Lower Tribunal Case Number(s): 2015-50,239(17F); 2015-50,245(17F)
The Florida Supreme Court has received the following documents reflecting a filing
date of 10119/2016.
Petition for Approval of Conditional Guilty Plea for Consent Judgment

Exhibit A - Conditional Guilty Plea for Consent Judgment
Statement of Costs
The Florida Supreme Court's case number must be utilized on all pleadings and
correspondence filed in this cause. Pursuant to rule 3-7.6(n)(3), bar counsel shall
assist the referee with the preparation of the index and record.
ld
cc:
NAVIN A. RAMNATH
KENNETH ERIC TRENT
ADRIA E. QUINTELA
~upreme (!Court of jflortba
THURSDAY, NOVEMBER 10,2016
CASE NO.: SC16-1893

Lower Tribunal No(s).:
2015-50,239(17F); 2015-50,245(17F)
THE FLORIDA BAR vs. KENNETH ERIC TRENT
Complainant(s) Respondent(s)
The conditional guilty plea and consent judgment for discipline are approved
and respondent is suspended from the practice of law for thirty days, effective
thirty days from the date of this order so that respondent can close out his practice
and protect the interests of existing clients. If respondent notifies this Court in
writing that he is no longer practicing and does not need the thirty days to protect
existing clients, this Court will enter an order making the suspension effective
immediately. Respondent shall fully comply with Rule Regulating the Florida Bar
3-5.1 (h). In addition, respondent shall accept no new business from the date this
order is filed until he is reinstated. Respondent is further directed to comply with
all other terms and conditions of the consent judgment.
Judgment is entered for The Florida Bar, 651 East Jefferson Street,
Tallahassee, Florida 32399-2300, for recovery of costs from Kenneth Eric Trent in
the amount of $1 ,683.1 0, for which sum let execution issue.

CASE NO.: SC16-1893
Page Two
Not final until time expires to file motion for rehearing, and if filed,
determined. The filing of a motion for rehearing shall not alter the effective date
of this suspension.
LABARGA, C.J., and P ARIENTE, LEWIS, QUINCE, CANADY, POLSTON,

and PERRY, JJ., concur.
A True Copy
Test:
~omasino
Clerk, Supreme Court
ld
Served:
NAVIN A. RAMNATH
KENNETH ERIC TRENT
ADRIA E. QUINTELA
Filing # 47749053 E-Filed 10/ 18/2016 11:49:18 AM
IN THE SUPREME COURT OF FLORIDA
THE FLORIDA BAR, Supreme Court Case

No. SC-
Complainant,
The Florida Bar File
v. Nos. 2015-50,239(17F)
and 2015-50,245(17F)
KENNETH ERIC TRENT,
Respondent.
__________________________/
CONDITIONAL GUlLTY PLEA FOR CONSENT JUDGMENT
COMES NOW, the undersigned respondent, Kenneth Eric Trent, and files
this Conditional Guilty Plea For Consent Judgment pursuant to Rule 3-7.9 of the
Rules Regulating The Florida Bar.
1. Respondent is, and at all times mentioned herein was, a member of

......
......
\0
...... The Florida Bar, subject to thedurisdiction of the Supreme Court of Florida.
0
~
-
00
...... 2. Respondent is currently the subject of Florida Bar disciplinary matters
0
......
which have been assigned The Florida Bar file numbers set forth above.
3. As to the above Florida Bar numbers, there has been a finding of
probable cause by Seventeenth Judicial Circuit Grievance Committee "F".
1
tii1
KET
Exhibit A
4. Respondent is acting freely and voluntarily in this matter, and tenders
this Plea without fear or threat ofi coercion. Respondent has chosen to represent
himselfithroughout these proceedings.
5. The disciplinary measures to be imposed upon Respondent are as
follows:
A. Respondent shall serve a 30-day suspension.
B. Respondent shall pay The Florida Bar's costs in this matter.
6. Respondent acknowledges that, unless waived or modified by the
Court on motion ofi Respondent, the Court Order will contain a provision that
prohibits Respondent from accepting new business from the date of,the Order or
Opinion and shall provide that the suspension is effective 30 days from the date ofi
the Order or Opinion so that Respondent may close out the practice of law and
protect the interest ofi existing clients.
7. The following allegations and rules provide the basis for Respondent's
guilty plea and for the discipline to be imposed in this matter:
The Florida Bar File No. 2015-50,239(17F)
A. Respondent was hired by Keith Ruyle to represent him in a
foreclosure matter.
2 Jdt\
K.ET
Filing # 59196320 E-Filed 07/18/2017 10:27:51 PM

CASE NO.: 502016-CA-009292
DIVISION AW

successor by merger to Bank of Coral
Gables, LLC,
Plaintiff
vs.
LAURENCE SCHNEIDER, STEPHANIE L.

