Filing # 79112877 E-Filed 10/10/2018 08 :25: 18 AM

IN THE CIRCUIT COURT OF THE 15TH

JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA

CASE NO. 502016CA009292:XXXXMB(AH)

FIRST AMERICAN BANK,

Plaintiff,

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vs.

LAURENCE S. SCHNEIDER,

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STEPHANIE L. SCHNEIDER, et al.

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Defendants.
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DEFENDANT LAURENCE S. SCHNEIDERS' REPLY IN OPPOSITION TO MOTION
TO DISBURSE CASH BOND,
AND
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MOTION TO DISBURSE CASH BOND TO DEFENDANT

COMES NOW, Laurence S. Schneider ("SCHNEIDER"), by and through the undersigned

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counsel and hereby file this REPLY IN OPPOSITION TO MOTION TO DISBURSE CASH
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BOND, AND MOTION TO DISBURSE CASH BOND TO DEFENDANT and as grounds

therefore states as follows:

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I. INTRODUCTION and FACTUAL BACKGROUND

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Defendant readopts and realleges the statements contained within its REPLY IN
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OPPOSITION, MOTION TO STRIKE MOTION CALENDAR HEARING AND MOTION TO

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EXTEND STAY.
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On August 17, 2016, FAB filed a Foreclosure Complaint against SCHNEIDER and

various other defendants containing two counts ("Complaint"). Count I sought recovery in equity

by foreclosing on a mortgage ("Mortgage"). Count II sought recovery for SCHNEIDER's

alleged breach of the very same contract, entitled Credit Agreement ("Credit Agreement") that

FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 10/10/2018 08:25: 18 AM
gave rise to the mortgage. Essentially, the two counts sought to recover the same loss through

two alternative legal theories.

On May 25, 2017, while SCHNEIDER was proceeding pro se, FAB filed a

Motion for Summary Judgment. On June 26, 2017, the Court held a hearing on FAB's Motion

for Summary Judgment. SCHNEIDER was not present at that hearing due to a scheduling

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conflict which was disclosed to Plaintiff's counsel by email dated May 26, 2017. Plaintiff's

counsel, Henry Bolz, Esq. received the email and replied that same day:

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"Your advices that you are "unavailable from between June 26, 2017 and

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July 5, 2017" precludes our ability to set the Motion for Summary
Judgment down for hearing on June 26, 2017. We will pursue alternate

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dates for the hearing." (Emphasis added.)

A true and correct copy of the May 26, 2017 email exchange is attached hereto as Exhibit "A".
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Despite same, the trial court granted FAB's Motion for Summary Judgment at a hearing
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on June 26, 2017 at which SCHNEIDER was not present, at a time when SCHNEIDER was

proceeding prose after his former counsel's suspension from the Florida Bar, then withdrawal
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from this matter, and while outstanding relevant discovery requests remained unresponded to by
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FAB. In the weeks following the summary judgment hearing, the trial court entered numerous

judgments and amended judgments in favor ofFAB and against SCHNEIDER.

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On July 11, 2017, SCHNEIDER filed a Motion for Rehearing and to Vacate Final
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Judgment; on July 18, 2017, the trial court entered an Order Denying the Motion for Rehearing
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and to Vacate Judgment. On July 18, 2017, SCHNEIDER filed a Notice of Appeal. After filing
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his Notice of Appeal, SCHNEIDER, still proceeding pro se, filed numerous motions seeking

post-judgment relief, including: (1) an Emergency Request for a Temporary Restraining Order,

dated August 7, 2017; and (2) an Emergency Motion for Stay of Execution of Judgment Pending

Appeal and Request to Extend Injunction, dated September 6, 2017 ("Motion for Stay"). On

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August 8, 2017, the trial court entered an Order stating it would treat SCHNEIDER's August 7,

2017 Emergency Request for a Temporary Restraining Order as a Motion for Stay of the

Foreclosure Sale pending appeal, resetting the foreclosure sale of the Property for September 12,

2017, and setting an evidentiary hearing on the Motion for Stay of the Foreclosure Sale for

September 1, 2017.

