Filing# 110332930 E-Filed 07/16/2020 11:29:29 AM

IN THE CIRCUIT COURT OF

THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA

CASE NO.: 502016-CA-009292

DIVlSION AH

FIRST AMERICAN BANK, as

successor by merger to Bank of
Coral Gables, LLC,

Plaintiff,

V.

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

Defendants.
- - -- -- - -- - -- - - -I
PLAINTIFF'S, FIRST AMERICAN BANK,
NOTICE OF COMPLIANCE WITH THIS COURT'S JUNE 23, 2020 ORDER

Plaintiff, FIRST AMERICAN BANK, by and through its undersigned counsel, and

pursuant to this Court's June 23 , 2020 Amended Order Setting Plaintiff's, FIRST AMERICAN

BANK, Motion for Assessment of Attorneys' Fees, Costs, and Expenses for Enforcement and

Collection of the Judgments filed May 18, 2020 and Plaintiff's, FIRST AMERICAN BANK,

Motion for Assessment of Attorneys ' Fees, Costs, and Expenses for Litigating Fees Amounts filed

May 18, 2020 on a Non-Jury Docket and Directing Prehearing Procedure [DE 455], hereby files

this its Notice of Compliance with this Court' s June 23, 2020 Order.

Plaintiff's Fee Expert

Plaintiff, FIRST AME RICAN BANK ("First American") has retained Scott G. Hawkins,

~ . as an expert w itness. Mr. Hawkins contact information is provided below:

 Scott G. Hawkins, Esq.
c/o Jones, Foster, Johnston & Stubbs, P.A.
_flagler Center Tower
----,.-----
505 South Flagler Drive, Suite 1100
; West~ ea£ FL 33401
Telephone No.: (561) 650-0460

Copies ofBilling Invoices,

Excerpted Transcripts, and Invoices for Costs and Expenses

On May 18, 2020, First American provided copies of the billing invoices (redacted),

excerpted transcripts I and invoices for the costs and expenses supporting its requests for fees,

costs, and expenses to Defendants.2 These documents were attached as exhibits to the Motion for

Assessment of Attorney's Fees, Costs, and Expenses Related to Preservation, Enforcement, and

Collection of the Judgments (bearing a Certificate of Service date of May 18, 2020) [DE 441) and

Motion for Assessment of Attorneys' Fees, Costs, and Expenses for Litigating Fees Amounts

(bearing a Certificate of Service date of May 18, 20202,[DE 442). Specifically,

1. Redacted copies of the billing invoices submitted by Keller & Bolz, LLP to First

American relating to the representation of First American's interest with respect to preservation,

enforcement, and collection of the Judgments from December 12, 2017 through March 31, 2020

were attached as Exhibit "B" to the Motion for Assessment of Attorney's Fees, Costs, and

Expenses Related to Preservation, Enforcement, and Collection of the Judgments [DE 441 at 73-

303);

First American submits redacted copies of the billing invoices and excerpted transcripts of the billing invoices
in order to (a) exclude matters that did not relate to the representation of First American's interest in this case; and (b)
preserve matters protected under its attorney-client privilege and the work product doctrine.

2
By submission of the evidence suppo1iing the Motion for Assessment of Attorney's Fees, Costs and Expenses
and Incorporated Memorandum of Law, the Motion for Appellate Attorney's Fees and Incorporated Memorandum of
Law and the Motion to Tax Appellate Costs, First American does not intend, nor shall it in any way be deemed, to
waive attorney-client privilege, work product doctrine protections or the protections of any applicable privilege or
doctrine.

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 2. Excerpted transcripts of the billing invoices submitted by Keller & Bolz, LLP to

First American relating to the representation of First American's interest with respect to

preservation, enforcement, and collection of the Judgments from December 12, 2017 through

March 31, 2020 were attached as Exhibit "A" to the Motion for Assessment of Attorney's Fees,

Costs, and Expenses Related to Preservation, Enforcement, and Collection of the Judgments [DE

441 at 17-72];

3. Copies of the invoices for costs and expenses incurred by First American relating

to the representation of First American' s interest with respect to preservation, enforcement, and

.,,collection of the Judgments from December 12, 2017 through March 31 , 2020 were attached as

Exhibit "C" to the Motion for Assessment of Attorney's Fees, Costs, and Expenses Related to

Preservation, Enforcement, and Collection of the Judgments LDE 441 at 304-343);

4. Redacted copies of the billing invoices submitted by Keller & Bolz, LLP to First

American relating to the representation of First American' s interest ·with respect to litigating the

fees amounts from July 30, 2018 through March 17, 2020 were attached as Exhibit ''B" to the

Motion for Assessment of Attorneys' Fees, Costs, and Expenses for Litigating Fees Amounts [DE

442 at 84-281);

5. Excerpted transcripts of the billing invoices submitted by Keller & Bolz, LLP to

First American relating to the representation of First American's interest with respect to Iitigating

the fees amounts from July 30, 2018 through March 17, 2020 were attached as Exhibit "A" to the

Motion for Assessment of Attorneys' Fees, Costs, and Expenses for Litigating Fees AmountsJ DE

...._4 42 at 18-83)

6. Copies of the invoices for costs and expenses incurred by First American relating

to the representation of First American' s interest with respect to litigating the fees amounts from

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,July 30, 2018 through March 171 2020 wer,s attached ';s Exhibit "C" to the Motion for Assessment

of Attorneys' Fees, Costs, and Expenses for Litigating Fees Amounts [DE 442 at 282-307].

Respectfully submitted,

KELLER & MESA, LLP

Attorneys for Plaintiff
121 Majorca A venue, #200
Coral Gables, FL 33134
Telephone: (305) 529-8500
Telefax: (305) 529-0228
Email: jkeller@kellermesa.com

By:_-=s"/'-.::;..Jo=h=n'-'W.-'--.:. . :Ki=e=ll=er:.. .i. .=Il=I_ __

John W. Keller, III
F lorida Bar N o. 229989

CERTIFICATE OF SERVICE

WE HEREBY CERTIFY that a true and correct copy of the foregoing, Plaintiffs, First

American Bank, Notice of Compliance with this Court' s June 23, 2020 Order, was delivered to:

LAURENCE S. SCHNEIDER (larry@sacapitalpartners.com), 17685 Circle Pond Court, Boca

Raton, FL 33496; STEPHANIE L. SCHN ELDER (steffschneider13@gmail.com), 17685 Circle

Pond Court, Boca Raton, FL 33496; ALEKSAN DRA NOVAKOVICH GONZALEZ, ESQ.

(foreclosures@ ssclawfirm.com), Sachs, Sax, Caplan, Attorneys for Oaks at Boca Raton, 6111

Broken Sound Parkway, N.W., #200, Boca Raton, FL 33487; and GEOFFREY M. CAHEN, ESQ.

(geoff@ cahenlaw.com), Cahen Law, P.A., 1900 Glades Road, Suite 270, Boca Raton, FL 33431

via the E-filing Portal on this 16th day of July, 2020.

KELLER & MESA, LLP

By:_~s/~Ji~o~h~n_W.~·~K,=e~ll~er'--'-=I=
lI_ __
John W. Keller, III

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