HomeMy Public PortalAboutPRR 16-2420RECORDS REQUEST (the "Request")
Date of Request: 11/30/2016
Requestor's Request ID#: 1352
REQUESTEE: Custodian of Records Sweetapple, Broeker & Varkas
Custodian of Records Jones, Foster, Johnston & Stubbs
Custodian of Records Town of Gulf Stream
Custodian of Records Richman Greer, P.A.
Custodian of Records Cole Scott & Kissane
Custodian of Records Johnson Anselmo Murdoch Burke Piper & Hochman. P.A.
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(o)commerce-group.com;
Phone: 954-360-7713; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442
REQUEST: In the last sentence of the sixth paragraph of the Coastal Star Letter to the
Editor of November 2.2016: Gulf Stream confident it's on the right track. Scott Morgan
states the following:
"That case was tried recently and there will be a hearing on fees in the near
future."
Please provide copies of all attorneys' fees and other costs incurred by the Town of Gulf
Steam related to the litigation styled Martin E. O'Boyle. Plaintiff vs. Town of Gulf
Stream, Defendant, Case No. 502014CA004474XXXXMB . See attached Exhibit A.
ADDITIONAL INFORMATION REGARDING REQUEST: The term "Town of Gulf Stream" shall
mean each of the following: the Town of Gulf Stream, its Commissioners, its Manager, its emolovees. its
officers, its staff, its Police Department, its Police Officers: including, without limitation. the
attorneys, employees and partners Of the following law firms: Sweetaovle. Broeker & Varkas:
Richman Greer, PA; Jones, Foster. Johnston & Stubbs; Cole, Scott & Kissane, P.A.: and Johnson
Anselmo Murdoch Burke Piper & Hochman. P.A.
THIS REQUEST IS MADE PURSUANT TO ARTICLE I, 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 5119,01(2)(F). FLORIDA STATUTES IF NOT AVAILABLE IN ELECTRONIC FORM, IT IS REQUESTED THAT THIS
RECORDS REOVEST BE FULFILLED ON 11 X 17 PAPER. NOTE: IN ALL CASE (UNLESS IMPOSSIBLE) THE COPIES
SHOULD BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119.07(4) (o) (2)
ALSO PLEASE TAKE NOTE OF §I19.07(l)(H) OF THE FLORIDA STATUTES, WHICH PROVIDES THAT"I F 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 Requestor 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
11.04.2016
Letter to the Editor: Gulf Stream confident it's on the right track - The Coastal Star
EXHIBIT A
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Letter to the Editor: Gulf Stream confident it's on the right track
• Posted by Mary Kaie Leminc an November 2, 2016 at 1:47pm in Island Tolk
• View Discussions
In 2014 and early 2015, the town of Gulf Strewn found itself under assault from Martin O'Boyle and Christopher O'Hare, two residents who
overwhelmed the town with thousands of public records requests and dozens of lawsuits. Town Hall became virtually unable to serve Gulf
Stream residents.
To defend against this ongoing public records abuse, Gulf Stream brought in legal staff to create a policy to respond to records requests. In
addition, Gulf Stream learned through its RICO investigation about other Florida abuses committed by the O'Boyle Law Firm and a related
O'Boyle company called Citizens Awareness Foundation, which it added to the town's defenses in the public records lawsuits.
Since Gulf Stream took these actions, public records requests have dropped from 80 -plus per day down to several a week. In addition, there
has not been another public records lawsuit against Gulf Stream in over a year and a half. Of the old lawsuits, Gulf Stream won or forced the
dismissal of four of them, and soon verdicts or forced the dismissal of six additional non-public records lawsuits.
I cannot overstate how the volume of lawsuits and records requests back in 2013 and 2014 overwhelmed our small staff. The clerks
regularly worked nights and weekends; they put off other town responsibilities; they hunted through old file cabinets and closed land -use
folders trying to respond to requests pouring in almost daily; they called mmmissioners, board members, past employees and active and retired
police to identify documents and their possible locations. But, the quantity of these requests was simply not manageable, and some documents
were inadvertently missed.
At no time did staff refuse the legitimacy of O'Boyle's or O'Hare's requests or try to prevent them from receiving documents. For example,
one such request required production of"All photos ofpeople riding bicycles on N. Ocean Blvd. in the town's public record." Since town
records go back to its founding in 1925, this request necessitated a needle -in -the -haystack search, and for which we were still sued over a
"gotcha" photograph.
A case currently being litigated involves some inadvertently missed documents. Despite a good -faith effort to locate all requested records,
missing records constitute a technical violation of the public records law, so the town offered to settle the case. O'Boyle's settlement demand,
however, was so outrageously high that the town concluded it was in its best financial interest to go to trial and let ajudge determine
reasonable fees. That case was tried recently and there will be a hearing on fees in the neer future.
The town is confident that under Florida law, the court will award fees up to the performance of the records request and not beyond. This is
why the town elected to try this case, as it will any other case where it appears that O'Boyle built up large attorneys' fees.
Gulf Stream will continue to defend the remaining O'Boyle and O'Hare lawsuits until our two litigious residents drop the meritless cases
and negotiate reasonable settlements in good faith on the others.
http://thecoastalstar.comlforumltopics/letter-to-the-editor-gulf-stream-confident-it-s-on-the...
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
December 2, 2016
Martin E. O'Boyle [mail to: recordsOcommerce-group.com]
Re: GS #2420 (PRR 1352)
In the last sentence of the sixth paragraph of the Coastal Star Letter to the Editor of November 2,
1016: GulfStream confident it's on the right trach Scott Morgan states the following:
"That case was tried recently and there will be a hearing on fees in the near future. "
Please provide copies of all attorneys' fees and other costs incurred by the Town of Gu f Steam
related to the litigation styled Martin E. O'Boyle, Plaintiff vs. Town of Gulf Stream, Defendant,
Case No. 502014CA004474A7C0W . See attached Exhibit A.
