Filing # 157128891 E-Filed 09/09/2022 06:07:48 PM

IN THE CIRCUIT COURT OF THE 15TH

JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA

CIRCUIT CIVIL DIVISION: AH

CASE NO. 50-2016-CA-009292-XXXX-MB

FIRST AMERICAN BANK, as successor
by merger to Bank of Coral Gables, LLC,

Plaintiff,

PY
vs.

LAURENCE S. SCHNEIDER,

CO
STEPHANIE L. SCHNEIDER, et al.,

Defendants.
___________________________________/

D
NOTICE OF TAKING VIDEO-CONFERENCE DEPOSITIONS DUCES TECUM
IE
PLEASE TAKE NOTICE that pursuant to Florida Rule of Civil Procedure 1.310, the
IF
undersigned will take the depositions of the below-named persons on the dates and times indicated
RT

below:
CE

Name Date and Time Place

Corporate September 30, 2022 at Meland Budwick, P.A.
Representative 2:00 p.m. 200 South Biscayne Blvd.
of Singer Wealth Suite 3200
A

Advisors, LLC Miami, FL 33131

Corporate October 10, 2022 Via Veritext Zoom
T

Representative of at 10:00 a.m. Videoconference

O

AT&T Mobility LLC

Meeting ID# and password
N

will be provided prior to the

examination
Corporate October 10, 2022 Via Veritext Zoom
Representative of at 2:00 p.m. Videoconference
Regions Bank
Meeting ID# and password
will be provided prior to the
examination


1
BUDWICK
MELAND I| BUDWICK
MELAND
3200 SOUTHEAST
3200 FINANCIAL CENTER
SOUTHEAST FINANCIAL 200 SOUTH
CENTER I| 200 SOUTH BISCAYNE BOULEVARD I| MIAMI, FL
BISCAYNE BOULEVARD FL 33131 | T 305-358-6363
33131 IT 305-358-6363

*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 09/09/2022 06:07:48 PM ***
Regarding the matters described in the respective subpoenas attached as Composite Exhibit “A”
hereto. The depositions will be taken upon oral examination before a court reporter Veritext Court
Reporter, Notary Public, in and for the State of Florida at Large, or some other officer duly
authorized by law to take depositions. These depositions are being taken for discovery, use at trial,
or any other purpose permitted under the Rules of Civil Procedure and Rules of Evidence. The
depositions will continue from hour to hour and from day to day until completed.

NOTICE IS FURTHER GIVEN that we reserve the right to conduct these depositions utilizing the
secure web-based deposition option afforded by Veritext or in the alternative video
teleconferencing (VTC) services offered by Veritext (“Web Deposition”) or telephonically only to

PY
provide remote access for those parties wishing to participate in the depositions via the internet
and/or telephone. Also take notice that, the court reporter may also be remote via one of the options
above for the purposes of reporting the proceeding and may or may not be in the presence of the

CO
deponents. Please contact the noticing attorney at least five (5) calendar days prior to the
depositions so that the necessary credentials, call-in numbers, testing and information, if
necessary, can be provided to you prior to the proceedings. In addition, we also reserve the
right to utilize instant visual display technology such that the court reporter’s writing of the

D
proceeding will be displayed simultaneous to their writing of same on one’s laptop, iPad, tablet or
other type of display device connected to the court reporter.
IE
In accordance with the Americans with Disabilities Act of 1990, persons needing a special
IF
accommodation to participate in this proceeding should contact Meaghan E. Murphy, Esquire
at Meland Budwick, P.A. telephone number (305) 358-6363, no later than seven (7) days prior
RT

to the proceeding. If hearing impaired, telephone Florida Relay Service at 1-800-955-8771 for
assistance.
CE

[REMAINDEROFPAGEINTENTIONALLYLEFTBLANK]
A
T
O
N


2
BUDWICK
MELAND I| BUDWICK
MELAND
3200 SOUTHEAST
3200 FINANCIAL CENTER
SOUTHEAST FINANCIAL 200 SOUTH
CENTER I| 200 SOUTH BISCAYNE BOULEVARD I| MIAMI, FL
BISCAYNE BOULEVARD FL 33131 | T 305-358-6363
33131 IT 305-358-6363
 CERTIFICATE OF SERVICE

I CERTIFY that the foregoing document has been furnished to all registered users via the
Florida Courts e-Filing Portal on September 9, 2022.

s/ Meaghan E. Murphy
Meaghan E. Murphy, Esq.
Florida Bar No. 102770
mmurphy@melandbudwick.com
Meland Budwick, P.A.

