Filing# 126315315 E-Filed 05/06/2021 02:34:20 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
successor by merger to Bank of
Coral Gables, LLC,

V.
Plaintiff,

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

Defendants.
_______________ /
PLAINTIFF'S,
#ERICAN BANK,
SECOND R PRODUCTION
(Attorney , and Expenses)

Plaintiff, FIRST its undersigned

S. SCHNEIDER an 1J:EPHANIE L. SCHNEIDER. All originals of the documents

and items re~uested are to be produced for inspection and copying at the law

orth in Fla. R. Civ. P . 1.350(b) .

Instructions

A. All responses to these requests shall set forth the request before

each response, and you should provide a separate response to each request.

l<** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 05/06/2021 02:34:20 PM ***
 B. If, after a good faith search, you conclude that there have never been

documents and/ or things responsive to a request, please so state.

C. Documents and/ or things produced for inspection must be

produced as they are kept in the usual course of business or be organized and

labeled to correspond to the request to which they are responsive.

D. If you object to any part of any request, please specify art of the

you will permit inspection and related activities as requested.

E. For each document and/ or thing withheld foam production on the

ground of attorney-client privilege, work produ oc ' ne or any other privilege

or doctrine, you should describe such do, u m enjj and/ or thing so that Plaintiff

may bring the question of privilege be ore h - Court. Documents and/or things

shall be deemed to be adequate} esc:ri ed for this purpose if you provide the

following information:

a. the specific for withholding the document and/ or thing;

b. a brief esGription of the document and/or thing, including:

the type of document and/or thing (letter, memoranda, etc.);

0 ii. the date of the document;

~ iii. the number of pages, attachments and appendices;

iv. the general subject matter of the document and/ or thing;

v. the author, addressee, and any other recipient of the

document and/or thing, and, where not apparent, the

relationship of the author, addressee, and any other recipient

Page 2 of 12
 to each other;

vi. the name and position of each person, other than your

attorneys, to whom the contents of the document and/or

thing have been communicated by copy, exhibition, reading,

or substantial summary; and

vii. the identity of each person who has custody oµ

document and/ or thing.

F. If any document and/or thing requested her in wa s at one time in

existence but has been not now in your

possession, custody, or control, identify and/ or thing as

completely as possible and provide the fol

a. the type of document an · g (letter, memoranda, etc.);

b.

c. the date or ate when the document and/or thing was

lost, discar troyed;

d. the rea .o or reasons for disposing of the document and/ or thing;

e. (Ji ident'1ty of all persons authorizing or having knowledge of the

surrounding the disposal of the document and/ or

thing;

f. the identity of the person(s) who lost, discarded, or destroyed the

document and/or thing; and

g. the identity of all persons having knowledge of the document's

contents.

Page 3 of 12
 Definitions

A. The term "you" or "your" as used herein means Laurence S.

Schneider and/or Stephanie L. Schneider.

B. The term "action" as used herein means the litigations styled:

i. First American Bank v. Laurence Schneider, et al., a e No.:

502016-CA-009292, which was filed in the Cir rt of the

15 th Judicial Circuit in and for Palm Beach Co

ii. First American Bank v. Laurence Schneider, et al., Case No.: 9:20-

cv-81728-DMM, which was filed i

C. The term "billing statement; ~ as herein means properly

redacted billing statements to prese ~ mat ers protected under your attorney-

client privilege and the work ne.

D. The term " used herein shall include all writings or

other materials, whethe- a dwritten, typed, printed, recorded, or reproduced

by any other physic . , mechanical, electronic or electrical means, including but

ecords, papers, quotes, bids, offers, bills, orders, invoices, checks,

receipts, memoranda, spreadsheets, charts, ledgers, financial statements,

assi ments, directives, bulletins, contracts, agreements, insurance policies or

certificates, or other official documents and legal instruments, correspondence,

letters, emails, Blackberry or other PDA messages, telegrams, cables, inter-office

communications, intra-office communications, notes, calendar or diary entries,

sketches, photographs, photographic slides, or negatives, videos, movies, films,

Page 4 of 12
filmstrips, tapes and recordings, summaries or records of telephone

conversations, summaries or records of personal conversations, and all carbons

or photocopies bearing any underlining, highlighting, additions, corrections, or

marginal notations, microfiche, microfilm, tapes, cassettes, cartridges, disks,

chips, CDs, and DVDs which are in your possession, custody, or con~ ther

collectively or separately, wherever located.

or "or" shall be both conjunctive and disjunctive; and the tte m "1hcluding" means

including without limitation. ~

F. Unless otherwise stated, the dater ng€~o~ e documents requested

is from April 1, 2020 to February 28 , 2

1. (including, but not limited to, retainer

correspondence, em ·1s, and text messages) which are, relate to, or reference

o have Andrew D. Wyman, Esq. represent you in this action.

A y and all documents (including, but not limited to, invoices,

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

Page 5 of 12
reference the time spent by Andrew D. Wyman, Esq. representing you in this

action.

