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HomeMy Public PortalAboutPRR 17-2606 Renee Basel From:Jonathan O'Boyle <jonathanroboyle@gmail.com> Sent:Thursday, November 16, 2017 12:03 PM To:Trey Nazzaro; Rita Taylor; Renee Basel; Jonathan O'Boyle; Jonathan O'Boyle Subject:Public Records Request Attachments:Stop Dirty Government Records Request 11.16.17.docx; Request Exhibits.pdf; Landscape Correspondence Ganger.pdf Dear Records Custodian, on behalf of Stopdirtygovernment, LLC, I submit the attached public records requests for production ASAP. Enclosed are instructions for the Request and copies of public records of the Town of Gulf Stream which we would like to receive certified copies. I will note, that the attachment containing exhibits are merely demonstrative and for the Town's assistance in identifying the public records requested. As for Exhibit 25, that original public record is in the Ganger Transfer file on the Town's website under the document that I believe is entitled Development Correspondence O'Boyle. I will also note that the requests for electronic records should be readily available since we are asking for copies of requests already transmitted to other requestors (with the exception of the fourth request). The requests are not aggregated and we would like production as soon as the records can be produced since time is at-issue. We do not desire to have the Town complete the entire request first and then transmit everything at once. As for Payment, I will send a courier to the Town to submit payment for the certified copies and any other lawful fees. The Courier will contact the Town later today to touch base and work out the details. Thank you ever so kindly for your prompt attention. If you have any questions please email me back at this address -- Jonathan O’Boyle, Esq., LLM. The O’Boyle Law Firm, P.C. www.oboylelawfirm.com joboyle@oboylelawfirm.com Pennsylvania Office 1001 Broad St. Johnstown, PA 15906 1 Tel: 814-535-5175 Fax: 215-893-3641 New Jersey Office 10 Grove St. Haddonfield, NJ 08033 Tel: 814-535-5175 Fax: 215-893-3641 Florida Office 1286 West Newport Center Drive Deerfield Beach, FL 33442 Office: 954-570-3533 Fax: 754-212-2444 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. 2 StopDirtyGovernment, LLC - Public Records Request 11.16.17 for Litigation Resuming on Monday, November 20, 2017. 1.Certified Copies of the Town’s public records reflected in Exhibits 18-23, 25 – that were th admitted into evidence in case 2014CA003721 in the 15 Judicial Circuit styled Stopdirtygovernment, LLC v. Town of Gulf Stream. (Attached Hereto). Specifically for Exhibit 25, we would like a certified color 1 copy that duplicates the document as shown on the Town’s website. 2.Certified copy of an April 23, 2013, letter and enclosures sent by Mr. Thrasher to Ms. Brown with a carbon copy to Mr. Ganger entitled “Re: Landcape Plan for 1465 North Ocean Blvd.” That document is most likely found in the building development file for 1465 North Ocean Blvd. (A copy is attached hereto). 3.A certified copy of Freda Defosse’s resignation letter to the Town of Gulf Stream. 4.Electronic copies of Freda Defosse’s time sheets and/or public records reflecting the amount of time Ms. Defosse worked for the Months of January and February 2014. 5.Electronic Copies of: (1) Town of Gulf Stream Request 587; (2) the initial response given to Request 587 on or about 2/3/2014; (3) any communication from Jones Foster to the O’Boyle Law Firm regarding Request 587 between March 1, 2014 and March 25, 2014 \[particularly from Ashlee Richman\]; (4) the cover page and public records transmitted to the O’Boyle Law Firm in March 2014 by Jones Foster in response to Request 587 and/or because of the litigation initiated pursuant to this request \[tip: March 12, 2014 is believed to be the date of transmission\]. 6.Electronic Copies of the request and response to Request 749 which was sent on March 28, 2014. 