Filinf#Sfll~di"r~¥.?i?

n~~oo)/(~~W2W~~5~~6 ~r ed
on FLSD Docket 10/21/2020 Page 1 of 5

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CA SE NO. 152016-CA-009292

FIRST AMERfCAN BANK, as successor

by me rge r to BA NK OF CORAL GABL
ES, LLC.

Pla intiff,

vs.

LAURENCE SCI INEIDER,

STE PH AN IE L. SC HN EID E~

Defendants.
- - - - - - - - -- - - - - - -I

State of Florida
County of Palm Beach

EM ER GE NC Y MOTION FO R TEM
PO RA RY RESTRAINING OR DE R
AN D/O R
TEMPORARY INJUNCTION

COMES NOW. Defendants Laurence Sch

neider and Stephanie Schneider, pro se
litigants, requ est the eme rgen cy issu ance
of an Emergency Peti/,/onfor Tempora
ry
.Restraining Ord er and /or Preliminar
y Injunction, and as grou nds for said requ
est
states:

1. Plaintiff, Firs1 American Bank, has intentio

nally defrauded Defendants. Laurence
Sch neid er and Step han ie Sch neid er ,
and Def end ant' s enti ties in a con spir acy
to
com mit fraudulent. uns afe and uns oun
d practices in violatio n of the Fed eral
Deposit Insurance Act (hereinafter referred
to as "FOi''). which include over

"A-39"
Case 9:20-cv-81728-DMM Document
17-39 Entered on FLSD Docket 10/
21/2020 Page 2 of 5

1.000 separate instances of mail fraud, wire

fraud, conspiracy to commit fraud,
preparing of fraudulent documents for the
purpose of committing fraud. Abuse of
Process, Malicious Prosecution, intimidation,
Defamation, Unjust Enrichment and
execution of knowingly false affidavits for
the purpose of committing fraud on
numerous judges in the 15th Circuit for Palm
Beach County, Florida, the United
States District Court for the Southern Dist
rict of Florida and the Florida Court of
Appeals.

2. Plaintiffs legal counsel, Keller & Mes

a, LLP (formerly known as Keller & Bolz,
LLP) bas conspired with First American Ban
k, its executives, directors and
employees to defraud Defendants, Laurenc
e Schneider and Stephanie Schneider,
and Defendant's entity, S&A Capital Partners
, which is owned in part by
Laurence Schneider and Stephanie Schneid
er, through false representations of
material facts including execution of knowin
gly false affidavits to commit fraud
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
M. Middlebrooks, Senior Judge Kenneth
A. Marra and Magistrate Judge David
Lee Brannon.

3. Plaintiff has filed a motion to obtain a

Writ ofPossession for Defendant' s primary
residence located at 17685 Circle Pond Cou
n, Boca Raton, Florida 33496, as a
result of these maliciously perpetuated frau
ds by Plaintiff and Plaintiff's counsel
on Defendants, Defendants' Entities, and
the numerous judges and courts of law
in Florida stated above. Upon this court's
granting the Motion for Withdrawal of
formal counsel, Charles Rodman and And
rew Wyman in mid-July of 2020, two
Case 9:20-cv-81728-DMM Document 17-3
9 Entered on FLSD Docket 10/21/2020
Page 3 of 5

weeks prior to the foreclosure sale, and upon attem

ptin g to review the thousands
of line-by-line objections co the heavily redacted
billing statements for attorney's
fees and costs for attorney'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 &
Peters, LLP. Attorney's Rodman and Wyman are
not the only counsel for
defendants, who have been intimidated or otherwis
e coerced into withdrawing
and in certain instances, betrayed by former coun
sel. On October 5, 2017, Henry
H. Bolz Ill of Keller & Bolz, LLP. filed a com
plaint against attorney Tantillo for
the unlicensed practice of law, despite the Honorab
le Federal District Court
Judge~ Donald M. Middlebrooks, granting Tant
illo pro hac vice in the related
federal cases. 17-80728 related to 17-80723. Add
itionally, attorney Kenneth Trent
was suspended by the Florida Bar in November
of 2016, according to Keller &
Bolz' billing records, as well as Bolz ' admission
during the March 27, 2019 Trial
for Attorney's Fees before this court. admitted to
coordinating the Motions to
Dismiss our counterclaims and affirmative defe
nses and said hearings for those
motions duri ng the period in which attorney Tren
t was suspended. Rather than
filing the Notice of Suspension required by the
Florida Bar, Trent filed a simple
Notice of Absence as to not alert the court of this
suspension and the Schneider's
absolute non-representation during that period and
without the Schneider's
knowledge of Keller & Bolz and First American
Bank' s specific intent to gain an
unfa ir advantage.
Case 9:20-cv-81728-DMM Document 17-39
Entered on FLSD Docket 10/21/2020 Page 4 of
5

4. Pursuant to the Affidavits of Laurence Schneider, Steph

anie Schneider, Zachary
Schneider, Jordyn Schneider and Muriel Schneider. in
support of the Emergency
Motion hereof and filed simultaneously with, these imme
diate family members
were intentionally harassed and Defendants were misre
presented to extended
family, significant others and colleagues (including two
minors) by private
investigator, Scott Fishman oflaw firm Freeborn & Peter
s, LLP. Partner of
Freeborn & Peters, Neal Levin and First American Bank
Chairman and CEO,
Thomas Wells, IV, along with Keller & Bolz, LLP had vario
us communications
where it is obvious that Plaintiff and Plaintiff's counsel
will go to any lengths to
harm the reputation, entities and overall wellbeing ofDefe
ndants. So much so,
that Defendant, Stephanie Schneider and daughter, Jordy
n Schneider, have been
seeking medical attention by a wide rang e of doctors for
the deterioration of their
mental states due to the unwarranted stress of this fraud
ulent forec losure.
5. Lastly, as this court is aware through numerous filing
s durin g the course of
litigation, that Laurence Schneider has been and is a Qui
Tam False Claims
Whistleblower against JPMorgan Chase Bank. and thus
has been litigating in the
shoes of the Federal and State government of the Unite
d States and under the
Florida False Claims Act laws. and the fact that the entir
e litigation has been an
obstruction ofjustice, the harms which would be cause
d by a Writ of Possession
granted by this court cannot be measured in monetary value
and makes the
ultimate resolution of this matter exponentially more comp
licated.
6. As such, an Emergency Temporary Restraining Orde
r and/o r Temporary
Injunction needs to be issued to prevent the wrongful grant
ing by this court for a
Case 9:20-cv-81728-DMM Document 17-39 Entered on
FLSD Docket 10/21/2020 Page 5 of 5

Writ of Possession, further obstruction of justice and excess hanns to

Defendants,
Defendant's family members which has been obtained by fraudulent,
deceptive
and unfair practices.

Dated: September 03, 2020. Respectfully Submitted,

LAURENCE SCHNEIDER
Pro se litigant

STEPHANIE SCHNEIDER
Pro se litigant