Filing# 139275829 E-Filed 11/29/2021 03:49:00 PM

IN THE CIRCUIT COURT OF THE

FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY,
FLORIDA

FIRST AMERICAN BANK, as CASE NO.: 502016-CA-009292

successor by merger to Bank of DIVISION AH

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Coral Gables, LLC,

Plaintiff,

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V.

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

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Defendants.
_______________ /
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DEFENDANT STEPHANIE L. SCHNEIDER'S RESPONSE TO PLAINTIFF'S,
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FIRST AMERICAN BANK, SECOND REQUEST FOR PRODUCTION

{Attorneys' Fees, Costs, and Expenses)
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COMES NOW Defendant STEPHANIE L. SCHNEIDER, by and through the

undersigned counsel and pursuant to Fla. R. Civ. P. 1.350, and hereby provides
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this response to Plaintiff, FIRST AMERICAN BANK's Second Request for

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Production to Defendants, LAURENCE S. SCHNEIDER and STEPHANIE L.

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SCHNEIDER.
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Response to Documents Requested

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Andrew D. Wyman, Esq.

1. Any and all documents (including, but not limited to, retainer

agreements, retention agreements, representation agreements, contracts,

correspondence, emails, and text messages) which are, relate to, or reference

your consent to have Andrew D. Wyman, Esq. represent you in this action.

l<** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 11/29/2021 03:49:00 PM***
 RESPONSE: After a diligent search, Defendant asserts that there in none

within Defendant's possession, custody, or control.

2. Any and all documents (including, but not limited to, invoices,

billing statements, emails, correspondence, text messages, checks, deposit

slips, payment of funds, transfer of funds, tax returns, financial statements,

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bank statements, ACH transfers, wire transfer messages, credit memos, debit

memos, Fed Wire or SWIFT messages, and attachments thereto) which are,

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relate to, or reference the time spent by Andrew D. Wyman, Esq. representing you in

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this action.

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RESPONSE: After a diligent search, Defendant asserts that there in none
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within Defendant's possession, custody, or control.
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3. Any and all documents (including, but not limited to, invoices,
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billing statements, emails, correspondence, text messages, checks, deposit slips,

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payment of funds, transfer of funds, tax returns, financial statements, bank

statements, ACH transfers, wire transfer messages, credit memos, debit memos,
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Fed Wire or SWIFT messages, and attachments thereto) which are, relate to, or
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reference payment of attorney's fees by you or on your behalf to Andrew D.

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Wyman, Esq. for services rendered in this action.

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RESPONSE: After a diligent search, Defendant asserts that there in none

within Defendant's possession, custody, or control.

 Wyman Legal Solutions

4. Any and all documents (including, but not limited to, retainer

agreements, retention agreements, representation agreements, contracts,

correspondence, emails, and text messages) which are, relate to, or reference

your consent to have Wyman Legal Solutions represent you in this action.

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RESPONSE: After a diligent search, Defendant asserts that there in none

within Defendant's possession, custody, or control.

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5. Any and all documents (including, but not limited to, invoices,

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billing statements, emails, correspondence, text messages, checks, deposit slips,
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payment of funds, transfer of funds, tax returns, financial statements, bank

statements, ACH transfers, wire transfer messages, credit memos, debit memos,
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Fed Wire or SWIFT messages, and attachments thereto) which are, relate to, or
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reference the time spent by attorneys, law clerks, or paralegals of Wyman Legal

Solutions representing you in this action.

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RESPONSE: After a diligent search, Defendant asserts that there in none

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within Defendant's possession, custody, or control.

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6. Any and all documents (including, but not limited to, invoices,

billing statements, emails, correspondence, text messages, checks, deposit slips,

payment of funds, transfer of funds, tax returns, financial statements, bank

statements, ACH transfers, wire transfer messages, credit memos, debit memos,

Fed Wire or SWIFT messages, and attachments thereto) which are, relate to, or

reference payment of attorney's fees, costs, and/ or expenses by you or on your

behalf to Wyman Legal Solutions for services rendered and/or expenses incurred

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in this action.

