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HomeMy Public PortalAboutPRR 17-2607 PUBLIC RECORDS REQUEST (the “Request”) [DS501093.DS2] Date of Request: November 16, 2017 Requestor’s Request ID#: __________________ TO: Custodian of Records Town of Gulf Stream 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 the following: 1. A copy of every ledger, statement and/or invoice received from (1) Sweetapple, Broeker & Varkas, (2) Jones, Foster, Johnston & Stubbs, (3) Richman Greer, P.A., (4) Cole Scott & Kissane and/or (5) Johnson Anselmo Murdoch Burke Piper & Hochman, P.A. for legal services provided in O’Boyle v. Town of Gulf Stream, Case No. 2014-CA-004474-AG (Fla. 15th Jud. Cir.), Town of Gulf Stream v. O’Boyle, Case No. 2016-CA-005437 (Fla. 15th Jud. Cir.), or Town of Gulf Stream v. Martin E. O’Boyle, et al., Case Nos. 4D16-3386 and 4D16-3634 (Fla. 4th DCA) from January 1, 2014 through the date of this Request. If a Response to this Request is not received by the close of business on November 23, 2017, we will send a formal 5 day notice to the Town of Gulf Stream (and its component parties as defined herein). 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 COPIES 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 November 17, 2017 Martin E. O’Boyle [e-mail to: records@commerce-group.com] Re: GS #2607 (PRR 1899) A copy of every ledger, statement and/or invoice received from (1) Sweetapple, Broeker & Varkas, (2) Jones, Foster, Johnston & Stubbs, (3) Richman Greer, P.A., (4) Cole Scott & Kissane and/or (5) Johnson Anselmo Murdoch Burke Piper & Hochman, P.A. for legal services provided in O’Boyle v. Town of Gulf Stream, Case No. 2014-CA-004474-AG (Fla. 15th Jud. Cir.), Town of Gulf Stream v. O’Boyle, Case No. 2016-CA-005437 (Fla. 15th Jud. Cir.), or Town of Gulf Stream v. Martin E. O’Boyle, et al., Case Nos. 4D16-3386 and 4D16-3634 (Fla. 4th DCA) from January 1, 2014 through the date of this Request. If a Response to this Request is not received by the close of business on November 23, 2017, we will send a formal 5 day notice to the Town of Gulf Stream (and its component parties as defined herein). Dear Martin E. O’Boyle [e-mail to: records@commerce-group.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/113879/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 22, 2017 Martin E. O'Boyle [mail to: records(a,commerce-erouo.coml Re: GS #2607 (PRR #1899) A copy ofevery ledger, statement and/or invoice received from (1) Sweetapple, Broeker & Parkas, (2) Jones, Foster, Johnston & Stubbs, (3) Richman Greer, P.A., (4) Cole Scott & Kissane and/or (5) Johnson Anselmo Murdoch Burke Piper & Hochman, P.A. for legal services provided in O'Boyle v. Town of Gulf Stream, Case No. 2014 -CA -004474 -AG (Fla. 15th Jud. Cir.), Town of Gulf Stream v. O'Boyle, Case No. 2016 -CA -005437 (Fla. 15th Jud. Cir.), or Town of Gu f Stream v. Martin E. O'Boyle, et al., Case Nos. 4D16-3386 and 4D16-3634 (Fla. 4th DCA) from January 1, 2014 through the date of this Request. If a Response to this Request is not received by the close of business on November 23, 2017, we will send a formal 5 day notice to the Town of Gulf Stream (and its component parties as defined herein). Dear Martin E. O'Boyle [mail to: recordsna.commerce-erouo.coml: 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: httv://www2.jzulf-strearn.org/weblink/O/doc/I 13879/Pagel.aspxx The Town understands the request to be seeking copies of approximately four years of bills from multiple law firms and that the more recent bills that have not been produced in response to other public records requests will need to be reviewed for attorney work product. To that