Dear Martin E. O'Boyle [mail to: records(a),commerce-grouo.coml:
The Town of Gulf Stream has received your public records request dated November 30, 2016. The
original public records request can be found at the following link:
hgp://www2.gulf-stream.org/weblink/O/doc/ 103 771 /Page l .asax
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,
Rm-d ROW441
As requested by Rita Taylor
Town Clerk, Custodian of the Records
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
March 28, 2017
Martin E. O’Boyle [mail to: records@commerce-group.com]
Re: GS #2420 (PRR 1352)
In the last sentence of the sixth paragraph of the Coastal Star Letter to the Editor of November 2,
2016: Gulf Stream confident it’s on the right track, Scott Morgan states the following:
“That case was tried recently and there will be a hearing on fees in the near future.”
Please provide copies of all attorneys’ fees and other costs incurred by the Town of Gulf Steam
related to the litigation styled Martin E. O’Boyle, Plaintiff vs. Town of Gulf Stream, Defendant,
Case No. 502014CA004474XXXXMB . See attached Exhibit A.
Dear Martin E. O’Boyle [mail to: records@commerce-group.com]:
The Town of Gulf Stream has received your public records request dated November 30, 2016.
You should be able to view your original request at the following link:
http://www2.gulf-stream.org/weblink/0/doc/103771/Page1.aspx
The Town understands the request to be seeking copies of approximately two and a half years of
bills from Jones, Foster, Johnston & Stubbs, P.A. and Sweetapple, Broeker, Varkas, P.L. and that
the more recent bills will need to be reviewed for attorney work product. To that end, the Town
has spent at least 15 minutes on your request and is providing you with a partial response at the
same link above.
The Town now estimates that to fully respond to your request will require approximately an
additional hour of administrative support at $37.34 per hour and one and a half hours of attorney
time at $250.00 per hour, the labor cost of the personnel providing the service, per Fla. Stat. §
119.07(4)(d). 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.
(1 hour @ 37.34 + 1 ½ hours @ 250.00) = Deposit Due: $412.34 in cash or check.
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,
Reneé Rowan Basel
As requested by Rita Taylor
Town Clerk, Custodian of the Records
Sweetapple, Broeker, Varkas, P.L.
20 South East 3rd. Street
Boca Raton, FL 33432
Telephone: (561)392-1230
Fax:(561)394-6102
yb� OF GULF STREAM
PrAYMENT APPROVED .4
April
29, 2014
Town of Gulf Stream Amount74, I`j
Invoice No. 10134
100 Sea Road
Gulf Stream, Fl, 33483 ,u� Date V
1By
;t•heck # 119tr1 Date
Client Number: 00949 Town of Gulf Stream
Matter Number: 1679
O'Boyle vs. Town of Gulf Stream
For Services Rendered Through 4/29/2014.
Fees
Date Tntknr
Description
Hours
Amount
04.!01/2014 RS
Review file; Conference; Prepare for meeting.
1.00
$350.00
04/02/2014 RS
Conferences; Review case law.
1.50
$525.00
04/03/2014 RS
Travel and attend meeting with town attorney and Scott Morgan;
7.50
$2,625.00
Begin review all files provided by Jones Foster (evening). (Date
04/02).
04/04/2014 RS
Conferences.
0.30
$105.00
04/06/2014 RS
Continue reviewing files.
1.50
$525.00
04/14/2014 RS
Review Sunshine and public records cases and status regarding
1.00
$350.00
pending claims; Receive and review emails.
04/17/2014 RS
Conference with Scott; Conference with Joanne.
0.30
$105.00
04118!2014 RS
Review reports and correspondence.
0.40
$140.00
04121/2014 RS
Review files.
1.50
$525.00
04/21/2014 RS
Review emails, memos and cases; Research regarding O'Hare and
2.20
$770.00
email to opposing counsel.
04/23/2014 RS
Review correspondence and emails.
0.40
$140.00
04/24/2014 RS
Prepare travel and attend hearing and settlement conference.
2.50
$875.00
04/25/2014 RS
Review Citizen Awareness files.
0.50
$ I75.00
Continued On Next Page
Client Number: 00949 04/29/2014
Matter Number: 1679 Page: 2
04!25/2014 RS Receive and review files; Conference with Scott. 0.60 S210.00
04/26/2014 RS Conference; Work on letter. 0.40 $140.00
Billable [lours I Fees: 21.60 $7,560.00
Cost Detail
Date Description Amaum Check No.
04/25!2014 Photocopy Charges - April 2014 $12.25
04/28/2014 Postage - April 2014 1.92
Total Costs S14.17
Prior Balance:
$0.00
Payments Received:
$0.00
Current Fees:
$7,560.00
Advanced Costs:
$14.17
TOTAL AMOUNT DUE:
S7,574.17
PLEASE REMIT TO: SWEETAPPLE. BROEKER R VARKAS. P.L.
20 S.E. 3rd. STREET. BOCA RATON. FL 33432
PLEASE INDICATE INVOICE NUMBER ON CHECK. THANK YOU!
Sweetapple, Broeker, Varkas, P.L.
20 South East 3rd. Street
Boca Raton, FL 33432
Telephone: (561)392-1230
Fax: (561)394-6102
Town of Gulf Stream
100 Sea Road
Gulf Stream, FL 33483
Client Number. 00949 Town of Gulf Stream
Matter Number: 1679 O'Boyle vs. Town of Gulf Stream
For Services Rendered Through 6/30/2014.
Fees
June 30, 2014
Invoice No. 10159
PAYMENT APPROVED .4
45.125. 517
By v" " Date
Check Y 111 51 Dale 7
Date
Tmknr
Description
Hours
Amount
05/04/2014
RS
Conferences with Scott, Joanne, Skip Randolph and law clerk;
0.75
$262.50
Duces tecum. (Date 05/03).
