962 First American First Amended Restraining Order Injunction 149010261

Filing# 149010261 E-Filed 05/05/2022 11:02:29 AM
IN THE CIRCUIT COURT OF THE 15TH

WDICIAL 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,
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Plaintiff,
vs.
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LAURENCE S. SCHNEIDER,
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STEPHANIE L. SCHNEIDER, et al.,
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Defendants.
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Plaintiff,
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vs.
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LAURENCE S. SCHNEIDER, STEPHANIE

L. SCHNEIDER, 1sT FIDELITY LOAN
SERVICING, LLC, S & A CAPITAL
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PARTNERS, INC., REAL ESTATE

& FINANCE, INC., BRAD AXEL and
PAIGE AXEL
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Third Party
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Defendants.
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FIRST AMERICAN BANK'S FIRST AMENDED MOTION FOR TEMPORARY

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RESTRAINING ORDER AND PRELIMINARY INJUNCTION
Plaintiff, First American Bank ("First American") files this First Amended Motion for
Temporary Restraining Order and Preliminary Injunction ("Motion"). The Declaration of Neal
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3200 SOUTHEAST FINANCIAL CENTER I 200 SOUTH BISCAYNE BOULEVARD I MIAMI, FL 33131 IT 305-358-6363
~** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 05/05/2022 11 :02:29 AM ***
Levin in support of this Motion is attached as Exhibit A. In support of this Motion, First
American states as follows:
FACTUAL BACKGROUND
This case arises out of First American's efforts to collect on the Final Judgment entered
on September 22, 2020 ("Judgment") in favor of First American, which ordered Laurence
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Schneider ("Laurence") to pay First American $1,547,391.54 with interest at 6.03% per year. 1
The Judgment remains almost fully unsatisfied. On information and belief, prior to and after
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issuance of the Judgment, Laurence, with help from his wife Stephanie Schneider ("Stephanie"
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and together with Laurence the "Schneiders"), engaged in a course of conduct to shield
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Laurence's assets from creditors, including First American, through fraudulent transfers,
commingling funds, and using entities Laurence owns and controls as his personal piggy bank.
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On April 15, 2022, First American filed its First Amended Supplemental Complaint for
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Reverse Piercing the Corporate Veil and Permanent Injunctive Relief (the "Complaint"), seeking
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orders from the Court reverse piercing the corporate veil as to three entities owned and
controlled by Laurence - 1st Fidelity Loan Servicing, LLC ("P 1 Fidelity"), S&A Capital Partners,
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Inc. ("S&A") and Real Estate & Finance, Inc. ("REF'), permanent injunctive relief preventing
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the Schneiders, 1st Fidelity, S&A, REF, and Brad and Paige Axel from accessing, controlling or
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disposing of assets or other property of 1st Fidelity, S&A and REF, and avoidance and recovery
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of fraudulent transfers made for Stephanie's benefit, and damages against Stephanie for civil
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conspiracy to commit fraudulent transfers and aiding and abetting such fraudulent transfers. A
copy of the Complaint is attached as Exhibit B.
The Judgment was also entered against Stephanie. On March 9, 2022, the Fourth District Court of Appeal
entered an order reversing the Judgment against Stephanie in Case No. 4D21-571 (the "Appear'). On March 22,
2022, First American filed a Motion for Rehearing and Motion or Rehearing En Banc in the Appeal, which remains
pending as of the date this Motion is being filed.
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As alleged in the Complaint, on information and belief, the Schneiders have made
various misrepresentations and engaged in various machinations to conceal Laurence's true
worth and assets. Laurence, with Stephanie's help and agreement, has made every effort to divest
himself of individual ownership of any and all assets that would otherwise be subject to the
payment of the Judgment, despite the fact that he remains in full control of those assets. One way
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in which Laurence has done this is by using entities he owns and controls, including 1st Fidelity,
S&A and REF, as his personal piggy bank. Additionally, Laurence, with the help and agreement
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of Stephanie, has ensured that nearly all other assets, including at least three family vehicles,
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were solely titled in Stephanie's name.
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Based on the bank records for the Schneiders' personal account (ending 913) at Northern
Trust (the "Personal Account"), 1st Fidelity is the Schneiders' primary, but not only, source of
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income. 2 When the Schneiders need money, it is often wired in from 1st Fidelity. Between
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January 2016 and July 2021, pt Fidelity wired between $2.4 and $2.9 million to the Personal
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Account. These transfers did not occur on predictable dates or in predictable amounts as would
be expected for transfers related to employment - instead, they occurred at irregular intervals and
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in varying amounts, from $15,000 to $500,000, and whenever the Schneiders needed larger sums
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of money for personal expenses, such as rent. 1st Fidelity also transferred substantial sums of
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money to the Schneiders' children, Jordyn and Zachary Schneider, for which they likely
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provided no value. Bank records further indicate large transfers totaling over $2 million into the
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Schneiders' personal accounts from one or more additional accounts controlled by Laurence.
These additional transfers, like the transfers from 1st Fidelity, occur at irregular intervals and in
varying amounts from $552 to $79,000. Records also indicate that money also moved between
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Despite bank records evidencing the contrary, Laurence failed to disclose income from 1st Fidelity in his
Fact Information Sheet.
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entities before ultimately being transferred to Laurence, and that both 1st Fidelity and REF
directly paid Stephanie's personal legal fees.
The Schneiders have also engaged m other susp1c10us financial activity, including
visiting a Northern Trust branch where they have a safety deposit box with a duffel bag and
backpack, and systematically over a period of years withdrawing large sums of cash just under
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the $10,000 trigger for cash transaction reports by writing checks to cash. Given the large
amounts of cash being withdrawn, First American believes that large amounts of cash are being
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kept in the safety deposit box and away from Laurence's creditors. Laurence, with Stephanie's
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agreement and assistance, also made a number of fraudulent transfers to Muriel Schneider
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including cash transfers totaling over $105,000.
All of this was discovered notwithstanding the obstructionist tactics the Schneiders have
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continued in the post-judgment litigation. For example, Laurence has failed to submit a complete
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Fact Information Sheet in derogation of Court orders. The Fact Information Sheets has has
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submitted have been incomplete, inaccurate, and missing required attachments. Laurence only
provided a sworn Fact Information Sheet after First American was forced to file and attend a
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hearing on a motion for order to show cause. Stephanie objected to every document subpoena
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that First American notified parties that it intended to serve, forcing substantial delay m
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obtaining necessary post-judgment discovery that First American was clearly entitled to.
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Based on the disregard for the law, orders of this Court, and continuing course of
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conduct, First American seeks the imposition of a temporary restraining order ("TRO")
preserving the status quo and preventing the Schneiders, Brad Axel (Brad''), Paige Axel
("Paige"), 1st Fidelity, S&A and REF from using, transferring or withdrawing any assets from 1st
Fidelity, S&A and REF's accounts without First American's consent, pending a hearing on First
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American's request for a preliminary injunction. Based on the Laurence's actions, with help
from the other Defendants, First American will suffer immediate and irreparable injury if the
TRO is not granted and Laurence is left to continue to disregard the law, the Judgment, and
transfer assets out of First American's reach. Indeed, given the Laurence's actions, there is
currently nothing in place to prevent him from transferring all of the funds out of the accounts of
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1st Fidelity, S&A and REF in new, hidden accounts. If this happens, First American will have no
adequate remedy at law. To protect against such injury, the TRO should be entered to preserve
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the status quo by preventing any transfers or withdrawals of assets in the 1st Fidelity, S&A and
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REF accounts without First American's consent in order to maintain the status quo pending a
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hearing on First American's request for a preliminary injunction.
ARGUMENT
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A movant must demonstrate four factors in seeking injunctive relief: "(1) a substantial
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likelihood of success on the merits, (2) the unavailability of an adequate remedy at law, (3)
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irreparable harm absent entry of an injunction, and (4) that the injunction would serve the public
interest." Florida Dep't of Health v. Florigrown, LLC, 317 So. 3d 1101, 1110 (Fla. 2021)
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(internal citations omitted). First American has established each of the four elements necessary to
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obtain a TRO and preliminary injunction.

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A. First American has a substantial likelihood of success on the merits.

