HomeMy Public PortalAboutPRR 17-2575RECORDS REQUEST (the “Request”)
Date of Request: _______________
Requestor’s Request ID#: __________________
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@commerce-group.com;
Phone: 954-360-7713; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442
REQUEST: Please provide a copy of all public records (including all communications) in connection
with or resulting from that certain deposition which occurred at the Law Offices of Johnson, Anselmo,
Murdoch, Burke, Piper & Hochman, P.A. located at 2455 East Sunrise Boulevard, Suite 1000, Ft.
Lauderdale, Florida 33304 (the “Premises”) on the evening of March 7, 2017 and all public records
(including all communications) resulting therefrom including, without limitation, all records in
connection with the following sentence. As an example, the Requestor asserted that the space was not
handicapped compliant. Since Martin O’Boyle visited the Premises in connection with an official matter
involving the Town of Gulf Stream, the Requestor believes that all records (including all
communications) requested above would be public records.
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 employees, its
officers, its staff, its Police Department, its Police Officers; including, without limitation, the
attorneys, employees and partners of the following law firms: Sweetapple, 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 §119.01(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 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 Requestor 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”.
IN CONNECTION WITH ANY RECORDS WITHHELD, NOT PRODUCED OR REDACTED, PLEASE PROVIDE US WITH A
“PRIVILEGE LOG” AND/OR THE BASIS (PURSUANT TO CHAPTER 119 OF THE FLORIDA STATUTES) FOR ANY SUCH
RECORDS WITHHELD, NOT PRODUCED OR REDACTED.
I/P/NP/FLRR
03.30.2017
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
August 8, 2017
Martin E. O’Boyle [mail to: records@commerce-group.com]
Re: GS #2575 (PRR 1892)
Please provide a copy of all public records (including all communications) in connection
with or resulting from that certain deposition which occurred at the Law Offices of Johnson,
Anselmo, Murdoch, Burke, Piper & Hochman, P.A. located at 2455 East Sunrise Boulevard, Suite
1000, Ft. Lauderdale, Florida 33304 (the “Premises”) on the evening of March 7, 2017 and all
public records (including all communications) resulting therefrom including, without limitation,
all records in connection with the following sentence. As an example, the Requestor asserted that
the space was not handicapped compliant. Since Martin O’Boyle visited the Premises in
connection with an official matter involving the Town of Gulf Stream, the Requestor believes that
all records (including all communications) requested above would be public records.
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
employees, its officers, its staff, its Police Department, its Police Officers; including, without
limitation, the attorneys, employees and partners of the following law firms: Sweetapple, Broeker
& Varkas; Richman Greer, PA; Jones, Foster, Johnston & Stubbs; Cole, Scott & Kissane, P.A.;
and Johnson Anselmo Murdoch Burke Piper & Hochman, P.A.
Dear Martin E. O’Boyle [mail to: records@commerce-group.com]:
The Town of Gulf Stream has received your public records request dated August 7, 2017. You
should be able to view your original request and partial response at the following link:
http://www2.gulf-stream.org/weblink/0/doc/112535/Page1.aspx
This partial production is also being provided to you in PDF format attached to this e-mail, and
will be made available in its original electronic format if desired.
This letter further requests clarification of public records “in connection with” your assertion at a
private law firm that “the space was not handicapped compliant.” We do not understand your
request to seek any particular records and cannot respond in good faith absent your clarification.
Please clarify the above request as indicated and the Town of Gulf Stream will proceed with
fulfilling your request after receipt of this clarification, or after payment of any requested deposit
or estimate if one is required. If we do not receive clarification 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
8/7(/2017 Johnson, Anselmo, Murdoch, Burke Mail -Re: FW: Anonymous Verbal; Request 4002
%
� M ' Jeff Hochman <hochman@jambg.com>
Re: FW: Anonymous Verbal; Request #002
1 message
Jeff Hochman <hochman@jamhg.com> Tue, Mar 21, 2017 at 9:55 AM
To: Rita Taylor <RTaylor@gulf-stream.org>
Cc: Karen Ericksen <Ericksen@jambg.com>, Hudson Gill <hglll@jambg.com>, Eileen Finley <finley@jambg.com>, Trey
Nazzaro <TNazzaro@gulf-stream.org>
Bee: Jeff Hochman <hochman@jambg.com>
Rita
My office has no responsive documents.