05/30/2014
RS
Conference with attorneys.
0.20
$70.00
06/01/2014
RS
Review motion and authorities.
0.20
$70.00
06/02/2014
RS
Conference with opposing counsel.
0.20
$70.00
06/02/2014
RS
Receive and review letter, motion and authorities; Conference.
0.40
5140.00
06/04/2014
RS
Additional conference regarding meeting with O'Boyle.
0.20
$70.00
06/05/2014
RS
Conferences with Scott and Jordan; Conference call with Scott and
1.40
$490.00
Joanne; Work on revisions to letter and subpoena. (Date 06/04).
06/06/2014
RS
Several conferences with client and opposing counsel; Receive
1.20
$420.00
and review entails.
06/08/2014
RS
Conference regarding strategy; Receive and review memo; Prepare
1.70
$595.00
memo. (Date 06/07).
06/09/2014
RS
Conference with Skip; Conference with client; Receive and review
1.20
$420.00
email.
06/10/2014
RS
Conferences with Kelly and Scott.
0.70
$245.00
Continued On Next Page
Client Number: 00949
Matter Number: 1679
06/30/2014
Page: 2
06.111/2014 RS
Receive and review emails and respond; Conference with Joanne;
2.20 $770.00
Review letter from town; Conference with Skip Randolph and
client; Conference with law clerk regarding research.
06/11/2014 RS
Receive and review email and respond, conference.
0.20 $70.00
06/11/2014 RS
Conference with client regarding research; Review strategy
4.00 $1,400.00
regarding O'Boyle interference with contract with counsel;
Conference with Ashley; Conference with Jones Foster regarding
research and claims; Conference with Scott regarding options;
Conference with Dave and A. Varkas regarding research about
O'Boyle late firm. (Date 06/10).
06/12/2014 RS
Conference with A. Varkas regarding requests; Conference
1.20 $420.00
regarding strategy; Receive and review documents and prepare
emails.
06/13/2014 RS
Receive and review emails and calls.
0.40 $140.00
06/13/2014 RS
Conference with Opposing counsel Conference with prospective
0.80 $280.00
opposing counsel; Conference with client.
06/13/2014 AV
Westlaw search 1) Litigation abuse i.e. threats 2) Interference with
1.50 $525.00
attorney/client relationship (read and summarize case law).
06/14/2014 RS
Work on Request for Admissions; Review case law and prepare
3.00 $1,050.00
memo; Conference with client and opposing counsel.
06/16/2014 RS
Conference with Gerry; Review information; Conference with
0.50 $175.00
client.
06/16/2014 RS
Conference with client; Conference with Joanne; Work on
0.70 $245.00
requests.
06/17/2014 RS
Review responses, answers and emails; Conference with law clerk.
0.70 S245.00
06/18/2014 RS
Receive and review records; Conference with A. Varkas; Prepare
1.25 $437.50
letter.
06/18/2014 RS
Conference with Gerry; Conference with Dave regarding research.
0.50 $175.00
06/19/2014 RS
Conference with Scott; Conference with Gerry; Interview.
0.60 $210.00
06/19/2014 RS
Receive and review article; Conference with client; Revise email
0.70 $245.00
and letter.
06/19/2014 RS
Prepare letters and emails; Review opinion.
1.20 $420.00
06/19/2014 RS
Follow up conference with client; Dictate pleading and revise
0.60 $210.00
letter.
06/19/2014 RS
Joint conference with counsel and client.
1.00 $350.00
Continued On Next Page
Client Number: 00949
Matter Number: 1679
06/30/2014
Page: 3
06/22/2014 RS
Conference with Joanne; Conference with client; Conference with
2.40 $840.00
Gerry; Conference media; Conference regarding expert witnesses;
Conference media; Review article. (Date 06/21).
06/23/2014 RS
Work on Motion for production; Meeting with Skip and Joanne at
2.25 $787.50
J. Fosters; Conference with client.
06/24/2014 RS
Conference with client; Meeting with potential expert. (Date
1.75 $612.50
06/22).
06/25/2014 RS
Conference with Scott; Conference with Joanne, Meeting with A.
2.50 S875.00
Varkas; Conference with Joanne; Review cases from Joanne;
Work on motion for sanctions; Receive and review emails from
Lily; Email to Joanne.
06/26/2014 RS
Revise Motion and request to produce.
0.40 $140.00
06/26/2014 RS
Dictate motion for sanctions, letter, Notice to Depo and request to
3.50 $1,225.00
produce; Review extensive material regarding M.O. in other
districts; Conference with client.
06/30/2014 RS
Meeting with client and conferences with Jamie Cole and A.
1.20 $420.00
Varkas regarding claims.
Billable hours / Fees: 43.20 $15,120.00
Cost Detail
Date Description Amount Check No.
06/25/2014 Photocopy Charges - June 2014 $3.50
06/26/2014 Postage - June 2014 2.07
Total Costs $5.57
Prior Valance: $7,024.78 Last Payment: 06/05/2014
Payments Received: ($7,024.78) 1
Current Fees: S15,120.00
Advanced Costs: $5.57
TOTAL AMOUNT DUE: S15,12557 aor 5'3116 513 JO
PLEASE REMIT TO: SWEETAPPLE. BROEKER & VARKAS. P.L.
20 S.E. 3rd. STREET. BOCA RATON. FL 33432
PLEASE INDICATE INVOICE NUMBER ON CHECK. THANK YOU!
® RECEIVED
JUL 28 2014
Town of Gulfstream, FL
Town of Gulf Stream
100 Sea Road
Gulf Stream, FL 33483
Sweetapple, Broeker, Varkas, P.L.
