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.
===========================================================
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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.
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ADDITIONAL INFORMATION REGARDING REQUEST:
REQUESTOR'S CONTACT INFORMATION: E -Mail: records@commerce-group.com
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Fax: 954-360-0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442
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Provide a copy of all billings and payments from and to the law firm of Swe pple,
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Broeker & Varkas, P.L. (including Robert Sweetapple singularly) for the bill' period
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ADDITIONAL INFORMATION REGARDING REQUEST:
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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
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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
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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