My office never ordered the transcript of the March 7, 2017, deposition of Pamela Latimore in the CG Acquisition v. Gulf
Stream matter, Case No. 14 -CA -07123, and as of this date (3/21/17) we have not received the transcript or copies of the
marked deposition exhibits from the court reporter or any other source.
Jeff
Jeffrey L. Hochman, Esq.
Johnson, Anselmo, Murdoch, Burke, Piper & Hochman, P.A.
2455 East Sunrise Blvd., Suite 1000
Fort Lauderdale, FL 33304
Office: , f) 463-0100 ext. 2917
Fax: (9'_'); 9:3-2444
I ,uchman&ambg.com
On Tue, Mar 21, 2017 at 8:48 AM, Rita Taylor <RTaylor@gulf-slream.crg> wrote:
Good morning, Jeff. Please send all responsive documents.
111111MI TV,
From: Records [mailto: cords@commerce-group.com]
Sent: Monday, March 20, 2017 4:45 PM
To: rs : . opI ` swe_._p,;;-iaw.com; OConnor, Joanne M. <JOConnor@jonesfoster.com>; Rita Taylor
<RTa;lor;;•{!oil eam.org>: postmen@csklegal.com;joshua.goldstein@csklegal.eom; hochman6,jmbg.com;
`rs icrc ,rcont
Subject: Anonymous Verbal; Request #002
We have recited the Verbal request below to avoid any possibility of misunderstanding.
Please provide all transcripts, including all exhibits, (including any and all portions of the transcripts; and
any copies of any such transcripts (including any and all portions of the transcripts) which have (or have
not) been certified) (the "Transcripts") received by the Town of Gulf Stream resulting from the deposition
of Pamela Lattimore dated March 7, 2017 relating to the litigation styled: CG Acquisition Company, Inc.
v. The Town of Gulf Stream. Case No.: 2014 -CA -007123 AG.
https://mail.google.com/maillu/0/7ui=2&ik=8c3l63b5f6&jsver-92leTe34hYB.en.&view=pt&cat=JHOCHMAN%2FE-Mail%20X-tra°/ 2FFollow%,2OUp %2F... 1/2
8/7/2017 Johnson, Anselmo, Murdoch, Burke Mall -Re: FW: Anonymous Verbal; Request#002
https:Hmall.google.comlmaMu/0/7ul=2&ik=8c3163b5f6&Jsver-921eTe34hY8.en.&view=pt&cat=JHOCHMAN%2FE-Mail%20X-tra%2FFollow%20Up%2F... 212
8/7/2017 Johnson, Anselmo, Murdoch, Burke Mail - RE: Pamela Lattimore Contract Records
G�/�
� - 1 Jeff Hochman <hochman@jambg.com>
RE: Pamela Lattimore Contract Records
1 message
Jonathan O'Boyle <joboyle@oboylelawfirm.com> Mon, Mar 13, 2017 at 2:00 PM
To: Jeff Hochman <hochman@jambg.com>
Cc: Kristina Russell <krussell@oboylelawfirm.com>, Jonathan O'Boyle <joboyle@oboylelawfirm.com>, Nick Taylor
<n t a y l o r@ o b o yl e l awfi rm. c o m>
Mr. Hochman, I am in Johnstown Pa for a trial this morning. In response to your email, I will confer with my clients
tomorrow.
Jonathan O'Boyle, Esq., LLM.
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
joboyle@oboylelawfirm.com
New Jersey Office
10 Grove St.
Haddonfield, NJ 08033
Tel: 814-535-5175
Fax: 215-893-3641
joboyle@oboylelawfirm.com
https://mail.gongle. com/mail/u/0/? ui=2&i k=8c3l63b5 r6&jsver-92leTe34hYB.en. &view=pt&cat=JHOC H MAN%2FE-Mail%20X-tm%2F Follow%20tl p%2 F... 114
87/2017 Johnson, Anselmo, Murdoch, Burka Mail - RE: Pamela Lattimore Contract Records
Florida Office
1286 West Newport Center Drive
Deerfield Beach, FL 33442
Office: 954-570-3533
Fax: 754-212-2444
joboyle@oboylelawfirm.com
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 (1) 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.