PY
Co-Counsel for First American Bank
3200 Southeast Financial Center
200 South Biscayne Boulevard

CO
Miami, FL 33131
Telephone: (305) 358-6363
Facsimile: (305) 358-1221

D
Email Designation per Fla. R. Jud.
Admin 2.516
IE
mmurphy@melandbudwick.com
mramos@melandbudwick.com
IF
mrbstate@yahoo.com
RT
CE
A
T
O
N


3
BUDWICK
MELAND I| BUDWICK
MELAND
3200 SOUTHEAST
3200 FINANCIAL CENTER
SOUTHEAST FINANCIAL 200 SOUTH
CENTER I| 200 SOUTH BISCAYNE BOULEVARD I| MIAMI,
BISCAYNE BOULEVARD FL 33131
MIAMI, FL | T 305-358-6363
33131 IT 305-358-6363
 IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA

CIRCUIT CIVIL DIVISION: AH

CASE NO. 50-2016-CA-009292-XXXX-MB

FIRST AMERICAN BANK, as successor

by merger to Bank of Coral Gables, LLC,

PY
Plaintiff,
vs.

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

Defendants.

D
___________________________________/
IE
SUBPOENA FOR DEPOSITION DUCES TECUM
IF
THE STATE OF FLORIDA:
TO: Singer Wealth Advisors, LLC
RT

Keith P. Singer
1515 S. Federal Hwy.
Ste. 211
CE

Boca Raton, FL 33432

YOU ARE HEREBY COMMANDED to appear before a person authorized by law to take
A

depositions at Meland Budwick, P.A., 3200 Southeast Financial Center, 200 South Biscayne
T

Blvd., Miami, Florida 33131 on September 30, 2022 at 2:00 p.m. EST, for the taking of your
O

deposition in this action concerning the following topics: (1) Laurence Schneider; (2) the
N

documents produced in response to the requests in Schedule A attached hereto; and (3) your

business record creation, keeping, and destruction practices and procedures. The documents

requested in Schedule A attached hereto shall be produced on the date and time of the taking of

your deposition, or at such other time and place as agreed by counsel.

1
COMPOSITE
EXHIBIT A
 The deposition will be upon oral examination before Veritext Legal Solutions, Notary

Public in and for the State of Florida at large, or some other officer duly authorized by law to take

depositions. The deposition will be recorded stenographically. This deposition is being taken for

discovery and/or any other purpose permitted under the Rules of Civil Procedure and Rules of

Evidence. The deposition will continue from hour to hour and from day to day until completed.

You are subpoenaed to appear by the following attorney, and unless excused from this

PY
Subpoena by said attorney or the Court, you shall respond to this Subpoena as directed. Please

CO
contact the undersigned attorney upon your receipt of this Subpoena. If you fail to appear, you

may be in contempt of Court.

D
DATED September 9, 2022.
IE
s/Meaghan E. Murphy
IF
Meaghan E. Murphy
For the Court
RT

Meaghan E. Murphy, Esq.

Florida Bar No. 102770
CE

mmurphy@melandbudwick.com
Meland Budwick, P.A.
Co-Counsel for First American Bank
A

3200 Southeast Financial Center

200 South Biscayne Boulevard
Miami, FL 33131
T

Telephone: (305) 358-6363

O

Facsimile: (305) 358-1221

N

In accordance with the Americans with Disabilities Act of 1990, persons needing a special
accommodation to participate in this proceeding should contact Meaghan E. Murphy, Esquire at Meland
Budwick, telephone number (305) 358-6363, no later than three (3) days prior to the proceeding. If
hearing impaired, please call telephone Florida Relay Service at 1-800-955-8771 for assistance.

2
 SCHEDULE A

INSTRUCTIONS

(1) All documents produced pursuant hereto are to be produced as they are kept in the

usual course of business or shall be organized and labeled (without permanently marking the item

produced) so as to correspond with the categories of each numbered request hereof.

(2) Each draft, final document, original, reproduction, and each signed and unsigned

PY
document and every additional copy of such document where such copy contains any commentary,

CO
note, notation or other change whatsoever that does not appear on the original or on the copy of

the one document produced shall be deemed and considered to constitute a separate document.

