Filing# 112279292 E-Filed 08/24/2020 03:10:01 PM

IN THE CIRCUIT COURT OF

THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA

CASE NO.: 502016-CA-009292

DIVISION AH

FIRST AMERICAN BANK, as

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successor by merger to Bank of
Coral Gables, LLC,

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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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PLAINTIFF'S, FIRST AMERICAN BANK,

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MOTION FOR WRIT OF POSSESSION

Plaintiff, FIRST AMERICAN BANK ("First American"), by and through its

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undersigned counsel, and as owner pursuant to the Certificate of Title, dated August
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17, 2020, hereby files its Motion for Writ of Possession, and, in support thereof
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states:
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1. The Amended Final Judgment of Foreclosure (Supplemental

Judgment) scheduled the foreclosure sale of the residential property located at 17685

Circle Pond Court, Boca Raton, Florida 33496-1002 ("Property") for April 1, 2020

[DE 384].

FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 08/24/2020 03: 10:01 PM
 2. Due to the outbreak of the Coronavirus Disease 2019 (COVID-19), on

March 18, 2020, the scheduled foreclosure sale was cancelled until further order of

the Court. See Administrative Order No.: 12.510-03/2020.3.

3. By Order, dated June 17, 2020, this Court reset the foreclosure sale of

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the Property for August 3, 2020 [DE 449].

4. On August 3, 2020, the foreclosure sale was conducted, First American

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purchased the "Property" by credit bid and the Clerk issued a Certificate of Sale [DE

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519].

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5. No objection to the sale was filed, and, on August 17, 2020, the Clerk
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issued a Certificate of Title to First American as the new owner of the Property [DE
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525].
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6. Despite same, the Property continues to be occupied by the former

mortgagors, who have failed and/or refused to vacate the Property.

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7. During the August 20, 2020 hearing on First American's Motion to

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Compel Compliance with this Court's June 23, 2020 Order, Defendant,
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LAURENCE S. SCHNEIDER, stated that by reason of the foreclosure sale, he

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would need to look for a new place to live. 1 Accordingly, it is clear that

SCHNEIDER knows he has no rights in the Property.

1 Undersigned's office has ordered a copy of the August 20, 2020 hearing transcript, and, upon
receipt of same the record will be supplemented.
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 8. Based on Defendant's statements during the August 20, 2020 hearing,

and the record in this case, the Property is not occupied by a bona fide tenant.

9. First American requires a Writ of Possession to be issued by the Clerk

of the Court so that First American may peaceably and without further delay be let

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into possession of the Property.

WHEREFORE, Plaintiff, FIRST AMERICAN BANK, respectfully requests

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that this Court enter an Order directing the Clerk of Court to issue a Writ of

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Possession.

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Respectfully submitted,
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KELLER & MESA, LLP
Attorneys for Plaintiff
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121 Majorca Avenue, #200

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

Telefax: (305) 529-0228
Email: jkeller@kellermesa.com
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By: s/ John W. Keller, III

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John W. Keller, III

Florida Bar No. 229989
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 CERTIFICATE OF SERVICE

WE HEREBY CERTIFY that a true and correct copy of the foregoing,

Plaintiffs, First American Bank, Motion for Writ of Possession, was delivered to:

LAURENCE S. SCHNEIDER (larry@sacapitalpartners.com), 17685 Circle Pond

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Court, Boca Raton, FL 33496; STEPHANIE L. SCHNEIDER

(steffschneider13@gmail.com), 17685 Circle Pond Court, Boca Raton, FL 33496;

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ALEKSANDRA NOVAKOVICH GONZALEZ, ESQ.

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(foreclosures@ssclawfirm.com), Sachs, Sax, Caplan, Attorneys for Oaks at Boca

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Raton, 6111 Broken Sound Parkway, N.W., #200, Boca Raton, FL 33487; and
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GEOFFREY M. CAREN, ESQ. (geoff@cahenlaw.com), Cahen Law, P.A., 1900
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Glades Road, Suite 270, Boca Raton, FL 33431 via the E-filing Portal on this 24th
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day of August, 2020.

KELLER & MESA, LLP

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By: s/ John W. Keller, III

John W. Keller, III
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