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Home My Public Portal AboutPRR 17-2471Renee Basel From: Jonathan O'Boyle <joboyle@oboylelawfirm.com> Sent: Friday, January 6, 2017 3:52 PM To: Trey Nazzaro; Renee Basel Cc: Jonathan O'Boyle Subject: Records Request Dear Custodian, I would like to make the following requests under Chap 119 and Art I Sec 24 Fla. Const. I would like Gerry Richman's RICO File that he created on behalf of the Town. I would like Robert Sweetapple's RICO file that was created on behalf of the Town. I would like Jones Foster's RICO file that was created as part of their duties as Town attorney. I would like the Town's RICO file. The above requests are seeking all documents related to the RICO case. To the extent there are emails, voicemails, text messages and memorandum, I would like those. If there is any doubt whether a record will be responsive, let me know, I can work with you guys on clarifying. I will note that I told Joanne in 2015 that she should preserve the Towns Rico files since I will be asking for them at the conclusion of litigation. I would like for estimates in advance, production schedules, and electronic documents where possible or feasible. I suspect that others may be asking for identical information so I am open to coordinating and not reduplicating efforts and/or tiering production. I would like emails sent from Scott Morgan first (please check with him about the use of his private emails and cell phone as he has used them in the past to conduct Town business). As a separate category of requests, I would also like communications (email/text/written) between Scott Morgan and Officer Passagiatta for September 15, 2015 to present. Thank you. I would also like emails between the Town and Jones Foster regarding Martin O'Boyle's Sober House Letter (dated 6/6/14) and Ordinance 14/2 between June 1, 2014 and up to the first reading of Ordinance 14/2. To be clear, I understand Jones Foster is the Town Attorney and I would like their internal communications which regard Martin O'Boyle's Sober House Letter and ordinance 14/2. I would also like all documents where William Thrasher 06.06.14.pdf was an attachment (electronic or otherwise if it was printed out). To help identify that document That PDF was in an email sent June 11, 2014 3:55 p.m. sent by Mr. Thrasher at bthrasher(aieulf-stream.ore. I would also like documents (electronic or otherwise) which show the transfer of funds received from permit fees collected pursuant to Resolution 011-7 after the funds were received. I want the records which memorialize where the funds were deposited into (an account i.e. general fund, payroll, ect.). I highlighted the last two requests because I would like those to take priority over all other requests. They are pertinent to pending litigation and thus, the need for these documents is heightened and paramount. If possible, I will be willing to pay a 'rush' service charge to acquire these documents ASAP. Thank you kindly, Please email me back at this email if any questions, comments, concerns arise. Jonathan O'Boyle, Esq., I.I.M. Licensed In Pennsylvania* Licensed In New Jersey* Licensed in Florida* The O'Boyle Law Firm, P.C. www.oboyielawfirm.com Pennsylvania Office 1001 Broad St. Johnstown, PA 15906 Tel: 814-535-5175 Fax: 215-893-3641 jobovle@obovlelawfirm.com New Jersey Office 30 Grove St. Haddonfield, NJ 08033 Tel: 814-535-5175 Fax: 215-893-3641 jobovle@obovlelawfi rm.com Florida Office 1286 West Newport Center Drive Deerfield Beach, FL 33442 Office: 954-570-3533 Fax: 754-212-2444 j o b o v l e@ o b oy t e l a wf i t m. co m IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication, unless expressly stated otherwise, was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax -related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any tax -related matter(s) addressed herein. ----------------------------------------------------------- NOTICE TO RECIPIENT: THIS E-MAIL IS MEANT FOR ONLY THE INTENDED RECIPIENT OF THE TRANSMISSION, AND MAY BE A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVED THIS E- MAIL IN ERROR, ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN E-MAIL AND PLEASE DELETE THIS MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR YOUR COOPERATION. TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail January 12, 2017 Jonathan O'Boyle [mail to: iobovle(7a.oboylelawfirm.coml Re: GS #2471 (Record Request — Towns RICO) I would like the Town's RICO file. Joanne in 2015 that she should preserve the Towns Rico files since I will be asking far them at the conclusion of litigation. I would like for estimates in advance, production schedules, and electronic documents where possible or feasible. I suspect that others may be asking for identical information so I am open to coordinating and not reduplicating efforts and/or tiering production. I would like emails sent from Scott Morgan first (please check with him about the use of his private emails and cellphone as he has used them in the past to conduct Town business). Dear Jonathan O'Boyle [mail to: ioboyle(d1obovlelawfirm.coml: The Town of Gulf Stream has received your public records request dated January 6, 2017. The original public records request can be found at the following link: httn://www2.gulf-stream.org/weblink/O/doc/104548/Pagel.aEx 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, t�D e �E RAWA4. $ As requested by Rita Taylor Town Clerk, Custodian of the Records TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail February 27, 2017 Jonathan O'Boyle [mail to: ioboyleCa,oboylelawfirm.com] Re: GS #2471 (Record Request - Town's RICO) I would like the Town's RICO file. Joanne in 2015 that she should preserve the Towns Rico files since I will be asking for them at the conclusion of litigation. I would like for estimates in advance, production schedules, and electronic documents where possible or feasible. I suspect that others may be asking for identical information so I am open to coordinating and not reduplicating efforts and/or tiering production. I would like emails sent from Scott Morgan first (please check with him about the use of his private emails and cellphone as he has used them in the past to conduct Town business). Dear Jonathan O'Boyle [mail to: ioboyle(a),oboylelawfirm.coml: The Town of Gulf Stream has received your public records request dated January 6, 2017. You should be able to view your original request at the following link: hgp://www2.mlf-stream.orF/weblink/O/doc/104548/Pagel asnx You can find responsive records by going to the Town's website, www.eulf-stream.ore and clicking on "Find a Town a Record", then going to "Legal", "Lawsuits", "Town of Gulf Stream". The Town considers these documents to be its "RICO File". We consider this request closed. Sincerely, Rased Riaw . 944d As requested by Rita Taylor Town Clerk, Custodian of the Records