D
(3) If any of the documents encompassed by the attached request for production of
IE
documents are deemed by you to be privileged, furnish all non-privileged documents and provide
IF
a log outlining all documents claimed as privileged that includes: (a) the type of privilege claimed
RT

for each document; (b) a brief description of the document; (c) the author of the document

sufficient to identify it; (d) the recipient(s) (if any); and (e) the date of the document.
CE

(4) When appropriate, the singular form of a word should be interpreted in the plural

as may be necessary to bring within the scope hereof any documents which might otherwise be
A

construed to be outside the scope hereof.

T

(5) Electronically stored information must be produced in a manner as not to alter the
O

document or any metadata associated with that document.

N

(6) Unless another time period is specified, this Request is addressed to documents

created since January 1, 2016.

3
 DEFINITIONS

All references to any Person (as defined below) includes his/her/its employees, agents,

servants, subsidiaries, parent company, affiliated company and any other person or entity or

Representative (as defined below) acting or purporting to act on behalf or under his/her control.

A. The connectives “and” and “or” shall be construed either disjunctively or

conjunctively as necessary to bring within the scope of the discovery request all responses that

PY
might otherwise be construed to be outside of its scope.

CO
B. “Document(s)” include every record of every type, and this term is used in the

broadest sense and includes any medium upon which intelligence or information can be recorded

D
and further includes all originals, nonidentical copies, and drafts of the following items, whether
IE
printed, handwritten, typed, recorded, or stored on any computer or electro-magnetic storage
IF
device, or reproduced by hand, and whether or not claimed to be privileged or otherwise excludable
RT

from discovery, including without limitation: correspondence, Communications, e-mails, text

messages (generated from any application or messaging program), voicemails, memoranda,

CE

invoices, receipts, records, ledger cards or other accounting records, vouchers, checks, shop orders,

diaries, policies, calendar entries, instructions, summaries of personal conversations or interviews,

A

minutes or records of meetings or conferences, transcripts, opinions or reports of consultants,

T

projections, drafts, contracts, agreements, confirmations, statistical statements, studies, telegrams,

O

telexes, books, notes, reports, logs, tape recordings, computer files, video cassettes, data
N

compilations from which information can be obtained, charts, photographs, notebooks, drawings,

plans, printed materials of any kind, charts, financial statements, tax returns, QuickBooks or

related accounting or bookkeeping files, interoffice communications, and any other writing of any

description.

4
 C. “Communication” or “Communications” includes any exchange of words,

thoughts, ideas or documents by any means, whether oral, electronic, written or otherwise.

D. “Including” means including but not limited to.

E. “You” and “Your” refers to you, then entity to whom this subpoena is directed, and

all Persons acting on your behalf or under your control.

F. “Person” or “Persons” includes any individual, business, firm, joint venture,

PY
partnership, corporation, group, association or organization, and reference to any person

CO
throughout these requests includes such person’s agent, officer, employer, employee,

representative, contractor, sub-contractor and attorney.

D
G. “Laurence Schneider” shall mean Laurence S. Schneider and all Persons acting on
IE
his behalf or under his control. Laurence Schneider’s identifying information is as follows: (a)
IF
date of birth: September 18, 1968; and (b) last known address: 2000 Island Blvd., Unit 2001,
RT

Aventura, FL 33160. Additional identifying information may be provided upon request.

H. “Jordyn Schneider” shall mean Jordyn A. Schneider and all Persons acting on her
CE

behalf or under her control. Jordyn Schneider’s identifying information is as follows: (a) date of

birth: March 29, 1998; and (b) last known address: 2000 Island Blvd., Unit 2001, Aventura, FL
A

33160. Additional identifying information may be provided upon request.

T

I. “Zachary Schneider” shall mean Zachary A. Schneider and all Persons acting on
O

his behalf or under his control. Zachary Schneider’s identifying information is as follows: (a) date
N

of birth: February 2001; and (b) last known address: 2000 Island Blvd., Unit 2001, Aventura, FL

33160. Additional identifying information may be provided upon request.

J. “Stephanie Schneider” shall mean Stephanie L. Schneider and all Persons acting on

her behalf or under her control. Stephanie Schneider’s identifying information is as follows: (a)

5
date of birth: May 13, 1968; and (b) last known address: 2000 Island Blvd., Unit 2001, Aventura,

FL 33160. Additional identifying information may be provided upon request.