20 South East 3rd. Street
Boca Raton, FL 33432
Telephone: (561)392-1230
Fax: (561)394-6102
July 25, 2014
Invoice No. 10169
VN OF GULF STRI
® PAYMENT APPROVED d
[All o nt I 90 So
Client Number: 00949 Town of Gulf Stream '7 __ Date-
MatterNumber:1679 O'Boyle vs. Town of Gulf Stream Check# /21L.e
For Services Rendered Through 7/25/2014. _ Dale 7 q
Fees
Dale Tmknr Description
Hours Amount
0627/2014 AV Research: Sanctions agreement opposing party and attorney for 1.75 $612.50
litigation abuse (read and summarize case law, treatise and rules);
Revise Motion for Sanctions Agreement O'Boyle, attorney and
son's law firm (include memo of law).
0613012014 RS
Review client edits to Motion and revise; Review case law
0.75
regarding abuse of process.
$262.50
06/302014 AV
Westlaw search 1) Limitations on rights to public records (read
1.50 $525.00
and summarize case law).
07/022014 RS
Conference with Scott; Work on files.
0.40 $140.00
07/022014 RS
Conference with Scott; Conference with Joanne.
0.40 $140.00
07/022014 AV
Westlaw search: Unauthorized practicing of law (read and
0.75
summarize cases); Conference with R. Sweetapple and Joanne
$262.50
O'Connor.
07/022014 RS
Conference with A. Varkas; Conference with Joanne; Review,
1.50 $525.00
revise notice; Revise Motion; Review additional case law.
07/042014 RS
Conference with Jeanne; Conference with client; Conference with
0.80 $280.00
A. Varkas and Ball.
07/062014 RS
Work on strategy; Outline projects; Conference with Scott;
Review email; New case exhibits; Conference with Joanne and
1.75 $612.50
Scott.
Continued On Next Page
Client Number: 00949
Matter Number: 1679
07252014
Page: 2
07/062014 RS
Conference with witness; Conference with witness counsel.
0.30 $105.00
07/062014 RS
Conference with Scott; Receive and review cases and documents;
1.50 $525.00
Work on claim.
07/082014 RS
Conference regarding witness interview, affidavit and deposition.
0.40 $140.00
07/082014 RS
Conference with Ken; Conference with attorney.
0.70 $245.00
07/092014 RS
Conferences with client and Joanne; Witness interview.
0.70 $245.00
07/102014 RS
Conference with Joanne and witness.
0.40 $140.00
07/112014 RS
Receive and review emails; Prepare response; Review Weiss
1.60
materials regarding Sober House; Conference with client and
$560.00
Joanne regarding deposition. Deposition preparation. (Date 07/10).
07/142014 RS
Receive and review entails; Conference with witness regarding
1.25 $437.50
deposition; Conference with client.
07/152014 AV
Westlaw, and statute search: Objection to O'Boyles witness
0.50
subpoena in R. Sweetapple (read and summarize statute and rule).
$175.00
07/162014 RS
Review evidence; Outline issues; Prepare for conference;
2.75
Conference with client. (Date 07/15).
$962.50
07/162014 AV
Westlaw search abuse of process - a cause of action against
1.50 $525.00
O'Boyle (read and summarize case law for R. Sweetapple).
07/172014 RS
Prepare Travel and attend hearings; Motion with two different
co -counsels regarding new claim; Interview witness; Conference
5.00 $1,750.00
with third co -counsel; Conference with client; Prepare letter;
Conference with opposing counsel.
07212014 RS
Conference with client and co -counsel; Prepare for meeting.
0.70 $245.00
07212014 AV
Review Motion for Protective Order/Objection to R. Sweetapple
0.25
deposition duces tecum (Mr. O'Boyle's subpoena).
$87.50
07222014 RS
Conference with client and opposing counsel; Prepare for meeting;
2.00 $700.00
Review cases provided; Receive and review subpoena; Conference
regarding PO.
07222014 RS
Prepare for meeting; Outline questions and chronology.
(Evening).
1.75 $612.50
07232014 RS
Prepare and travel; Meeting and statement of witness; Conference
13.50 $4,725.00
with client and co -counsel; Research regarding RICO.
07242014 RS
Work on RICO claims; Research.
1.50 $525.00
07242014 RS
Travel and attend meeting with opposing counsel and Joanne;
2.00
Conferences with Scott.
$700.00
07242014 RS
Work on Motion for PO.
0.30 $105.00
Continued On Next Page
Client Number: 00949
Matter Number: 1679 07252014
Page: 3
0724/2014 RS Conference with Bill Trusher; Conference with Scott Morgan; 120 $420.00
Conference with Dave regarding research; Conference will, Jerry
Richman regarding RICO; Conference with Weissing regarding
class action.
07252014 RS Assemble evidence; Receive and review motion for Summary 1.75 5612.50
judgment filed by Martin; Receive and review entails; Conference
with co -counsel.
Billable Hours/ secs: 51.15 517,902.50
Prior Balance: $15,125.57
Payments Received: ($15,125.57) Last Payment: 07/142014
Current fees: $17,902.50
Advanced Costs: $0.00
TOTAL AMOUNT DUE: $17,902.50 101 r31 / p 513 /O
PLEASE REMIT TO: SWEETAPPLE. BROEKER & VARKAS, P.L.
20 S.E. 3rd. STREET. BOCA RATON. FL 33432
PLEASE INDICATE INVOICE NUMBER ON CHECK. THANK YOU!
0
Town ofGulf Stream
100 Sea Road
Gulf Stream, FL 33483
Sweetapple, Broeker, Varkas, P.L.
20 South East 3rd. Street
Boca Raton, FL 33432
Telephone: (561)392-1230
Fax: (561)394-6102
'TOWN OF GULF STREAM
P PAYMENT APPROVED -4
Amount_ 019_, +5
heck
Client Number: 00949 TownofGulfStream
Matter Number: 1679 O'Boyle vs. Town of Gulf Stream
For Services Rendered Through 9/29/2014.