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First American is likely to succeed in proving that 1st Fidelity, S&A and REF are the alter
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egos of Laurence, and thus in reverse piercing the corporate veil. There are three factors which
must be proven by a preponderance of the evidence: "(1) the shareholder dominated and
controlled the corporation to such an extent that the corporation's independent existence was in
fact non-existent and the shareholders were in fact alter egos of the corporation; (2) the corporate
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form must have been used fraudulently or for an improper purpose; and (3) the fraudulent or
improper use of the corporate form caused injury to the claimant." Seminole Boatyard, Inc. v.
Christoph, 715 So. 2d 987, 990 (Fla. 4th DCA 1998) (internal citations omitted). Courts look to
corporate formalities such as whether the company maintained separate bank accounts, had
meetings, or operated from independent office space in determining whether a shareholder
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dominated a corporation to the point of eliminating its independent corporate existence. See
Hilton Oil Transp. v. Oil Transp. Co., 659 So. 2d 1141, 1153 (Fla. 3d DCA 1995).
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The facts demonstrate that these entities are dominated and controlled by Laurence to the
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extent that there is no genuine separateness between them. 1st Fidelity, S&A and REF merely
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serve as Laurence's personal piggy bank - nothing more. Bank records evidence massive
commingling among the accounts Laurence controls, which allows Laurence to use all the funds
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in all those accounts for his and the Schneiders' personal use in order to avoid paying the
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Judgment to First American and continue to live their lavish lifestyle. Laurence's refusal to
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truthfully disclose his income and assets alone speaks volumes.
1st Fidelity and REF are wholly owned and controlled by Laurence, and both are entirely
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managed by Laurence. No one other than Laurence is publicly affiliated with 1st Fidelity or REF.
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Both 1st Fidelity and REF maintain identical principal, mailing, registered agent, and authorized
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person addresses of 1199 South Federal Highway, #369, Boca Raton, FL 33432. When a process
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server arrived at this location to serve writs of garnishment, it was a UPS store, and the employee
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reported that the box had been inactive for over a year. Similarly, S&A's principal, mailing,
registered agent, and authorized persons addresses are all 2901 Clint Moore Rd, #410, Boca
Raton, FL 33496, which according to a process server, is another private mailbox location where
an employee reported the box was expired. None of these entities maintain independent office
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space or even current registered agent addresses where they can be properly served. Of the three
entities, only S&A has a website. Neither 1st Fidelity nor REF have any cognizable online
presence nor are there any phone numbers associated with them online. These entities simply
serve as places to stash Laurence's money and assets away from the reach of creditors.
There is immense commingling occurring among the accounts controlled by Laurence.
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Laurence did not disclose the millions of dollars in income that he received from 1st Fidelity in
his Fact Information Sheet, which is transferred into the Personal Account at irregular intervals
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in varying amounts from $15,000 to $500,000, and whenever the Schneiders need substantial
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sums of money to pay for personal expenses and their lavish lifestyle. As described in the
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Complaint, in February 2021, it is believed that the Schneiders were in the process of renting a
property in Boca Raton. On February 16, 2021, pt Fidelity wired $50,000 to the Personal
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Account. The next day, the Schneiders withdrew $17,500 in cash from a Northern Trust branch
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and immediately traveled to the Boca Raton property, where they presumably paid the deposit or
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rent with that cash. Similarly, in March 2021, Stephanie needed to pay the deposit and prepay
rent to Ms. Figueras to the tune of approximately $100,000 pursuant to a lease between
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Stephanie and Ms. Figueras, and 1st Fidelity wired money to the Personal Account to cover those
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expenses.
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In addition to transferring money directly to the Schneiders, 1st Fidelity also transferred
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$9,500 to an account jointly titled in the names of the Schneiders and their adult daughter, Jordyn
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Schneider, as well $5,000 directly to Stephanie's former landlord, Ms. Figueras. Neither Jordyn
nor Ms. Figueras provided any value to 1st Fidelity in exchange for these transfers. There is no
question that Laurence uses 1st Fidelity to pay for personal matters and expenses as he needs or
desires.
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Commingling is also occurnng among other accounts reasonably believed to be
controlled by Laurence. Bank records show that the Schneiders receive other sizable transfers at
varying times and in varying amounts from unknown "private" transferors, which are believed to
be S&A and/or REF. These transfers range from $552 to $79,000. Laurence only disclosed a
total of $40,000 in annual income in 2020 from S&A in his Fact Information Sheets, yet none of
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the transfers into the Personal Account in 2020 indicate they are from S&A. At least one of the
unknown transferors is S&A. Similarly, in his Fact Information Sheet, Laurence disclosed that he
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is employed by REF, and at some point, REF must have paid him. But again, none of the
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transfers into the Personal Account indicate they are from REF, thus, another of the unknown
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transferors is REF.
These facts show that Laurence controls 1st Fidelity, S&A and REF to an extent that their
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independent existence is in fact non-existent. Laurence, with the agreement and help of
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Stephanie and the other Defendants, uses these entities for an improper and fraudulent purpose -
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to shield assets from his creditors, which has caused injury to First American.
B. First American will suffer irreparable harm and there is no adequate remedy at
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law.
If the Defendants are able to transfer assets out of the 1st Fidelity, S&A and REF
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accounts, First American will suffer immediate and irreparable harm. As alleged in the
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Complaint, 1st Fidelity, S&A and REF are all the alter egos of Laurence, making the assets of
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these entities subject to the Judgment. There is no adequate remedy at law to compensate First
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American for the harm it will suffer if Laurence, with help from 1st Fidelity, S&A, REF,
Stephanie, Brad and Paige, are able to transfers assets or other property to third parties out of the
reach of First American. As evidenced by the extensive post-judgment litigation that has already
occurred, there is an inadequate remedy at law. A remedy at law is adequate only where it is
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plain, certain, prompt, speedy, sufficient, complete, practical, and efficient. See Liza Danielle,
Inc. v. Jamko, Inc., 408 So. 2d 735, 738 (Fla. 3d DCA 1982). Here, a TRO should be entered to
preserve the status quo, i.e., to prevent the Defendants from transferring any assets of 1st Fidelity,
S&A and REF to any third parties without prior approval, pending a hearing on First American's
request for a preliminary injunction.
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Restricting transfer of 1st Fidelity, S&A and REF's assets that belong to Laurence without
First American's approval will simply preserve the current status quo until the allegations within
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the Complaint are determined. First American has done nothing wrong, yet risks irreparable
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harm, where Laurence has flouted the Judgment, made fraudulent transfers, and used his entities
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to fund the Schneiders' lavish lifestyle as needed in order to evade payment of the Judgment; as
such, the balance of equities certainly weighs in favor of First American.

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C. A TRO will serve the public interest.
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Public policy is served by entry of a TRO and preliminary injunction. Laurence is not
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entitled to use entities he controls to shield his assets from creditors, including First American.
An injunction would promote public interest by preventing Laurence from using 1st Fidelity,
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S&A and REF for illegitimate purposes.

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Request for Preliminary Injunction

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First American requests a hearing on a preliminary injunction as soon as practical to

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prohibit the continuing threat of irreparable harm disused herein and in the Complaint. The
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purpose of a preliminary injunction is to preserve the status quo pending the final outcome of a
cause. See, e.g., Yardley v. Albu, 826 So. 2d 467,470 (Fla. 5th DCA 2002).
MELAND I BUDWICK
WHEREFORE, First American respectfully requests entry of a temporary restraining
order and preliminary injunction against the Schneiders, 1st Fidelity, S&A, REF, Brad and Paige
as follows:
(a) Immediately, temporarily and preliminarily enJommg Laurence Schneider,
Stephanie Schneider, Brad Axel, Paige Axel, 1st Fidelity Loan Servicing, LLC, S & A Capital
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Partners, Inc., and Real Estate & Finance, Inc. from: (i) taking any steps to sell, transfer, convey,
assign or otherwise change ownership of any asset and real estate owned by 1st Fidelity, S&A
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and REF under their control, including but not limited to cash, without First American's consent
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until further order of the Court; or (ii) using, transferring or withdrawing any cash from the
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accounts of pt Fidelity, S&A and REF without First American's consent until further order of
the Court.
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REMAINDER OF PAGE LEFT INTENTIONALLY BLANK
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MELAND I BUDWICK
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served on May 5,
2022, via the Florida court's e-filing portal upon all registered users.
s/ Meaghan E. Murphy
Meaghan E. Murphy, Esquire
Florida Bar No. 102770
mmurphy@melandbudwick.com
Alina A. Nowicki, Esquire
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Florida Bar Number: 1010500
anowicki@melandbudwick.com
MELAND BUDWICK, P.A.
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200 South Biscayne Boulevard, Suite 3200
Miami, Florida 33131
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Telephone: (305) 358-6363
Facsimile: (305) 358-1221
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Co-Counsel for Plaintiff
Email Designation per Fla. R. Jud.

Admin2.516
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mramos@melandbudwick.com
mrbstate@yahoo.com
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MELAND I BUDWICK

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Plaintiff,
vs.
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Defendants.
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Plaintiff,
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vs.
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PAIGE AXEL
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Third Party
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Defendants.
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DECLARATION OF NEAL LEVIN IN SUPPORT OF FIRST AMERICAN

BANK'S FIRST AMENDED MOTION FOR TEMPORARY RESTRAINING ORDER
AND PRELIMINARY INJUNCTION
STATE OF ILLINOIS )
) ss:
COUNTY OF COOK )
EXHIBIT A
Neal Levin, deposes and states as follows:
1. I am an attorney at Freeborn & Peters LLP ("Freeborn") and am counsel to First
American Bank ("First American"). I make this Declaration in support of First American's First
Amended Motion for Temporary Restraining Order and Preliminary Injunction (the "Motion")
against Laurence Schneider ("Laurence"), Stephanie Schneider ("Stephanie"), 1st Fidelity Loan
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Servicing, LLC ("P 1 Fidelity"), S & A Capital Partners, Inc. ("S&A"), Real Estate & Finance,
Inc. ("REF'), Brad Axel ("Brad'') and Paige Axel ("Paige"). 1
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2. The Motion stems from First American's efforts to collect on the Final Judgment
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entered on September 22, 2020 ("Judgment") in favor of First American, which ordered
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Laurence to pay First American $1,547,391.54, with interest at 6.03% per year, plus additional
costs and fees, almost all of which remains unsatisfied. 2

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3. The facts set forth in this Declaration are personally known to me based on
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information provided to me from First American, post-judgment discovery conducted by First

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American, and First American's investigations. I am duly authorized to make this Declaration.
4. Most of the facts set forth in this Declaration are encompassed in First
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American's First Amended Supplemental Complaint for Reverse Piercing the Corporate Veil and
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Permanent Injunctive Relief (the "Supplemental Complaint').

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5. On information and belief, prior to and since the entry of the Judgment, Laurence,
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with Stephanie's agreement and help, has engaged in a continuous and improper course of
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conduct in an effort to shield his assets from creditors, including First American, and to evade
payment on the Judgment.
Laurence and Stephanie together are the "Schneiders".