K. The use of the singular form of any word includes the plural and vice versa.

PY
CO
D
IE
IF
RT
CE
A
T
O
N

6
 DOCUMENTS TO BE PRODUCED

For the period January 1, 2016 to the present, unless otherwise noted, You are directed

to produce the following Documents:

1. Your entire file relating to Laurence Schneider.

2. Your communications with Laurence Schneider.

3. Your communications with any other person relating to Laurence Schneider.

PY
4. Your entire file relating to Stephanie Schneider.

CO
5. Your communications with Stephanie Schneider.

6. Your communications with any other person relating to Stephanie Schneider.

D
7. Your entire file relating to Jordyn Schneider.

8. IE
Your communications with Jordyn Schneider.
IF
9. Your communications with any other person relating to Jordyn Schneider.
RT

10. Your entire file relating to Zachary Schneider.

11. Your communications with Zachary Schneider.

CE

12. Your communications with any other person relating to Zachary Schneider.

13. Your entire file relating to 1st Fidelity Loan Servicing, LLC.
A

14. Your communications with 1st Fidelity Loan Servicing, LLC.

T

15. Your communications with any other person relating to 1st Fidelity Loan Servicing,
O

LLC.
N

16. Your entire file relating to S&A Capital Partners, Inc.

17. Your communications with S&A Capital Partners, Inc.

18. Your communications with any other person relating to S&A Capital Partners, Inc.

19. Your entire file relating to Real Estate & Finance, Inc.

7
20. Your communications with Real Estate & Finance, Inc.

21. Your communications with any other person relating to Real Estate & Finance, Inc.

PY
CO
D
IE
IF
RT
CE
A
T
O
N

8
 IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA

CIRCUIT CIVIL DIVISION: AH

CASE NO. 50-2016-CA-009292-XXXX-MB

FIRST AMERICAN BANK, as successor

by merger to Bank of Coral Gables, LLC,

PY
Plaintiff,
vs.

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

Defendants.

D
___________________________________/
IE
SUBPOENA FOR DEPOSITION DUCES TECUM
IF
THE STATE OF FLORIDA:
TO: AT&T Mobility LLC
RT

c/o CT Corporation System

1200 South Pine Island Road
Plantation, FL 33324
CE

YOU ARE HEREBY COMMANDED to appear before a person authorized by law to take

depositions at Meland Budwick, P.A., 3200 Southeast Financial Center, 200 South Biscayne
A

Blvd., Miami, Florida 33131 on October 10, 2022 at 10:00 a.m. EST, for the taking of your
T

deposition in this action concerning the following topics: (1) Laurence Schneider; (2) the
O

documents produced in response to the requests in Schedule A attached hereto; and (3) your
N

business record creation, keeping, and destruction practices and procedures. The documents

requested in Schedule A attached hereto shall be produced two business days before of the taking

of your deposition, or at such other time and place as agreed by counsel.

1
 The deposition will be upon oral examination before Veritext Legal Solutions, Notary

Public in and for the State of Florida at large, or some other officer duly authorized by law to take

depositions. The deposition will be recorded stenographically. This deposition is being taken for

discovery and/or any other purpose permitted under the Rules of Civil Procedure and Rules of

Evidence. The deposition will continue from hour to hour and from day to day until completed.

You are subpoenaed to appear by the following attorney, and unless excused from this

PY
Subpoena by said attorney or the Court, you shall respond to this Subpoena as directed. Please

CO
contact the undersigned attorney upon your receipt of this Subpoena. If you fail to appear, you

may be in contempt of Court.

D
DATED September 9, 2022.
IE
s/Meaghan E. Murphy
IF
Meaghan E. Murphy
For the Court
RT

Meaghan E. Murphy, Esq.

Florida Bar No. 102770
CE

mmurphy@melandbudwick.com
Meland Budwick, P.A.
Co-Counsel for First American Bank
A

3200 Southeast Financial Center

200 South Biscayne Boulevard
Miami, FL 33131
T

Telephone: (305) 358-6363

O

Facsimile: (305) 358-1221

N

In accordance with the Americans with Disabilities Act of 1990, persons needing a special
accommodation to participate in this proceeding should contact Meaghan E. Murphy, Esquire at Meland
Budwick, telephone number (305) 358-6363, no later than three (3) days prior to the proceeding. If
hearing impaired, please call telephone Florida Relay Service at 1-800-955-8771 for assistance.

