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FW: Service of Court Document - Case Number 502016CA009292XXXXMB

The document is a motion to strike the defendants' objection to an October 2, 2017 hearing and provides notice of unauthorized practice of law. It argues that Brent Tantillo, a lawyer licensed in DC but not Florida, drafted the defendants' objection and has been advising and representing the defendants in the case in violation of Florida bar rules prohibiting unauthorized practice of law. The motion requests that the defendants' objection be stricken and that Tantillo be ordered to cease unauthorized practice in the case.

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0% found this document useful (0 votes)
100 views

FW: Service of Court Document - Case Number 502016CA009292XXXXMB

The document is a motion to strike the defendants' objection to an October 2, 2017 hearing and provides notice of unauthorized practice of law. It argues that Brent Tantillo, a lawyer licensed in DC but not Florida, drafted the defendants' objection and has been advising and representing the defendants in the case in violation of Florida bar rules prohibiting unauthorized practice of law. The motion requests that the defendants' objection be stricken and that Tantillo be ordered to cease unauthorized practice in the case.

Uploaded by

lschneider68
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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 Reply all |  Delete Junk |  

FW: SERVICE OF COURT DOCUMENT - CASE NUMBER


502016CA009292XXXXMB

Larry Schneider Reply all | 


 Fri 9/29/2017, 3:24 PM
Brent Tantillo (btantillo@tantillolaw.com); Ajit Narasimhan <aj@tantillolaw.com> 

Sent Items

Motion To Strike.pdf
6 MB

Show all 1 attachments (6 MB) Download

Here is Bolz again.  He is coming after all of us now.   We need to file a new federal case, including RICO and naming
Bolz and Keller & Bolz as Defendants along with FAB.  Motion for a TRO.
 
From: eservice@myflcourtaccess.com [mailto:eservice@myflcourtaccess.com]

Sent: Friday, September 29, 2017 3:17 PM

Subject: SERVICE OF COURT DOCUMENT - CASE NUMBER 502016CA009292XXXXMB


 

Notice of Service of Court Documents

Filing Information

Filing #: 62208103
Filing Time: 09/29/2017 03:16:17 PM ET
Filer: Henry H Bolz III 305-529-8500
Court: Fifteenth Judicial Circuit in and for Palm Beach County, Florida
Case #: 502016CA009292XXXXMB
Court Case #: 50-2016-CA-009292-XXXX-MB
Case Style: FIRST AMERICAN BANK - SCHNEIDER, LAURENCE S

Documents

Title File
M2 Strike 09-29-17.pdf

Motion To Strike

E-service recipients selected for service:


Name Email Address
 Reply all |  Delete Junk |  
Henry H Bolz III hbolz@kellerbolz.com
ahart@kellerbolz.com
Laurence and Stephanie Schneider larry@sacapitalpartners.com
Jay Samuel Levin jlevin@ssclawfirm.com
foreclosures@ssclawfirm.com
jaylevin.esq@gmail.com
Brent Tantillo BTantillo@walkerdimarcopc.com
Larry Schneider larry@sacapitalpartners.com
Brent Tantillo btantillo@tantillolaw.com
lwills@tantillolaw.com
Stephanie L Schneider steffschneider13@gmail.com

E-service recipients deselected for service:

Name Email Address


Kenneth E Trent trentlawoffice@yahoo.com
Stuart S. Mermelstein smermelstein@hermanlaw.com
mconnor@hermanlaw.com

This is an automatic email message generated by the Florida Courts E-Filing Portal.
This email address does not receive email.

Thank you,

The Florida Courts E-Filing Portal

request_id#:62208103;Audit#:211921273;UCN#:502016CA009292XXXXMB;
Filing# 62208103 E-Filed 09/29/2017 03:16:17 PM

IN THE CIRCUIT COURT OF


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

CASE NO.: 502016-CA-009292

DIVISION AW

FIRST AMERICAN BANK, as

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successor by merger to Bank of
Coral Gables, LLC,

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Plaintiff,

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V.