From: Jeff Hochman [mallto:hochman@jambg.com]
Sent: Thursday, March 09, 2017 11:18 AM
To: Jonathan O'Boyle
Cc: Trey Nazzaro; Karen Erlcksen; Robert Sweetapple; Hudson Gill
Subject: Re: Pamela Lattimore Contract Records
Mr. O'Boyle:
As discussed during the deposition of Pam Latimore on March 7, 2017, 1 have attached the requested engagement
agreement.
The attachment is being provided as an accommodation between counsel in Case No. 14 -CA -007123, CG Acquisition
Co. v. Town of Gulf Stream.
Please note that I am not in a position to accept your email as a public records request. My law firm is not the custodian
of the requested item, is not otherwise obligated to provide the requested item, and is not properly characterized as an
"agency" under section 119.011, Florida Statutes. If the intent of your email was to Issue a public records request, please
proceed under section 119.0701 (3), Florida Statutes.
https://mail.google.com/mal/u/O/7ul=2&ik--8c3l63b5f6&jsver-92leTe34hY8. en.&view-pt&cat-JHOCHMAN%2FE-Mail%20X-tra%2FFollow%2OUp%2F... 2/4
8!7/2017 Johnson, Anselmo, Murdoch, Burke Mail - RE: Pamela Lattimore Contract Records
Your direct examination and re -direct examination of Ms. Latimore extended slightly longer than 3 hours. Please issue a
check made payable to "Town of Gulf Stream" in the amount of $600 ($200 per hour x 3 hours) and send the check to my
office for delivery to the Town.
If the Plaintiff objects, please provide the basis for the objection so I can file a motion and make arrangements for a fee
hearing under Rule 1.390(c).
Jeff
Jeffrey L. Hochman, Esq.
Johnson, Anselmo, Murdoch, Burke, Piper & Hochman, P.A.
2455 East Sunrise Blvd., Suite 1000
Fort Lauderdale, FL 33304
Office: (954) 463-0100 ext. 2917
Fax: (954) 463-2444
Hochman@jambg.com
On Tue, Mar 7, 2017 at 9:32 PM, Jonathan O'Boyle <joboyle@oboylelawfirm.com> wrote
Mr. Hochman, I request Ms. Lattimore's contract with the Town for her $150/200 per hour engagement/contract under
Chapter 119 or under your and/or her representation that you would provide me with the contract. Thank you kindly.
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
joboyle@oboyielawfirm.com
New Jersey Office
httpsJ/mail.google.mmimaillu/0/7ui=2&ik=8c3l63b5f6&jsver=92]eTe34hY8,en.&view=pt&cat=JHOCHMAN°/ 2FE-Mail % 20X-tra % 2FFollow % 2OUp % 2F... 3/4
8/7/2017 Johnson, Anselmo, Murdoch, Burke Mail - RE: Pamela Lattimore Contract Records
10 Grove St.
Haddonfield, NJ 08033
Tel: 814-535.5175
Fax: 215.893.3641
joboyle@oboylelawfirm.com
Florida Office
1286 West Newport Center Drive
Deerfield Beach, FL 33442
Office: 954-570-3533
Fax: 754-212-2444
joboyle@oboylelawfirm.com
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 b- used, for the purpose of (I) avoiding
tax -related penalties under the Intc nal 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.
https://mail.google.com/mall/u/Onui=2&Ik=Bc3l63b5fB&jsver-92leTe34hY8.en.&viev -pt&cat=JHOCHMAN%2FE-Mail%20X-tra%2FFollow%2OUp%2F... 4/4
ENGAGEMENT AGREEMENT BETW t, N
TOWN OF GULF STREAM AND PAMELA LATIMORE
The Town of GuifStream ("Town") hereby engages, retains, and employs Pamela Latimore
("Latimore") to provide services as an expert witness with respect to litigated matters involving the
Town an the following terms:
1. FEES: Latimore is employed on anhourlybasis and will charge the Town forher services
based upon the amount of time she devotes to a particular litigated matter.