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Additionally, on or about August 30, 2017, again proceeding prose, SCHNEIDER filed a

pleading titled "Defendants' Opposition to Plaintiff's Motion to Strike; Defendant's Motion to

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Compel; Memorandum of Points and Authorities in Support Thereof," seeking, among other

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relief, an Order compelling FAB to produce to SCHNEIDER unredacted, accurate, and itemized

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attorneys' fee statements ("Motion to Compel"). As more fully explained in the Motion to

Compel, on or about August 28, 2017, FAB's counsel, Keller & Bolz, LLP, ("Bolz") first
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produced to SCHNEIDER the billing statements it had sent to Plaintiff ("Billing Records").
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Those Billing Records, however, were redacted to the point where it is unclear whether or how a
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substantial portion of the work for which Bolz billed FAB was related to the instant case at all,

let alone whether it was related to an issue on which FAB was successful. Even with the
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redaction, however, the Billing Records reference an unnamed "co-counsel" who has never filed
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a notice of appearance in this matter. A comparison of Bolz's Billing Records to the Loan
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History attached to the Smith Affidavit reflected payments from F AB to Bolz for its attorneys'
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fees and costs in this matter on or near the same dates on which FAB assessed "assess loan
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expense fee[s]" in identical amounts on the loan, which "loan fees". The redacted attorney's

billing include communication with FAB's Chairman of the Board. Chief Executive Officer, and

Chief Financial Officer.

On September 6, 2017, SCHNEIDER filed a pleading captioned "Emergency Motion for

Stay of Execution of Judgment Pending Appeal; Request to Extend Injunction," seeking a

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continuation of the evidentiary hearing on SCHNEIDER's Motion for Stay due to the scheduled

court closure on September 8, 2017 for Hurricane Irma and a further postponement of the

foreclosure sale until after the continued evidentiary hearing. Due to Hurricane Irma, all

foreclosure sales set to take place on September 12, 2017, were cancelled. Accordingly, on

September 21, 2017, F AB filed a Motion to Reset Sale Date, requesting that the trial court "enter

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an Order resetting the foreclosure sale of the Property as soon as possible." On October 2, 2017,

the trial court entered several Orders. One was titled "Order Resetting Evidentiary Hearing on

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Defendant's Emergency Request for Temporary Restraining Order/Motion for Stay Pending

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Appeal Filed on September 6, 2017". It provided that the evidentiary hearing on SCHNEIDER's

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September 6, 2017 "Emergency Request For Temporary Restraining Order/Motion For Stay

Pending Appeal" was to be held on November 6, 2017. That same day, the trial court entered an
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Order resetting the foreclosure sale date of the Property for November 27, 2017.
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On November 1, 2017, SCHNEIDER retained the undersigned counsel for the trial court
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proceeding, who immediately filed his Notice of Appearance in the trial court. On November 6,

2017 SCHNEIDER, through his new counsel, filed a Memorandum of Law in Support of Motion
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for Stay Pending Appeal. In the Memorandum, SCHNEIDER argued a stay pending appeal
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should be granted based on conditions other than posting of a full bond under Florida Rule of
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Appellate Procedure 9.3 lO(a). SCHNEIDER further argued that the trial court should consider
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the identical amounts set forth in FAB' s Loan History and Bolz' s Billing Records in determining
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the appropriate conditions of a stay pending appeal. On the afternoon of November 6, 2017, the

parties appeared for the Evidentiary Hearing on SCHNEIDER's Motion for Stay. At the

November 6, 2017 hearing, FAB's appraisal of the Property was entered into evidence and the

parties stipulated that the fair market value of the Property is approximately $1,300,000 and that

the Property is not in danger of any waste. Additionally, Bolz's Billing Records, showing FAB
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was billed and paid $285,587.41 in attorney's fees and costs solely related to the underlying

litigation in this matter, were entered into evidence over SCHNEIDER's objection. After

entering these exhibits into evidence, and pursuant to SCHNEIDER's Motion to Continue

Evidentiary Hearing, the trial court recessed the proceedings for two days, allowing

SCHNEIDER's new counsel to file supplemental materials prior to the continued Evidentiary

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Hearing, and entered an Order granting SCHNEIDER's Motion to Continue and resetting the

Evidentiary Hearing for November 8, 2017. On November 7, 2017, SCHNEIDER filed a

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Supplemental Memorandum of Law in Support of Motion for Stay Pending Appeal.

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In that Memorandum, SCHNEIDER argued a stay pending appeal is appropriate due to

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SCHNEIDER's likelihood of success on the merits on appeal and the likelihood of harm to

SCHNEIDER if a stay is not granted and a foreclosure sale on the Property proceeds before
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SCHNEIDER has the opportunity to exercise his appellate rights. SCHNEIDER submitted that
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appropriate conditions for a stay pending appeal included requiring SCHNEIDER to post a
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$115,000 bond, representing the approximate difference between the stipulated fair market value

of the Property found in FAB's appraisal ($1,300,000) and the Amended Damages Judgment
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($1,625,072.21), less the amount of attorney's fees and costs apparently included in the
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Amended Damages Judgment, as reflected in both the Loan History and Bolz's Billing Records
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($211,067.80).
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On November 8, 2017, the parties again appeared before the trial court for the continued
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Evidentiary Hearing. The trial court then heard extensive argument from both parties regarding

whether a stay pending appeal should be granted and, if so, what the appropriate conditions

should be. F AB argued that SCHNEIDER should be required to post two separate bonds in the

full amount of each judgment, plus costs and fees.