LAURENCE S. SCHNEIDER,

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STEPHANIE L. SCHNEIDER, et al.,

Defendants.
______________/
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MOTION TO STRIKE DEFENDANTS' OBJECTION
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AND NOTICE OF UNAUTHORIZED PRACTICE OF LAW

COMES NOW the Plaintiff, FIRST AMERICAN BANK, by and through its
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undersigned counsel, and in accordance with the applicable Florida Rules of Civil
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Procedure and R. Regulating Fla. Bar 4-5.5, hereby files this its Motion to Strike
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Defendants' Objection to October 2, 2017 Hearing (bearing a Certificate of Service date

of September 28, 2017) and Notice of Unauthorized Practice of Law.


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Since May 1, 2017, the Defendants have ostensibly been representing themselves
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in this matter on a pro se basis. Neither LAURENCE SCHNEIDER nor STEPHANIE


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SCH N El DER is an attorney admitted to The Florida Bar and, accordingly, neither of them

can represent the other.

FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 09/29/2017 03:16:17 PM
On September 28, 2017, Defendants, LAURENCE SCHNEIDER and STEPHANIE

SCHNEIDER ("Defendants"), purportedly prepared and filed Defendants' Objection to

October 2, 2017 Hearing ("Objection"). A copy of Defendants' Objection is attached

hereto as Exhibit "1." Upon close examination, however, it quickly becomes obvious that

Exhibit "B" attached to the Objection contains a September 28, 2017 (8:15 a.m.) email

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from Defendant, LAURENCE SCHNEIDER to Brent Tantillo of "Tantillo Law," 1 wherein

the Defendant directs Brent Tantillo to: "We need to postpone this" - the October 2, 2017

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scheduled hearing. A copy of Defendant, LAURENCE SCHNEIDER, email to Brent

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Tantillo is attached hereto as Exhibit "B" to Exhibit "1."

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Brent Tantillo, is an attorney licensed to practice in the District of Columbia. 2 Brent

Tantillo is not a member of the Florida Bar nor is he authorized to practice law in this case
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by virtue of an order allowing him to appear pro hac vice or otherwise. Respectfully,
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Plaintiff would suggest that Defendants' Objection (a somewhat polished legal document)
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which was filed just 7 hours and 12 minutes after Defendant's, LAURENCE SCHNEIDER,

email directing Brent Tantillo to "postpone" FIRST AMERICAN's October 2, 2017 hearing
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(Exhibit "1 ") was drafted by Brent Tantillo (or some other lawyer at "Tantillo Law"), not by
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the Defendants.
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Tantillo Law operates out of an office in Florida, to wit:


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Tantillo Law, PLLC


6810 N State Road 7, Suite 300
Coconut Creek, FL 33073

2 On September 26, 2017, Defendants (Appellants in the pending appeal to the 4 th DCA) purportedly
prepared and filed a Motion for Extension of Time to File Initial Brief, which was not signed by either
Defendant. Rather, it was signed by "Brent Tantillo for" the Defendants. A copy of Defendants' Motion for
Extension of Time to File Initial Brief is attached hereto as Exhibit "2." Plaintiff's Response/Objection to
Defendants' Motion for Extension of Time to File Initial Brief is attached hereto as Exhibit "3."

Page 2 of 4
In this same regard, FIRST AMERICAN would further advise this Court that on

September 1, 2017, Brent Tantillo not only attended the hearing on Defendants

Emergency Request for Temporary Restraining Order (bearing a Certificate of Service

date of August 7, 2017), which this Court is treating as a Motion for Stay of for the

Foreclosure Sale Pending Appeal, but also consulted with and instructed the Defendants

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during the hearing.

Shortly stated, Brent Tantillo, either as an individual or as a District of Columbia

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attorney, by preparing Defendants' Objection, consulting with the Defendants during the

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September 1, 2017 hearing and signing Defendant's Motion for Extension of Time to File

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Initial Brief, has done so in knowing and intentional violation of the Rules Regulating The

Florida Bar. Specifically, Brent Tantillo is engaging in the unauthorized practice of law on
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behalf of the Defendants. See R. Regulating Fla. Bar 4-5.5.
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WHEREFORE, FIRST AMERICAN BANK requests that Defendants' Objection to