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pending as of the date the Motion and this Declaration are being filed.
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6. As described in part below, on information and belief, the Schneiders have made
misrepresentations and engaged in numerous machinations in an effort to conceal Laurence's
true worth and assets.
7. Based on First American's investigations and post-judgment discovery, over the
last number of years, Laurence, with the help and agreement of Stephanie, has taken every effort
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to divest himself of individual ownership of any and all assets that would otherwise be subject to
the payment of the Judgment, despite the fact that he remains in full control of those assets.
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8. One way in which Laurence divested himself of ownership of his assets was by
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using entities he owns and controls, including pt Fidelity, S&A and REF, as his personal piggy
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bank.
9. Based on First American's investigations and post-judgment discovery, I believe

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that 1st Fidelity is solely owned and controlled by Laurence, and Laurence serves as its manager,
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president and registered agent.

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that S&A is owned and controlled, at least in part, by Laurence. Laurence is the president of
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S&A. The vice president of S&A is Brad, Laurence's brother-in-law. Paige is a shareholder of
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S&A.
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that REF is solely owned and controlled by Laurence, and Laurence serves as its president and
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registered agent.
12. 1st Fidelity and REF maintain identical principal, mailing, registered agent, and
authorized person addresses of 1199 South Federal Highway, #369, Boca Raton, FL 33432.
Based on First American's investigations and post-judgment discovery, I believe that this
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address is a UPS store, and box #369 is inactive or expired. Neither 1st Fidelity nor REF maintain
any cognizable online presence, nor are there any phone numbers associated with either of them
online.
13. S&A's principal, mailing, registered agent, and authorized persons addresses are
all 2901 Clint Moore Rd, #410, Boca Raton, FL 33496. Based on First American's investigations
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and post-judgment discovery, I believe that this address is a private mailbox location, and box
#410 is inactive or expired.
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14. The Schneiders have actively obstructed First American's post-judgment
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discovery and collection efforts. For example, Laurence has not been forthcoming in post-
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judgment discovery about income and transfers from any source. His first Fact Information Sheet
was woefully incomplete and contained false information (including a knowingly outdated
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residence address). His second Fact Information Sheet was still incomplete and failed to attach
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required documents. Stephanie objected to every document subpoena that First American
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notified parties that it intended to serve, forcing substantial delay in obtaining necessary post-
judgment discovery that First American is clearly entitled to.

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15. But even with the benefit of only limited discovery, First American has uncovered
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evidence of Laurence's incestuous financial relationship with entities he controls, commingling

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of funds both with those entities and family members, and other suspicious conduct
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demonstrating Laurence's intent to frustrate creditors.

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Commingling of Entity and Family Funds
16. On September 29, 2021, the Sheriff of Palm Beach County levied three vehicles
pursuant to a writ of execution. On November 18, 2021, two of those vehicles were sold at a
Sheriffs Sale, both to First American. After taking possession of the vehicles, First American
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downloaded and analyzed data from the vehicles' infotainment systems (which includes both
GPS and phone contact information, among other things). Combined with information learned
from bank records produced by The Northern Trust Company ("Northern Trust") and
surveillance, First American has been able to piece together some of the Schneider's actions and
discover various facts evidencing Laurence's gamesmanship and incestuous financial
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relationships with his corporate entities.
17. On February 17, 2021, from approximately 12:39 p.m. to 1:25 p.m., one or both
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of the Schneiders was at 6312 NW 26th Terrace, Boca Raton, FL 33413 (the "Boca Raton
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Property"). After leaving the Boca Raton Property, Laurence and/or Stephanie traveled to a
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Northern Trust bank branch located at 3100 N. Military Trail, Boca Raton, FL 33431, and at 2:31
p.m. withdrew $17,500 in cash by check #7177 drawn on their personal account (ending 913)
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(the "Personal Accounf'). After this withdrawal, Laurence and/or Stephanie traveled back to the
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Boca Raton Property and remained there from 2:48 p.m. to 3:14 p.m.
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18. Upon further investigation, First American learned that the Boca Raton Property
is located in the Grand Oaks of Arvida Country Club, Boca Raton Rentals. An online search of
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this residence revealed that it was renting for $9,500 per month. This activity took place
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approximately one month before the Schneiders moved into the luxury townhouse located at 628
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SE 5th St., Unit 2, Delray Beach, FL 33483 (the "Delray Beach Property"), which was rented
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from Michelle Figueras beginning on March 29, 2021 for a period of eight months. The
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Schneiders moved out of the Delray Beach Property on or about November 29, 2021.
19. As noted above, I believe that pt Fidelity is an entity owned and controlled by
Laurence. My review of the public records in Sunbiz do not list anyone affiliated with 1st Fidelity
other than Laurence. Based on the bank records for the Personal Account, 1st Fidelity is the
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Schneider's primary, but not only, source of income. When the Schneiders need money, it is
often wired in from pt Fidelity. Between January 2016 and July 2021, pt Fidelity wired between
$2.4 and $2.9 million to the Personal Account. These transfers did not occur on predictable dates
or in predictable amounts as would be expected for transfers related to employment - instead,
they occurred at irregular intervals and in varying amounts, from $15,000 to $500,000, and
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whenever the Schneiders needed larger sums of money for personal expenses.
20. For example, when the Schneiders needed money in February 2021 to pay the
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$17,500 presumed deposit or rent for the Boca Raton Property, money was wired into their
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Personal Account from 1st Fidelity. See Exhibit A to the Supplemental Complaint.
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21. In March 2021, Stephanie needed money to pay the deposit and prepay rent to
Michelle Figueras for the Delray Beach Property pursuant to a lease between Stephanie and
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Michelle Figueras (the "Lease"). Pursuant to the Lease, which was in Stephanie's name only,
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rent was not paid monthly; it was all due upon execution of the Lease, along with an $11,500
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security deposit for a total of $103,500 upon signing. On March 19, 2021, pt Fidelity transferred
$25,000 to the Personal Account. The Lease was signed only by Stephanie on March 25, 2021.
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On March 26, 2021, a cashier's check was drawn on the Personal Account for $11,500. See
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Exhibit B to the Supplemental Complaint.

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22. On March 29, 2021, pt Fidelity transferred $100,000 to the Personal Account.
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The next day, $94,300 was transferred from the Personal Account to Michelle Figueras, relating
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to the Lease. See Exhibit C to the Supplemental Complaint. On June 11, 2021, pt Fidelity sent
Ms. Figueras another $5,000 relating to the Lease.
23. 1st Fidelity also transferred money to an account jointly titled in the names of the
Schneiders and their adult daughter, Jordyn Schneider, including a $9,500 transfer to Jordyn on
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September 21, 2020. Based on First American's investigations and post-judgment discovery, I do
not believe Jordyn provided any value to 1st Fidelity in exchange for this transfer, as she does not
receive regular transfers from 1st Fidelity that would indicate employment by 1st Fidelity. The
money deposited into Jordyn's account was then spent in ways expected of a younger adult, such
as jewelry and clothing retailers, beauty retailers, restaurants, and Starbucks. See Exhibit D to the
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Supplemental Complaint.
24. Commingling among the Schneiders' entities, including pt Fidelity, S&A, and
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REF, and the Schneiders and their immediate family members, as a way to avoid and frustrate
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creditors and fund the Schneiders' lifestyle is evident in other ways as well. For example, on
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information and belief, Jordyn received other transfers from pt Fidelity between 2016 and 2022
totaling approximately $196,184 for which she provided no value. On information and belief,
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during the same time period, her brother, Zachary Schneider, received transfers from 1st Fidelity
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totaling approximately $116,000 for which he provided no value.

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25. Money also moved between and among S&A, REF and the Schneiders. On
information and belief, between 2016 and 2021, S&A directly transferred the Schneiders
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approximately $520,023. On information and belief, S&A is REF's primary and possibly sole
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source of funding. Between 2016 and 2021, S&A transferred REF $568,966. In that same time
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period, REF transferred the Schneiders approximately $398,361.

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26. On information and belief, in 2021, pt Fidelity and REF cumulatively paid in
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excess of $200,000 directly to Stephanie's attorneys, further evidencing commingling.
Suspicious Financial Activities
27. The Schneiders also have a safety deposit box at Northern Trust. It is unknown
specifically what assets the Schneiders are keeping in the safety deposit box and away from
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Laurence's creditors. On July 2, 2021, the Schneiders arrived at the Northern Trust bank branch.
Laurence carried a backpack and duffle bag into the bank, while Stephanie remained in the car
for approximately 25 minutes. Given the need for a backpack and duffle bag, and the large
amounts of cash being withdrawn as discussed below, I reasonably believe that more than
paperwork is being kept in the box and that in fact, large amounts of cash are being kept in the
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safety deposit box.
28. The Northern Trust records have also revealed that the Schneiders may be paying
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expenses largely in cash and withdrawing that cash in transactions that are just under the $10,000
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trigger for a cash transaction report to the IRS. Many of these cash transactions are not standard
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cash withdrawals - they are accomplished by writing checks to cash, endorsed by the same
person with the same signature as the person who wrote the check. See Exhibit E to the
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Supplemental Complaint.
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29. In some instances, multiple smaller checks are made to cash within a short time
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period to withdraw $10,000 in total without triggering a cash transaction report. See Exhibit F to
the Supplemental Complaint.