end, the Town has spent at least 15 minutes on your request and is providing you with a partial response at the same link above. The Town now estimates that to fully respond to your request will require approximately an additional two hours of administrative support at $26.95 per hour and 3.7 hours of attorney time at $68.74 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. (Two hours @ $26.95 = $53.90 + 3.7 hours @ $68.74 = $254.34) = Deposit Due: $308.24 in cash or check. Upon receipt of your deposit, the Town will use its very best efforts to further respond to your public records request in a reasonable amount of time. If we do not hear back from you within 30 days of this letter, we will consider this request closed. Sincerely, t tO( As requested by Rita Taylor Town Clerk, Custodian of the Records Sweetapple, Broelcer, Varlcas, P.L. 20 South East 3rd. Street Boca Raton, FL 33432 Telephone: (561)392-1230 Fax: (561)394-6102 %;F GULF STREAM 1�'rAYMEN TAPPROVED -1 Town of Gulf Stream Amount 7,17 100 Sea Road Gulf Strewn, FL 33483 BY Dale t �t-heclt.P 114f�I Dale April 29,2014 Invoice No. 10134 Client Number. 00949 Town of Gulf stream Matter Number. 1679 O'Boyle vs. Town of Gulf stream Pur Services Rendered Through 4129/2014. Fees Date Tn, kn Description flour Amount 04!0112014 RS Review file; Conference; Prepare for meeting. 1.00 $350.00 04102/1014 RS Conferences; Review case law. 1.50 $523.00 04!03!2014 Rs Travel and attend meeting with town attorney and Scott Morgan; 7.50 $2,625.00 Begin review all files provided by Jones Foster (evening). (Date 04/02). 04/04/2014 RS Conferences. 0.30 $105.00 04!06/2014 RS Continue reviewing files. 1.50 5525.00 04/14i20I4 RS Review Sunshine and public records cases and status regarding 1.00 5350.00 pending claims; Receive and review emails. 04,01712014 RS Conference with Scott; Conference with Joanne. 0.30 S105.00 04118.r2014 Rs Review reports and correspondence. 0.40 S140.00 04!21/2014 RS Review files. 1.50 5525.00 04`21/2014 RS Review emails, memos and cases; Research regarding O'Hare and 2.20 5770.00 email to opposing counsel. 04;23!2014 RS Review correspondence and emails. 0.40 5140.00 04i24i2014 RS Prepare travel and attend hearing and settlement conference. 2.50 5875.00 04!2512014 RS Review Citizen Awareness frits. 0.50 5175.00 Continued On Nest Page Client Number: 00949 Matter Number: 1679 041352014 R5 Receive and review files; Conference will, Scott. 04!26/2014 RS Conference; Work on letter. Billable Hours! Pees: Cost Detail Dole Description 04!25!2014 Plmlocopy Charges - April 2014 040-8!3014 Postage - April 2014 'Fatal Costs Prior Balance: 50.00 Payments Received: $0.00 Current Fees: $7,560.00 Advanced Costs: SI4.17 TOTAL AB10UIr f DUE: S7,574.17 04.'34'2014 Pine 2 0.60 S210.00 0.40 $140.00 21.611 $7,560.00 Ammim Chect: Nn. 51325 1.92 SI -1.17 PLEASE REMIT TO: SWEETAPPLE. BROEKER & VARKAS. P.L. 20 S.E. 3rd. STREET. BOCA RATON. FL 33432 PLEASE INDICATE INVOICE NUMBER ON CHECK. THANK YOUI Sweetapple, Broeker, Varkas, P.L. 20 South East 3rd. Street Boca Raton, FL 33432 Telephone: (561)392-1230 Fax: (561)394-6102 Town of Gulf Stream 100 Sea Road Gulf Stream, FL 33483 June 30, 2014 invoice No. 10159 ClientNumbcr. 00949 TownofGulfSueam MaticrNumhcr: 1679 O'Boyle vs. To%nofGulf Sutam Gar Services Rendered Through 6/302014. _ + u n� I MrAAIVI I-, PAYMENT APPROVED -4 Amou t 15 /? 113y 4/ Date, hj 1 Check;, IAI 31 Date '1 1 )4 Fees Date Tmknr Description hours ,Amount 05/04/3014 RS Conferences with Scott, Joanne, Skip Randolph and law clerk; 0.75 5362.50 Duces tecum. (Date 05/03). 05/30/2014 RS Conference with attorneys. 0.20 570.00 06/01/2014 RS Review motion and authorities. 