Fees
September 29, 2014
Invoice No. 10188
Date Tmknr
Description
[fours Amount
08/22/2014 RS
Document review; Revise letter and correspondence regarding
0.20 $70.00
depositions of Demartini and Ring.
08/2502014 RS
Review multiple emails; Conferences with Scott.
0.50 $175.00
0825/2014 RS
Receive and review request to produce; Conference.
0.30 $105.00
08252014 RS
Conference with witness.
0.20 $70.00
08272014 RS
Conference with Scott; Review multiple emails.
0.40 $140.00
0827/2014 RS
Conference with Joanne; Conference with Scott; Prepare for
1.10 $385.00
hearings; Sober house research.
08/27/2014 RS
Conference with Gerry regarding RICO and legislature;
0.40 S140.00
Conference with Scott.
08/28/2014 RS
Travel and attend hearing on Motion to Compel deposition; Draft
2.00 5700.00
amended motion for sanctions.
0828/2014 RS
Prepare travel and attend hearing; Conference with Gerry;
3.30 $1,120.00
Conference with Joanne; Conference with Scott; Meeting with
paralegal; Set hearing; Amend motion; Conference regarding
additional depositions and multiple emails regarding potential
pleadings. (Date 08/23).
08292014 RS
Conference with Gerry regarding class action; Review multiple
0.70 5245.00
emails; Conference with Scott.
Continued On Next Page
Client Number: 00949
Matter Number: 1679
09/29/2014
Page: 2
08/29/2014 RS
Conference with Scott and Joanne; Receive and review material;
1.40 $490.00
Amend motion and prepare subpoenas; Conference; Conference;
Other prospective plaintiff.
09/02/2014 RS
Review multiple emails and prepare for settlement conference.
1.25 5437.50
09i02/2014 RS
Conference with Scott, Conference with Joanne; Review files and
0.70 $245.00
prepare for settlement conference.
09/02/2014 RS
Receive and review emails from Skip Smith and Motion; Prepare
1.50 $525.00
for meetings.
09/03/2014 DS
Prepare notices of depositions to J. O'Boyle, W. Ring and D.
0.60 575.00
DeMartini.
09/03/2014 RS
Conference wills client; Settlement conference with O'Hare and
5.00 $1,750.00
counsel; Meeting with Joanne regarding case strategy (9am -
2pm).
09/04/2014 RS
Conference with Scott and counsel; Conference regarding RICO
125 5437.50
complaint; Prepare letter. (Date 09/03).
09/05/2014 RS
Conference with Scott; Receive and review another group of
0.70 5245.00
request to SBV from O'Boyle. (Date 09/04).
09/082014 RS
Review multiple emails; Conference with Joanne regarding
0.50 $175.00
O'Boyle and O'Hare.
09/08/2014 RS
Conference with client and counsel; Prepare emails to Hama, Skip
0.80 $280.00
Smith and Nick Taylor.
09/09/2014 RS
Review O'Boyle's response.
0.30 $105.00
09/092014 RS
Conference with Scott and Joanne; Provide documents to Town.
0.70 $245.00
09/102014 RS
Conference with Scott; Email.
0.40 $140.00
09/12/2014 RS
Conferences with Scott; Prepare for deposition; Review multiple
4.50 51,575.00
emails.
09/14/2014 RS
Deposition preparation of O'Boyle; Review all files and evidence;
11.00 $3,850.00
Outline questions; Outline affirmative defenses and counterclaim.
(Date 09/13).
09/15/2014 RS
Prepare travel; Take deposition of M. O'Boyle; Conference with
11.00 $3,850.00
law clerk regarding assignments (8:30-7:30); Meeting with Scott,
Joanne and Bill Thrasher.
09/16/20 14 RS
Conference with Gerry and Joanne, Conference with Scott
1.10 5385.00
regarding opinion letter to commission.
09/162014 RS
Conferences with Joanne; Receive and review motions; Review
1.30 $455.00
file and research; Draft letter. (O'Hare).
Continued On Next Page
Client Number: 00949
Matter Number: 1679
09292014
Page: 3
09/162014 AV
Review Motion to Disqualify R. Sweetapple; Westlaw search
2.50 5875.00
regarding case law (read and summarize); Read Bar rules (read
and summarize); Draft outline for opposing affidavit.
09/17/2014 CB
Research 15th. Circuit website regarding allegations in Motion to
0.50 S62.50
Disqualify, closed matter listing. (O'Hare).
09/172014 RS
Conference with Scott; Conference with Nick Taylor regarding
1.75 $612.50
deposition; Conference with Kaleel; Review Motion and research
O'Hare alleged representation; Conference with law clerk.
(O'Hare).
09222014 RS
Conference with Joanne; Review multiple emails; Review case
1.70 S595.00
law regarding motion; Conference with Cynthia regarding
deposition; Conference with A. Varkas regarding preparation of
memo. (Date 09/18, 09/19). (O'Hare).
09222014 AV
Dmft response to Motion to Disqualify (included memo of law);
1.00 5350.00
Revise affidavit. (O'Hare).
09232014 RS
Conference with Scott and Joanne; Conference with Berwick;
3.50 $I?25.00
Conference with Cynthia regarding research; Prepare draft of
report. (Date 09/18).
09/23/2014 AV
Draft request to produce; Revise R. Sweetapple affidavit; Revise
1.00 $350.00
response to Motion to Disqualify. (O'Hare).
09/24/2014 RS
Conference with Scott Morgan, Conference with Morgan's
3.70 S1,295.00
counsel; Conference with Chandler, Conference with Berwick,-
erwick;Work
Workon report; Conference with Cynthia; Notice of deposition
and appearance CAFI; Prepare for meeting with Gerry, Joanne and
Scott.
09242014 AV
Add additional memorandum of law to response (see latest F.L.
0.75 5262.50
weekly opinion). (O'Hare).
09252014 DV
Travel and attend meeting with R. Sweetapple, Scott Morgan,
4.00 $800.00
Gerry Richman and Joanne O'Connors.