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30. The Schneiders then use the cash they systematically withdraw to pay their
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expenses. For example, on September 30, 2021 at 9:36 p.m., the Schneiders and their adult
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children were at the Island Vibes Kava Bar in Delray Beach. Just prior to leaving, Laurence gave
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their adult son cash, who then placed the cash on the bar to settle the tab.
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31. Laurence also made a number of fraudulent transfers from the Personal Account
to Muriel Schneider, his mother. Between December 13, 2016 and August 9, 2019, Muriel
received $105,899 in transfers from Laurence. The transfers were paid by check from the
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Personal Account, either made directly to Muriel or made to "cash" and endorsed by Muriel.
Upon information and belief, Muriel provided no value in exchange for these transfers.
Additional Transfers
32. Laurence is a controlling person for not only 1st Fidelity, but also S&A and REF.
The Personal Account records alone have made clear that Laurence uses at least one of his
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corporate entities (Pt Fidelity) to fund the Schneiders' personal expenses on an as-needed basis,
making that corporate entity account effectively his. But there are other accounts making
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sizeable, private transfers into the Personal Account at irregular intervals and in varying
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amounts, from $552 to $79,000. See Exhibit G to the Supplemental Complaint. Based on First
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American's investigations and post-judgment discovery, I believe some or all of those transfers
are from S&A and/or REF.

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33. Some of these private transfers are in repeating amounts of $552, which might
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indicate employment income. It is unknown at this time whether these $552 transfers are from
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the same transferor as some of the large private transfers, but I believe they are, as some occur on
the same day as a $552 transfer. 3

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34. Laurence disclosed a total of $40,000 in annual income in 2020 from S&A in his
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Fact Information Sheet, yet none of the transfers into the personal account in 2020 indicate they
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are from S&A. At least one of the unknown transferors is S&A. Laurence also disclosed in his
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Fact Information Sheet, that he is employed by REF, so at some point, REF must have paid him.
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But again, none of the transfers into the Personal Account indicate they are from REF, thus,
another of the unknown transferors is REF.
See, e.g., March 2017, Sept. 2017, Nov. 2020 contained in Ex. G.
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35. Additional information further indicates these private transfers are sent from
accounts that are owned and controlled by Laurence, but for which Northern Trust did not
produce documents because such accounts were not titled in the name(s) of the Schneiders. In
August 2017 and February 2019, private transfers were sent to the Personal Account from an
account ending 411- one in the amount of $17,000 and the other $4,275.55. See Exhibit G to the
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Supplemental Complaint. The 411 account is Jordyn Schneider's account, which is jointly titled
in the Schneiders' names. This transfer information was not redacted by Northern Trust since
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statements for the 411 account were already provided by Northern Trust as part of its production
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to First American. Sizeable transfers from their adult daughter's account, which is controlled by
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the Schneiders, further evidence commingling of funds.
36. In response to a writ of garnishment relating to Laurence, Northern Trust froze

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accounts titled in the names of S&A and REF, which also indicates that Laurence maintains
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ownership and control over the funds in those accounts.

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Pursuant to 28 U.S.C. § 1746 and § 92.525, Fla. Stat., under penalties of perjury, I
declare that I have read the foregoing Declaration of Neal Levin in Support of First American
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Bank's First Amended Motion for Temporary Restraining Order and Preliminary Injunction and
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that the facts stated in it are true.

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Isl Neal Levin

Neal Levin
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Counsel to First American Bank

Filing# 147788620 E-Filed 04/15/2022 03:41 :33 PM


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Plaintiff,
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vs.
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Defendants.
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Plaintiff,
vs.
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PAIGE AXEL
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Third Party Defendants.

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FIRST AMERICAN BANK'S FIRST AMENDED SUPPLEMENTAL COMPLAINT FOR

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REVERSE PIERCING THE CORPORA TE VEIL, PERMANENT INJUNCTIVE

RELIEF, AVOIDANCE AND RECOVERY OF FRAUDULENT TRANSFERS, AND
OTHER RELATED RELIEF
Plaintiff, First American Bank ("First American"), pursuant to Section 56.29, Florida
Statutes, files this First Amended Supplemental Complaint for Reverse Piercing the Corporate
MELAND I BUDWICK FYHlRTT R

3200 SOUTHEAST FINANCIAL CENTER I 200 SOUTH BISCAYNE BOULEVARD I MIAMI, FL 33131 IT 3tl'5~3S~-:36S'
Veil, Permanent Injunctive Relief, Avoidance and Recovery of Fraudulent Transfers, and Other
Related Relief against Judgment Debtor Laurence S. Schneider ("Laurence"), Stephanie L.
Schneider ("Stephanie" and together with Laurence, the "Schneiders"), 1st Fidelity Loan
Servicing, LLC ("P 1 Fidelity"), S & A Capital Partners, Inc. ("S&A"), Real Estate & Finance,
Inc. ("REF'), Brad Axel ("Brad'') and Paige Axel ("Paige") (collectively the "Defendants") and
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alleges as follows:
PARTIES, JURISDICTION, AND VENUE
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1. First American Bank is an Illinois corporation authorized to do and conducting
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business in Florida.
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2. Laurence is a Florida resident, and upon information and belief, residing in Palm
Beach County.
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3. Stephanie is a Florida resident, and upon information and belief, residing in Palm
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Beach County.
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4. 1st Fidelity is a Florida limited liability company.
5. S&A is a Florida for-profit corporation.

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6. REF is a Florida for-profit corporation.

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7. Brad is a Florida resident, residing in Palm Beach County.

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8. Paige is a Florida resident, residing in Palm Beach County.

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9. This Court has jurisdiction because the amount in controversy exceeds $30,000,
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exclusive of interest, costs, and attorney's fees.
10. Venue is proper in Palm Beach County because the acts complained of occurred
in Palm Beach County and the property that is the subject of this action is located in Palm Beach
County.
MELAND I BUDWICK
All conditions precedent to the filing of this First Amended Supplemental Complaint have been
fulfilled, waived, or excused.
INTRODUCTION
11. On August 17, 2016, First American filed suit against the Schneiders.
12. On September 22, 2020, this Court entered a Final Judgment ("Judgment") in
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favor of First American and ordered Laurence to pay First American $1,547,391.54 with interest
at the rate of 6.03% per year. 1
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13. The Judgment against Laurence remains due and unsatisfied.
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14. Prior to and since the entry of the Judgment, Laurence has engaged in a
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continuous and improper course of conduct in an effort to shield his assets from creditors,
including First American, and to evade payment on the Judgment.

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15. As described in part below, the Schneiders have made misrepresentations and
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engaged in numerous machinations in an effort to conceal Laurence's true worth and assets.
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16. Upon information and belief, over the last number of years, Laurence, with the
help and agreement of Stephanie, has taken every effort to divest himself of individual
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ownership of any and all assets that would otherwise be subject to the payment of the Judgment,
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despite the fact that he remains in full control of those assets.

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17. One way in which Laurence has divested himself of ownership of his assets was
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by using entities he owned and controlled, including 1st Fidelity, S&A and REF, as his personal
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piggy bank. Additionally, Laurence, with the help and agreement of Stephanie, has ensured that
pending as of the date this Supplemental Complaint is being filed.
MELAND I BUDWICK
nearly all other assets, including at least three family vehicles, were solely titled in his wife
Stephanie's name.
18. Accordingly, First American brings this Supplemental Complaint for entry of an
order permitting reverse piercing of the corporate veil of pt Fidelity, S&A and REF. First
American further requests that the Court permanently enjoin Laurence's further access or control
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over 1st Fidelity, S&A and REF's assets so that they may be turned over to First American to
satisfy the Judgment against Laurence. First American also seeks avoidance and recovery of
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fraudulent transfers made for Stephanie's benefit, and damages against Stephanie for civil
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conspiracy to commit fraudulent transfers and aiding and abetting such fraudulent transfers.
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FACTUAL ALLEGATIONS
19. Upon information and belief, 1st Fidelity is solely owned and controlled Laurence,
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and Laurence serves as its manager, president and registered agent.
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20. S&A is owned and controlled, at least in part, by Laurence. Laurence is the
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president of S&A. The vice president of S&A is Brad, Laurence's brother-in-law. Upon
information and belief, Paige is a shareholder of S&A.

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21. Upon information and belief, REF is solely owned and controlled by Laurence,
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and Laurence serves as its president and registered agent.

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22. 1st Fidelity and REF maintain identical principal, mailing, registered agent, and
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authorized person addresses of 1199 South Federal Highway, #369, Boca Raton, FL 33432.
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Upon information and belief, this address is a UPS store, and box #369 is inactive or expired.
Neither pt Fidelity nor REF maintain any cognizable online presence, nor are there any phone
numbers associated with either of them online.
MELAND I BUDWICK
23. S&A's principal, mailing, registered agent, and authorized persons addresses are
all 2901 Clint Moore Rd, #410, Boca Raton, FL 33496. Upon information and belief, this
address is a private mailbox location, and box #410 is inactive or expired.
24. The Schneiders have actively obstructed First American's post-judgment
discovery and collection efforts. For example, Laurence has not been forthcoming in post-
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judgment discovery about income and transfers from any source. His first Fact Information Sheet
was woefully incomplete and contained false information (including a knowingly outdated
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residence address). His second Fact Information Sheet was still incomplete and failed to attach
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required documents. Stephanie objected to every document subpoena that First American
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notified parties that it intended to serve, forcing substantial delay in obtaining necessary post-
judgment discovery that First American is clearly entitled to.

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25. But even with the benefit of only limited discovery, First American has uncovered
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evidence of Laurence's incestuous financial relationship with entities he controls, commingling

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of funds both with those entities and family members, and other suspicious conduct
demonstrating Laurence's intent to frustrate creditors.