2. RATES: Latimore will bill the Town at the rate of S150 per hour for her services related
to review, analysis, preparation of opinions, and travel. Latimom will bill the Town at the rate of
5200 perhourforher services related to testifying during depositions and trial.
3. BILLS: Latimore will issue a separate monthly statement to the Town for each litigated
matter for which she provided her services. Each such statement will provide (1) a brief description
of the services she provided, (2) the date the services were provided, and (3) the amount of time
charged forherservices. Typical examples ofsueb billing entries include thefollov&g: 92.20,16—
Reviewed public records request dated April 3, 2014 .... 0.5 hours' , "12.28.16 — Formulated expert
opinions .... 1.0 hour"; "1.5.17 -- Prepared letter to Town attorney regarding arrangements for
deposition .... 0.1'; "1.6.17 — Participated in telephone conference with Town attorney .... 0.3
hours", "1.10.17 —Testified at trial .... 2.2 hours."
4. PUBLIC RECORDS: Aspart ofthe services provided undert@s Engagement Agreement,
Latimore will comply with Florida's public records laws, including section 119.0701(2)(b), Florida
Statutes, the text of which statutory provision is hereby incorporated into this Engagement
Agreement by reference as if filly printed an this page. IF LATIMORE HAS QUESTIONS
REGARDING THE APPLICATION OF CHAPTER 119, FLORIDA STATUTES,
TO HER DUTY TO PROVIDE PUBLIC RECORDS RELATING TO THIS
ENGAGEMENT AGREEMENT, LATIMORE WILL CONTACT the Town Clerk,
Rita Taylor, 100 Sea Road, Gulf Stream, FL 33483, (561) 276-5116
(rtayl or®gulf-stream. org).
DATED this /B day of February 2017.
Town of Gulf Stream
By: U'
& �Q
William Thrasher
As Town Manager
COMMERCE GROUP
I:/P/NPR/FLRR
www.commerce-group.com
TEL. 954.360.7713 FAX. 954.360.0807
1280 WEST NEWPORT CENTER DRIVE, DEERFIELD BEACH, FLORIDA 33442
moboyle@commerce-group.com
Direct Dial Telephone #954-570-3505
[DS501002.DS2]
August 10, 2017
VIA E-MAIL: RBasel@gulf-stream.org
TELEPHONE #561-276-5116
TELECOPY #561-737-0188
Town of Gulf Stream
100 Sea Road
Gulf Stream, FL 33483
Attn: Reneé Rowan Basel, Executive Administrative Assistant
Re: PRR #1892 (GS#2575)
Dear Ms. Basel:
This will acknowledge your letter of August 8, 2017 regarding our request
#1892. A copy of our Records Request #1892 and your letter of August 8,
2017 are attached for convenience.
Firstly, addressing your partial Response, I point out the following:
1. The Responsive Documents are illegible (the “Illegible Responsive
Documents”). Please provide legible documentation.
2. It appears that there were certain attachments to certain of the
Illegible Responsive Documents. When providing legible copies of the
Illegible Responsive Documents, I ask that you also provide legible
copies of the attachments.
With respect to your request for clarification, please advise as to the
clarification that you are looking for. As I read the Request, it appears to me
to be quite clear; and I do not know how to respond to such a “broad brush”
request for clarification, when I don’t know the area in which you wish the
Reneé Rowan Basel, Executive Administrative Assistant
August 10, 2017
Page 2
__________________________________________________
I:/P/NPR/FLRR
clarification. Specificity in this regard will help us achieve the goal in a
prompt and efficient fashion.
Considering the foregoing, I look for your prompt and courteous response.
Sincerely yours,
COMMERCE GROUP, INC.
Martin E. O'Boyle
President
Attachments
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
August 31, 2017
Martin E. O’Boyle [mail to: records@commerce-group.com]
Re: GS #2575 (PRR 1892)
Please provide a copy of all public records (including all communications) in connection
with or resulting from that certain deposition which occurred at the Law Offices of Johnson,
Anselmo, Murdoch, Burke, Piper & Hochman, P.A. located at 2455 East Sunrise Boulevard, Suite
1000, Ft. Lauderdale, Florida 33304 (the “Premises”) on the evening of March 7, 2017 and all
public records (including all communications) resulting therefrom including, without limitation,
all records in connection with the following sentence. As an example, the Requestor asserted that
the space was not handicapped compliant. Since Martin O’Boyle visited the Premises in
connection with an official matter involving the Town of Gulf Stream, the Requestor believes that
all records (including all communications) requested above would be public records.