09252014 RS
Travel and attend motion at Gerry Richman's office with Joanne
4.50 $1,575.00
and Scott, Receive and review subpoena and letter from Ring;
Work on letter to commissioner, Review rules and case law;
Conference with Chandler; Receive and review emails.
09252014 RS
Receive and review responses; Receive and review letter and
0.60 S210.00
subpoena.
Date Description
Billable Hours / Fees:
Cost Detail
Continued On Next Page
78.50 526,627.50
Amount Check No.
Client Number:
00949
Payments Received:
Matter Number.
1679
0929/3014Page.
Advanced Costs:
S391.95
4
08252014
Postage - August 2014
09/08/3014
WestLaw
S6.97
09/24/2014
Photocopy Charges - September 2014
323.47
09262014
Postage - September 2014
5550
6.01
Total Costs 5391.95
Prior Balance:
527,27035
Payments Received:
(527,27035) Last Payment: 09/05/:014
Current Fees:
S26,627.50
Advanced Costs:
S391.95
TOTAL AMOUNT DUE: 527,019.45
PLEASE REMIT TO: S WEETAPPLE. BROEKER & VARKAS. P.L.
20 S.E. 3rd. STREET. BOCA RATON. FL 33432
PLEASE INDICATE INVOICE NUMBER ON CHECK. THANK YOU!
Town of Gulf Stream
100 Sea Road
Gulf Stream, FL 33483
Sweetapple, Brooker, Varkas, P.L.
20 South East 3rd. Street
Boca Raton, FL 33432
Telephone: (561)392-1230
Fax: (561)394-6102
Check v_ p390 p ,, /o/a3/#
Client Number: 00949 Town of Gulf Stream
Matter Number: 1679 O'Boyle vs. Town of Gulf Stream
For Services Rendered Through 1022/2014.
Fees
October 22, 2014
Invoice No. 10208
nate Tmknr
Deserintinn
hours Amount
09262014 AV
Westlaw search: protective order, deposition, transcript of J.
0.75 $262.50
Chandler from discovery (Citizens Awareness vs. J. Chandler)
involving work product privilege (read and summarize case law).
09262014 RS
Work on response to Motion to Disqualify and affidavit. (O'Hare).
0.70 $245.00
09282014 RS
Review Motion for Protective Order, Motion to Disqualify and
1.20 $420.00
entails; Conference regarding researches.
09292014 RS
Revise response to subpoena; Revise letter to Ring; Revise letter
0.50 5175.00
to Town.
09292014 AV
Revise affidavit, request to produce and response to Motion to
0.25 $87.50
Disqualify into Final form. (O'Hare).
09292014 AV
Revise response to motion for Protective Order (regarding W.
2.00 $700.00
King and J. O'Boyle); Read case late cited; Read Motion and
Amended Motion for Sanctions; Analyze issues of underlining
lawsuit to issues found in Motion for Sanctions.
09/292014 DV
Meeting with R. Sweetapple regarding instrudtions; Draft response
4.20 S840.00
letter for R. Sweetapple review; Draft motion far A. Varkas and R.
Sweetapple review; Meeting with A. Varkas to discuss motion;
Research case law for A. Varkas; Edit letter per R. Sweetapple
comments.
Continued On Next Page
Client Number: 00949
Matter Number: 1679
10222014
Page: 2
09292014 RS
Conference with Scott and Joanne; Conference with Chandler;
1.75 $612.50
Meeting with D. Vitale and A. Varkas regarding response to
Motion to Disqualify and Crime Fraud exception; Read all case
law.
09/302014 RS
Conference with Joanne; Conference with Scott; Conference with
1.75 $612.50
Gerry regarding report to Commission, depositions and Protective
Order; Meeting with A. Varkas regarding O'Boyle's motion;
Receive and review numerous emails.
09/302014 AV
Revise motion for Protective Order regarding documents and
0.25 S87.50
deposition transcript of Chandler. (Citizen Awareness vs.
Chandler lawsuit).
10/0i2014 AV
Review verified motion to disqualify R. Sweetapple (O'Boyle);
4.00 $1,400.00
Revise law on verification, procedure for disqualification
(discovery right and evidentiary hearing); Read treatise and read
and summarize relevant case law.
10/012014 DV
Meeting with A. Varkas to discuss verified motion; Call with R.
1.60 5320.00
Sweetapple; Research case late cited by opposing counsel and
statutory provisions regarding privilege.
10/022014 AV
Revise affidavit; Draft response to motion to disqualify.
5.00 51,750.00
10/022014 RS
Conference with attorneys and Scott; Work on responses and
2.20 S770.00
disqualification of O'Boyle and suit; Revise reports. (Date 10/01).
10/032014 AV
Westlaw search: deposing opposing counsel (read and summarize
4.00 $1,400.00
cases); Revise affidavit; Westlaw search: evidentiary hearing on
motion for protective order.
10/062014 AV
Revise response to motion to disqualify; Dictate response to
3.50 $1,225.00
motion for protective order.
10106r -)O 1 4 RS
Conference with Joanne and Scott; Conference with Gerry;
1.40 S490.00
Conference with D. Vitale; Work on response to motions.
10/072014 RS
Work on Request to produce; Conference with Hanna regarding
0.20 $70.00
deposition.
10/072014 RS
Receive and review new request for records; Review new DCA
0.60 $210.00
opinion and correspondence; Conference with Scott and Joanne.
10/072014 AV
Review first draft of response to motion for Protective Order.
2.00 5700.00
10/082014 RS
Conference with Scott; Revise report draft.
0.70 5245.00
10/082014 RS
Work on responses.
0.50 $175.00
10/082014 RS
Work an disqualification; Prepare letter to De Souza and Hanna.