7.Certified Copies of a Request and Response 1671 made by Asset Enhancement, Inc. in December of 2014 which regarded Sweetapple’s November Billing Records. In addition to certified copies of redacted billings, it is also requested that a certified copy of the unredacted billings be provided as well. 1 The Highlighted requests are very time sensitive and are needed immediately. In addition, if electronic copies of records are sought, please email them to records@commerce-group.com; joboyle@oboylelawfirm.com; wring@oboylelawfirm.com; and moboyle@commerce-group.com TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail November 16, 2017 Jonathan O’Boyle [e-mail to: jonathanroboyle@gmail.com] Re: GS #2606 (Public Records Request for Litigation Resuming on Monday, November 20, 2017 (7)) 7. Certified Copies of a Request and Response 1671 made by Asset Enhancement, Inc. in December of 2014 which regarded Sweetapple’s November Billing Records. In addition to certified copies of redacted billings, it is also requested that a certified copy of the unredacted billings be provided as well Dear Jonathan O’Boyle [e-mail to: jonathanroboyle@gmail.com] The Town of Gulf Stream has received your public records request dated November 16, 2017. The original public records request can be found at the following link: http://www2.gulf-stream.org/weblink/0/doc/113872/Page1.aspx 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, Reneé Rowan Basel As requested by Rita Taylor Town Clerk, Custodian of the Records TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail November 17, 2017 Jonathan O'Boyle [mail to: ionathanrobovleAgmail.coml Re: GS #2606 (Public Records Request for Litigation Resuming on Monday, November 20, 2017 (7)) 7. Certified Copies ofa Request and Response 1671 made by Asset Enhancement, Inc. in December of 2014 which regarded Sweetapple's November Billing Records. In addition to certified copies ofredacted billings, it is also requested that a certified copy of the unredacted billings be provided as well. Dear Jonathan O'Boyle [mail to: ionathanrobovle(a,gmail.com]: The Town of Gulf Stream has received your public records requests dated November 16, 2017. You should be able to view your original request at the following link: hU://www2.gulf-stream.org/weblink/O/doc/113872/Paeel asix The certified copies you requested are available to be picked up at Town Hall any time between the office hours of 9:00 AM and 4:00 PM. (13 copies @ 1.00 per page) = $13.00 cash or check only. We consider this request closed. Sincerely, ° As requested by Rita Taylor Town Clerk, Custodian of the Records TGS OWN OF ULF TREAM PBC, F ALM EACH OUNTYLORIDA Delivered via e-mail November 17, 2017 Jonathan O’Boyle \[mail to:jonathanroboyle@gmail.com\] Re: GS #2606 (Public Records Request for Litigation Resuming on Monday, November 20, 2017 (7)) 7. Certified Copies of a Request and Response 1671 made by Asset Enhancement, Inc. in December of 2014 which regarded Sweetapple’s November Billing Records. In addition to certified copies of redacted billings, it is also requested that a certified copy of the unredacted billings be provided as well. Dear Jonathan O’Boyle \[mail to:jonathanroboyle@gmail.com\]: The Town of Gulf Stream has received your public records requests dated November 16, 2017. You should be able to view your original request at the following link: http://www2.gulf-stream.org/weblink/0/doc/113872/Page1.aspx The certified copies you requested are available to be picked up at Town Hall any time between the office hours of 9:00 AM and 4:00 PM. (13 copies @ 1.00 per page) = $13.00 cash or check only. The certified copies were picked up by your courier on 11/17/17 and given a receipt for the $13.00 cost. We consider this request closed. Sincerely, Reneé Rowan Basel As requested by Rita Taylor Town Clerk, Custodian of the Records RECORDS REQUEST (the "Request") Date of Request: 12/17/2014 Requestor's Request M#: 959 REQUESTEE: Custodian of Records Town of Gulf Stream REQUESTOR: Asset Enhancement, Inc. h ADDITIONAL INFORMATION REGARDING REQUEST: REQUESTOR'S CONTACT INFORMATION: E -Mail: records@commerce-group.com o Fax: 954-360-0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 a a Uj m m REQUEST: y Provide a copy of all billings and payments from and to the law firm of Swe pple, = o m � {LOO W -Y U p � m o 60 Broeker & Varkas, P.L. (including Robert Sweetapple singularly) for the bill' period Q C is h ADDITIONAL INFORMATION REGARDING REQUEST: . 