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Commingling of Entity and Family Funds

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26. On September 29, 2021, the Sheriff of Palm Beach County levied three vehicles
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pursuant to a writ of execution. On November 18, 2021, two of those vehicles were sold at a
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Sheriffs Sale, both to First American. After taking possession of the vehicles, First American
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downloaded and analyzed data from the vehicles' infotainment systems (which includes both
GPS and phone contact information, among other things). Combined with information learned
from bank records produced by The Northern Trust Company ("Northern Trust") and
surveillance, First American has been able to piece together some of the Schneider's actions and
MELAND I BUDWICK
discover vanous facts evidencing Laurence's gamesmanship and incestuous financial
relationships with his corporate entities.
27. On February 17, 2021, from approximately 12:39 p.m. to 1:25 p.m., one or both
of the Schneiders were at 6312 NW 26th Terrace, Boca Raton, FL 33413 (the "Boca Raton
Property"). After leaving the Boca Raton Property, Laurence and/or Stephanie traveled to a
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Northern Trust bank branch located at 3100 N. Military Trail, Boca Raton, FL 33431, and at 2:31
p.m. withdrew $17,500 in cash by check #7177 drawn on their personal account (ending 913)
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(the "Personal Account"). After this withdrawal, Laurence and/or Stephanie traveled back to the
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Boca Raton Property and remained there from 2:48 p.m. to 3:14 p.m.
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28. Upon further investigation, First American learned that the Boca Raton Property
is located in the Grand Oaks of Arvida Country Club, Boca Raton Rentals. An online search of
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this residence revealed that it was renting for $9,500 per month. This activity took place
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approximately one month before the Schneiders moved into the luxury townhouse located at 628
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SE 5th St., Unit 2, Delray Beach, FL 33483 (the "Delray Beach Property"), which was rented
from Michelle Figueras beginning on March 29, 2021 for a period of eight months. The
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Schneiders moved out of the Delray Beach Property on or about November 29, 2021.
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29. As noted above, 1st Fidelity is an entity owned and controlled by Laurence. Public
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records in Sunbiz do not list anyone affiliated with 1st Fidelity other than Laurence. Based on the
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bank records for the Personal Account, 1st Fidelity is Laurence's primary, but not only, source of
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income. When the Schneiders need money, it is often wired in from 1st Fidelity. The millions of
dollars in transfers did not occur on predictable dates or in predictable amounts as would be
expected for transfers related to employment - instead, they occurred at irregular intervals and in
MELAND I BUDWICK
varying amounts, from $15,000 to $500,000, and whenever the Schneiders needed larger sums of
money for personal expenses.
30. For example, when the Schneiders needed money in February 2021 to pay the
$17,500 presumed deposit or rent for the Boca Raton Property, money was wired into their
Personal Account from 1st Fidelity. See Exhibit A.
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31. In March 2021, Stephanie needed money to pay the deposit and prepay rent to
Michelle Figueras for the Delray Beach Property pursuant to a lease between Stephanie and
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Michelle Figueras (the "Lease"). Pursuant to the Lease, which was in Stephanie's name only,
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rent was not paid monthly; it was all due upon execution of the Lease, along with an $11,500
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security deposit for a total of $103,500 upon signing. On March 19, 2021, pt Fidelity transferred
$25,000 to the Personal Account. The Lease was signed only by Stephanie on March 25, 2021.
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On March 26, 2021, a cashier's check was drawn on the Personal Account for $11,500. See
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Exhibit B.
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32. On March 29, 2021, pt Fidelity transferred $100,000 to the Personal Account.
The next day, $94,300 was transferred from the Personal Account to Michelle Figueras, relating
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to the Lease. See Exhibit C.

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33. The UBS account to which the $94,300 deposit was wired belongs to Ms.
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Figueras. On June 11, 2021, 1st Fidelity sent Ms. Figueras another $5,000 relating to the Lease.
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34. 1st Fidelity also transferred money to an account jointly titled in the names of the
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Schneiders and their adult daughter, Jordyn Schneider, including a $9,500 transfer to Jordyn on
September 21, 2020. Upon information and belief, Jordyn provided no value to pt Fidelity in
exchange for this transfer, as she does not receive regular transfers from 1st Fidelity that would
indicate employment by pt Fidelity. The money deposited into Jordyn's account was then spent
MELAND I BUDWICK
in ways expected of a younger adult, such as jewelry and clothing retailers, beauty retailers,
restaurants, and Starbucks. See Exhibit D.
35. Commingling among the Schneiders' entities, including pt Fidelity, S&A, and
REF, and the Schneiders and their immediately family members as a way to avoid and frustrate
creditors and fund the Schneiders lifestyle is evident in other ways as well. For example, on
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information and belief, Jordyn received other transfers from pt Fidelity between 2016 and 2022
totaling approximately $196,184 for which she provided no value. On information and belief,
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during the same time period, her brother, Zachary Schneider, received transfers from 1st Fidelity
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totaling approximately $116,000 for which he provided no value.
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36. Money also moved between and among S&A, REF and the Schneiders. On
information and belief, between 2016 and 2021, S&A directly transferred the Schneiders
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approximately $520,023. On information and belief, S&A is REF's primary and possibly sole
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source of funding. Between 2016 and 2021, S&A transferred REF $568,966. In that same time
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period, REF transferred the Schneiders approximately $398,361.
Suspicious Financial Activities

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37. The Schneiders also have a safety deposit box at Northern Trust. It is unknown
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specifically what assets the Schneiders are keeping in the safety deposit box and away from
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Laurence's creditors. On July 2, 2021, the Schneiders arrived at the Northern Trust bank branch.
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Laurence carried a backpack and duffle bag into the bank, while Stephanie remained in the car
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for approximately 25 minutes. Given the need for a backpack and duffle bag, presumably more
than paperwork is being kept in the box. Given the large amounts of cash being withdrawn, as
discussed below, First American believes that large amounts of cash are being kept in the safety
deposit box.
MELAND I BUDWICK
38. The Northern Trust records have also revealed that the Schneiders may be paying
expenses largely in cash and withdrawing that cash in transactions that are just under the $10,000
trigger for a cash transaction report to the IRS. Many of these cash transactions are not standard
cash withdrawals - they are accomplished by writing checks to cash, endorsed by the same
person with the same signature as the person who wrote the check. See Exhibit E.
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39. In some instances, multiple smaller checks are made to cash within a short time
period to withdraw $10,000 in total without triggering a cash transaction report. See Exhibit F.
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40. The Schneiders then use the cash they systematically withdraw to pay their
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expenses. For example, on September 30, 2021 at 9:36 p.m., the Schneiders and their adult
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children were at the Island Vibes Kava Bar in Delray Beach. Just prior to leaving, Laurence gave
their adult son cash, who then placed the cash on the bar to settle the tab.
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41. Laurence also made a number of fraudulent transfers from the Personal Account
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to Muriel Schneider, his mother. Between December 13, 2016 and August 9, 2019, Muriel
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received $105,899 in transfers from Laurence. The transfers were paid by check from the
Personal Account, either made directly to Muriel or made to "cash" and endorsed by Muriel.
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Upon information and belief, Muriel provided no value in exchange for these transfers.
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Additional Transfers
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42. Laurence is a controlling person for not only 1st Fidelity, but also S&A and REF.
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The Personal Account records alone have made clear that Laurence uses at least one of his
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corporate entities (Pt Fidelity) to fund the Schneider's personal expenses on an as-needed basis,
making that corporate entity account effectively his. But there are other accounts making
sizeable, private transfers into the Personal Account at irregular intervals and in varying
MELAND I BUDWICK
amounts, from $552 to $79,000. See Exhibit G. Upon information and belief, some or all of
those transfers are from S&A and/or REF.
43. Some of these private transfers are in repeating amounts of $552, which might
indicate employment income. It is unknown at this time whether these $552 transfers are from
the same transferor as some of the large private transfers, but upon information and belief, they
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are, as some occur on the same day as a $552 transfer. 2
44. Information further indicates these private transfers are sent from accounts that
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are owned and controlled by Laurence and/or Stephanie, but for which Northern Trust did not
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produce documents because such accounts were not titled in the name(s) of the Schneiders. In
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August 2017 and February 2019, private transfers were sent to the Personal Account from an
account ending 411 - one in the amount of $17,000 and the other $4,275.55. See Ex. G. The 411
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account is Jordyn Schneider's account, which is jointly titled in the Schneider's names. This
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transfer information was not redacted by Northern Trust since statements for the 411 account
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were already provided by Northern Trust as part of its production to First American. Sizeable
transfers from their adult daughter's account, which is controlled by the Schneiders, further
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evidences commingling of funds.

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45. In response to a writ of garnishment pertaining to Laurence, Northern Trust froze

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accounts titled in the names of S&A and REF, which indicates that Laurence maintains
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ownership and control over the funds in the accounts.

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COUNTI
Reverse Piercing the Corporate Veil against 1st Fidelity and the Schneiders
46. First American reasserts and realleges paragraphs 1-45 above.
See, e.g., March 2017, Sept. 2017, Nov. 2020 contained in Ex. G.
MELAND I BUDWICK
47. pt Fidelity is dominated and controlled by Laurence in such a way that it is the
mere alter ego of Laurence, and pt Fidelity is used solely for Laurence's personal benefit to
shield assets from his creditors.
48. Laurence dominates and controls 1st Fidelity, using Stephanie as a puppet, by
directing transfers from pt Fidelity's bank account to whomever he chooses and to otherwise
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avoid 1st Fidelity's assets being subject to Laurence's creditors.
49. Laurence uses 1st Fidelity's funds for his own personal use.
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50. Laurence uses 1st Fidelity as a mere instrumentality for his own personal benefit
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with the help of Stephanie.
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51. Upon information and belief, Laurence is the person that manages and controls 1st
Fidelity on a day-to-day basis, and the Schneiders are the only members.
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52. The personal affairs of Laurence have become confused with the business affairs
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of 1st Fidelity, and funds are put in and taken out of 1st Fidelity for personal rather than business
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purposes.
53. The principal, mailing, registered agent, and authorized person addresses for 1st
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Fidelity and REF are all the same inactive or expired private mailbox at a UPS store.
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54. pt Fidelity does not maintain physical office space independent of Laurence's
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residence.
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55. 1st Fidelity has no website or publicly listed phone number.