0.60 $210.00
Continued On Next Page
Client Number: 00949 10222014
platter Number. 1679 Page: 3
10109r-3014 RS Conference with Joanne regarding meetings and depositions of 1.50 $525.00
O'Hare and secretary; Revise letters; Work on affidavit; Review
Fla disqualification cases.
101092014 AV
Continue to revise response to Motion for Protective Order;
4.50 51,575.00
Westlaw search 1) Ethical and legal objections regarding receipt
of documents to which opposing counsel may assert a privilege
(read and summarize cases regarding inadvertent receipt of
privilege documents 2) Rules of Professional conduct; Phone call
to Fla. Bar; Review ethics opinion 07.1.
10/102014 AV
Continue research on attorneys ethical duties regarding when
3.50 51,225.00
obtains documents possible subject to protection by privilege or
giving unfair advantage; Read ethics opinions; U.S. Supreme
Court opinion (Hickmanffaylor); Revise affidavit.
10/122014 RS
Conference with Scott; Conference with Joanne; Work on affidavit
2.70 S945.00
and disqualification of O'Hare and O'Boyle; Conference with
Chandler; Review suit and case conference.
10/122014 AV
(At home research) Westlaw search 1) Common interest
1.00 5350.00
exemption to attomey/client privilege (read and summarize cases)
(see 687/888; 585/461); Search: Non -parry privilege exercised by
party (no cases found).
10/132014 RS
Conference with Scott; Outline all projects in pending cases.
0.60 $210.00
10/132014 RS
Conference with Joanne and Scott; Work on requests, subpoena
2.50 $875.00
and notices; Review multiple emails. (Date 10/10).
10/142014 RS
Conference with Scott, Meeting with A. Varkas regarding
1.40 5490.00
disqualification, affidavit and case scheduling order regarding
deposition of Ring, O'Boyle, DeMartini and law regarding public
indecency regarding S. Morgan's banners.
10/142014 DV
Research case law regarding factual disputes requiring evidentiary
0.20 540.00
hearing; Affidavit from non -lawyer issue.
10/162014 RS
Travel and attend meetings at Richman's office regarding research
2.50 5875.00
motion and town hall trip regarding public record's research
(O'Hare); Conference with D. Vitale regarding deposition and
research.
10/162014 RS
Prepare affidavit and draft motion; Review Hage memo regarding
1.50 $525.00
Sober House.
10/192014 RS
Review case law and statute regarding O'Hare deposition; Prepare
3.70 $1,295.00
motion; Draft affidavit far Chandler review; Read Chandler
statement. (Date 10/18).
10202014 RS
Conference with Scott; Conference with Joanne; Conference and
2.10 5735,00
Meeting with Gerry; Conference with Chandler; Revise affidavit
and response. (Chandler).
Continued On Next Page
Client Number:
00949
Payments Received:
Last Payment: 10!032014
($27,019.45)
Current Fees:
10/22/2014
Matter Nmnber.
1679
Page. 4
10/212014 DV
Index M. O'Boyle deposition by going through discs I and 2 part
5.60 $1,120.00
of 3 per R. Sweetapple instructions; Create word documents in
support.
10222014 RS
Conference with D. Vitale; Prepare letter to Chandler, Work an
1.60 $560.00
law regarding Ring and O"Boyle P.O.; Revise motions and
affidavit; Conference with Scott and Gery's office.
Billable Hours / Fees: 74.55 524,352.50
Prior Balance:
527,019.45
Payments Received:
Last Payment: 10!032014
($27,019.45)
Current Fees:
$24,352.50
Advanced Casts:
$0.00
TOTAL AMOUNT DUE:
524,352.50
PLEASE REMIT TO: S WEETAPPLE. BROEKER & VARKAS. P.L.
20 S.E. 3rd. S'T'REET. BOCA RATON. FL 33432
PLEASE INDICATE INVOICE NUMBER ON CHECK. THANK YOU!
Sweetapple, Broeker, Varkas, P.L.
20 South East 3rd. Street
Boca Raton, FL 33432
Telephone: (561)392-1230
rax: (561)394-6102
Continued On Next Page
6 PAYMENT APPROVED -4
November 21, 2014
Town ofGulf Stream
100 Sea Road
Amount D65.
Invoice No. 10216
By Dale
Gulf Stream, FL 33483
Check i ?'i ID Date J l 5&
Client Number: 00949 Town of Gul(Stream
Mancr Number: 1679 O'Boyle vs. Town of Gulf Stream
For Services Rendered Through 11/212014.
Fees
Date Tmknr Descrindan
Hours Arnount
10222014 RS Conference with Scott regarding new public records request;
2.20 $770.00
Conference with Joanne; Prepare for O'Hare deposition; Review
all documents regarding O'Hare; Conference with Morgan's
counsel.
10222014 RS Conference with Scott; Conference with A. Varkas; Call to
2.00 5700.00
Chandler; Prepare for O'Hare's deposition.
0222014 DV Complete index of deposition testimony for R. Sweetapple.
2.60 S520.00
10242014 AV Attend deposition of Chris O'Hare.
6.00 $2,100.00
1024/2014 RS Travel and take O'Hare deposition.
6.00 $2,100.00
10252014 RS Conference with Scott; Receive and review emails; Meeting with
Loo $350.00
law clerk regarding projects (O'Boyle and O'Hara).
10262014 RS Review Chandler's edits.
0.20 $70.00
10272014 RS Revise Motion; Call to Chandler; Conference with Joanne; Review
1.30 $455.00
litigation privilege regarding RICO, state and federal; Prepare for
conference with Gerry.
10272014 DV Research statutes and case law rc: MOB's banners.
0.80 $160.00
10282014 RS Conference with clerk; Review O'Hare website.
0.50 $175.00
Continued On Next Page
Client Number: 00949 11212014
Matter Number: 1679
Page 2
10282014 RS
Conference with Joanne, Gerry and Scott regarding pending cases;
1.75 $612.50
Work on files, Conference with Chandler, Call to opposing
counsel.