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RESPONSE: After a diligent search, Defendant asserts that there in none

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within Defendant's possession, custody, or control.

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Charles F. Rodman, Esq.
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7. Any and all documents (including, but not limited to, retainer
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agreements, retention agreements, representation agreements, contracts,

correspondence, emails, and text messages) which are, relate to, or reference
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your consent to have Charles F. Rodman, Esq. represent you in this action.
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RESPONSE: After a diligent search, Defendant asserts that there in none

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within Defendant's possession, custody, or control.

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8. Any and all documents (including, but not limited to, invoices,
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billing statements, emails, correspondence, text messages, checks, deposit slips,

payment of funds, transfer of funds, tax returns, financial statements, bank

statements, ACH transfers, wire transfer messages, credit memos, debit memos,

Fed Wire or SWIFT messages, and attachments thereto) which are, relate to, or

reference the time spent by Charles F. Rodman, Esq. representing you in this
action.

RESPONSE: After a diligent search, Defendant asserts that there in none

within Defendant's possession, custody, or control.

9. Any and all documents (including, but not limited to, invoices,

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billing statements, emails, correspondence, text messages, checks, deposit slips,

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payment of funds, transfer of funds, tax returns, financial statements, bank

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statements, ACH transfers, wire transfer messages, credit memos, debit memos,

Fed Wire or SWIFT messages, and attachments thereto) which are, relate to, or

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reference payment of attorney's fees by you or on your behalf to Charles F.
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Rodman, Esq. for services rendered in this action.
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RESPONSE: After a diligent search, Defendant asserts that there in none

within Defendant's possession, custody, or control.

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Rodman Employment Law

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10. Any and all documents (including, but not limited to, retainer

agreements, retention agreements, representation agreements, contracts,

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correspondence, emails, and text messages) which are, relate to or reference your
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consent to have Rodman Employment Law represent you in this action.

RESPONSE: After a diligent search, Defendant asserts that there in none

within Defendant's possession, custody, or control.

11. Any and all documents (including, but not limited to, invoices,
billing statements, emails, correspondence, text messages, checks, deposit slips,

payment of funds, transfer of funds, tax returns, financial statements, bank

statements, ACH transfers, wire transfer messages, credit memos, debit memos,

Fed Wire or SWIFT messages, and attachments thereto) which are, relate to, or

reference the time spent by attorneys, law clerks, or paralegals of Rodman

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Employment Law representing you in this action.

RESPONSE: After a diligent search, Defendant asserts that there in none

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within Defendant's possession, custody, or control.

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12. Any and all documents (including, but not limited to, invoices,
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billing statements, emails, correspondence, text messages, checks, deposit slips,

payment of funds, transfer of funds, tax returns, financial statements, bank

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statements, ACH transfers, wire transfer messages, credit memos, debit memos,
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Fed Wire or SWIFT messages, and attachments thereto) which are, relate to, or

reference payment of attorney's fees, costs, and/ or expenses by you or on your

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behalf to Rodman Employment Law for services rendered and/ or expenses

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incurred in this action.

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RESPONSE: After a diligent search, Defendant asserts that there in none

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within Defendant's possession, custody, or control.

 Martin G. McCarthy, Esq.

13. Any and all documents (including, but not limited to, retainer

agreements, retention agreements, representation agreements, contracts,

correspondence, emails, and text messages) which are, relate to, or reference

your consent to have Martin G. McCarthy, Esq. represent you in this action.

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RESPONSE: See retainer agreement produced herewith.

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14. Any and all documents (including, but not limited to, invoices,

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billing statements, emails, correspondence, text messages, checks, deposit slips,

payment of funds, transfer of funds, tax returns, financial statements, bank

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statements, ACH transfers, wire transfer messages, credit memos, debit memos,
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Fed Wire or SWIFT messages, and attachments thereto) which are, relate to, or
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reference the time spent by Martin G. McCarthy, Esq. representing you in this

action.
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Response: See attached redacted invoice for legal services from January
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4, 2021 to March 2, 2021.