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 On November 15, 201 7, the trial court entered an Order on Defendants', Laurence S.

SCHNEIDER and Stephanie L. SCHNEIDER, Emergency Motion for Stay of Execution of

Judgment Pending Appeal; Request to Extend Injunction. That Order granted a stay pending

appeal on all judgments and amended judgments as to SCHNEIDER and provided that, upon the

posting of a bond, the November 27, 2017 foreclosure sale of the Property was stayed pending

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further order of the trial court. The order stated:

"1. The Court has considered the Defendants' significant likelihood of success

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on the merits, and the likelihood of harm should a stay not be granted as set
forth in Perez v. Perez, 769 So. 2d 389, 391 n.4 (Fla. 3d DCA 1999). The Court

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takes considerable consideration of the fact that the only evidence given at the
summary judgment hearing related to the balance owed by Defendants, at which

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no one appeared on behalf of the Defendants, was the Affidavit of Indebtedness
attached to Plaintiff's Motion for Summary Judgment executed by Gary S.
Smith, Senior Vice President of Plaintiff. Said Affidavit alleged that the
Principal due to Plaintiff was $1,488,554.76, interest in the amount of
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$64,304.08, and taxes in the amount of $66,870.93 for a total of $1,619.729.77.
The Affidavit attached a "Loan History" dated May 25, 2017. Said Loan History
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referenced numerous "Assess Loan Expense Fee[s]." The Court reviewed

Plaintiff's counsel's Monthly Invoices. The Assess Loan Expense Fee[s] are
actual the amounts of fees billed by Plaintiff's counsel and paid by Plaintiff. No
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other financial statements were attached to Plaintiff's Motion for Summary

Judgment such that the Court could determine the actual amount of principal
owed Plaintiff, especially in light of the following:
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a. The Loan History stated that the current balance is $1,553,895.74; and
b. The Loan History sets forth Assess Loan Expense Fee[s] far in excess of
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$65,340.98 (current balance as indicated on the Loan History of

$1,553,895.74 less Principal due to Plaintiff as alleged in the Affidavit
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of Indebtedness executed by Gary S. Smith, Senior Vice President of

Plaintiff in the amount of $1,488,554.76).
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As conditions of stay, the Order required SCHNEIDER to post a supersedeas bond in the
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amount of $115,000.00, representing "the approximate difference between the fair market value

of the home as stipulated to by the parties ($1,300,000.00) and the amount of the Amended

Damages Judgment ($1,625,072.21), less the amount of the attorney's fees and costs set forth in

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Plaintiff's counsel's invoices ($211,067.80) without rendering a determination if same were

included therein.". On November 22, 2017, SCHNEIDER posted the $115,000.00 bond.

Only July 25, 2018 the Fourth District Court of Appeal issued its Opinion Granting in

Part and Denning in Part SCHNEIDER's appeal stating:

"Laurence Schneider appeals a final judgment of foreclosure and a separate

amended final judgment awarding damages to First American Bank (the

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"Bank") for breach of a credit agreement. We reverse to the extent that the
judgments improperly allowed the Bank to simultaneously execute on the
money judgment and foreclose on appellant's property. On all other issues,

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we affirm."

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And further,

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"Here, we find that the trial court erred in entering two judgments-a money
judgment and a foreclosure judgment-that together allowed the Bank to
simultaneously execute on the money judgment and foreclose on appellant's
property. To remedy this error, we reverse only the foreclosure judgment. On
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remand, the trial court shall modify the foreclosure judgment so as to
withhold the setting of the foreclosure sale of the property until the Bank
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certifies that its money judgment remains unsatisfied. See Royal Palm, 89 So.
3d at 928. This procedure assures that, while the Bank was free to pursue
both remedies, it will not obtain a recovery that exceeds the amount of the
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debt. Id. at 933. Moreover, once the Bank "has obtained a foreclosure sale of
the property, it cannot collect on the note other than to pursue the
appropriate deficiency amount." Bonita Real Estate Partners, LLC v. SLF IV
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Lending, L.P., 222 So. 3d 647, 652 (Fla. 2d DCA 2017).