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
employees, its officers, its staff, its Police Department, its Police Officers; including, without
limitation, the attorneys, employees and partners of the following law firms: Sweetapple, Broeker
& Varkas; Richman Greer, PA; Jones, Foster, Johnston & Stubbs; Cole, Scott & Kissane, P.A.;
and Johnson Anselmo Murdoch Burke Piper & Hochman, P.A.
Dear Martin E. O’Boyle [mail to: records@commerce-group.com]:
The Town of Gulf Stream has received your public records request dated August 7, 2017. You
should be able to view your original request and partial response at the following link:
http://www2.gulf-stream.org/weblink/0/doc/112535/Page1.aspx
Thank you for letter dated August 10, 2017, in response to the Town’s letter of August 8, 2017,
which provided a partial production of records responsive to your request.
In your letter you state that:
1. The Responsive Documents are illegible (the “Illegible Responsive Documents”).
Please provide legible documentation.
2. It appears there were certain attachments to certain of the Illegible Responsive
Documents. When providing legible copies of the Illegible Responsive Documents, I
ask that you also provide legible copies of the attachments.
Please be advised that the Town has reviewed the alleged Illegible Responsive Documents and
finds them to be legible. Further, the Town produced these documents to you in PDF format,
along with the attachment, on August 8, 2017. As a courtesy, the Town is producing those records
now in their original electronic format.
After spending 15 minutes on your request, the Town now estimates that to fully respond to your
request will require approximately 15 minutes of administrative support at $38.54 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.
(.25 @ $38.54) = Deposit Due: $9.64 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 the Town does 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
Renee Basel
From:Jeff Hochman <hochman@jambg.com>
Sent:Monday, August 14, 2017 1:24 PM
To:Trey Nazzaro
Cc:Karen Ericksen
Subject:Native format response to Request No. 1892 (1 of 2)
Attachments:Latimore Engagement Agreement.pdf
Trey:
The email string below was sent to you previously in pdf to assist in the Town's response to Records Request
No. 1892 dated August 7, 2011, issued by Martin O'Boyle.
As requested, the email string is now being sent in its native format.
If you have any questions, please call me.
Jeff
Jeffrey L. Hochman, Esq.
Johnson, Anselmo, Murdoch, Burke, Piper & Hochman, P.A.
2455 East Sunrise Blvd., Suite 1000
Fort Lauderdale, FL 33304
Office: (954) 463-0100 ext. 2917
Fax: (954) 463-2444
Hochman@jambg.com
_____________________________________________________________
---------- Forwarded message ----------
Jonathan O'Boyle
From: <joboyle@oboylelawfirm.com>
Date: Mon, Mar 13, 2017 at 2:00 PM
Subject: RE: Pamela Lattimore Contract Records
To: Jeff Hochman <hochman@jambg.com>
Cc: Kristina Russell <krussell@oboylelawfirm.com>, Jonathan O'Boyle <joboyle@oboylelawfirm.com>, Nick
Taylor <ntaylor@oboylelawfirm.com>
Mr. Hochman, I am in Johnstown Pa for a trial this morning. In response to your email, I will confer with my clients
tomorrow.
Jonathan O’Boyle, Esq., LLM.
Licensed In Pennsylvania*
Licensed In New Jersey*
1
Licensed in Florida*
The O’Boyle Law Firm, P.C.
www.oboylelawfirm.com
Pennsylvania Office
1001 Broad St.
Johnstown, PA 15906
Tel: 814-535-5175
Fax: 215-893-3641
joboyle@oboylelawfirm.com
New Jersey Office
10 Grove St.
Haddonfield, NJ 08033
Tel: 814-535-5175
Fax: 215-893-3641
joboyle@oboylelawfirm.com
Florida Office
1286 West Newport Center Drive
Deerfield Beach, FL 33442
Office: 954-570-3533
Fax: 754-212-2444
joboyle@oboylelawfirm.com
2
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.