15. Any and all documents (including, but not limited to, invoices,
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billing statements, emails, correspondence, text messages, checks, deposit slips,

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payment of funds, transfer of funds, tax returns, financial statements, bank

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statements, ACH transfers, wire transfer messages, credit memos, debit memos,
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Fed Wire or SWIFT messages, and attachments thereto) which are, relate to, or

reference payment of attorney's fees by you or on your behalf to Martin G.

McCarthy, Esq. for services rendered in this action.

Response: See attached redacted invoice for legal services from January
 4, 2021 to March 2, 2021.

Emre Yersel, Esq.

16. Any and all documents (including, but not limited to,

retaineragreements, retention agreements, representation agreements,

contracts,correspondence, emails, and text messages) which are, relate to, or

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reference your consent to have Emre Yersel, Esq. represent you in this action.

RESPONSE: See #13 supra.

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17. Any and all documents (including, but not limited to, invoices,

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billing statements, emails, correspondence, text messages, checks, deposit slips,

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payment of funds, transfer of funds, tax returns, financial statements, bank

statements, ACH transfers, wire transfer messages, credit memos, debit memos,
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Fed Wire or SWIFT messages, and attachments thereto) which are, relate to, or
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reference the time spent by Emre Yersel, Esq. representing you in this action.
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RESPONSE: See # 14 supra.

18. Any and all documents (including, but not limited to, invoices,
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billing statements, emails, correspondence, text messages, checks, deposit slips,

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payment of funds, transfer of funds, tax returns, financial statements, bank

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statements, ACH transfers, wire transfer messages, credit memos, debit memos,
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Fed Wire or SWIFT messages, and attachments thereto) which are, relate to, or
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reference payment of attorney's fees by you or on your behalf to Emre Yersel,

Esq. for services rendered in this action.

RESPONSE: See # 15 supra.

McCarthy & Yersel, PLLC

 19. Any and all documents (including, but not limited to, retainer

agreements, retention agreements, representation agreements, contracts,

correspondence, emails, and text messages) which are, relate to or reference your

consent to have McCarthy & Yersel, PLLC represent you in this action.

RESPONSE: See #13 supra.

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20. Any and all documents (including, but not limited to, invoices,

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billing statements, emails, correspondence, text messages, checks, deposit slips,

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payment of funds, transfer of funds, tax returns, financial statements,

bankstatements, ACH transfers, wire transfer messages, credit memos, debit memos,

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Fed Wire or SWIFT messages, and attachments thereto) which are, relate to, or
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reference the time spent by attorneys, law clerks, or paralegals of McCarthy & Yersel,

PLLC representing you in this action.

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RESPONSE: See # 14 supra.

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21. Any and all documents (including, but not limited to, invoices,

billing statements, emails, correspondence, text messages, checks, deposit slips,

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payment of funds, transfer of funds, tax returns, financial statements, bank

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statements, ACH transfers, wire transfer messages, credit memos, debit memos,
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Fed Wire or SWIFT messages, and attachments thereto) which are, relate to, or
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reference payment of attorney's fees, costs, and/ or expenses by you or on your

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behalf to McCarthy & Yersel, PLLC for services rendered and/or expenses

incurred in this action.

RESPONSE: See #15 supra.

 CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy hereof has been furnished on November 29, 2021, via
email service to all parties designated to receive Service of Court documents via Florida's eFiling
Portal pertaining to this case, via email to John W. Keller, Esq. jkeller@kellermesa.com and Sheyla
Mesa, Esq. smesa@kellermesa.com, at KELLER & MESA, LLP, 121 Majorca Avenue, #200, Coral
Gables, FL 33134.

Respectfully Submitted,

MCCARTHY & YERSEL, PLLC

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Attorneys for Defendant Stephanie Schneider
4929 SW 74th CT
Miami, FL 33155

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Ph.: (305) 407 -8006 / Fax.: (866) 676-4671

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By: / s / Martin G. McCarthy
Martin G. McCarthy, Esq. Florida Bar No.: 149896

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Service Email: mccarthy@myattorneyservices.com
Emre Yersel, Esq., Florida Bar No.: 114485
Service Email: eyersel@myattorneyservices.com
Service Email 2: lawclerk@myattorneyservices.com
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