Fili ng# 112820114 E-F iled 09/03/2020 05:5

8:26 AM

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 152016-CA-009292

FIR ST AM ERI CA N BANK, as ·successor
by merger to BA'NK OF CORALGABLES, LLC
.
Plaintiff,

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vs.

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LAURENCE SCHNEIDER,

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STEPHANIE L. SCHNEIDER;

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.Defendants.
-- -- -- -- -- -- -- -- -I FI
State•ofFlorida
County of Palm Beach
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EMERGENCY MO TIO N FOR TEM POR

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ARY RESTRAINING ORDER AND /OR

TEM POR ARY INJ UNC TIO N.

COMES NOW, Defendants Laurence Schneider

arid S_tephanie Schneider;pro se
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litigants, request the emergency issuance ofanEme

rge1icyPetiti011for Temporafj
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·Restrai11i11g Order a11dlor Prelimi11aryJ11j1mctio1

1, and as grounds for said reqµest
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states:
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1~ "Plaintiff, First American Bank, has intentionally

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defrauded Defenda11ts~ Laurence

Schneider arid Stephanie Schneider, arid Defenda
nt's entities in a conspiracy to
commit fraudulent, unsafe and unsound practices
in.vioiatiori of the Federal.
Deposit Insurance Act (hereinafter referred to as
"FDI,,),which include over

FILED: PALM BEACH COUNTY, FL, SHA

RON R. BOCK, CLERK, 0
 1,000 separate instances of mail fraud, wire fraud,.conspira
.
cy to commit fraud,
.

preparing offraudulent documents for the purpose of comm

itting fraud, Abuse of
Process, Malicious Prosecution, intimidation, Defamatio
n, Unjust Enrichment and
execution of knowingly false affidavits for the purpose of
committing fraud on
numerous judges in the 15th Circuit for Palm Beach Coun
ty, Florida, the United

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States District Court for the Southern District of Florida
and the Florida Court of
Appeals.

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2. Plaintiffs legal counsel, Keller & Mesa, LLP (formerly
known as Keller & Bolz,

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LLP) has conspired with First American Bank, its executive
s, directors and

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employees to defraud Defendants, Laurence Schneider and
Stephanie Schneider,
and Defendant's entity, S&A Capital Partners, which is owne
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d in part by
Laurence Schneider and Stephanie Schneider, through false
representations of
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material facts including execution of knowingly false affid

avits to commit fraud
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upon numerous 15th Circuit Court Judges in Palm Beach

County and the United
States District Court for the Southern District of Florida,
including Judge Donald
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M. Middlebrooks, Senior Judge Kenneth A. Marra and Mag

istrate Judge David
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Lee Brannon.
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3. Plaintiff has filed a motion to obtain a Writ of Possessio

n for Defendant's primary
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residence located at I 7685 Circle.Pond Court, Boca Rato

n, Florida 33496, as a
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result of these maliciously perpetuated frauds by Plaintiff

and Plaintiffs counsel
on Defendants, Defendants' Entities, and the numerous judg
es and courts of law
in Florida stated above. Upon this court's granting the Moti
on for Withdrawal of
formalcounsel, Charles Rodman and Andrew Wyman in
mid-July of 2020, two
 weeks prior to the foreclosure sale, and upon attempting to review
the thousands
ofline -by-li ne objections to the heavily redacted billing statem
ents for attorney's
fees and costs for attorn ey's fees and costs for their fraudulent
foreclosure action,
it is blatantly obvious that the entire default and litigation was
a choreographed
series of frauds, including communications with yet another law
firm, Freeborn &

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Peters, LLP. Attor ney's Rodm an and Wyman ru::e not the only
counsel for
defendants, who have been intimidated or otherwise coerced into
withdrawing

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and in certain instances, betrayed by former counsel. On Octob
er 5, 2017, Henry

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H. Bolz III of Keller & Bolz, LLP, filed a complaint against attorn
ey Tantillo for

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the unlicensed practice oflaw , despite'the Honorable Federal
District Court
Judge, Dona ld M: Middlebrooks, granting Tantillo pro hac vice
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in the related
federal cases, 17-80728 related to 17-80723. Additionally, attorn
ey Kenneth Trent
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was suspended by the Florida Bar in Nove mber of 2016, accor

ding to Kelle r &
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Bolz' billing records; as well as Bolz' admission during the Marc

h 27, 2019 Trial
for Attor ney's Fees before this court, admitted to coordinating
the Motions to
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Dismiss our counterclaims and affirmative defenses and said hearin

gs for those
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motions during the period in which attorney Trent was suspended.

Rather than
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filing the Notice of Suspension required by the Florida Bar, Trent

filed a simple
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Notice of Absence as to not alert the court of this suspension and

the Schneider's
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absolute non-representation during that period and without the

Schneider's
knowledge of Kelle r &Bo lz and First American Bank 's specif
ic intent to gain an
unfair advantage.
 4. Pursuantto the Affidavits of Laurence Schneide
r, Stephanie Schneider, Zachary
Schneider, Jordyn Schneider and Muriel Schneide
r, in support of the Emergency
Motion hereof and filed simultaneously with, thes
e immediate family members
were intentionally harassed and Defendants were
misrepresented to extended
family, significant others and colleagues (includi
ng two minors) by private

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investigator, Scott Fishman ofla w firm Freeborn
& Peters, LLP. Partner of
Freeborn & Peters, Neal Levin and First American
Bank Chairman and CEO,

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Thomas Wells, IV, along with Keller & Bolz, LLP
had various communications

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where it is obvious that Plaintiff and Plaintiff's coun
sel will go to any lengths to

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harm the reputation, entities and overall wellbein
g of Defendants. So much so,
that Defendant, Stephanie Schneider and daughter,
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Jordyn Schneider, have been
seeking medical attention by a wide range of doct
ors for the deterioration of their
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mental states due to the unwarranted stress of this

fraudulent foreclosure.
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5. Lastly, as this court is aware through numerou

s filings during the course of
litigation, that Laurence Schneider has been and
is a Qui Tam False Claims
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Whistleblower against JPMorgan Chase Bank, and

thus has been litigating in the
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shoes of the Federal and State government of the

United States and under the
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Florida False Claims Act laws, and the fact that the
entire litigation has been an
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obstruction ofjustice, the harms which would be

caused by a Writ of Possession
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granted by this court cannot be measured in mon

etary value and makes the
~Itimate resolution of this matter exponentially mor
e complicated.
6. As such, an Emergency Temporary Restraining
.Order and/or Temporary
Injunction needs to be issued to prevent the wrongfu
l granting by this court for a
 Writ of Possession, further obstruction of justice and excess bann
s to Defendants,
Defendant's family members which has been obtained by fraud
ulent, deceptive
and unfair practices.

Dated: September 03, 2020. Respectfully Submitted,

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LAURENCE SCHNEIDER
Pro se litigant

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STEPHANIE SCHNEIDER
Pro se litigant

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