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56. As demonstrated by the foregoing, there is such unity of interest and ownership
that separate personalities of Laurence and 1st Fidelity do not exist.
57. Adhering to the fiction of pt Fidelity as its own separate entity would promote
injustice, fraud or inequitable consequences.
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MELAND I BUDWICK
58. Laurence has been using 1st Fidelity for an improper purpose, to shield assets
from creditors, and as a result, hindering First American's ability to collect on the Judgment.
59. Any purported corporate separateness should therefore be disregarded.
60. As a result of the foregoing, First American is entitled to reverse pierce the
corporate veil of pt Fidelity, and subsequently, an order that pt Fidelity's assets may be levied
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upon and applied toward the satisfaction of the Judgment.
WHEREFORE, First American respectfully requests this Honorable Court enter an
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Order:
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(a) reverse piercing the corporate veil of 1st Fidelity;
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(b) adjudicating Laurence and 1st Fidelity to be one and the same and the alter egos of
each other;
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(c) declaring that Stephanie has no interest in 1st Fidelity;
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(d) ordering 1st Fidelity's assets be levied to satisfy the Judgment; and
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(e) granting any other relief as this Court deems just and equitable.
COUNT II
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Reverse Piercing the Corporate Veil against S&A, Brad, Paige and the Schneiders
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62. S&A is dominated and controlled by Laurence in such a way that it is the mere
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alter ego of Laurence, and S&A is used for Laurence's personal benefit to shield assets from his
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creditors.
63. Laurence dominates and controls S&A, usmg Brad, Paige and Stephanie as
puppets to avoid S&A's assets being subject to Laurence's creditors.
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MELAND I BUDWICK
64. Laurence uses S&A as a mere instrumentality for his own personal benefit with
the help of Brad, Paige and Stephanie.
65. Upon information and belief, Laurence uses S&A's funds for his own personal
use.
66. The principal, mailing, registered agent, and authorized person addresses for S&A
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are all the same inactive or expired private mailbox.
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that separate personalities of Laurence and S&A do not exist.
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68. Adhering to the fiction of S&A as its own separate entity would promote
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injustice, fraud or inequitable consequences.
69. Laurence has been using S&A for an improper purpose, to shield assets from
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creditors, and as a result, hindering First American's ability to collect on the Judgment.
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corporate veil of S&A, and subsequently, an order that S&A's assets may be levied upon and
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applied toward the satisfaction of the Judgment.

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Order:
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(a) reverse piercing the corporate veil of S&A;

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(b) adjudicating Laurence and S&A to be one and the same and the alter egos of each
other;
(c) declaring that Brad, Paige and Stephanie have no interest in S&A;
(d) ordering S&A's assets be levied to satisfy the Judgment; and
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MELAND I BUDWICK
(f) granting any other relief as this Court deems just and equitable.
COUNTIII
Reverse Piercing the Corporate Veil against REF and the Schneiders
73. REF is dominated and controlled by Laurence in such a way that it is the mere
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alter ego of Laurence, and REF is used solely for Laurence's personal benefit to shield assets
from his creditors.
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74. Upon information and belief, Laurence dominates and controls REF, usmg
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Stephanie as a puppet, by directing transfers from REF's bank account to whomever he chooses
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and to otherwise avoid REF's assets being subject to Laurence's creditors.
75. Upon information and belief, Laurence uses REF's funds for his own personal
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use.
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76. Laurence uses REF as a mere instrumentality for his own personal benefit with
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the help of Stephanie.
77. Upon information and belief, Laurence is the person that manages and controls
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REF on a day-to-day basis, and the Schneiders are the only shareholders.
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78. The personal affairs of Laurence have become confused with the business affairs
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of REF, and funds are put in and taken out of REF for personal rather than business purposes.
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79. The principal, mailing, registered agent, and authorized person addresses for REF
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and 1st Fidelity are all the same inactive or expired private mailbox at a UPS store.
80. REF does not maintain physical office space independent of Laurence's
residence.
81. REF has no website or publicly listed phone number.
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MELAND I BUDWICK
that separate personalities of Laurence and REF do not exist.
83. Adhering to the fiction of REF as its own separate entity would promote injustice,
fraud or inequitable consequences.
84. Laurence been using REF for an improper purpose, to shield assets from creditors,
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and as a result, hindering First American's ability to collect on the Judgment.
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corporate veil of REF, and subsequently, an order that REF's assets may be levied upon and
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applied toward the satisfaction of the Judgment.

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Order:
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(a) reverse piercing the corporate veil of REF;

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(b) adjudicating Laurence and REF to be one and the same and the alter egos of each
other;
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(c) declaring that Stephanie has no interest in REF;

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(d) ordering REF' s assets be levied to satisfy the Judgment; and

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(e) granting any other relief as this Court deems just and equitable.
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COUNTIV
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Permanent Injunction against the Schneiders, Brad and Paige
88. First American seeks a permanent injunction to enjoin the Schneiders, Brad and
Paige from accessing, controlling or disposing of the assets of 1st Fidelity, S&A and/or REF.
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MELAND I BUDWICK
89. pt Fidelity, S&A and REF are the mere alter egos of Laurence and as such, their
assets are subject to the Judgment.
90. The right of First American as a judgment creditor to be paid on its outstanding
Judgment by Laurence, who, with the help of Stephanie, Brad and Paige, is persistently evading
payment is a protectable interest.
PY
91. Further, it is a protectable right for First American to collect on its Judgment
without the intervention of Brad, Paige and Stephanie aiding in Laurence's attempts to delay and
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manipulate 1st Fidelity, S&A and REF to avoid paying the Judgment.
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92. As a result of their actions, a permanent injunction against the Schneiders, Brad
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and Paige as to 1st Fidelity, S&A and REF is necessary to prevent irreparable harm.
93. 1st Fidelity, S&A and REF are believed to be the among the only assets that can
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be used to satisfy the Judgment against Laurence.
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94. As demonstrated by the extensive post-judgment litigation, there is an inadequate

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remedy at law.
95. First American as a substantial likelihood of success on the merits in this matter.
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96. After substantial time and effort attempting to collect on its Judgment, it is clear
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that Laurence will continue to avoid paying First American.

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97. The threatened injury to First American outweighs the harm the permanent
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injunction would inflict on the Schneiders, Brad and Paige, because they participated in the acts
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to use 1st Fidelity, S&A and REF as a shield against First American.
98. Based on the deliberate and consistent improper course of conduct to shield assets
from Laurence's creditors, including First American, a permanent injunction would promote the
16
MELAND I BUDWICK
public interest by preventing Laurence from using 1st Fidelity, S&A and REF for illegitimate
purposes.
99. Without the permanent injunction, Laurence will continue to commingle 1st
Fidelity, S&A and REF's funds at his own discretion.
100. Accordingly, a permanent injunction is proper to prevent the fraudulent use of 1st
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Fidelity, S&A and REF and to allow First American to collect on its Judgment.
WHEREFORE, First American respectfully requests this Honorable Court enter:
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(a) a permanent injunction preventing the Schneiders, Brad and Paige from accessing,
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controlling or disposing of assets or other property of 1st Fidelity, S&A and REF; and
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(b) grant any other relief as this Court deems just and equitable.
COUNTY
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Avoidance and Recovery of Fraudulent Transfers Pursuant to Fla. Stat.§§ 726.lOS(l)(a)
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and 726.108 against Stephanie

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102. At all times from August 2016, First American was a creditor of pt Fidelity, as
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Laurence's alter ego.
103. On March 19, 2021, pt Fidelity Transferred $25,000 to the Personal Account, of
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which, $11,500 was used for Stephanie's benefit relating to the Lease.
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104. On March 29, 2021, pt Fidelity transferred $100,000 to the Personal Account, of
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which, $94,300 was used for Stephanie's benefit and subsequently transferred to Michelle
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Figueras pursuant to the Lease.
105. On June 11, 2021, pt Fidelity transferred $5,000 to Michelle Figueras for
Stephanie's benefit, relating to the Lease.
17
MELAND I BUDWICK
106. pt Fidelity made these transfers for Stephanie's benefit with the actual intent to
hinder, delay, or defraud Laurence's creditors, including First American.
WHEREFORE, First American respectfully requests this Honorable Court enter
judgment in favor of First American and against Stephanie: (1) determining that the transfers
described above relating to the Lease were fraudulent and avoiding these and any other
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fraudulent transfers to or for the benefit of Stephanie hereafter discovered by First American; (2)
awarding First American the amount or value of the transfers described above relating to the
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Lease, together with pre-judgment and post-judgment interest to the extent allowed under
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applicable law or statute; and (3) any other relief this Court deems just and appropriate.
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COUNT VI

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112. pt Fidelity made these transfers for Stephanie's benefit with the actual intent to
hinder, delay, or defraud Laurence's creditors, including First American.
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MELAND I BUDWICK
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COUNT VII
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118. 1st American did not receive reasonably equivalent value in exchange for the
transfer described above related to the Lease.
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MELAND I BUDWICK
119. At the time pt Fidelity made these transfers, pt Fidelity, as Laurence's alter ego,
intended to incur, or believed or reasonably should have believed it would incur debts beyond its
ability to pay as they became due.
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ED
COUNT VIII
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Avoidance and Recovery of Fraudulent Transfers Pursuant to Fla. Stat.§§ 726.106 and
726.108 against Stephanie
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121. At all times from in or around August 2016, First American was a creditor of pt
Fidelity, as Laurence's alter ego.