3 mmiu� .'t O y d~ U p~Uj Uj {LOO W -Y U p W Uj .'t O y d~ U p~Uj Uj {LOO W -Y U p � O QQJ w figg` �U yfc 1_2 THIS REQUEST IS MADE PURSUANT TO PUBLIC RECORDS ACT, CHAPTER 119 OF THE FLORIDA STATUTES AND IS ALSO REQUESTED UNDER THE COMMON LAW RIGHT TO KNOW, THE COMMON LAW RIGHT OF ACCESS; AND ANY STATUTORY RIGHT TO KNOW (INCLUDING, WITHOUT LIMITATION, ANY STATUTORY RIGHT OF ACCESS, AS APPLICABLE). THIS REQUEST IS ALSO MADE PURSUANT TO THE RIGHTS OF THE REQUESTOR PROVIDED IN THE FLORIDA CONSTITUTION. IT IS REOUESTED THAT THIS RECORDS_ REQUEST BE FULFILLED IN ELECTRONIC FORM. 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) 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. I:P/NPR/FRR 09.12.14 FORM TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail December 19, 2014 Asset Enhancement, Inc. [mail to: records@commerce-group.com] Re: GS #1671 (959) Provide a copy of all billings and payments from and to the law firm of Sweetapple, Broeker & Parkas, P.L. (including Robert Sweetapple singularly) for the billing period November, 2014. Dear Asset Enhancement, Inc. [mail to: recordsna,commerce-erouo.coml, The Town of Gulf Stream received your public records request on December 17, 2014. If your request was received in writing, then the request can be found at the following link htty://www2.gulf-stream.org/WebLink8/0/doc/31647/Pagel.asnx. If your request was verbal, then the description of your public records request is set forth in the italics above. In future correspondence, please refer to this public records request by the above referenced number. 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 further respond to your public records request in a reasonable amount of time. Sincerely, Town Clerk CLERK S i,ERTIFICATL STATE OF FLORIDA J COUNTY OF PALM BEACH) ss TOWN OF GULF STREAM ) I Rita L Taylor hereby certify that I am the duly appointed ano acting Clerk of the Town of Gulf Stream, Florida, that the foregoing Is a true and correct copy of a Document, the original of which is on file In the Office of the Town Clerk of the Town of Gulf Sheam, Flonda IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal of said Town, this�day of AD 1u] (SEAL) Rita L. Taykir Town Clark Sweetapple, Broeker, Varkas, P.L. 20 South East 3rd. Street Boca Raton, FL 33,132 Telephone: (561)392-1230 Fax: (561)394-6102 TOWN OF GULF STREAM 0, PAYMENT APPROVED -4 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 Por Services Rendered Through 11/212014. Fees November 21, 2014 Invoice No. 10216 Doe Tmknr Description Ilours Amount 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 S700.00 Chandler; Prepare for O'Hare's deposition. 10222014 DV Complete index of deposition testimony for R. Sweetapple. 2.60 5520.00 10242014 AV Attend deposition of Chris O'Hare. 6.00 $2,100.00 10242014 RS Travel and take O'Hare deposition. 6.00 $2,100.00 10252014 RS Conference with Scott; Receive and review entails; Meeting with 1.00 $350.00 law clerk regarding projects (O'Boyle and O'Hare). 10262014 RS Review Chandler's edits. 020 $70.00 10/27/220 1 4 RS Revise Motion; Call to Chnndler, Conference with Joanne; Review 1.30 $455.00 litigation privilege regarding RICO, state and federal; Prepare for CLERn Sc,�fIFpcc,81,Eilh Gerry. STATEOF F1QS%l70,Pl4 DVI Research statutes and case law re: MOB's banners. 0.80 $160.00 CC1uNry OF PAtW &EA. i) l ul FCrvuN OF Conference with clerk; Review O'Hare website. 