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October 2, 2017 Hearing be stricken from the record and that Brent Tantillo be directed

by this Court to cease and desist from the unlicensed practice of law in this litigation,
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together with such further and other relief as the Court deems just and appropriate under
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the circumstances.
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Page 3 of 4
Respectfully submitted,

KELLER & BOLZ, LLP


Attorneys for Plaintiff
121 Majorca Avenue, #200
Coral Gables, FL 33134
Telephone: (305) 529-8500
Telefax: (305) 529-0228

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Email: hbolz@kellerbolz.com

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By: s/ Henry H. Bolz. Ill

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Henry H. Bolz, Ill
Florida Bar No. 260071

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CERTIFICATE OF SERVICE
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WE HEREBY CERTIFY that a true and correct copy of the foregoing, Motion to

Strike Defendants' Objection and Notice of Unauthorized Practice of Law, was delivered
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to: LAURENCE S. SCHNEIDER, (larry@sacapitalpartners.com), 360 E. Coconut Palm


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Road, Boca Raton, FL 33432; STEPHANIE L. SCHNEIDER

(steffschneider13@gmail.com), 360 E. Coconut Palm Road, Boca Raton, FL 33432; and


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JAYS. LEVIN, ESQ.(foreclosures@ssclawfirm.com), Sachs, Sax, Caplan, Attorneys for


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Oaks at Boca Raton, 6111 Broken Sound Parkway, N.W., #200, Boca Raton, FL 33487
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via the E-filing Portal on this 29th day of September, 2017.


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KELLER & BOLZ, LLP

By: s/ Henry H. Bolz. Ill


Henry H. Bolz, Ill

Page 4 of 4
Filing# 62147415 E-Filed 09/28/2017 03:27:28 PM

IN THE CIRCUIT COURT OF


THE FIFTEENTH JUDICIALCIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA

FIRST AMERICAN BANK, as Case No.: 50-2016-CA-009292


successor by merger to Bank of Coral
Gables, LLC,

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Plaintiff

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Vs.

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LAURENCE SCHNEIDER, STEPHANIE L.
SCHNEIDER, et. Al.

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Defendants FI
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DEFENDANTS' OBJECTION TO OCTOBER 2, 2017 HEARING


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COME NOW Laurence Schneider and Stephanie L Schneider ("Defendants"), and

pursuarit to an Order issued by this Court on September 27, 2017 on Defendants' emergency
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motion to extend the injunction which was cancelled due to Hurricane Irma, and pursuant to an
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email sent by counsel for Plaintiff First American Bank ("FAB") setting an arbitrary date without
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Defendants' consent, hereby opposes FAB's hearing request as follows:


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In the September 27, 2017 Order [See attached Exhibit A], this Court stated unequivocally
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that, "ORDERED that the parties shall coordinate a hearing in the newly assigned Division

AH ... It is further ORDERED that a sale date shall not occur prior to the hearing."

[ExhibitA- Order].

Exhibit "1"
On September 28, 2017, counsel for FAB sentDefendants the following email [See

attached Exhibit B]:

"As you are both aware, the referenced Foreclosure Litigation was transferred to

Judge Lisa Small on September 19, 2017. Since that transfer, our office has been

attempting to obtain hearing dates from Judge Small's office with respect.to (1) FAB's

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Motion to Reset Foreclosure Sale and (2) your Motions to Reset Hearing on

Injunction (regarding Schneider's Motion to Stay the Foreclosure Sale Pending

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AppeaUthe establishment of a Supersedcas Bond). It is developing, however, that both

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motion calendar and special-set hearings can be difficult to obtain in front of Judge

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Small on short notice; we are currently advised thather earliest available hearing

date (of any type) are motion calendars at 8:45 a.m. on October 16, 18 and 19, 2017.
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Unfortunately, Acting Chief Judge Peter Blanc's Administrative Order dated
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September 14,2017 (copy attached for ease of reference), requires FAB's Motion to
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Reset Foreclosure Sale to rescheduled within 30 days from that Administrative Order.

Accordingly, FAB does not have the luxury of waiting until the week of October 16,
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2017 to reschedule the Foreclosure Sale. Laurence Schneider's emails makeit clear
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that he remains available to attend the motion calendar hearing we obtained in front
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ofJudge Small at 8:45 a.m. on Monday, October 2, 2017." [Exhibit B- Email]


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Defendants dispute this one".'sided meet and confer on the hearing date, and atno time did
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either Defendant indicate to FAB the willingness to attend a hearing set by FAB.

