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Home My Public Portal AboutPRR 16-2338RECORDS REQUEST (the "Request") Date of Request: 10/11/2016 Requestor's Request ID#: 1305 REQUESTEE: Custodian of Records Sweetapple, Broeker & Varkas Custodian of Records Jones, Foster, Johnston & Stubbs Custodian of Records Town of Gulf Stream REQUESTOR: Martin E. O'Boyle REQUESTOR'S CONTACT INFORMATION: E -Mail: records@commerce-group.com Fax: 954-360-0807 or Contact Records Custodian at records ,commerce-group.com; Phone: 954-360-7713; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Please provide all records, including without limitation, entails and letters generated by, sent by or received by Edward "Trey" Navarro or which relate to or mention the words "Tref or "Navarro" during the period when he was employed by, worked for. Jones. Foster. Johnston & Stubbs _ for the period January 1. 2013 though the date of this Request. ADDITIONAL INFORMATION REGARDING REQUEST: THIS REQUEST IS MADE PURSUANT TO ARTICLE 1, SECTION 24 OF THE FLORIDA CONSTITUTION AND CHAPTER 119, FLORIDA STATUTES IF THE PUBLIC RECORDS BEING SOUGHT ARE MAINTAINED BY YOUR AGENCY IN AN ELECTRONIC FORMAT PLEASE PRODUCE THE RECORDS IN THE ORIGINAL ELECTRONIC FORMAT IN WHICH THEY WERE CREATED OR RECEIVED. SEE 8119.01(2)(F). FLORIDA STATUTES. IF NOT AVAILABLE IN ELECTRONIC FORM, IT IS REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED ON 11 X 17 PAPER NOTE: IN ALL CASES (UNLESS IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119.07(4) (a) (2) ALSO PLEASE TAKE NOTE OF §119.07(1)(H) OF THE FLORIDA STATUTES. WHICH PROVIDES THAT "IF A CIVIL ACTION IS INSTITUTED WITHIN THE 30 -DAY PERIOD TO ENFORCE THE PROVISIONS OF THIS SECTION WITH RESPECT TO THE REQUESTED RECORD, THE CUSTODIAN OF PUBLIC RECORDS MAY NOT DISPOSE OF THE RECORD EXCEPT BY ORDER OF A COURT OF COMPETENT JURISDICTION AFTER NOTICE TO ALL AFFECTED PARTIES." ALL ELECTRONIC COPIES ARE REQUESTED TO BE SENT BY E-MAIL DELIVERY. PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC RECORDS REQUEST IN ADVANCE. It will be required that the Requester approve of any costs, asserted by the Agency (as defined in Florida Statute, Chapter 119.01 (Definitions)), in advance of any costs imposed to the Requester by the Agency. "BY FULFILLING THIS RECORDS REQUEST, THE AGENCY ACKNOWLEDGES THAT THE RESPONSIVE DOCUMENTS ARE "PUBLIC RECORDS" AS DEFINED IN CHAPTER 119, FLORIDA STATUTES". I/P/NP/FLRR 07.28.2015 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail October 12, 2016 Martin E. O'Boyle [mail to: records(7a,commerce-erouo.coml Re: GS #2336, #2337, #2338 (PRR's 1303,1304, 1305) Please provide all records, including without limitation, emails, letters, contracts/agreements (including without limitation, drafts of contracts/agreements including relative communications) employment offers and employment acceptances (whether or not conditional) plus any related communications in regard to a party whose name is Edward C. "Trey" Navarro, for the period January 1, 2016 through the date of this Request. Please provide all records, including without limitation, emails, letters, contracts/agreements (including without limitation, drafts of contracts/agreements including relative communications) employment offers and employment acceptances (whether or not conditional) plus any related communications containing the name "Trey" or "Navarro"for the period January 1, 2013 through the date of this Request but only during the time that Mr. Navarro was employed by (or working at or far or on behalf qfi Jones, Foster, Johnston & Stubbs. Please provide all records, including without limitation, entails and letters generated by, sent by or received by Edward "Trey" Navarro or which relate to or mention the words "Trey" or "Navarro " during the period when he was employed by, worked for, Jones, Foster, Johnston & Stubbs for the period January 1, 1013 though the date of this Request. Dear Martin E. O'Boyle [mail to: records(a,commerce-ffoup.coml: The Town of Gulf Stream has received your public records requests dated October 11, 2016. The original public record request can be found at the following link: htto://www2.gulf-stream.ore/weblink/0/doc/102386/Pasel.aslx htti)://www2.gulf-stream.org/weblink/O/doc/102387/Pagel.aspx htti)://www2.gulf-streatn.org/weblink/O/doc/102391/Pagel.asox Please be advised that the Town of Gulf Stream is currently working on a