0.50 $175.00 I Rita L Taylor halaby Cerhly Mar I im the duly appointed ant. acting C6 k of Ilia Town of Gull Sliewn Flnndathat the foregoing is a true and correct copy of a Dncumeir fhe: oeginal of watch itbMfdoew On Next Page the OLfke or the Town Clerk of the Town rf Gulf SL earn Fk,da IN WITNESS WHEREOF, I have herearlo s," my hm:d arta alti.ed ore official seal of said Town, thisl 7111, day of�A D 2ur� � / (SEAL) " Rita L. Taylor Town Clerk Client Number: 00949 Matter Number: 1679 11212014 Page: 2 10282014 RS Conference with Joanne, Gerry and Scott regarding pending cases; 1.75 $612.50 1.50 5525.00 Work on files, Conference with Chandler; Call to opposing 11/032014 RS Prepare multiple emails to opposing counsel; Work on RICO suit; counsel. Conference with Scott; Conference with law clerk regarding 10282014 AV Westlaw search;DraR and revise motion. 1.00 5350.00 10292014 RS Research regarding fee entitlement; Proposal for settlement; Read 1.60 5560.00 Morgan's letter and latest documents request; Multiple emails with 11/042014 RS Prepare letter and notice; Conference. opposing counsel. 11/052014 RS Review extensive request to produce from O'Boyle; Conference 10/302014 RS Work on request to produce; Conference. 0.30 $105.00 1013 12014 RS Conference with Morgan, Chandler and Joanne, Conference with 1.60 $560.00 2.00 $700.00 A. Varkas regarding disqualification and 57.105 letters and emails 11/072014 RS (11/7/14 - 11/9/14) Conferences and emails. Review article and with opposing counsel; Meeting with Inw clerk regarding research. work on discovery. 10/31/2014 AV Draft motion 57.105; Demand letter; Revise response to motion to 1.50 $525.00 1 nn STATE OF FLUY,I 014 RS Conference with- Email. Work on RICO. Work on and disqualify, notice of filing motion; Westlaw search procedure. COuNTv OF PALM BEACH / ss review responses to request to produce. Conference with Scott 10131P-01,1 AV Draft motion 57.105; Demand letter; Revise response to motion to 1.50 $525.00 I Rita L Taylal lUlaglabrt&Sthat I a9dhfi!00tKXdPdlbfmba=nsel and Scott Morgan and Clerk disqualify, notice of filing motion; Westlaw search procedure. acting Clerk of the Town of Gull Stream, Florida that the foregoing is (O'Hare). 10/312014 AV Draft request to produce to Plaintifl' O'Hare. 0.50 5175.00 11/022014 RS Conference with Scott (Sat) ;Prepare request to produce regarding 1.50 5525.00 RICO claims; Emails.. 11/032014 RS Prepare multiple emails to opposing counsel; Work on RICO suit; 1.50 5525.00 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'Ilare 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 S245.00 11/052014 RS Conference with Scott and Chandler, Receive and review emails; 2.00 $700.00 Conference regarding RICO and work on discovery request. 11/072014 RS (11/7/14 - 11/9/14) Conferences and emails. Review article and 1.60 $560.00 work on discovery. CLERK E UERTIFICAT 1 nn STATE OF FLUY,I 014 RS Conference with- Email. Work on RICO. Work on and 2.75 $962.50 COuNTv OF PALM BEACH / ss review responses to request to produce. Conference with Scott TOWN OF GULF STREAM ) Morgan. I Rita L Taylal lUlaglabrt&Sthat I a9dhfi!00tKXdPdlbfmba=nsel and Scott Morgan and Clerk 0.40 $140.00 acting Clerk of the Town of Gull Stream, Florida that the foregoing is a true and correct copy of a Document. the orfgmal o/ which is Si %nnfd On Next Page the Office of the Town Clerk of the Town of Gulf Stream, Florida IN WITNESS WHEREOF; 1 have heer�r��unto set my hand and affixed the � fl A official seal of said Town, this] 7 rraaay of A 2 Y AD 2u Fla. Stat. § 119.071(1)(d). (SEAL) YL& Y. ori >r Rita L. Taylor Town Clerk Client Number; 00949 Matter Number: 1679 11212014 Page: 3 11/122014 RS Conference with Ge Richman Joanne O'Connor and Scott 1.50 $525.00 Morgan regarding and strategy on RICO suit. Work on discovery ar SO 11/132014 RS Meet with law clerk regarding settlement proposal and strategy. 