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On September 7, 2018 the Fourth District Court of Appeal issued its Mandate. On

September 10, 2018 FAB filed PLAINTIFF'S MOTION TO ENFORCE DECREE AND TO
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LIFT STAY PENDING REVIEW. Contemporaneous with its filing PLAINTIFF'S MOTION
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TO DISBURSE CASH BOND, , FAB also filed PLAINTIFF'S MOTION TO ENFORCE

DECREE AND TO LIFT STAY PENDING REVIEW.

DISCUSSION

FAB' s actions throughout this litigation and especially since the entry of the Mandate are

unreconcilable. FAB's MOTION TO ENFORCE DECREE AND TO LIFT STAY PENDING

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REVIEW cites Superior Garlic Int'!, Inc. v. E&A Produce Corp., 934 So. 2d 484, 486 (Fla. 3d

DCA 2004) for the proposition that" .... once the mandate issues: "It is the duty of the trial court

to enforce the mandate and not stray from it."). "The mandate of an appellate court is a final

judgment in a cause, and compliance [therewith] is a ministerial act to be performed by the trial

court." While, SCHNEIDER does not dispute this, FAB's contemporaneous filing of its

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MOTION TO DISBURSE CASH BOND flies directly in the face of Superior. Specifically, the

Court in Superior stated:

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"The mandate of an appellate court is a final judgment in the cause, and

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compliance [therewith] is a ministerial act to be performed by the trial
court." Nicholson v. Ariko, 565_So. 2d_843 (Fla. 5th DCA 1990). Upon issuance

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of a mandate, an automatic stay resulting from the posting of a supersedeas bond
is automatically lifted, and the judgment creditor has the right to either
execute on the judgment or proceed against the supersedeas bond. See Fla.
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R.App. P. 9.310(e). (Emphasis added.)
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FAB cannot seek to execute on the judgment and proceed against the supersedeas bond
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based on this one cited case law. FAB must elect one of the two remedies it seeks and cannot

attempt an end around by seeking such unreconcilable relief by way of two motions set at two
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separate hearings over SCHNEIDER's request as SCHNEIDER previously advised FAB's

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counsel that this motion cannot be heard at a five-minute motion calendar.

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Most important to the Court's analysis, is that SCHNEIDER argued to the Court and to
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the Appellate court that it was improper to allow Plaintiff to proceed with the sale of the property
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and execute on the money judgment. The Fourth District Court of Appeal agreed with

SCHNEIDER on this issue and has required Plaintiff to submit an amended judgment of

foreclosure. Therefore, SCHNEIDER was the prevailing party as to this issue on appeal.

Plaintiff acknowledges same in its motion which states "The appellate court reversed the Final

Judgment of Foreclosure ..... "

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 II. ADDITIONAL ISSUES REQUIRING AN EXTENSION

Immediately upon receipt of the Forth District's Mandate, the undersigned attempted to

schedule a meeting with SCHNEIDER to discuss this matter. Unfortunately, the undersigned and

SCHNEIDER have been unable to meet or otherwise discuss the pending issues at any length

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due to the fact that SCHNEIDER's father fell ill and was transferred to hospice. Despite same

the undersigned and SCHNEIDER were set to meet on September 25, 2018 to prepare. However,

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SCHNEIDER's father passed away earlier that day.

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Additionally, On September 10, 2018, the same day FAB filed its MOTION TO

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ENFORCE DECREE AND TO LIFT STAY PENDING REVIEW and MOTION TO

DISBURSE CASH BOND, undersigned counsel formed a new law firm, George Gesten
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McDonald PLLC. Undersigned counsel has been diligently attempting to set up this new law
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firm with his partners and expects to be operational on October 15, 2018. The offices require
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extensive renovations, initial set up, and technological hardware and software installations

requiring substantial time and effort of the undersigned. The undersigned will have to onboard
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SCHNEIDER at its new firm and will require time to clear conflicts once the firm is operational
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on or about October 15, 2018.

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WHEREFORE, Defendants respectfully request that this Court enter an Order disbursing
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the supersedeas bond to SCHNEIDER, and for such other and further relief as the Court deems
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just and proper.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished on
October 10, 2018, via transmission of a notice of electronic filing generated by the Florida
Courts E-Filing Portal to Henry H. Bolz, III, Esq., Counsel for Plaintiff, Keller & Bolz, LLP, 121
Majorca Ave., Suite 200, Coral Gables, FL 33134 (hbolz@kellerbolz.com) and Jay S. Levin,

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Esq., Counsel for Oaks at Boca Raton, Sachs, Sax, Caplan, 6111 Broken Sound Pkwy., NW,
Suite 200, Boca Raton, FL 33487 (foreclosures@ssclawfirm.com).