2
 SCHEDULE A

INSTRUCTIONS

(1) All documents produced pursuant hereto are to be produced as they are kept in the

usual course of business or shall be organized and labeled (without permanently marking the item

produced) so as to correspond with the categories of each numbered request hereof.

(2) Each draft, final document, original, reproduction, and each signed and unsigned

PY
document and every additional copy of such document where such copy contains any commentary,

CO
note, notation or other change whatsoever that does not appear on the original or on the copy of

the one document produced shall be deemed and considered to constitute a separate document.

D
(3) If any of the documents encompassed by the attached request for production of
IE
documents are deemed by you to be privileged, furnish all non-privileged documents and provide
IF
a log outlining all documents claimed as privileged that includes: (a) the type of privilege claimed
RT

for each document; (b) a brief description of the document; (c) the author of the document

sufficient to identify it; (d) the recipient(s) (if any); and (e) the date of the document.
CE

(4) When appropriate, the singular form of a word should be interpreted in the plural

as may be necessary to bring within the scope hereof any documents which might otherwise be
A

construed to be outside the scope hereof.

T

(5) Electronically stored information must be produced in a manner as not to alter the
O

document or any metadata associated with that document.

N

(6) Unless another time period is specified, this Request is addressed to documents

created since January 1, 2016.

3
 DEFINITIONS

All references to any Person (as defined below) includes his/her/its employees, agents,

servants, subsidiaries, parent company, affiliated company and any other person or entity or

Representative (as defined below) acting or purporting to act on behalf or under his/her control.

A. The connectives “and” and “or” shall be construed either disjunctively or

conjunctively as necessary to bring within the scope of the discovery request all responses that

PY
might otherwise be construed to be outside of its scope.

CO
B. “Document(s)” include every record of every type, and this term is used in the

broadest sense and includes any medium upon which intelligence or information can be recorded

D
and further includes all originals, nonidentical copies, and drafts of the following items, whether
IE
printed, handwritten, typed, recorded, or stored on any computer or electro-magnetic storage
IF
device, or reproduced by hand, and whether or not claimed to be privileged or otherwise excludable
RT

from discovery, including without limitation: correspondence, Communications, e-mails, text

messages (generated from any application or messaging program), voicemails, memoranda,

CE

invoices, receipts, records, ledger cards or other accounting records, vouchers, checks, shop orders,

diaries, policies, calendar entries, instructions, summaries of personal conversations or interviews,

A

minutes or records of meetings or conferences, transcripts, opinions or reports of consultants,

T

projections, drafts, contracts, agreements, confirmations, statistical statements, studies, telegrams,

O

telexes, books, notes, reports, logs, tape recordings, computer files, video cassettes, data
N

compilations from which information can be obtained, charts, photographs, notebooks, drawings,

plans, printed materials of any kind, charts, financial statements, tax returns, QuickBooks or

related accounting or bookkeeping files, interoffice communications, and any other writing of any

description.

4
 C. “Communication” or “Communications” includes any exchange of words,

thoughts, ideas or documents by any means, whether oral, electronic, written or otherwise.

D. “Including” means including but not limited to.

E. “You” and “Your” refers to you, then entity to whom this subpoena is directed, and

all Persons acting on your behalf or under your control.

F. “Person” or “Persons” includes any individual, business, firm, joint venture,

PY
partnership, corporation, group, association or organization, and reference to any person

CO
throughout these requests includes such person’s agent, officer, employer, employee,

representative, contractor, sub-contractor and attorney.

D
G. “Laurence Schneider” shall mean Laurence S. Schneider and all Persons acting on
IE
his behalf or under his control. Laurence Schneider’s identifying information is as follows: (a)
IF
date of birth: September 18, 1968; and (b) last known address: 2000 Island Blvd., Unit 2001,
RT

Aventura, FL 33160. Additional identifying information may be provided upon request.

H. The use of the singular form of any word includes the plural and vice versa.
CE
A
T
O
N

5
 DOCUMENTS TO BE PRODUCED

For the period January 1, 2016 to the present, unless otherwise noted, You are directed

to produce the following Documents:

1. All account statements for telephone number (305) 710-4201.

2. Documents evidencing the source of payments received by You for the account

associated with the telephone number (305) 710-4201.

