HomeMy Public PortalAboutPRR 16-2426Renee Basel
From:
Daniel DeSouza <ddesouza@desouzalaw.com>
Sent:
Monday, December 5, 2016 11:19 AM
To:
Rita Taylor
Cc:
'OConnor, Joanne M.'
Subject:
Public Records Request
Ms. Taylor,
This is a public records request under Chapter 119, Florida Statutes. I am requesting that Gulf Stream provide to me the
two categories of documents identified below. Prior to providing the documents, please provide me an estimate (via e-
mail) of any costs associated with the production or if Gulf Stream claims any privilege/exemption as to the request.
Please forward the documents to me electronically. If you have any questions, please do not hesitate to contact me.
Thank you for your prompt attention to this matter.
miry 1
1. All e-mails and text messages to or from any attorney and/or law firm representing Gulf Stream (including, but not
limited to, attorneys employed by Richman Greer, Sweetapple Broeker, and/or Jones Foster) in which the subject matter
concerns the pre -suit investigation, the identity of parties to be included as defendants, the likelihood of success, the
expected results, prosecution, and/or appeal of the RICO lawsuit filed by Gulf Stream and Wantman Group in February
2015 (Case No. 9:15-cv-80182) (the "RICO Lawsuit").
2. All memoranda prepared by any attorney and/or law firm representing Gulf Stream (including, but not limited to,
attorneys employed by Richman Greer, Sweetapple Broeker, and/or Jones Foster) in which the subject matter concerns
the pre -suit investigation, the identity of parties to be included as defendants, the likelihood of success, the expected
results, prosecution, and/or appeal of the RICO Lawsuit.
Daniel DeSouza
DeSouza Law. P.A.
101 NE Third Avenue I Sulte 1500 1 Fort Lauderdale, FL 33301
954.603.1340 (office) 1954.551.5320 (mobile)
ddesouza(Mclesouzalaw.com I www.desouzalaw.com
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
December 7, 2016
Daniel DeSouza [mail to: ddesouza(a,desouzalaw.coml
Re: GS #2426 (Public Records Request)
This is a public records request under Chapter 119, Florida Statutes. I am requesting
that Gulf Stream provide to me the two categories of documents identified below.
1. All e-mails and text messages to or from any attorney and/or law firm representing
Gut( Stream (including, but not limited to, attorneys employed by Richman Greer,
Sweetapple Broeker, and/or Jones Foster) in which the subject matter concerns the pre -
suit investigation, the identity of parties to be included as defendants, the likelihood of
success, the expected results, prosecution, and/or appeal of the RICO lawsuit filed by
Gulf Stream and Wantman Group in February 2015 (Case No. 9:15-cv-80182) (the
"RICO Lawsuit').
2. All memoranda prepared by any attorney and/or law firm representing Gulf Stream
(including, but not limited to, attorneys employed by Richman Greer, Sweetapple
Broeker, and/or Jones Foster) in which the subject matter concerns the pre -suit
investigation, the identity of parties to be included as defendants, the likelihood of
success, the expected results, prosecution, and/or appeal of the RICO Lawsuit.
Dear Daniel DeSouza [mail to: ddesouza(&desouzalaw.coml:
The Town of Gulf Stream has received your public records request dated December 5, 2016. The
original public records request can be found at the following link:
httv://www2.gulf-stream.org/weblink/O/doc/103834/Pagel.asvx
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,
As requested by Rita Taylor
Town Clerk, Custodian of the Records
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
December 13, 2016
Daniel DeSouza [mail to: ddesouza(a.desouzalaw.coml
Re: GS #2426 (Public Records Request)
This is a public records request under Chapter 119, Florida Statutes. I am requesting that Gulf
Stream provide to me the two categories ofdocuments identified below:
1. All a -mails and text messages to or from any attorney and/or law firm representing Gulf
Stream (including, but not limited to, attorneys employed by Richman Greer, Sweetapple
Broeker, and/or Jones Foster) in which the subject matter concerns the pre -suit investigation,
the identity ofparties to be included as defendants, the likelihood ofsuccess, the expected
results, prosecution, and/or appeal of the RICO lawsuit filed by Gulf Stream and Wantman
Group in February 2015 (Case No. 9:15-cv-80182) (the "RICO Lawsuit').
2. All memoranda prepared by any attorney and/or law firm representing Gulf Stream
(including, but not limited to, attorneys employed by Richman Greer, Sweetapple Broeker,
and/or Jones Foster) in which the subject matter concerns the pre -suit investigation, the identity
of parties to be included as defendants, the likelihood of success, the expected results,
prosecution, and/or appeal of the RICO Lawsuit.
Dear Daniel DeSouza [mail to: ddesouza(a),desouzalaw.coml:
The Town of Gulf Stream received your public records requests on December 5, 2016. You
should be able to view your request at the following link:
hn://www2.gulf-strearn.org/weblink/O/doc/103834/Paize l .asox
In future correspondence, please refer to this public records request by the above referenced
numbers.
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 attorney time from Sweetapple at
$350.00 per hour and an additional hour of attorney time from Jones, Foster 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.
(One hour @ $350.00 + One hour @ $250.00) = Deposit Due: $600.00 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,
Jzip-d Raw"
As requested by Rita Taylor
Town Clerk, Custodian of the Records