1.60 $560.00 Initial review or 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 Swectapple and Alexander Varkas re: status 0.10 $20.00 and responsive motion. 11/172014 RS Conference re: all pending cases 0.25 $87.50 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. Swectapple appearance on alletter O'Boyle and O'Hare matters. Meeting with Gerry Richman re: drafting RICO case; conference tooth co -counsel. 11/182014 RS Conference w, Gerry Richman re: Berger settlement conference. 0.20 $70.00 11/182014 RS Work on lawsuits (eve); Review pending cases to appear 0.50 S175,00 11118/2014 DV Conference w. R. Stveetapple re: motion to disqualify 0.20 540.00 11/18/2014 DV Conference with R. Stveetapple re: case status 0.50 5100.00 11/19/2014 RS Receipt and review of emails. Conference with Joanne or 0.75 5262.50 and law clerk re: Man strategy. 11/192014 RS Receipt and review of emails; conference with Joanne O'Connor 0.50 $175.00 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. 11202014 DV COnference call with R. Sweetapple, G. Richman, J. O'Connor and 0.60 $120.00 S. Morgan 11212014 RS Conference with Scott Morgan; Conference with law clerk re: 125 5437.50 Motion to Compel and Request to Produce in sanctions case. Work on O'Hare cases. 11212014n S h.ERT��e deposition for facts/material to be inserted into 2.30 S460.00 a TA FE OF FLORIDA ) responsive motion to disqualify; Insert into A. Varkas's initial draft COUNry OF PALM BEACH / ss abd print for A. Varkas's review.; Conference with Cynthia Bailey TCIrvN OF GULF STREAM / re: request for expedited hearing per R. Sweetapple's instruction ! ting L Taylor herei y cemly that I aln the duly appointed ant, acting Clerk of the .' awl: JI Gulf Stream, Flurida, Met 1110, fereg4749ti9ued On Next Page a flue and collect cupy of a U,.culnen! fhe nnyuwl of which 1s un W6,if the Office of Me Town CIOA of the Town o1 Gull Flarrla IN WITNESS WHEREOF, I have hereunto, ;0,r Bey darn and a!Gx� . file Fla. Stat. § 119.071(1)(d). Official seal of Said Town, fhas day ot-,4�0 ✓ A D 2ulz (SE=AL) ,CL"t - Rita L. Taylor Town Dock Client Number: 00949 Matter Number: 1679 11212014 Page: 4 Billable Hours / Fees: 61.60 520,195.00 Cost Detail Dae Descrintinn Amount Check No. 10272014 Postage - October 2014 $2.88 10272014 Photocopy Charges - October 2014 8.00 Total Casts 510.88 Prior Balance: $24,352.50 Payments Received: (524,352.50) Last Payment: 1027201-0 Current Fees: $20,195.00 Advanced Costs: 510.88 TOTALAMOUNTDUE: $20,205.88 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! CLERK S-r/FICAIt 6TATE OF FLORIDA COuNry OF PALM BEACH l "OWN OF GULF STREAM )) ys I Rita L Taylor herety cerlrly that I am the duly appointed am, acting Cle,k o1 the Town of Gull Stream, a true and correct copy Florida, that the foregoing Is the Ocorner" the original of which is on hie m lfice of the Town Clerk of of the Town of Gulf Stream, Florida IN WITNESS WHEREOF, I have hereunto set my hang and affixed the official seal of said Town, in day of AD 7UL7 (SEAL)' Rita L. raylor Town Clerk Bill Thrasher From: Cynthia Bailey <cbailey@sweetapplelaw.com> Sent: Friday, November -21,2014 3:28 PM To: Bill Thrasher Subject: Town of Gulf Stream Attachments: Invoice 10216.pdf Mr. Thrasher, Attached please rind invoice no. 10216 for your review. Thank you. CYNTHIA J. BAILEY Certified Paralegal/Florida Certified Paralegal/Florida Registered Paralegal Sweetapple, Broeker & Varkas, P.L. 20 SE 3rd Street Boca Raton, FL 33432 (561) 392-1230 (t) x. 305 (561) 394-6102 (f) cbailev(@sweetappielaw.com STATEMENT OF CONFIDENTIALITY The information in this e-mail is confidential and may be legally privileged. If you are not the named addressee, or if this message has been addressed to you in error, you are directed not to read, disclose, reproduce, distribute, disseminate, maintain, save or otherwise use this email. Please contact the sender at the above number immediately. Delivery of this message to any person