PY
CO
D
IE
IF
RT
CE
A
T
O
N

6
 IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA

CIRCUIT CIVIL DIVISION: AH

CASE NO. 50-2016-CA-009292-XXXX-MB

FIRST AMERICAN BANK, as successor

by merger to Bank of Coral Gables, LLC,

PY
Plaintiff,
vs.

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

Defendants.

D
___________________________________/
IE
SUBPOENA FOR VIDEO-CONFERENCE DEPOSITION DUCES TECUM
IF
THE STATE OF FLORIDA:
TO: Regions Bank
RT

c/o Corporation Service Company

1201 Hays Street
Tallahassee, FL 32301
CE

YOU ARE HEREBY COMMANDED to appear before a person authorized by law to take

depositions via Veritext Zoom Videoconference (meeting ID# and password will be provided by
A

Veritext prior to the examination) on October 10, 2022 at 2:00 p.m. EST, for the taking of your
T

deposition in this action concerning the following topics: (1) Laurence Schneider; (2) Jordyn
O

Schneider; (3) Zachary Schneider; (4) Stephanie Schneider; (5) transfers between and among all
N

of the above; (6) the documents produced in response to the requests in Schedule A attached hereto;

and (7) your business record creation, keeping, and destruction practices and procedures. The

documents requested in Schedule A attached hereto shall be produced two business days before

the taking of your deposition, or at such other time and place as agreed by counsel.

1
 The deposition will be upon oral examination before Veritext Legal Solutions, Notary

Public in and for the State of Florida at large, or some other officer duly authorized by law to take

depositions. The deposition will be recorded stenographically. This deposition is being taken for

discovery and/or any other purpose permitted under the Rules of Civil Procedure and Rules of

Evidence. The deposition will continue from hour to hour and from day to day until completed.

You are subpoenaed to appear by the following attorney, and unless excused from this

PY
Subpoena by said attorney or the Court, you shall respond to this Subpoena as directed. Please

CO
contact the undersigned attorney upon your receipt of this Subpoena. If you fail to appear, you

may be in contempt of Court.

D
DATED September 9, 2022.
IE
s/Meaghan E. Murphy
IF
Meaghan E. Murphy
For the Court
RT

Meaghan E. Murphy, Esq.

Florida Bar No. 102770
CE

mmurphy@melandbudwick.com
Meland Budwick, P.A.
Co-Counsel for First American Bank
A

3200 Southeast Financial Center

200 South Biscayne Boulevard
Miami, FL 33131
T

Telephone: (305) 358-6363

O

Facsimile: (305) 358-1221

N

In accordance with the Americans with Disabilities Act of 1990, persons needing a special
accommodation to participate in this proceeding should contact Meaghan E. Murphy, Esquire at Meland
Budwick, telephone number (305) 358-6363, no later than three (3) days prior to the proceeding. If
hearing impaired, please call telephone Florida Relay Service at 1-800-955-8771 for assistance.

2
 SCHEDULE A

INSTRUCTIONS

(1) All documents produced pursuant hereto are to be produced as they are kept in the

usual course of business or shall be organized and labeled (without permanently marking the item

produced) so as to correspond with the categories of each numbered request hereof.

(2) Each draft, final document, original, reproduction, and each signed and unsigned

PY
document and every additional copy of such document where such copy contains any commentary,

CO
note, notation or other change whatsoever that does not appear on the original or on the copy of

the one document produced shall be deemed and considered to constitute a separate document.

D
(3) If any of the documents encompassed by the attached request for production of
IE
documents are deemed by you to be privileged, furnish all non-privileged documents and provide
IF
a log outlining all documents claimed as privileged that includes: (a) the type of privilege claimed
RT

for each document; (b) a brief description of the document; (c) the author of the document

sufficient to identify it; (d) the recipient(s) (if any); and (e) the date of the document.
CE

(4) When appropriate, the singular form of a word should be interpreted in the plural

as may be necessary to bring within the scope hereof any documents which might otherwise be
A

construed to be outside the scope hereof.

T

(5) Electronically stored information must be produced in a manner as not to alter the
O

document or any metadata associated with that document.

N

(6) Unless another time period is specified, this Request is addressed to documents

created since January 1, 2016.

3
 DEFINITIONS

All references to any Person (as defined below) includes his/her/its employees, agents,

servants, subsidiaries, parent company, affiliated company and any other person or entity or

Representative (as defined below) acting or purporting to act on behalf or under his/her control.