From: Jeff Hochman \[mailto:hochman@jambg.com\]
Sent: Thursday, March 09, 2017 11:18 AM
To: Jonathan O'Boyle
Cc: Trey Nazzaro; Karen Ericksen; Robert Sweetapple; Hudson Gill
Subject: Re: Pamela Lattimore Contract Records
Mr. O'Boyle:
As discussed during the deposition of Pam Latimore on March 7, 2017, I have attached the requested
engagement agreement.
The attachment is being provided as an accommodation between counsel in Case No. 14-CA-007123, CG
Acquisition Co. v. Town of Gulf Stream.
Please note that I am not in a position to accept your email as a public records request. My law firm is not the
custodian of the requested item, is not otherwise obligated to provide the requested item, and is not properly
characterized as an “agency” under section 119.011, Florida Statutes. If the intent of your email was to issue a
public records request, please proceed under section 119.0701(3), Florida Statutes.
Your direct examination and re-direct examination of Ms. Latimore extended slightly longer than 3 hours.
Please issue a check made payable to "Town of Gulf Stream" in the amount of $600 ($200 per hour x 3 hours)
and send the check to my office for delivery to the Town.
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If the Plaintiff objects, please provide the basis for the objection so I can file a motion and make arrangements
for a fee hearing under Rule 1.390(c).
Jeff
Jeffrey L. Hochman, Esq.
Johnson, Anselmo, Murdoch, Burke, Piper & Hochman, P.A.
2455 East Sunrise Blvd., Suite 1000
Fort Lauderdale, FL 33304
Office: (954) 463-0100 ext. 2917
Fax: (954) 463-2444
Hochman@jambg.com
On Tue, Mar 7, 2017 at 9:32 PM, Jonathan O'Boyle <joboyle@oboylelawfirm.com> wrote:
Mr. Hochman, I request Ms. Lattimore’s contract with the Town for her $150/200 per hour engagement/contract
under Chapter 119 or under your and/or her representation that you would provide me with the contract. Thank
you kindly.
Jonathan O’Boyle, Esq., LLM.
Licensed In Pennsylvania*
Licensed In New Jersey*
Licensed in Florida*
The O’Boyle Law Firm, P.C.
www.oboylelawfirm.com
4
Pennsylvania Office
1001 Broad St.
Johnstown, PA 15906
Tel: 814-535-5175
Fax: 215-893-3641
joboyle@oboylelawfirm.com
New Jersey Office
10 Grove St.
Haddonfield, NJ 08033
Tel: 814-535-5175
Fax: 215-893-3641
joboyle@oboylelawfirm.com
Florida Office
1286 West Newport Center Drive
Deerfield Beach, FL 33442
Office: 954-570-3533
Fax: 754-212-2444
joboyle@oboylelawfirm.com
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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)
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ENGAGEMENT AGREEMENT BETW t, N
TOWN OF GULF STREAM AND PAMELA LATIMORE
The Town of GuifStream ("Town") hereby engages, retains, and employs Pamela Latimore
("Latimore") to provide services as an expert witness with respect to litigated matters involving the
Town an the following terms:
1. FEES: Latimore is employed on anhourlybasis and will charge the Town forher services
based upon the amount of time she devotes to a particular litigated matter.
2. RATES: Latimore will bill the Town at the rate of S150 per hour for her services related
to review, analysis, preparation of opinions, and travel. Latimom will bill the Town at the rate of
5200 perhourforher services related to testifying during depositions and trial.
3. BILLS: Latimore will issue a separate monthly statement to the Town for each litigated
matter for which she provided her services. Each such statement will provide (1) a brief description
of the services she provided, (2) the date the services were provided, and (3) the amount of time
charged forherservices. Typical examples ofsueb billing entries include thefollov&g: 92.20,16—
Reviewed public records request dated April 3, 2014 .... 0.5 hours' , "12.28.16 — Formulated expert
opinions .... 1.0 hour"; "1.5.17 -- Prepared letter to Town attorney regarding arrangements for
deposition .... 0.1'; "1.6.17 — Participated in telephone conference with Town attorney .... 0.3
hours", "1.10.17 —Testified at trial .... 2.2 hours."