other than the intended recipient(s) is not intended in any way to waive privilege or confidentiality. CLERA S SERI �t STATE OF FLORIDA COUN r OF PALM BE. ICH Of Twty OF GULF STREAM S ss I I'm C Taylor hereby ,;vgify that l am the duly appointed ant, acfm9 Clo, k o1 the Town o! Gull Strearn, Florida, that the fore om a hue and cared copy u/ a Document the ongmal of which is on file in the Office Ofthe Town Clerk of the Town of Gulf Stream, Florrya g Is IN WITNESS WNF.REOF, I have hereunto set my hens and affixed the oKicia/ sea; of said Town, this {/� , dayof �-=Y�A.D 2Uy (SEAL) i2 cy'F_ RiteLlor Town Oft n z .w -----_- ----- --- ---- .: (q)(S) LL 66LL 7e3S ld O33uenslnd pa7Oepaa ZME ld 'NOlVd V008 13AHIS PIC 3'S OZ 'I'd 'SVN):IVA 8 213N30a8 '31ddV133MS 3O a 8B"SOZ'OZ ..$ E130110 311101 0 ..SJeIlOO 00L18B Pue aAI al un o nvd .i P P 4 PuesnOy) /(juaMl„ 1NOOWV )103110 66600 OL6ZL 6LOZI9ZILL OLl49CZ (L0S) LZbbEB6EE ld'WV3I31531n0 'ON NO3HO 31tl0 )133HO OVOEI V3S OOI IMIZ E9 1Nn000V ONIMEWO .NOKHVO Onvai )1NvelsnulNns Wtl3tl1S =11M=11Md0 NMOl OL17Z l HS,50VOZS SN 50 M t111Z75iilI 00'OS 98'SOi.'OiS 0005 89-SOZ'OZS OL17EL , Ah alcicl unupV �s,,inng I Vn 101-E I S -OI I Es- [IN) yg �c Q 0: LL r o Q ma ,2'So a w o ti LL OJ T Oa ti v n N W m X22 z y �. AuN-PO tIOZ IC I I ZME l:l'NO1Vi1 VJOe 139815 PIE as OZ 'l'd'SV.FHVAV8383O88'97ddVl9-lMS of 1Nn000V ONUVEl3d0 maul jlno 30 NMOL TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail January 6, 2015 Asset Enhancement, Inc. [mail to: records@commerce-group.com] Re: GS #1671 (959) Provide a copy of all billings and payments from and to the law firm of Sweetapple, Broeker & Parkas, P.L. (inchlding Robert Sweetapple singularly) for the billing period November, 2014. Dear Asset Enhancement, Inc. [mail to: records(a)commerce-eroun.coml, The Town of Gulf Stream has received your public records requests dated December 17, 2014. I£ your request was received in writing, then the requests can be found at the following link http://www2.gulf-stream.org/WebLink8/0/doc/31647/Pagel.aspx. If your request was verbal, then the description of your public records request is set forth in the italics above. Please refer to the referenced number above with any future correspondence. The responsive documents can be found at the same link. As reflected on the attached record, exempt information has been redacted pursuant to Fla. Stat. § 119.071(1)(d). A public record that was prepared by an agency attorney or at the attorney's express direction for imminent or ongoing litigation that relates to counsel's mental impression, conclusion, legal strategy, or legal theory is exempt pursuant to Fla. Stat. § 119.071(1)(d). The exempt information here relates to pending and reasonably anticipated imminent litigation involving the Town, William Thrasher, Garrett Ward, Scott Morgan and Robert Sweetapple, on the one hand, and Martin O'Boyle and entities controlled by or affiliated with him including, but not limited to, Commerce GP, Inc., the Commerce Group, Inc., Commerce Realty Group, Asset Enhancement, Inc., CG Acquisition Company, Inc., Citizens Awareness Foundation, Inc., Airline Highway, LLC, N984AC Caravan LLC, CRO Aviation, Inc., and STOPDIRTYGOVERNMENT, LLC., and Christopher O'Hare, on the other hand. Please also note that the checking account number has bet FgcLicpd ppursuant/-i 3 rr - I (5)(b). r L OR10A t UUNTV OF PALM BEACH) ss We consider this matter closed. TOWN OF GULF STREAM / 1 Rita L Taylor hereby candy that I am the duly app led ant, Sincerely, acting Clmk,of the Town o1 Gulf St On? Florida that the foregoing la a true and f the copy u/ a Document, the dngmul of which /s on file n the Once of the rows Clerk of the Town of Gulf Sneam. Flonaa Town Clerk, Custodian of the Records IN WITNESS WHEREOF, I have hereunto set my hand and affixed the Official seal of said Town, this L �> Of &Y c ��day oA.0 1upI (SEAL) �D Rr<aL Taylor raw Cb* Town of Gulf Stream 100 Sea Road Gulf Stream, FL 33483 Sweetapple, Broelrer, Varkas, P.L. 20 South East 3rd. Street Boca Raton, FL 33432 Telephone: (561)392-1230 Fax: (561)394-6102 TOWN OF GULF STREAM 11, -PAYMENT APPROVED -4 heck lr Client Number. 