To be clear, the September 27, 2017 Order_ indicated that the parties "shall coordinate a

hearing";

2
However, FAB has arbitrarily picked and chosena hearing date on the Hon.Judge Small's

calendar, in total ignorance of this Court's order and without Defendants' consent.

Defendants are not able to attend the. FAB set October 2, 2017 hearing, and have indicated

as much to FAB andits counsel of record.

While FAB grudgingly notes that October 16, 18 and 19,2017 are available for a hearing

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on the matter, Defendants request one of those three days to conductthe hearing on extending the

injunction in place and to determine what, if any, supersedes bond would be required to continue

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•said injunction.

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As Defendants are the moving party on the motion, it is only proper that Defendants be

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afforded the right to set a hearing date conducive with their respective schedules, and not be

pigeonholed into agreeing to any arbitrary date FAB desires to set.


FI
PlaintiffFAB will not suffer any prejudice or hindrance to their case by having the hearing
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on a mutually amicable date, as Ordered by this Court.


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As such, Defendants object to the October 2, 2017 hearing date set by FAB without [Bold

Emphasis Added] Defendants' consideration or agreement, and respectfully request this Court set
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the hearing on either October 16, 18 or 19,2017, in accordance with Hon. Judge Small's
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calendar.
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WHEREFORE, For the above and foregoing reasons, Defendants respectfully object to
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the arbitrary October 2, 2017 hearing date set by FAB, request that the matter be heard on either
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October 16, 18 or 19, 2017, and any such other relief as maybe afforded at this time

3
Respectfully Submitted,

Date: September 28, 2017


Boca Raton, FL
......

LAURENCE S. SCHNEIDER, Pro Se


360 E. COCONUT PALM DRIVE
BOCA RATON, FL 33432
larrv(@.sacapitalpartners.com

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O
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STEPHANIE L. SCHNEIDER, Pro Se

ED
360 E. COCONUT PALM DRIVE
BOCA RATON, FL 33432
larry@sacapitalpartncrs.com.
FI
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ER

CERTIFICATE OF SERVICE
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I hereby certify that a copy hereof has been furnished to Henry H. Bolz III, 121 Majorca

Ave. #200. Coral Gables, FL 33134, by mail this 28th day of September 2017.
A
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Laurence Schneider, pro se


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4
Filing# 62156028 E-Filed 09/28/2017 04:29:05 PM

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT


IN AND FOR PALM BEACH COUNTY, FLORIDA

CIRCUIT CIVIL DIVISION AW


CASE NO. 502016CA009292XXXXMB
FIRST AMERICAN BANK
v.
LA \VRENCE J. SCHNEIDER, ET AL,

_________ _____________;/
Defendant(s).

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ORDER ON DEFENDANT'S EMERGENCY REQUEST FOR TEMPORARY
RESTRAINING ORDER/MOTION FOR ST AY PENDING APPEAL

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THIS MATTER came before the court sua sponte pursuant to the cancellation of the

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hearing scheduled for September 8, 2017 because of hurricane Irma. Inasmuch as this case has

ED
been reassigned to Division AH and the hearing involves the issues of whether the case should

be stayed pending appellate review and whether bond or other conditions should be set (see
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attached order), it is
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ORDERED that the parties shall coordinate a hearing in the newly assigned Division AH.
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It is further
ORDERED that a sale date shall not occur prior to the hearing.
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DONE AND ORDERED in West Palm Beach, Palm Beach County, Florida, this

ia~ho-
A

!11 dayof ,2017.