0.20 $70.00 06/03/2014 RS Conference with apposing counsel. 0.20 570.00 0610212014 RS Receive and review letter, motion and authorities; Conference. 0.40 5140.00 06104!3014 RS Additional conference regarding meeting with O'Boyle. 0.20 570.00 06;052014 RS Conferences with Scott and Jordan; Conference call with Scott and 1.40 5490.00 Joanne; Work on revisions to letter and subpoena. (Date 06/04). 06/06/2014 RS Several conferences with client and opposing counsel; Receive 1.20 $420.00 and review emails. 06108!2014 RS Conference regarding strategy; Receive and review memo; Prepare 1.70 S595.00 memo. (Date 06/07). 06/09/2014 RS Conference with Skip; Conference with client; Receive and review 1.20 5420.00 email. 06/10/2014 RS Conferences with Kelly and Scott. 0.70 5345.00 Continued On Nat Page Client Number: 00949 Natter Number: 1679 063012014 Page: 2 06/11/2014 RS Receive and review emails and respond; Conference with Joanne; 210 5770.00 Review letter from town; Conference with Skip Randolph and client; Conference with law clerk regarding research. 06/11/2014 RS Receive and review email and respond, conference. 0.20 570.00 06111/2014 RS Conference with client regarding research; Review strategy 4.00 51,400.00 regarding O'Boyle interference with contract with counsel; Conference with Ashley; Conference with Jones Paster regarding research and claims; Conference with Scott regarding options; Conference with Dave and A. Varkas regarding research about O'Boyle law firm. (Date O6110). 06/12/2014 RS Conference with A. Varkas regarding requests; Conference 110 5420.00 regarding strategy; Receive and review documents and prepare emails. 06/13/2014 RS Receive and review emails and calls. 0.40 $140.00 0611312014 RS Conference with opposing counsel Conference with prospective 0.80 $280.00 opposing counsel; Conference with client. 06/13/2014 AV Westlaw search 1) Litigation abuse i.e. threats 2) Interference with 1.50 $525.00 attorney/client relationship (read and summarize case law). 06/14!2014 RS Work on Request for Admissions; Review case law and prepare 3.00 $1,050.00 memo; Conference with client and opposing counsel. 06/16/2014 RS Conference with Gerry; Review information; Conference with 0.50 5175.00 client. 06/16/2014 RS Conference with client; Conference with Joanne; Work on 0.70 5245.00 requests. 06/17/2014 RS Review responses, answers and emails; Conference with law clerk. 0.70 5245.00 06/1 V2014 RS Receive and review records; Conference with A. Varkas; Prepare 1.25 5437.50 letter. 06/19/2014 RS Conference with Gerry; Conference with Dave regarding research. 0.50 S175.00 0611912014 RS Conference with Scott; Conference with Gerry; Interview. 0.60 5210.00 06119/2014 RS Receive and review article; Conference with client; Rcvise email 0.70 5245.00 and letter. 06!19/2014 RS Prepare letters and emails; Review opinion. 110 5420.00 06!19/2014 RS Follow up conference with client; Dictate pleading and revise 0.60 5210.00 letter. 06/19/2014 RS Joint conference with counsel and client. 1.00 5350.00 Continued On Next Page Client Number. 00949 Matter Number: 1679 06/30/2014 Past 3 06/222014 RS Conference with Joanne; Conference with client; Conference with 2.40 5940.00 515,120.00 Gerry; Conference media; Conference regarding expert witnesses; 5557 Conference media; Review article. (Date 06121). 0623/2014 RS \Nark on Motion for production; Meeting with Skip and Joanne at 235 5787.50 J. Fosters; Conference with client. 06/24/3014 RS Conference with client; Meeting with potential expert. (Date 1.75 5612.50 06122). 06/25/2014 RS Conference with Scott; Conference with Joanne, Meeting with A. 2.50 5875,00 Varkas; Conference with Joanne; Review cases from Joanne; Work on motion for sanctions; Receive and review entails from Lily; Email to Joanne. 