00949 TownofGulfStream Mauer Number: 1679 O'Boyle vs. Town of Gulf Stream Par Services Rentlered Through 11/212014. Fees November 21, 2014 Invoice No. 10216 Date Tmknr Description (lours Amount 1027/2014 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 $700.00 Chandler; Prepare for O'Hare's deposition. 101_22014 DV Complete index of deposition testimony for R. Sweetapple. 2.60 S520.00 10242014 AV Attend deposition of Chris O'Hare. 6.00 52,100.00 10242014 RS Travel and take O'Hare deposition. 6.00 52,100.00 10252014 RS Conference with Scott; Receive and review emails; Meeting with 1.00 $350.00 law clerk regarding projects (O'Boyle and O'Hare). 10262014 RS Review Chandler's edits. 020 $70.00 10127P-0 1 4 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 ResearchSfdfif0ls51= Ec; MOB's banners. 0.80 $160.00 J T4 r OF FLQF IDa lo1_82g16411 OF PXP�tc�e�gF ttiith clerk; Review O'Hare website. 0.50 5175.00 r(,'WN OF GULF S TREAM .., I Rita L Taylor hercuy certify that 1 am the duly p,�_vI�fa,� u acting Clv,A of the Town of Gulf Stream, rfAg�[ y0Wd, "gejoret eng Is a true and c0fr;;ct copy of a Document fhe onga, )I whiel: on ilifile in the Office of file Town Clerk of the Town of Gulf .Sheam. Flvrr IN WITNESS WHEREOF, I havehertXinto set my need and a/6x6,, the official seal of said Town, this 12�'I v day of 0 G, , D ? , (SEAL) Hila L. Taylor TOwnClerk Client Number: 00949 Matter Number: 1679 11212014 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 search;Draft and revise motion. 1.00 $350.00 10292014 RS Research regarding fee entitlement; Proposal for settlement; Read 1.60 S560.00 Morgan's letter and latest documents request; Multiple emails with opposing counsel. 10/302014 RS Work on request to produce, Conference. 0.30 $105.00 101310-014 RS Conference with Morgan, Chandler and Joanne; Conference with 1.60 $560.00 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 $525.00 disqualify, notice of filing motion; Westlaw search procedure. 10/312014 AV Draft motion 57.105; Demand letter; Revise response to motion to 1.50 $525.00 disqualify, notice of filing motion; Westlaw search procedure. (O'Hare). 10/31/2014 AV Draft request to produce to Plaintif' O'Hare. 0.50 5175.00 11/022014 RS Conference with Scott (Sat) ;Prepare request to produce regarding 1.50 $525.00 RICO claims; Emails.. 111032014 RS Prepare multiple emails to opposing counsel; Work on RICO suit; 1.50 $525.00 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 $437.50 Richman; Work on O'Boyle 57.105 package; Work on O'llare 57.105 package. 1110412014 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 5245.00 11/05h_014 RS Conference with Scott and Chandler, Receive and review emails; 2.00 $700.00 Conference regarding RICO and work on discovery request. 11/072014 RS (11/7/14 - 11/9/14) Conferences and emails. Review article and 1.60 $560.00 TIME s- UM9CNTt: J tVkQ/t,4114L 0040A Conference with NJ counsel. Email. Work on RICO. Work on and 2.75 $962.50 COuN t v OF PALM HE lreiviq,& responses to request to produce. Conference with Scott /OWNOF GULF STREAMmigan. acting Clebk of e6�ifd(�3i6e�44iElS �ILol4��+11@fldBcott Morgan and Clerk n!e� Gulf Shuam. Flhada if the faregamnct is 0.40 5140.00 a Irue and correct copy of a Document the ungm,,Cpnt4W49a)N2pf; ggge the Office Of the Town CIerA of the Town Of Gull Sheam. Flung= IN WITNESS WHEREOF, I have hereunto set my nano and affixed rtte official seal of said Town, lhisA!2�doy of eov t.D ?uf (SEAL)22 . Q Rita L. Taylor Town Clerk Client Number: 00949 Matter Number: 1679 11/182014 RS Work on lawsuits (eve); Review pending cases to appear 11212014Page: 11/182014 DV Conference w. IL Sweetapple re: motion to disqualify 0.20 S40.00 11/18/2014 DV Conference with R. Sweetapple re: case status 3 11/122014 RS Conference with Gerry Richman, Joanne O'Connor and Scott 1.50 S525.00 Sweetapple to appear in and strategy. Morgan regarding settlement offer and strategy on RICO suit. 11/192014 RS Receipt and review of emails; conference with Joanne O'Connor 0.50 5175.00 and Scott Morgan Work on discovery for RICO suit. 11202014 DV Index Martin O'Boyle deposition from prior case per R. 2.00 $400.00 11/132014 RS Meet with law clerk regarding settlement proposal and strategy. 