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O

Susan Lubitz Q
Senior .Judge
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Page 1 of 2

Exhibit "A"
Copies furnished to:

HENRY H. BOLZ
121 MAJORCA AVE., STE 200
CORAL GABLES, FL 33134

JAYS. LEVIN
6111 BROKEN SOUND PKWY NW, STE
#200

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BOCA RATON, FL 33487

LAURENCE S. SCHNEIDER

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360 EAST COCONUT PALM ROAD
BOCA RATON, FL 33432

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STEPHANIE L. SCHNEIDER

ED
360 EAST COCONUT PALM ROAD
BOCA RA TON, FL 33432
FI
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ER
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A
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Page 2 of2
Filing# 60089250 E-Filed 08/08/2017 10:14:51 AM

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT


IN AND FOR PALM BEACH COUNTY, FLORIDA

FORECLOSURE DMSION AW
CASE NO. 50-2016-CA-009292-XXXX-MB
FIRST AMERICAN BANK,
Plaintiff/Petitioner
vs.
LAURENCE S SCHNEIDER,
STEPHANIE L. SCHNEIDER,

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JEFFREY MARC HERMAN,
et al.,
Defendant/Respondents.

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- - - - - - - - - - - - - - - -I

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ORDER ON DEFENDANT SCHNEIDER'S MOTION FOR STAY OF
FORECLOSURE SALE PENDING APPEAL

ED
THIS MATTER came before the Court on Prose Defendant's Laurence and Stephanie L

Schneider's " Emergency Request for a Temporary Restraining Order." The Court will treat this
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as a Motion for Stay of the Foreclosures Sale, pending the appeal filed by the Defendant in
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which they seek an appellate review of the Amended Final Judgment entered on June 30, 2017.

At present, the foreclosure sale of the Defendant real property is scheduled for August
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10, 2017. That sale is cancelled and reset for Sept 12, 2017 at 10:00am at

www.mypalmbeachclerk.clerlamctioncom
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Prior to that date on Friday, September I, 2017 at 1:30 pm(l hour reserved) in Courtroom
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IOA, the Court will conduct a hearing on Defendant's Motion to Stay the Foreclosure Sales. At

that time the Court will hear arguments as to whether the action should be stayed pending
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appellate review. If so, the Court will take evidence as to whether the stay should be
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conditioned on the posting of a good and sufficient bond, or other conditions , and what the
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amcnmt of that bond should be.

Page 1 of 2

FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 08/08/2017 10:14:51 AM
Case No.50-2016-CA-009292-XXXX-:MB

DONE AND ORDERED, in West Palm Beach, Palm Beach County, Florida this 8th day
of August, 2017.

so-2o·rn~cA-oil!i292.xxxx-MB oaioalio·11
James T. Ferrara
Clrcult Judge

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COPIES TO:

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HENRY H. BOLZ 121 MAJORCA AVE HBOLZ@KELLERBOLZ.CO

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SUITE200 M
CORAL GABLES, FL 33134 ahart@kellerbolz.com
JAYS.LEVIN 6111 BROKEN SOUND Jlevin@ssclawfinncom

ED
PKWYNW foreclosures@ssclawfinncom
#200 jaylevin.esq@gmail.com
BOCA RATON, FL 33487
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LAURENCE S. SCHNEIDER 360 EAST COCONUT PALM LARRY@SACAPITALP ART
ROAD NERS.COM
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BOCA RATON, FL 33432


STEPHANIE L. 360 EAST COCONUT PALM LARRY@SACAPITALPART
SCHNEIDER ROAD NERS.COM
ER

BOCA RATON, FL 33432


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A
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Page 2 of2
Filing# 62156028 E-Filed 09/28/2017 04:29:05 PM

Ajit Narasimhan <aj@tantillolaw.com>

Fwd: First American Bank v. Schneider - Foreclosure Litigation


1 message

Larry Schneider <larry@sacapitalpartners.com> Thu, Sep 28, 2017 at 8: 15 AM


To: Brent Tantillo <btantillo@tantillolaw.com>, "aj@tantillolaw.com" <aj@tantillolaw.com>

We need to postpone this.