4. PUBLIC RECORDS: Aspart ofthe services provided undert@s Engagement Agreement,
Latimore will comply with Florida's public records laws, including section 119.0701(2)(b), Florida
Statutes, the text of which statutory provision is hereby incorporated into this Engagement
Agreement by reference as if filly printed an this page. IF LATIMORE HAS QUESTIONS
REGARDING THE APPLICATION OF CHAPTER 119, FLORIDA STATUTES,
TO HER DUTY TO PROVIDE PUBLIC RECORDS RELATING TO THIS
ENGAGEMENT AGREEMENT, LATIMORE WILL CONTACT the Town Clerk,
Rita Taylor, 100 Sea Road, Gulf Stream, FL 33483, (561) 276-5116
(rtayl or®gulf-stream. org).
DATED this /B day of February 2017.
Town of Gulf Stream
By: U'
& �Q
William Thrasher
As Town Manager
Renee Basel
From:Jeff Hochman <hochman@jambg.com>
Sent:Monday, August 14, 2017 1:24 PM
To:Trey Nazzaro
Cc:Karen Ericksen
Subject:Native format response to Request No. 1892 (2 of 2)
Trey:
The email string below was sent to you previously in pdf to assist in the Town's response to Records Request
No. 1892 dated August 7, 2011, issued by Martin O'Boyle.
As requested, the email string is now being sent in its native format.
If you have any questions, please call me.
Jeff
Jeffrey L. Hochman, Esq.
Johnson, Anselmo, Murdoch, Burke, Piper & Hochman, P.A.
2455 East Sunrise Blvd., Suite 1000
Fort Lauderdale, FL 33304
Office: (954) 463-0100 ext. 2917
Fax: (954) 463-2444
Hochman@jambg.com
___________________________________________________________
---------- Forwarded message ----------
Jeff Hochman
From: <hochman@jambg.com>
Date: Tue, Mar 21, 2017 at 9:55 AM
Subject: Re: FW: Anonymous Verbal; Request #002
To: Rita Taylor <RTaylor@gulf-stream.org>
Cc: Karen Ericksen <Ericksen@jambg.com>, Hudson Gill <hgill@jambg.com>, Eileen Finley
<finley@jambg.com>, Trey Nazzaro <TNazzaro@gulf-stream.org>
Rita:
My office has no responsive documents.
My office never ordered the transcript of the March 7, 2017, deposition of Pamela Latimore in the CG
Acquisition v. Gulf Stream matter, Case No. 14-CA-07123, and as of this date (3/21/17) we have not received
the transcript or copies of the marked deposition exhibits from the court reporter or any other source.
Jeff
Jeffrey L. Hochman, Esq.
Johnson, Anselmo, Murdoch, Burke, Piper & Hochman, P.A.
2455 East Sunrise Blvd., Suite 1000
1
Fort Lauderdale, FL 33304
Office: (954) 463-0100 ext. 2917
Fax: (954) 463-2444
Hochman@jambg.com
On Tue, Mar 21, 2017 at 8:48 AM, Rita Taylor <RTaylor@gulf-stream.org> wrote:
Good morning, Jeff. Please send all responsive documents.
Thanks!
From:
Records \[mailto:records@commerce-group.com\]
Sent:
Monday, March 20, 2017 4:45 PM
To:
rsweetapple@sweetapplelaw.com; OConnor, Joanne M. <JOConnor@jonesfoster.com>; Rita Taylor
<RTaylor@gulf-stream.org>; postman@csklegal.com; joshua.goldstein@csklegal.com;
hochman@jambg.com; cfeld@richmangreer.com
Subject:
Anonymous Verbal; Request #002
We have recited the Verbal request below to avoid any possibility of misunderstanding.
Please provide all transcripts, including all exhibits, (including any and all portions of the transcripts; and any
copies of any such transcripts (including any and all portions of the transcripts) which have (or have not) been
certified) (the “Transcripts”) received by the Town of Gulf Stream resulting from the deposition of Pamela
Lattimore dated March 7, 2017 relating to the litigation styled: CG Acquisition Company, Inc. v. The Town of
Gulf Stream. Case No.: 2014-CA-007123 AG.
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