large number of incoming public records requests. The Town will use its very best efforts to respond to you in a reasonable amount of time with the appropriate response or an estimated cost to respond. Sincerely, R"4i RaW44$" As requested by Rita Taylor Town Clerk, Custodian of the Records TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail December 6, 2016 Martin E. O'Boyle [mail to: recordsaa.commerce-group.coml Re: GS #2338 (PRR 1305) Please provide all records, including without limitation, emails and letters generated by, sent by or received by Edward "Trey " Navarro or which relate to or mention the words "Trey" or "Navarro " during the period when he was employed by, worked for Jones, Foster, Johnston & Stubbs for the period January 1, 2013 though the date of this Request. Dear Martin E. O'Boyle [mail to: records@commerce-eroup.coml: The Town of Gulf Stream received your public records requests on October 11, 2016. You should be able to view your original request and a partial responsive production at the following link: http://www2.gulf-strearn.org/weblink/O/doc/I02391/PaeeI.ast)x We are taking this request with the assumption that you are meaning Mr. Nazzaro. Based on that understanding, the Town has spent at least 15 minutes on your request and now estimates that to respond to your request will require approximately an additional hour of administrative support at $35.60 per hour, an additional half hour of IT support at $95.00 per hour and 12 %2 hours of attorney time at $250.00 per hour, the labor cost of the personnel providing the service, per Fla. Stat. § I I9.07(4)(d). In light of the breadth of your request, which covers "all records generated by, sent by or received by Edward "Trey" Navarro or which relate to or mention the words "Trey" or "Navarro " during a nearly four-year period, producing all records responsive to your request will require extensive clerical or supervisory assistance. As you are aware, the Town is presently defending approximately 40 public records lawsuits that were filed during the time period encompassed by your request. Your request thereby encompasses documents prepared by the Town's attorneys exclusively for litigation or in anticipation of imminent litigation and that reflect the mental impressions, conclusions, litigation strategies, or legal theories of the Town's attorneys or the Town and would be exempt under Florida Statute § 119.0171(1)(d) until the conclusion of the litigation. As a result and given the fact that very few of the litigation files pending during the referenced time period are now closed, the Town reasonably anticipates needing significant attorney time to review any records that may be responsive to your request for exemptions under Florida Statute § 119.0171(1)(d). This request generated more than 1,500 email documents from a review of the Town of Gulf Stream's email files alone. This does not include any potential attachments to the emails or other hard copies of communications. We have estimated the review and production of these entails alone will require approximately 12 '/2 work hours of attorney support from the Town's outside legal counsel at $250.00 per hour, the labor cost of the personnel providing the service, per Fla. Stat. § I I9.07(4)(d). This estimate is based upon an extremely conservative estimate of 30 seconds to review each email and to redact any potential emails or portions of an email as allowed under the Florida Statutes. (One hour @ $35.60 + One half hour @ $95.00 + 12 1/2 hours @ $250) = Deposit Due: $3,208.10 in cash or check. The Town is willing to fulfill this public records request but we require payment of the estimated special service fee of $3,208.10 in advance before we begin. If the costs of producing these documents will exceed your deposit, the Town will provide you with an initial production of responsive records and an estimate for the production of any additional responsive records. If the costs of production are less than the deposit, the Town will provide you with the responsive records and a refund. Upon receipt of your deposit, the Town will use its very best efforts to further respond to your public records request in a reasonable amount of time. If we do not hear back from you within 30 days of this letter, we will consider this request closed. Sincerely, Sip441d ROW" D As requested by Rita Taylor Town Clerk, Custodian of the Records