Sent from my iPhone

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Begin forwarded message:

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From: "Henry Bolz" <hbolz@kellerbolz.com>
To: "Larry Schneider" <larry@sacapitalpartners.com>, "Stephanie Schneider
(steffschneider13@gmail.com)" <steffschneider13@gmail.com>

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Cc: "Jay Levin Esq. (foreclosures@ssclawfirm.com)" <foreclosures@ssclawfirm.com>, "Jay Levin, Esq."
<jlevin@ssclawfirm.com>

ED
Subject: First American Bank v. Schneider - Foreclosure Litigation

As you are both aware, the referenced Foreclosure Litigation was transferred to Judge
FI
Lisa Small on September 19, 2017 Since that transfer, our office has been attempting to
obtain hearing dates from Judge Small's office with respect to (1) FAB's Motion to Reset
Foreclosure Sale and (2) your Motions to Reset Hearing on Injunction (regarding
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Schneider's Motion to Stay the Foreclosure Sale Pending Appeal/the establishment of a


Supersedeas Bond)
ER

It is developing, however, that both motion calendar and special set hearings can be
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difficult to obtain in front of Judge Small on short notice; we are currently advised that her
earliest available hearing date (of any type) are motion calendars at 8:45 a.m. on October
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16, 18 and 19, 2017.


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Unfortunately, Acting Chief Judge Peter Blanc's Administrative Order dated September
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14, 2017 (copy attached for ease of reference), requires FAB's Motion to Reset
Foreclosure Sale to rescheduled within 30 days from that Administrative Order.
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Accordingly, FAB does not have the luxury of waiting until the week of October 16, 2017 to
reschedule the Foreclosure Sale.

Laurence Schneider's emails make it clear that he remains available to attend the motion
calendar hearing we obtained in front of Judge Small at 8 45 am on Monday, October 2,
2017. Moreover, those emails also make it clear that Stephanie Schneider will retain legal
counsel this week; whatever attorney she might retain can attend Monday's hearing on her
behalf.

Exhibit "B"
We take this opportunity to advise you that the undersigned will be attending Judge
Small's Motion Calendar at 8:45 a.m. on Monday, October 2, 2017, at which time FAB's
Motion to Reset Foreclosure Sale is scheduled. In addition, as per the attached Re-
Notice, we are going to ask Judge Small to specially-set a one-hour evidentiary hearing on
your Motions to Stay the Foreclosure Sale Pending Appeal/establish Supersedeas Bond.

Be advised that we have no intention of arguing any substantive Motions or positions at


Monday's hearing. The hearing is ministerial in nature, it is designed only to obtain
hearing dates from Judge Small on the two Motions referenced above and neither Motion
requires any significant preparation.

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While I hope to see one or both of you (or your respective attorneys) on Monday, October
2, 2017, at 8:45 a.m., be advised that I will be appearing before Judge Small at that

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time/date.

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Regards,

HENRY H. BOLZ. III


ED
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KELLER & BOLZ, LLP
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121 MAJORCA A VENUE. #200


ER

CORAL GABLES, FL 33134


TELEPHONE: (305) 529-8500
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TELEFAX: (305) 529-0228


E-MAIL: HBOLZ@KELLERBOLZ.COM
A
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IMPORTANT: THIS E-MAIL. AND ANY ATTACHMENTS THERETO. IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY
TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS LEGALLY PRIVILEGED. CONFIDENTIAL AND
EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. IF THE READER OF THIS E-MAIL IS NOT THE INTENDED RECIPIENT,
OR THE EMPLOYEE OR AGENT RESPONSIBLE FOR DELIVERING THE E-MAIL TO THE INTENDED RECIPIENT, YOU ARE
HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY
PROHIBITED. IF YOU HAVE RECEIVED THIS E-MAIL IN ERROR, PLEASE IMMEDIATELY NOTIFY THE SENDER BY E-MAIL OR
TELEPHONE (IF CONTACT INFORMATION IS PROVIDED)AND PERMANENTLY DELETE THE ORIGINAL OR ANY PRINTOUT
THEREOF.

4 attachments

~ Admin Order 2017-12.704.pdf


944K
@ ATT00001.htm
1K

~ 2017-09-28 NOH - M2 Reset Sale and lnjuction Hrg.pdf


11K

@ ATT00002.htm
1K

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IN THE COURT OF APPEALS OF THE
STATE OF FLORIDA-FOURTH
DISTRICT

LAURENCE SCHNEIDER, STEPHANIE L. SCHNEIDER.,


Defendants- Appellants,

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V.
FIRST AMERICAN BANK

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Plaintiff- Appellee

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Appeal from the Fifteenth Judicial Circuit in and for Palm Beach County

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Case No. 50-2016-CA-009292
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MOTION FOR EXTENSION OF TIME TO FILE INITIAL BRIEF
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ER

LAURENCE SCHNEIDER, STEPHANIE L. SCHNEIDER, Pro Se


360 E. COCONUT PALM DRIVE
BOCA RATON, FL 33432
Iarry@sacapitalpartners.com
C
A
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e_
L.:•.: •
(,..,.:,
......