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MELAND I BUDWICK
125. 1st Fidelity did not receive reasonably equivalent value m exchange for the
transfers relating to the Lease made for Stephanie's benefit.
126. At the time 1st Fidelity made the Transfers, it was insolvent.
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COUNTIX
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Civil Conspiracy to Commit Fraudulent Transfer against Stephanie
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128. Stephanie and Laurence agreed and conspired to use 1st Fidelity to initiate and
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fund fraudulent transfers relating to the Lease, which is unlawful.

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129. Stephanie and Laurence caused pt Fidelity to fraudulently transfer not less than
$110,800 for Stephanie's benefit relating to the Lease.

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130. First American has been damaged as a result of Stephanie's acts performed
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pursuant to this conspiracy.

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judgment for damages in favor of First American and against Stephanie, together with pre-
judgment and post-judgment interest to the extent allowed under applicable law, and for any
other relief this Court deems just and appropriate.
21
MELAND I BUDWICK
COUNTX
Aiding and Abetting Fraudulent Tran sfer against Stephanie
132. pt Fidelity fraudulently transferred not less than $110,800 for Stephanie's benefit
relating to the Lease.
133. Stephanie had knowledge of the fraudulent transfers relating to the Lease.
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134. Stephanie provided substantial assistance to pt Fidelity and Laurence to advance
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the commission of the fraudulent transfers relating to the Lease.
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135. First American has been damaged as a result of Stephanie's aiding and abetting
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acts.
REMAINDER OF PAGE LEFT INTENTIONALLY BLANK

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MELAND I BUDWICK
judgment for damages in favor of First American and against Stephanie, together with pre-
judgment and post-judgment interest to the extent allowed under applicable law, and for any
other relief this Court deems just and appropriate.
Dated: April 15, 2022.
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Respectfully submitted,
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ls/Meaghan E. Murphy
Meaghan E. Murphy, Esquire
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ED
Alina A. Nowicki, Esquire
MELAND BUDWICK, P.A.
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3200 Southeast Financial Center
200 South Biscayne Boulevard
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Miami, Florida 33131

Telephone: (305) 358-6363
Facsimile: (305) 358-1221
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Co-Counsel for Plaintiff

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Email Designation per Fla. R. Jud.

Admin2.516
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mramos@melandbudwick.com
mrbstate@yahoo.com
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MELAND I BUDWICK
EXHIBIT A
Feb. 2021 Statement:
Deposits and Credits

Date Description Al,,o.in't
02-16 DomesbC Wire Recvci WIRE IN #OOE0707i BY FWR#OOCM54 ORG-= 50.000.00

1ST FIDEUTY LOAN SERVICING LLC
PY
02-17 Deposrt DEPOSIT 1i.61d.63
02-25 DomesbC Wire Recvci WIRE IN #0001 ~:,5 BY FWR#0021J 17 OR G-= 25.000 00
1ST FIDELrTY LOAN SERVICING LLC
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LAURENCE SCHNEIDER ":904 7177
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STEPHANIE SCHNEIDER
1199 S, t-l:.06.FW. HNY., SUITE~
BOCA RATON. Fl 33432
ML><)_
r,:,.;.,
ED
- c::z:::::::---
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C•:?117/2021 2 31 08 PM a33 00l0004 OBG42 5161 304473581 p33
-, •
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EXHIBITB
March 2021 Statement:
I 03-,~ Domestic Wire Re-cvd WiRE IN-010W3B1 BY FWR#00~-206 ORG=

!ST FIDELITY LOAN SERVICING LLC
:?5.000.00
L - -- - ■
PY
03-26 W!lhdrawal For purtnau at: C»h1er"s Checa 1t.500 OD
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EXHIBITC
March 2021 Statement:
I 03-29 Domestic Wire Recvci Wl RE IN ,iiQ 107Q861 BY FWRMli Ii OOR(;=

!ST FIOELfTY LOAN SERVICING UC
10000000
PY
I 03-30 Domesnc W1~ Sent WIRE OL!T-0085902_. BY FWR-'004186 BN~
USS FINANCW. SERVICES INC
94,300 00
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EXHIBITD
Sept. 2020 Statement:

WIRE IN -00858237 SY FWR#OO l ◄ TT ORG-
IST FIDELITY LOAN SERVICING UC JS
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EXHIBITE
LAURENCE SCHNEIDER LAURENCE SCHNEIDER

STEPHANIE SCHNEIDER STEPHANIE SCHNEIDER
1199S. FEDERALt,WY_. SUITE 369 1199S. FEDERALt,WY_, SUITE 369
BOCA RATON, FL. 33432 BOCA RATON, FL. 33432
NORTHERN TRUST Al'tCHOR ACCOUNT NORTHERN TRUST Al'tCHOR ACCOUNT
PY
12119'2019 3 43.42 PM B33 0000904 0EG46 5161 303284537 0 6
• 12119'2019 3 43.42 PM B33 0000904 0EG46 5161 303284537 0 6
•
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211~12019 3 ◄ 3.39 PM &33 OEG4L5 5161 303284:X7 C€i 211~12019 3 ◄ 3.39 PM &33 OEG4L5 5161 303284:X7 C€i
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LAURENCESCHNEIDEA --go~
..... 7030
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STEPHANIE SCHNEIDER >"l_/ f 10
;~~✓,;;:,i. , A;,~'~..
-~~t9-~~Ct«JAArmlM
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$ NORTHERN TRUST
J!,,lf>IO!r.~~ION!IIIJSTCO,Wl'ANf ~
.,..---~···
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•
091.2112020 2:11 59 PM BJJ. 0000304 08G42 5161 303263446 0 3-2
04/03/.2020 1.45.31 PM 833 0000004 0EG46 5161 303287160 0 15
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LAURENCE SCHNEIDER
STEPHANIE SCHIIEIDER LAURENCE SCHNEIDER
i,99 S, FEOEflALHWv .• SUllf 369 STEPHANIE SCHNEIDER
BOCA AJ\TON, fl ~ 1199 S FEDERAL HWY., SUITE 36'9
80CA RATON, FL 33432
$ NORTHERN TRUST
l~f ,r,.<tT,!f~'l 1~,l',1 {'.WM\1
07113,1020 1 20 45 F'M 83'.!. 0000904 0£G,i6 5161 303'2S37S1 0 2a

09121'2020 2-43:40 PM 633 0000903 0SH8-9 5154 302720821 0 41
PY
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$ NORTHERN TRUST
Tttr 'IC'Mltnll'I lfl:UST(OMP/l.tll1
ED
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5
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08'24/'2020 12.12.19 PM 833 OO0J904 0BG42 5161 303261534 0 30

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EXHIBITF
LAURENCE SCHNEIDER ~ 904 7128

STE?HANIE SCHNEIDER
11Q98. FEOEFIALHWY.,SIJITE 36'li' 7,,:{/2 r
90CA RATON, FL 33432
"'" -!/-1~--o::J..
■ OFIOEFI
P.VTOThCOf ~
c.__.s,r
,,,-,,,- - _ Ci.J. ' I $ t,),W~
Ek ( J ~ QQO,.ILRS
NOfffltEAN TRUST ANCHOR ACCOUNT
+-~-
,:;;--
PY
----------
071JIJ2021 2.24:44 Pt-J 833 l)()'.)0918 OSMD8 5214 303760786 0 23
07/02/2021 3 JS 24 PM 833 0000904 0BG42 5161 304470783 0 18
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•J?·-0112021 2' 2alll 17 PM83300009l8 l:SM08 0000 30~7':-07ll3 0 23
··-.·-,21
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,.
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EXHIBIT G
Jan.2016
Deposib and Credits

Date Amount
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12-14
12-15
12-2&
12-2';.
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01-04
01-04 PRVT PASSP
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Deposib and Credits
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Date Descrollon Amount
01-11 Deposit DEPOSIT e 504.50

01-20 Domestic Wn Recvd WIRE IN-0043153-4 BY FWR#000073 ORG= 100.000.00
1ST FIDELITY LOAN SERVICING LLC
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01-.:?!:, Domestic Wire Recvd WIRE IN ai0Da333g(J BY FWR#0000J ORG= 65000.00
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ER
May 2016 - June 2016

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~
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Pttc!liton Amount
0!:-10 Deposrt DEPOSIT 9713!¼1

Q:,-13, Domestic w,re: Re:cvd WlRE IN it00560i50 BY fWR#000402 ORG= 100000 00
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!ST FIDELITY LOAN SERVICING LLC

□ !:-1~ Phone Tmsfef Credit PRVT PASiORT TRF FROM •, I · 552 00
□ :--1~ Phone Tmsfer Cred,t PRVT PASS ORT TRF FROM•. • 5 021 00
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□ 6-02 Phone Tmsfer Credrt PRVT PASSPORT TRF FROM •,:n · 552.00
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July 2016
Deposit$ and Credits

Date Descrplion Amount
07-01
□ 7-01
Ptlone Tmsfet- Credrt
Ptx>ne Tmsfer Credrt
PRVT PASSPORT TRF
PRVT PASSPORT TRF
FROMr•~••.a1=•j
FROM:i•l•t.:;1~ 55200
20.000.00
Aug. 2016