06/26/2014 RS Revise Motion and request to produce. 0.40 $140.00 0626!2014 RS Dictate motion for sanctions, letter, Notice to Depo and request to 3.50 $1,225.00 produce; Rcview extensive material regarding M.O. in other districts; Conference with client. 06130.2014 RS Meeting with client and conferences with Jamie Cole and A. 130 5420.00 Varkas regarding claims. Billable Hours / Fees: 43.20 515,120.00 Cost Detail hale neserlptinn 06/25/2014 Photocopy Charges - June 2014 06/26/2014 Postage - June 2014 Amount Check Nn. 53.50 2.07 Total Costs S5.57 Prior Balance: Payments Received: 57,04.78 LestPaymen40G/052014 (57,0_4.78) Current Fees: 515,120.00 Advanced Costs: 5557 TOTALAMOUNTDUE: SI5,12557 001 5'3l/O 515 ID PLEASE REMIT TO: S WEETAPPLE. BROEKER & VARKAS. P.L. 20 S.E. 3rd. STREET. BOCA RATON. FL 33433 PLEASE INDICATE INVOICE NUMBER ON CHECK. THANK YOU! I> RECEIVED q JUL 28 2014 Town of Gulfstream, FL Town of Gulf Stream 100 Sea Road Gulfstream, FL 33483 Sweetapple, Brock -or, Varkas, P.L. 20 South East 3rd. Street Boca Raton, PL 33432 Telephone: (561)392-1230 Fax: (561)394-6102 P Client Number. 00949 TownofGulrstreamY_� Matter Number. 1679 O'Boyle vs. Town ofGulfstrcam Check :S rorSen,ices Rendered Through 7/252014. 1-'—_,_�. IF, July 25, 2014 Invoice No. 10169 GULF &T—RI UT APPROVED a Rale Tmknr nescrinllan Noon Amount AV Research: Sanctions agreement opposing party and attorney for 1.75 5612.50 litigation abuse (read and summarize case late, treatise and rules); Revise Motion for Sanctions Agreement O'Boyle, attorney and son's law firm (include memo of law). 06/30t-7014 RS Review client edits to Motion and revise; Review case law 0.75 regarding abuse of process. S262.50 06/301-014 AV Wcsllaw search 1) Limitations on rights to public records (rend 1.50 and summarize case low). S525.00 071022014 RS Conference with Scott; Work an files. 0.40 s140.00 07/022014 RS Conference with Scott; Conference will) Joanne. 0.40 5140.00 07/02/2014 AV Westlaw search: Unauthorized practicing of low (read and 0.75 summarize cases); Conference with R. Sweetapple and Joanne S262.50 O'Connor. 07/022014 RS Conference with A. Varkas; Conference with Joanne; Review, 1.50 revise notice; Revise Motion; Review additional case law. 5525.00 07/042014 RS Conference with Joanne; Conference with client; Conference with 0.80 A. Varkas and Ball. 5280.00 07/062014 RS Work an strategy; Outline projects; Conference with Scott; 1.75 Review email; New case exhibits; Conference with Joanne and S612.50 Scott. Continued On Next Page Client Number. D0949 alaller Number. 1679 07252014 Page: 2 07/062014 RS Conference with Witness; Conference with witness counsel. 0.30 5105.00 07/06P-014 RS Conference with Scott; Receive and review cases and documents; 1.50 S525.00 Work on claim. 07/082014 RS Conference regarding witness interview, affidavit and deposition. 0.40 071082014 RS Conference with Ken; Conference 5140.00 with attorney. 0.70 5245.00 07/092014 RS Conferences with client and Joanne; Witness interview. 07/102014 RS Conference will, Joanne and witness. 0.70 5245.00 07/112014 RS Receive and review emails; Prepare response; Review Weiss 0.40 s140.00 materials regarding Sober !douse; Conference with client and 1.60 5560.00 Joanne regarding deposition. Deposition preparation. (Date 07/10). 07/142014 RS Receive and review emails; Conference with witness regarding 125 deposition; Conference with client. S437.50 07/152014 AV Westlaw and statute search: Objection to O'Boyles Witness subpoena in R. Swcetnpple (read and summarize statute and rule). 