1.60 $560.00 S. Morgan Initial review of NJ transcript and witness conference. Revise 11212014 RS Conference with Scott Morgan; Conference with law clerk re: 125 $437.50 Motion to Compel and Request to Produce in sanctions case. Work motion. on O'Hare cases. CLERK S t,ERI'IFICATE 11/132014 RS (O'Hare) Conference with Paul Nicoletti. Prepare affidavit and 0.70 S245.00 TOWN OF GULF STPEA,bt abd paint for A. Varkas's review.; Conference with Cynthia Bailey letter. I Rita L Taylor harcDy certify5905m thfor expedited aPPomted ant, per R. Stveetapple's instruction 11/172014 DV Conference w. Robert Sweetapple and Alexander Varkas re: status 0.10 $20.00 IN WITNESS WHEREOF, I have hereunto set my hand and allixed the and responsive motion. official seal of said Town, lhis_L_Itsof if/ i 2U,(2 11/17/22014 RS Conference re: all pending cases 0.25 $87.50 11/172014 RS Conference with cd -counsel; prepare for (tearing 0.70 $245.00 11/182014 RS Prepare, travel and attend hearing. Meeting with Joanne O'Connor. 3.00 S1,050.00 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 wool 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. IL Sweetapple re: motion to disqualify 0.20 S40.00 11/18/2014 DV Conference with R. Sweetapple re: case status 0.50 5100.00 11/192014 RS Receipt and review of emails. Conference with Joanne O'Connor 0.75 S262.50 and late 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 $400.00 Sweetapple; create word document in support. 11200_014 DV COnference call with R. Sweetapple, G. Richman, J. O'Connor and 0.60 $120.00 S. Morgan 11212014 RS Conference with Scott Morgan; Conference with law clerk re: 125 $437.50 Motion to Compel and Request to Produce in sanctions case. Work on O'Hare cases. CLERK S t,ERI'IFICATE aTATE UP L44AIADV /Parse deposition for facts/materiel to be inserted into 2.30 S460.00 COuNry OF PALM BE,ICN I %sponsive motion to disqualify; Insert into A. Varkas's initial draft TOWN OF GULF STPEA,bt abd paint for A. Varkas's review.; Conference with Cynthia Bailey I Rita L Taylor harcDy certify5905m thfor expedited aPPomted ant, per R. Stveetapple's instruction 6011179 Clark of the ;'nwn of Gulf Stream. Florida, that th forg , [i� a true and corrucl copy of a Document, the urrgmal of wbipntu ""N7�7e"m ext Pege the Office of the Town Clerk of the Town of Gulf Slraew. Florrrin IN WITNESS WHEREOF, I have hereunto set my hand and allixed the official seal of said Town, lhis_L_Itsof if/ i 2U,(2 (SEAL) /kf -A � Rita L. Taylor Town Clerk Client Number: 00949 hlntier Number: 1679 Cost DDtail DPI.4 Description 10/27/2014 Postage - October 2014 10272014 Photocopy Charges - October 2014 11/21/2014 Page: I Billable Hours / Fees: 61.60 520,195.00 Amnunt Check No. 52.88 8.00 Total Costs $10.88 Prior Balance: $24,352.50 Lust Payment: 10/27201) Payments Received: ($24,352.50) Current Fees: $20,195.00 Advanced Costs: S10.88 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! CLERII S t,ERr1FI d r STATE OF FLORIDA COUNry OF PALM BEACH TOWN OF GULF STREAM )ss I Rife L Taylor hereby certify that I am the duly appointed ant. acting Clark of the Town of Gulf Stream, Florida, that the foregoing IS ah true and correct Copy Of a Document, fhe Original is of which on hm ie e Office of the Town Clark of the TOwn of Gulf Stream. ch das IN WITNESS WHEREOF, 1 have hereunto set my hand and affixed the O fiolal seal of said Town, thiSJQ2 day of AD 2uj� AZ4V Z,, �-- RifaaLTaylor Town Clerk