D:E:w:Ptioo Amount
07-07 Domestic Wire Recvd WIRE IN -0Dm5:?7 BY FWR#0000..'"'3 ORG: 30 000.00
~Si FIDELITY LOAN SERVICING LLC
Phone Tmsfe( Credrt PRI/T PASSPORT TRF FROM •, 552 00
Phone Tmsfe( Credit PRVT PASSPORT TRF FROM•, • !i.0:?1.00
Phone Tmste,, C,edrt PRI/T PASSPORT TRF FROM •. • - 15.000.00
PY
Feb. 2017 - March 2017
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Qescr:pbon Amount
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ED
Phone Tmster Oedrt
~rt DEPOSIT
Phone Tmsfer Oedrt
Phone Tmsfer- Oedrt FR0~4•ti!!&•j
PRVT PASSPORT TRF FR0Mr;•'
PRVT PASSPORT TRF • 1
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July - Aug. 2017
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Dille Descrpbon Amount
07-07 ~it DEPOSIT 0674.00

07-tS Phone Tmsfef Credrt PRI/T PASSPORT TRF FROM •. 552.00
07-1S Phone Tmsfe( Credit PRI/T PASSPORT TRF FROM •• ~021.00
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07-:?4 Phone Tmsf@( Credit PRI/T PASSPORT TRF FROM •, I 7~ 000.00

07-31 ~rt DEPOSIT 1B0000.00
OS-01 ~it DEPOSIT 448.~
08--02 C~1 Transfer TWSFER FROM DEPOSIT ACCOUNT 17.000.00
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111
PRVT PASSPORT TRF FROM •• ••
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Descrption Amount
OS-!! C~1 Transfe< DEPOSIT 100000 00
OS--23
0S-2S
Phone Tmw Credit
Pr.one Tm5fer Credrt
PRI/T PASSPORT TRF FRm.,r•a••-er't
PRI/T PASSPORT TRF FR0~,4 •t :ij 30.000.00
t 000.00
□ S-30 Deposrt DEPOSIT 3!i.OOO.OO
Sept. - Oct. 2017

~ D:e:s9'.J)bon Amount
Ofa-1~ Deposit DEPOSIT 25 000.00

0~2S Pr.one Tm~ Credrt PRVT PASSPORT TRF FROM •• 552.00
0~25 Phone Tm5fer- ljedrt PRVT PASSPORT TRF FROM •, 13.000 00
10-04 Ptlooe Tmsfef Cl-edit PRVT PASSPORT TRF FROM •, • 50.00000
May - June 2018
PY
O
.
Dze 0!$fpbon Amount
0!-10 Phone Tmster c«-dit PRVT PASSPORT TRF FROM ..·~ •' 552 00
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0:,..10 Phone Tm!ifer Credrt PRVT PASSPORT TRF FROM - 552.00
0!-10 Phone Tmster Credrt PRVT PASSPORT TRF FROM •,::n- 55200
0!-11 Domestic Wire Re,r;yd WlRE IN -005170~ BY = 50 00000
ED
0!-30
Oo-01
Phone Tmsfer Cre-drt
Phone Tmsfe,- Credrt
PRVT PASSPORT TRF
PRVT PASSPORT TRF
FROMr:1••11=•1
FRo•41•t ft
15.000.00
552.00
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D3te Dejcfpbon Amount
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□6-20 Desx,sit DEPOSIJl_ 900.02

06-21 Phone Tmsfe( Credit PRVT PASSPORT TRF ~ 40.000.00
0~2.2 Domestic Wrre Recw WiRE IN -0052H!8'4 BY , = 35.000 00
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Oct. 2018
C

A
~ Descrption Amount
10-04 Pr.one Tmsfer Cl-edit PRVT PASSPORT TRF FROM •,:11• 7.50000
10-04 Phone Tmsf~ Credrt PRVT PAS.SPORT TRF FROM •, • · 10000.00
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10-04 Domestic Wire Recvd WIRE IN -0075742(1 BY 25.000 00

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Feb.2019
N

D.ate [)esgpbon Amount
□ 2-11 Phone Tmsfer Oe<lit PRVT PASSPORT TRF FROM xllU.K.X7411 4.275.55
02-11 Ptlorle Tmsfet Credrt PRVT PASSPORT TRF ~ 50.000.00
02-13 Domestic Wire Re,r;yd WIRE IN -000189!3 BY ... = 20 000.00
Nov. -Dec. 2019

Date Qescrption Amount
11-18 Phone Tmsfer Crecht PRVT PASSPORT TRF FROM •; 552.00

11-1 S Phone Tmsw Credrt PRVT PASSPORT TRF FROM •. 552.00
12-0.2 Phone Tmsfer Credrt PRVT PASSPORT TRF FROM •, • 552.00
Jan.2020
PY
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Otw:Pton Amount
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ED
Nov. 2020

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Phone Tmsfef' Credit

Phone Tmsfer Credit PRVT PASSPORT TRF F
Phone Tmsfef' Credit PRVT PASSPORT ~F FR
A
Phone Tmsfef' Credrt PRVT PASSPORT TRF FR

Phone Tmsfef" Credit PRVT PASSPORT TRF FR
T

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Phone Tmsfe( Credrt PRVTPASSPORTTRFF~OM~ •· •• 25.000.00

Phone Tmsfer Credrt PRVT PASSPORT TRF FROM ., • · • 05.000.00
Domestic Wire Recw WIRE IN -00985i55 BY - 25.000 00
March 2021

Descr;ption Amount
Domestic Wire Re-cvd WiRE IN -010Q7361 BY FWR#00!:,20!\ ORG= :!5.0D0.00

tST FIDELITY LOAN SERVICING LLC
Phone Tmsfef Credit PRVT PASSPORT TRF FROM •, •• 1!i 000 00
Phone Tmsfef O'edit PRVT PASSPORT TRF FROM "· I - 7g_ooooo
Domestic Wire Re-cvd WlRE IN -0107~801 BY = 100.000 00
PY
Sept. - Oct. 2021
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P!SC!Ption Amount
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Phone Tmsfef 0-edit PRVT PASSPORT TRF FROM •, 48 750.00
Phone Tmsfer O'edit PRVT PASSPORT TRF FROM •, 10_000.00
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Date Desctytion Amount
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10-07
10-13
Phone Tmsfef Credit
Phone Tmsfef O'edit
PRVT PASSPORT TRF FROMr-1••
PRVT PASSPORT TRF FROU £·
ia1=•i
•t :t 2!5.000.00
25.000.00
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962 First American First Amended Restraining Order Injunction 149010261

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962 First American First Amended Restraining Order Injunction 149010261

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Filing# 149010261 E-Filed 05/05/2022 11:02:29 AM

IN THE CIRCUIT COURT OF THE 15TH

CIRCUIT CIVIL DIVISION: AH

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

FIRST AMERICAN BANK, as successor

LAURENCE S. SCHNEIDER, STEPHANIE

PARTNERS, INC., REAL ESTATE

FIRST AMERICAN BANK'S FIRST AMENDED MOTION FOR TEMPORARY

RESTRAINING ORDER AND PRELIMINARY INJUNCTION

American states as follows:

copy of the Complaint is attached as Exhibit B.

various misrepresentations and engaged in various machinations to conceal Laurence's true

directly paid Stephanie's personal legal fees.

obtain a TRO and preliminary injunction.

A. First American has a substantial likelihood of success on the merits.

meetings, or operated from independent office space in determining whether a shareholder

truthfully disclose his income and assets alone speaks volumes.

There is immense commingling occurring among the accounts controlled by Laurence.

request for a preliminary injunction.

such, the balance of equities certainly weighs in favor of First American.

S&A and REF for illegitimate purposes.

Request for Preliminary Injunction

First American requests a hearing on a preliminary injunction as soon as practical to

(a) Immediately, temporarily and preliminarily enJommg Laurence Schneider,

Email Designation per Fla. R. Jud.

CIRCUIT CIVIL DIVISION: AH

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

FIRST AMERICAN BANK, as successor

LAURENCE S. SCHNEIDER, STEPHANIE

PARTNERS, INC., REAL ESTATE

DECLARATION OF NEAL LEVIN IN SUPPORT OF FIRST AMERICAN

1. I am an attorney at Freeborn & Peters LLP ("Freeborn") and am counsel to First

Inc. ("REF'), Brad Axel ("Brad'') and Paige Axel ("Paige"). 1

costs and fees, almost all of which remains unsatisfied. 2

information provided to me from First American, post-judgment discovery conducted by First

Permanent Injunctive Relief (the "Supplemental Complaint').

payment on the Judgment.

Laurence and Stephanie together are the "Schneiders".

misrepresentations and engaged in numerous machinations in an effort to conceal Laurence's

true worth and assets.

7. Based on First American's investigations and post-judgment discovery, over the

9. Based on First American's investigations and post-judgment discovery, I believe

president and registered agent.

10. Based on First American's investigations and post-judgment discovery, I believe

11. Based on First American's investigations and post-judgment discovery, I believe

#410 is inactive or expired.

judgment discovery that First American is clearly entitled to.

evidence of Laurence's incestuous financial relationship with entities he controls, commingling

demonstrating Laurence's intent to frustrate creditors.

Commingling of Entity and Family Funds

discover various facts evidencing Laurence's gamesmanship and incestuous financial

or in predictable amounts as would be expected for transfers related to employment - instead,

Exhibit B to the Supplemental Complaint.

Ms. Figueras another $5,000 relating to the Lease.

totaling approximately $116,000 for which he provided no value.

period, REF transferred the Schneiders approximately $398,361.

excess of $200,000 directly to Stephanie's attorneys, further evidencing commingling.

Suspicious Financial Activities

the Supplemental Complaint.

are from S&A and/or REF.

the same day as a $552 transfer. 3

another of the unknown transferors is REF.

36. In response to a writ of garnishment relating to Laurence, Northern Trust froze

ownership and control over the funds in those accounts.