SCHNEIDER, et. AI.
Defendants
DEFENDANTS' NOTICE OF FILING
NOTICE IS GIVEN that Laurence Schneider and Stephanie L Schneider, Plaintiffs In pro
per, hereby provide Notice to the Court of two additional Exhibits that they were unable to file
with the Defendants' Motion for Reconsideration filed on July 18, 2017.
Respectfully Submitted,
Date: July 18, 2017

Boca Raton, FL
3?
LAURENCE S. SCHNEIDER, ProSe

STEPHANIE L. SCHNEIDER, Pro Se
360 E. COCONUT PALM DRIVE
[email protected]

D.E. 140 Vacate, July 18, 2017

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Filing # 59196253 E-Filed 07/18/2017 10:13:06 PM

From: La rry Schneider

by the Solicitor General.

From: Larry Schneider

From: Larry Schneider

Please note that I will be filing a notice with the court.

Sent from my iPhone

On Jun 23, 2017, at 7:25AM, Henry Bolz <hbolz@kellerbolz .com> wrote:

Mr. and Mrs. Schneider,

Henry H. Bolz, III

<#9 Order ofRemand 06-22-17.pdf>

From: Larry Schneider

Your assistance is greatly appreciated.

From: Larry Schneider

From: Henry Bolz [mailto:[email protected]]

We are in receipt of your first request for production.

From: Larry Schneider [mailto:[email protected]]

From: Larry Schneider

Sent from my iPhone

On Jun 8, 2017, at 11:20 AM, Henry Bolz <[email protected]> wrote:

Henry H. Bolz, III

From: Larry Schneider [mailto:[email protected]]

From: Henry Bolz [mailto:[email protected]]

Mr. and Mrs. Schneider,

Henry H. Bolz, III

From: Larry Schneider

From: Larry Schneider

Sent from my iPhone

On Jun 8, 2017, at 11:20 AM, Henry Bolz <[email protected]> wrote:

Henry H. Bolz, III

From: Larry Schneider [mailto:[email protected]]

From: Henry Bolz [mailto:[email protected]]

Mr. and Mrs. Schneider,

Henry H. Bolz, III

From: Larry Schneider

Sent from my iPhone

On Jun 8, 2017, at 11:20 AM, Henry Bolz <[email protected]> wrote:

Henry H. Bolz, III

From: Larry Schneider [mailto:[email protected]]

From: Henry Bolz [mailto:[email protected]]

Mr. and Mrs. Schneider,

[ORAL ARGUMENT NOT YET SCHEDULED]

IN THE UNITED STATES COURT OF APPEALS

UNITED STATES OF AMERICA, EX REL. LAURENCE SCHNEIDER, ET AL.,

JPMORGAN CHASE BANK, NATIONAL ASSOCIATION; JPMORGAN

BRIEF FOR THE UNITED STATES AS AMICUS CURIAE

CERTIFICATE AS TO PARTIES, RULINGS, AND RELATED CASES

A. Parties and Amici

State of California, ex rel. Laurence Schneider; State of Delaware, ex rel. Laurence

Schneider; State of Florida, ex rel. Laurence Schneider; State of Georgia, ex rel.

Laurence Schneider; State of Hawaii, ex rel. Laurence Schneider; State of Illinois, ex

rel. Laurence Schneider; Commonwealth of Massachusetts, ex rel. Laurence

Schneider; State of Minnesota, ex rel. Laurence Schneider; State of Montana, ex rel.

Schneider; State of Rhode Island, ex rel. Laurence Schneider; State of Tennessee, ex

rel. Laurence Schneider; Commonwealth of Virginia, ex rel. Laurence Schneider;

District of Columbia, ex rel. Laurence Schneider. The plaintiff-appellant is Laurence

Schneider. The defendants-appellees are JPMorgan Chase Bank, National

States is participating as amicus curiae.

B. Rulings Under Review