RYAN D. GESTEN, P.A.

Attorneys for Defendant, SCHNEIDER
Main Address:
200 South Andrews Avenue, Ninth Floor
Fort Lauderdale, Florida 33301
Mailing Address:
3389 Sheridan Street, #284

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Hollywood, Florida 33021
Telephone: (888) 421-0050
Email: Ryan@GestenLaw.com

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By: Isl Ryan D. Gesten

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RYAN D. GESTEN, ESQ.
Florida Bar No.: 240760

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Larry Schneider

From: Henry Bolz <hbolz@kellerbolz.com>

Sent: Friday, May 26, 2017 12:53 PM
To: Larry Schneider
Subject: RE: First American Bank v. Schneider et al.
Attachments: E2 Schneider 05~24-17.pdf; E2 Schneider 05-16-17.pdf

Mr. Schneider,

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I am in receipt of and have reviewed your email to me of 11 :12.a.m. today. I take this opportunity to
respond to the statements and requests set out therein.

Your advices that you are "unavailable from between June 26, 2017 and July 5, 2017" precludes our

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ability to set the Motion for Summary Judgment down for hearing on June 26, 2017. We will pursue
alternate dates for the hearing.

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For the reasons that I gave you in my email to you of yesterday.(copy attached for ease of reference),

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neither First American Bank nor Keller & Bolz, LLP are willing to acquiesce in your request for yet·
another ''ten business daysllstandstill. · ·

Our office has no knowledge or information about your relationship with Attorney Kenneth Trent
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between August 2016 and the present. With that said, AttorneyTrent was your record legal counsel
up to May 1, 2017. Accordingly, any and all of the correspondence, pleadings and documents that
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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.
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In response to your query as to when you should expect to receive First American Bank's responses
to the April 24; 2017 First Request for Production, as I stated to you in my May 16, 2017 email (copy
attached for ease of reference), First American Bank will.not be responding to those Requests due to
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deficiencies (A-E) identified in my email.

Regards,
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HenryH. Bolz~. Ill

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Keller & Bolz, LLP

121 Majorca Avenue, #200
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Coral Gables, FL 33134

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

E-mail: hbolz@kellerbolz.com

IMPORTANT: THIS E-MAIL AND ANY ATTACHMENTS THERETO: IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS
ADDRESSED AND MAY CONTAIN INFORMATION THAT IS LEGALLY PRIVILEGED. CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER
APPLICABLE LAW IFTHE 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.

EXHIBIT "A" 1
From: Larry Schne.ider [mailto:larry@sacapitalpartners.com]
Sent: Friday, May 26, 2017 11:12 AM
To: Henry Bolz <hbolz@kellerbolz.com>
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

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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

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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

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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.

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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 will be, prior to providing me with the communications. For the above mentioned reasons, I request that you
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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
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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.
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If you are unable or unwilling to assist me in providing the communications, please let me know immediately. 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.
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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 Produc_tion which I sent on April 24, 2017, and
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when we can expect to receive FAB's responses to these requests.

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Sincerely,
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Larry Schneider
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305-710-4201
la rry@sacapitalpartners.com

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

Sent: Friday, May 26, 2017 9:53 AM
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To: Larry Schneider<larry@sacapitalpa rtners.com>; Stephanie Schneider (steffschneiderl3@gmail.com)
<steffschneider13@gmail.com>
Subject~ f,rst American Bank v. Schneider et al.

Mr. and Mrs. Schneider,

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 2:30 p.m. on Monday, June 26, 2017. Please let us know {by noon) if you can attend the
h~aring on June 26, 2016 and at what time.

Regards.

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Henry H. Bolz, Ill
Keller & Bolz, LLP
121 Majorca Avenue, #200

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Coral Gables, FL 33134
Telephone: (305) 529-8500

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Telefax: (305) 529-0228
E-mail: hbolz@kellerbolz.com

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IMPORTANT: THIS E-MAIL AND ANY ATTACHMENTS THERETO, IS INTENDED FOR THE USE
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OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN
INFORMATION THAT IS LEGALLY PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM
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DISCLOSURE UNDER APPLICABLE LAW. IF THE READER OF THIS E-MAIL IS NOT THE
INTENDED RECIPIENT, OR THE EMPLOYEE OR AGENTRESPONSIBLE FOR DELIVERING THE
E-MAIL TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY
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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)
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AND PERMANENTLY DELETE THE ORIGINAL OR ANY PRINTOUT THEREOF.

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