10282014 AV
Westlaw scarch;Draft and revise motion.
1.00 $350.00
10292014 RS
Research regarding fee entitlement; Proposal for settlement; Read
1.60 5560.00
Morgan's letter and latest documents request; Multiple emails with
opposing counsel.
10/30/22014 RS
Work on request to produce; Conference.
0.30 $105.00
1013IP-014 RS
Conference with Morgan, Chandler and Joanne; Conference with
1.60 5560.00
A. Varkas regarding disqualification and 57.105 letters and emails
with opposing counsel; Meeting with law clerk regarding research.
10/312014 AV
Draft motion 57.105; Demand letter; Revise response to motion to
1.50 5525.00
disqualify, notice of filing motion; Westlaw search procedure.
10/312014 AV
Draft motion 57.105; Demand letter; Revise response to motion to
1.50 5525.00
disqualify, notice of filing motion; Westlaw search procedure.
(O'Hare).
10,312014 AV
Draft request to produce to Plaintiff O'Hare.
0.50 5175.00
111022014 RS
Conference with Scott (Sat) ;Prepare request to produce regarding
1.50 $525,00
RICO claims; Emails..
11/032014 RS
Prepare multiple emails to opposing counsel; Work on RICO suit;
1.50 S525.00
Conference with Scott; Conference with law clerk regarding
project.
11/032014 RS
Work on O'Hare request and 57.105 package; Conference with G.
1.25 5437.50
Richman; Work on O'Boyle 57.105 package; Work on O'Hare
57.105 package.
11/042014 RS
Prepare letter and notice; Conference.
0.30 S105.00
11/052014 RS
Review extensive request to produce from O'Boyle; Conference
0.60 $210.00
with opposing counsel.
11/052014 RS
Meeting with law clerk; Work on RICO case.
0.70 $245.00
11/052014 RS
Conference with Scott and Chandler; Receive and review emails;
2.00 $700.00
Conference regarding RICO and work on discovery request.
11/07/_014 RS
(11/7/14 - 11/9/14) Conferences and emails. Review article and
1.60 S560.00
work on discovery.
111100-014 RS
Conference with NJ counsel. Email. Work on RICO. Work on and
2.75 5962.50
review responses to request to produce. Conference with Scott
Morgan.
I III 12014 RS
Conference with co -counsel and Scott Morgan and Clerk
0.40 S140.00
Continued On Next Page
Client Number: 00949
Matter Number; 1679
11212014
Page= 3
11/122014 RS
Conference with Gerry Richman, Joanne O'Connor and Scott
1.50 S525.00
Morgan regarding settlement offer and strategy on RICO suit.
Work on discovery for RICO suit.
11/132014 RS
Meet with law clerk regarding settlement proposal and strategy.
1.60 5560.00
Initial review of NJ transcript and witness conference. Revise
motion.
11/132014 RS
(O'Hare) Conference with Paul Nicoletti. Prepare affidavit and
0.70 $245.00
letter.
11/172014 DV
Conference w. Robert Sweetapple and Alexander Varkas re: status
0.10 $20.00
and responsive motion.
11/172014 RS
Conference re: all pending cases
0.25 S87.50
11/172014 RS
Conference with co -counsel; prepare for hearing
0.70 5245.00
11/182014 RS
Prepare, travel and attend hearing. Meeting with Joanne O'Connor.
3.00 51,050.00
Conference with Scott Morgan. Meet with David Vitale regarding
R. Sweetapple appearance on alletter O'Boyle and O'Hare matters.
Meeting with Gerry Richman re: drafting RICO case; conference
With co -counsel.
11/182014 RS
Conference w. Gerry Richman re: Berger settlement conference.
0.20 570.00
11/182014 RS
Work on lawsuits (eve); Review pending cases to appear
0.50 $175.00
11/182014 DV
Conference w. R. Sweetapple re: motion to disqualify
0.20 540.00
11/182014 DV
Conference with R. Sweetapple to: case status
050 5100.00
11/192014 RS
Receipt and review of entails. Conference with Joanne O'Connor
0.75 $262.50
and law clerk re: additional cases Mayor Morgan has asked R.
Sweetapple to appear in and strategy.
11/192014 RS
Receipt and review of emails; conference with Joanne O'Connor
0.50 5175.00
and Scott Morgan
11202014 DV
Index Martin O'Boyle deposition from prior case per R.
2.00 S400.00
Sweetapple; create word document in support.
!1202014 DV
Conference call with R. Sweetapple, G. Richman, J. O'Connor and
0.60 5120.00
S. Morgan
11212014 RS
Conference with Scott Morgan; Conference with law clerk re:
1.25 5437.50
Motion to Compel and Request to Produce in sanctions case. Work
on O'Hare cases.
11/212014 DV
Parse O'Hare deposition for facts/material to be inserted into
2.30 5460.00
responsive motion to disqualify; Insert into A. Varkas's initial draft
abd print for A. Varkas's review.; Conference with Cynthia Bailey
re: request for expedited hearing per R. Sweetapple's instruction
Continued On Next Page
Client Number: 00949
Matter Number: 1679
Cost Detail
Date Descrinlinn
10/272014 Postage -October 2014
10272014 Photocopy Charges - October 2014
11/21/2014
Page: 4
Billable Hours / Fecs: 61.60 S20,195.00
Amount Check No.
$2.88
8.00
Total Costs $10.88
Prior Balance:
524,352.50
Payments Received:
($24,352.50) Last Payment: 10/272014
Current Fees:
$20,195.00
Advanced Costs:
$10.88
TOTAL AMOUNT DUE: 520,205.88
PLEASE REMIT TO: S WEETAPPLE. BROEKER & VARKAS. P.L.
20 S.E. 3rd. STREET. BOCA RATON. FL 33432
PLEASE INDICATE INVOICE NUMBER ON CHECK. THANK YOU!