Filing # 158160988 E-Filed 09/26/2022 08:18:47 PM

IN THE CIRCUIT COURT OF THE 15TH

JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA

CIRCUIT CIVIL DIVISION: AH

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

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

Plaintiff,

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vs.

LAURENCE S. SCHNEIDER,

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STEPHANIE L. SCHNEIDER, et al.,

Defendants.
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AMENDED1 NOTICE OF TAKING VIDEO-CONFERENCE DEPOSITION
DUCES TECUM
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PLEASE TAKE NOTICE that pursuant to Florida Rule of Civil Procedure 1.310, the
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undersigned will take the depositions of the below-named persons on the dates and times indicated

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below:
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Name Date and Time Place

Corporate September 30, 2022 Via Veritext Zoom Videoconference
Representative at 2:00 p.m.
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of Singer https://proceedings.veritext.com/?token=ff77ab4222
Wealth 044615ea60941e11e18b86
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Advisors, LLC Meeting ID: 84914504408

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Password: NA82pIh43D
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Regarding the matters described in Schedule A. The depositions will be taken upon oral
examination before a court reporter Veritext Court Reporter, Notary Public, in and for the State of
Florida at Large, or some other officer duly authorized by law to take depositions. These
depositions are being taken for discovery, use at trial, or any other purpose permitted under the
Rules of Civil Procedure and Rules of Evidence. The depositions will continue from hour to hour
and from day to day until completed.

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

*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 09/26/2022 08:18:47 PM ***
NOTICE IS FURTHER GIVEN that we reserve the right to conduct these depositions utilizing the
secure web-based deposition option afforded by Veritext or in the alternative video
teleconferencing (VTC) services offered by Veritext (“Web Deposition”) or telephonically only to
provide remote access for those parties wishing to participate in the depositions via the internet
and/or telephone. Also take notice that, the court reporter may also be remote via one of the options
above for the purposes of reporting the proceeding and may or may not be in the presence of the
deponents. Please contact the noticing attorney at least five (5) calendar days prior to the
depositions so that the necessary credentials, call-in numbers, testing and information, if
necessary, can be provided to you prior to the proceedings. In addition, we also reserve the
right to utilize instant visual display technology such that the court reporter’s writing of the

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proceeding will be displayed simultaneous to their writing of same on one’s laptop, iPad, tablet or
other type of display device connected to the court reporter.

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In accordance with the Americans with Disabilities Act of 1990, persons needing a special
accommodation to participate in this proceeding should contact Meaghan E. Murphy, Esquire
at Meland Budwick, P.A. telephone number (305) 358-6363, no later than seven (7) days prior
to the proceeding. If hearing impaired, telephone Florida Relay Service at 1-800-955-8771 for

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

I CERTIFY that the foregoing document has been furnished to all registered users via the
Florida Courts e-Filing Portal on September 26, 2022.

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

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

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

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Email Designation per Fla. R. Jud.
Admin 2.516
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mmurphy@melandbudwick.com
mramos@melandbudwick.com
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mrbstate@yahoo.com
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BUDWICK
MELAND I| BUDWICK
MELAND
3200 SOUTHEAST
3200 FINANCIAL CENTER
SOUTHEAST FINANCIAL 200 SOUTH
CENTER I| 200 SOUTH BISCAYNE BOULEVARD I| MIAMI, FL
BISCAYNE BOULEVARD FL 33131 | T 305-358-6363
33131 IT 305-358-6363
 SCHEDULE A

INSTRUCTIONS

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

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

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

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

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

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

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

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(3) If any of the documents encompassed by the attached request for production of
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documents are deemed by you to be privileged, furnish all non-privileged documents and provide
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a log outlining all documents claimed as privileged that includes: (a) the type of privilege claimed
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for each document; (b) a brief description of the document; (c) the author of the document

sufficient to identify it; (d) the recipient(s) (if any); and (e) the date of the document.
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(4) When appropriate, the singular form of a word should be interpreted in the plural

as may be necessary to bring within the scope hereof any documents which might otherwise be
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construed to be outside the scope hereof.

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(5) Electronically stored information must be produced in a manner as not to alter the
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document or any metadata associated with that document.

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

created since January 1, 2016.

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 DEFINITIONS

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

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

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

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

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

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might otherwise be construed to be outside of its scope.

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

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

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and further includes all originals, nonidentical copies, and drafts of the following items, whether
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printed, handwritten, typed, recorded, or stored on any computer or electro-magnetic storage
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device, or reproduced by hand, and whether or not claimed to be privileged or otherwise excludable
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from discovery, including without limitation: correspondence, Communications, e-mails, text

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

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

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

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

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

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telexes, books, notes, reports, logs, tape recordings, computer files, video cassettes, data
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compilations from which information can be obtained, charts, photographs, notebooks, drawings,

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

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

description.

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

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

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

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

all Persons acting on your behalf or under your control.

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

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

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

representative, contractor, sub-contractor and attorney.

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G. “Laurence Schneider” shall mean Laurence S. Schneider and all Persons acting on
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his behalf or under his control. Laurence Schneider’s identifying information is as follows: (a)
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date of birth: September 18, 1968; and (b) last known address: 2000 Island Blvd., Unit 2001,
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Aventura, FL 33160. Additional identifying information may be provided upon request.

H. “Jordyn Schneider” shall mean Jordyn A. Schneider and all Persons acting on her
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behalf or under her control. Jordyn Schneider’s identifying information is as follows: (a) date of

birth: March 29, 1998; and (b) last known address: 2000 Island Blvd., Unit 2001, Aventura, FL
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33160. Additional identifying information may be provided upon request.

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I. “Zachary Schneider” shall mean Zachary A. Schneider and all Persons acting on
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his behalf or under his control. Zachary Schneider’s identifying information is as follows: (a) date
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of birth: February 2001; and (b) last known address: 2000 Island Blvd., Unit 2001, Aventura, FL

33160. Additional identifying information may be provided upon request.

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

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

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

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

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

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 DOCUMENTS TO BE PRODUCED

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

to produce the following Documents:

1. Your entire file relating to Laurence Schneider.

2. Your communications with Laurence Schneider.

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

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4. Your entire file relating to Stephanie Schneider.

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5. Your communications with Stephanie Schneider.

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

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7. Your entire file relating to Jordyn Schneider.

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Your communications with Jordyn Schneider.
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9. Your communications with any other person relating to Jordyn Schneider.
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10. Your entire file relating to Zachary Schneider.

11. Your communications with Zachary Schneider.

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

13. Your entire file relating to 1st Fidelity Loan Servicing, LLC.
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14. Your communications with 1st Fidelity Loan Servicing, LLC.

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15. Your communications with any other person relating to 1st Fidelity Loan Servicing,
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LLC.
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16. Your entire file relating to S&A Capital Partners, Inc.

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

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

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

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

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

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