Exhibit "2"
COMES NOW Appellants in Pro Per Laurence Schneider and Stephanie L Schneider,

and hereby files this Motion for Extension of Time to File Initial Brief and in support thereof

states:

1. The issues in this case are complex, and ongoing at the state level- post judgment.

2. Additional time is necessary to prepare a Brief.

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3. The Appellants request additional time in which to file the Initial Brief, so that the Initial

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Brief shall be due on or before October 25, 2017.

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4. There will be no prejudice to Appellee in granting this request for extension of time to file

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the Initial Brief.

5. This Motion is made in good faith, and not merely for purposes of delay.
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6. In order to draft the Appellants' initial brief, Appellants must receive the record to be
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compiled by the clerk of the lower court in order to properly cite to the record in the brief in
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compliance with Fla. R. App. P. 9.200.

7. However, Appellants have been prevented from obtaining this mandatory information due
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to Hurricane Irma, which necessitated closing of all South Florida Courts.


A

8. Without the record compiled by the clerk of the lower court in order to properly cite to the
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record in the brief in compliance with Fla. R. App. P. 9.200, the Appellants will be unable
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to file the initial brief in accordance with the deadlines prescribed by the Florida Rules of
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Appellate Procedure.

9. The undersigned certifies that the font and size in this Notice is Time New Roman, 12

point, in compliance with Rule 9.210, Florida Rules of Appellate Procedure.


WHEREFORE, Appellants respectfully request this Court grant this Motion for Extension

of Time and grant the Appellants an extension of thirty days from the receipt of the record

index to file their initial brief, and for such other relief as may be afforded at this time.

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Respectfully Submitted,

Date: September 25, 2017

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Boca Raton, FL

,?J;~~

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LAURENCE S. SCHNEIDER, Pro Se
360 E. COCONUT PALM DRIVE

ED
BOCA RATON, FL 33432
larry@sacapitalpartners.com
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STEPHANIE L. SCHNEIDER, Pro Se


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360 E. COCONUT PALM DRIVE


BOCA RATON, FL 33432
larry@sacapitalpartners.com
C
A

CERTIFICATE OF SERVICE
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I hereby certify that a copy hereof has been furnished to Henry H. Bolz Ill, 121 Majorca
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Ave. #200. Coral Gables, FL 33134, by mail this 25 th day of September 2017.
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Laurence Schneider, pro se


IN THE DISTRICT COURT OF APPEAL OF FLORIDA,
FOURTH DISTRICT

CASE NO: 4Dl 7-2239


Lower Tribunal Case No.: 2016-CA-009292

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(!) LAURENCE SCHNEIDER and
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STEPHANIE SCHNEIDER,

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~0 Appellants,
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vs.

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FIRST AMERICAN BANK,

Appellee.
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___________./
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APPELLEE'S RESPONSE/OBJECTION TO APPELLANTS'


MOTION FOR EXTENSION OF TIME TO FILE INITIAL BRIEF
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COMES NOW the Appellee, FIRST AMERICAN BANK, by and through its
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undersigned attorneys, and pursuant to Fla. R. App. P. 9.300(a) and R. Regulating


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Fla. Bar 4-5.5, hereby files its Response/Objection to Appellants', LAURENCE


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SCHNEIDER and STEPHANIE SCHNEIDER, Motion for Extension of Time to


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File Initial Brief (bearing an unsigned Certificate of Service date of September 25,
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2017).

The Appellants are ostensibly representing themselves in this appeal on a pro

se basis. Neither LAURENCE SCHNEIDER nor STEPHANIE SCHNEIDER is an

Exhibit "3"
attorney admitted to The Florida Bar and, accordingly, neither of them can represent

the other.