3. 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 statemend , bank

Wyman, Esq. for services rendered in this action.

Wyman Legal So

4. Any and all documents not limited to, retainer

agreements, retention agreement( agreements, contracts,

correspondence, emails, and tex ess-ages) which are, relate to, or reference

billing statements, e rails, correspondence, text messages, checks, deposit slips,

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

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

Fe m Qr SWIFT messages, and attachments thereto) which are, relate to, or

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

Solutions representing you in this action.

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

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

Page 6 of 12
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

in this action.

Charles F. Rodman, Esq. 0

,s,.
behalf to Wyman Legal Solutions for services rendered and/or expenses d-i.curred

~
7. Any and all documents (including, but no retainer

agreements, retention agreements, contracts,

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

reference th ent by Charles F. Rodman, Esq. representing you in this

action. 0
9:. 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

Page 7 of 12
reference payment of attorney's fees by you or on your behalf to Charles F.

Rodman, Esq. for services rendered in this action.

Rodman Employment Law

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

agreements, retention agreements, representation

payment of funds, transfer of funds , tax ret , rns~ :ti . ancial statements, bank

statements, ACH transfers, wire transfer m.-C~~s, credit memos, debit memos,

billing statements, e rails, correspondence, text messages, checks, deposit slips,

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

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

Fe m Qr 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 Rodman Employment Law for services rendered and/or expenses

incurred in this action.

Page 8 of 12
 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 ct on.

statements, ACH transfers, wire transfer messages, c eoi memos, debit memos,

Fed Wire or SWIFT messages, and attachment Mcret ) which are, relate to, or

reference the time spent by Martin G. Mo sq. representing you in this

action.

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

'.!FT messages, and attachments thereto) which are, relate to, or

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

Esq. for services rendered in this action.

Emre Yersel, Esq.

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

agreements, retention agreements, representation agreements, contracts,

Page 9 of 12
correspondence, emails, and text messages) which are, relate to, or reference

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

1 7. 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 statemend , bank

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

Fed Wire or SWIFT messages, and attachments thereto) whicfl ar , relate to, or

reference the time spent by Emre Yersel, Esq. representin

18. Any and all documents (including, b; limited to, invoices,

billing statements, emails, correspondence, tex

payment of funds, transfer of funds , t 1nancial statements, bank

statements, ACH transfers, wire tra .s fe es, credit memos, debit memos,

Fed Wire or SWIFT messages, a tl attae'. ments thereto) which are, relate to, or

reference payment of attar eY- , ees by you or on your behalf to Emre Yersel,

Esq. for services rendere

19. An~ aJ: McCarthy & Yersel, PLLC

documents (including, but not limited to, retainer

agreements, representation agreements, contracts,

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

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

20. 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

Page 10 of 12
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 McCarthy &

Yersel, PLLC representing you in this action.

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

billing statements, emails, correspondence, text messages, chec si slips,

statements, ACH transfers, wire transfer messages, credit

behalf to McCarthy & Yersel, PLLC fo s e:rvic s rendered and/or expenses

incurred in this action.

"V
~ :' KELLER & MESA, LLP

G
Attorneys for Plaintiff
121 Majorca Avenue, #200
Coral Gables, FL 33134
~ Telephone: (305) 529-8500
A i ' Telefax: (305) 529-0228
~~ Email: jkeller@kellermesa.com

" By: s/ John W. Keller, III

V John W. Keller, III
Florida Bar No. 229989

Page 11 of 12
 CERTIFICATE OF SERVICE

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

Plaintiffs, First American Bank, Second Request for Production (Attorneys' Fees,

Costs, and Expenses), was delivered to: LAURENCE S. SCHNEIDER

(larry@sacapitalpartners.com / jordyn.schneider1998@gmail.com)1; MA "TING.

MCCARTHY, ESQ. (mccarthy@myattorneyservices.com), McCar)fi

GONZALEZ, ESQ. (foreclosures@ssclawfirm.co ), , obs, Sax, Caplan, Attorneys

for Oaks at Boca Raton, 6111 Broken Sou~ ar:J,furay, N.W., #200, Boca Raton,

P.A., 1900 Glades Road, Suite oca Raton, FL 33431 via the E-filing Portal

on this 6 th day of May, 202

KELLER & MESA, LLP

~~ By: __s~/_Jo_h_n_W_._Ki_e_l_le_r~,I_II__
John W. Keller, III

~c
1 Defendant, Laurence Schneider, has failed to comply with this Court's Order Granting Motion

to Withdraw as Counsel for Defendants, Laurence S. Schneider and Stephanie L. Schneider, and
Directing Clerk of Court to Change Counsel of Record [DE 489, '1[4], in that he has not filed a
"notice with the style of this case with the Clerk of Court setting forth each new address and
providing a copy to all counsel of record in the event of any and each address change."

Page 12 of 12