A. The connectives “and” and “or” shall be construed either disjunctively or

conjunctively as necessary to bring within the scope of the discovery request all responses that

PY
might otherwise be construed to be outside of its scope.

CO
B. “Document(s)” include every record of every type, and this term is used in the

broadest sense and includes any medium upon which intelligence or information can be recorded

D
and further includes all originals, nonidentical copies, and drafts of the following items, whether
IE
printed, handwritten, typed, recorded, or stored on any computer or electro-magnetic storage
IF
device, or reproduced by hand, and whether or not claimed to be privileged or otherwise excludable
RT

from discovery, including without limitation: correspondence, Communications, e-mails, text

messages (generated from any application or messaging program), voicemails, memoranda,

CE

invoices, receipts, records, ledger cards or other accounting records, vouchers, checks, shop orders,

diaries, policies, calendar entries, instructions, summaries of personal conversations or interviews,

A

minutes or records of meetings or conferences, transcripts, opinions or reports of consultants,

T

projections, drafts, contracts, agreements, confirmations, statistical statements, studies, telegrams,

O

telexes, books, notes, reports, logs, tape recordings, computer files, video cassettes, data
N

compilations from which information can be obtained, charts, photographs, notebooks, drawings,

plans, printed materials of any kind, charts, financial statements, tax returns, QuickBooks or

related accounting or bookkeeping files, interoffice communications, and any other writing of any

description.

4
 C. “Communication” or “Communications” includes any exchange of words,

thoughts, ideas or documents by any means, whether oral, electronic, written or otherwise.

D. “Including” means including but not limited to.

E. “You” and “Your” refers to you, then entity to whom this subpoena is directed, and

all Persons acting on your behalf or under your control.

F. “Person” or “Persons” includes any individual, business, firm, joint venture,

PY
partnership, corporation, group, association or organization, and reference to any person

CO
throughout these requests includes such person’s agent, officer, employer, employee,

representative, contractor, sub-contractor and attorney.

D
G. “Laurence Schneider” shall mean Laurence S. Schneider and all Persons acting on
IE
his behalf or under his control. Laurence Schneider’s identifying information is as follows: (a)
IF
date of birth: September 18, 1968; and (b) last known address: 2000 Island Blvd., Unit 2001,
RT

Aventura, FL 33160. Additional identifying information may be provided upon request.

H. “Jordyn Schneider” shall mean Jordyn A. Schneider and all Persons acting on her
CE

behalf or under her control. Jordyn Schneider’s identifying information is as follows: (a) date of

birth: March 29, 1998; and (b) last known address: 2000 Island Blvd., Unit 2001, Aventura, FL
A

33160. Additional identifying information may be provided upon request.

T

I. “Zachary Schneider” shall mean Zachary A. Schneider and all Persons acting on
O

his behalf or under his control. Zachary Schneider’s identifying information is as follows: (a) date
N

of birth: February 2001; and (b) last known address: 2000 Island Blvd., Unit 2001, Aventura, FL

33160. Additional identifying information may be provided upon request.

J. “Stephanie Schneider” shall mean Stephanie L. Schneider and all Persons acting on

her behalf or under her control. Stephanie Schneider’s identifying information is as follows: (a)

5
date of birth: May 13, 1968; and (b) last known address: 2000 Island Blvd., Unit 2001, Aventura,

FL 33160. Additional identifying information may be provided upon request.

K. The use of the singular form of any word includes the plural and vice versa.

PY
CO
D
IE
IF
RT
CE
A
T
O
N

6
 DOCUMENTS TO BE PRODUCED

For the period January 1, 2016 to the present, unless otherwise noted, You are directed

to produce the following Documents:

1. All account documents, including but not limited to, opening documents, cancelled

checks (front and back), deposit slips, wire receipts, and statements for any accounts in the name

of Jordyn Schneider or for which Jordyn Schneider has signatory authority.

PY
2. All documents relating to any safe deposit box, including but not limited to logs,

CO
held in the name of Jordyn Schneider or to which Jordyn Schneider has authorized access.

3. All account documents, including but not limited to, opening documents, cancelled

D
checks (front and back), deposit slips, wire receipts, and statements for any accounts in the name
IE
of Zachary Schneider or for which Zachary Schneider has signatory authority.
IF
4. All documents relating to any safe deposit box, including but not limited to logs,
RT

held in the name of Zachary Schneider or to which Zachary Schneider has authorized access.
CE
A
T
O
N