This Court, first on August 16, 2017 and then again on August 28, 2017, made

it clear that:

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"Appellants are reminded that all filings must be signed by
both appellants."

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Order dated August 16, 2017; and

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"By order dated August 16, 2017, this court directed
appellants to file an amended notice of appeal with both

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appellants' signatures and advising them that all future
pleadings must be signed by both appellants."
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Order dated August 28, 2017.
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The Appellants' Motion for Extension of Time to File Initial Brief was filed
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with the Fourth District Court of Appeal on Tuesday, September 26, 2017. In blatant

violation of this Court's August 16 and August 28, 2017 Orders, neither
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LAURENCE SCHNEIDER nor STEPHANIE SCHNEIDER signed the Motion for


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Extension of Time to File Initial Brief. Moreover, the Motion for Extension of Time
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to File Initial Brief concludes with an unsigned Certificate of Service block dated
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September 25, 2017. Appellants never served Appellee a copy of their Motion for

Extension of Time to File Initial Brief.

Appellee would also submit that the Appellants' Motion for Extension of

Time to File Initial Brief, while not signed by either Appellant, was signed by "Brent

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Tantillo for" the Appellants. Appellee would further submit that Brent Tantillo is

not a member of The Florida Bar despite the fact that he is apparently authorized to

practice law in the District of Columbia. Appellee would also submit that Brent

Tantillo, despite not being a member of The Florida Bar or authorized to practice

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law in this case by virtue of an order allowing him to appear pro hac vice or

otherwise, in some fashion operates out of an office in Florida, to wit:

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Tantillo Law, PLLC

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6810 N State Road 7, Suite 300
Coconut Creek, FL 33073

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Shortly stated, Brent Tantillo, either as an individual or as a District of Columbia
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attorney, by signing Appellants' Motion for Extension of Time to File Initial Brief,
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did so in knowing and intentional violation of this Court's Orders dated August 16,
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2017 and August 28, 2017. Moreover, by signing and filing pleadings with this

Court, Brent Tantillo is engaging in the unauthorized practice of law. See R.


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Regulating Fla. Bar 4-5.5.


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WHEREFORE, FIRST AMERICAN BANK demands that the Appellants'


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Motion for Extension of Time to File Initial Brief be stricken from the record and
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that the Appellants' Motion be denied, together with such further and other relief as

the Court deems just and appropriate under the circumstances.

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Respectfully submitted,

Henry H. Bolz, III, Esq.


KELLER & BOLZ, LLP
Counsel for Appellee
121 Majorca Avenue, Suite 200
Coral Gables, FL 33134
Telephone: (305) 529-8500

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Telefax: (305) 529-0228
Email: hbolz@kellerbolz.com

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By: s/Henry H. Bolz, III

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Henry H. Bolz, III
Fla. Bar No. 260071

CERTIFICATE OF SERVICE
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I hereby certify that the foregoing document, Appellee's Response/Objection
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to Appellants' Motion for Extension of Time to File Initial Brief, has been furnished
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to LAURENCE S. SCHNEIDER, (larry@sacapitalpartners.com), 360 E. Coconut


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Palm Road, Boca Raton, FL 33432; STEPHANIE L. SCHNEIDER


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(steffschneider13@gmail.com), 360 E. Coconut Palm Road, Boca Raton, FL 33432;


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and JAY S. LEVIN, ESQ. (foreclosures@ssclawfirm.com), Sachs, Sax, Caplan,


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Attorneys for Oaks at Boca Raton, 6111 Broken Sound Parkway, N.W., #200, Boca
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Raton, FL 33487 via Email on this 27 th day of September, 2017.

KELLER & BOLZ, LLP

By: s/Henry H. Bolz, III


Henry H. Bolz, III
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CERTIFICATE OF COMPLIANCE

I hereby certify that Appellee' s Response/Objection to Appellants' Motion for

Extension of Time to File Initial Brief complies with the font requirements of Florida

Rule of Appellate Procedure 9 .100(1) because this memorandum has been prepared

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using Times New Roman 14-point font.

KELLER & BOLZ, LLP

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By: s/Henry H Bolz, III
Henry H. Bolz, III

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