0.50 5175.00 07/162014 RS Review evidence; Outline issues; Prepare for conference; Conference with client. (Date 07/15). 2.75 5962. 50 07/162014 AV Westlaw search abuse of process - a cause of action against O'Boyle (read and summarize case lav for R. Sweelapple). ISO 5525.00 07/172014 RS Prepare Travel and attend hearings; Motion with two different co -counsels regarding new claim; Interview witness; Conference 5.00 S1,750.00 with Wird co -counsel; Conference With client; Prepare letter; Conference with opposing counsel. 07212014 RS Conference will, client and co -counsel; Prepare for meeting. 07212014 AV Review Motion for Protective Order/Objection 0.70 5245.00 to R. Sweelapple deposition duces tecum (Mr. O'Boyle's 0.25 S87.50 subpoenn). 07/122014 RS Conference will, client and opposing counsel; Prepare for meeting; 2.00 Review cases provided; Receive and review subpoena; Conference 5700.00 regarding PO. 07222014 RS prepare for meeting; Outline questions and chronology, (Evening). 1.75 07232014 RS Prepare and travel; Meeting and 5612.50 statement of witness; Conference with client and co -counsel; Research regarding RICO. 13.50 S4,725.00 07242014 RS Work on RICO claims; Research. 07242014 RS Travel and attend meeting with opposing 1.50 5525.00 counsel and Joanne; Conferences with Scott. 2.00 5700.00 07242014 RS Work on Motion for PD. 0.30 SIOS.OD Continued On Next Page Client Number: 00949 platter Number: 1679 07252014 Pu9c: 3 07242014 RS Conference with Bill Trusher, Conference with Scott Morgan; 1.20 5420.00 Conference with Dave regarding research; Conference with Jerry Richman regarding RICO; Conference with Weissing regarding class action. 07252014 RS Assemble evidence; Receive and review motion for Summary175 5612.50 judgment filed by Martin; Receive and review cmails; Conference with co -counsel. 131llable Hours / recs: 51.15 S17,902.50 Prior Balance: 515,125.57 Payments Received: (515,125.57) 1.151 Payment: 07/142014 Current rees: S17,902.50 Advanced Costs: 50.00 TOTAL AMOUNT DUE: 517,902.50 G01 r31/p J�131O PLEASE REWT TO: SWEETAPPLE. BROEKER & VARKAS. P.L. 3rd. STREET. BOCA PLEASE INDICATE INVOICE O ENUMB R ONCHECK.3THANK YOU! Sweetapple, Broelter, Varlcas, P.L. 20 South East 3rd. Street Boca Raton, FL 33432 Telephone: (561)392-1230 Fax:(561)394-6102 lAmount TOWN OF GULF STREAM September 29, 2014 Town of Gulf Stream pPAYh1ENTAPPROVED-4 Invoice No. 10188 100 Sea Road __/ ��h 019 . +5 GulfStrcam, FL 33483 t ..1, t 7 --— Check: 19 Client Number: 00949 Toon of Gulf Stream Matter Number: 1679 O'Boyle vs. Town of Gulf Stream ForSen4ces Rendered Tbraugb 929Q014. Fees Date Tmknr aescrintinn flours Amount 08/2212014 RS Document review; Revise letter and correspondence regarding 0.20 $70.00 depositions of Demartini and Ring. 08252014 RS Review multiple emails; Conferences with Scott. 0.50 5175.00 08!252014 RS Receive and review request to produce; Conference. 0.30 5105.00 0825/2014 RS Conference with witness. 0.20 570.00 06.272014 RS Conference with Scott; Review multiple emails. 0.40 5140.00 08272014 RS Conference with Joanne; Conference with Scott; Prepare for 1.10 5385.00 hearings; Sober house research. OBn_72o14 RS Conference with Gerry regarding RICO and legislature; 0.40 5140.00 Conference with Scott. 08282014 RS Travel and attend hearing on Motion to Compel deposition; Draft 2.00 5700.00 amended motion farsanctions. 06282014 RS Prepare travel and attend hearing; Conference with Gerry; 3.20 51,120.00 Conference with Joanne; Conference with Scott; Ivlceting with paralegal; Set hearing; Amend motion; Conference regarding additional depositions and multiple cmails regarding potential pleadings. (Date 08/23). 08292014 RS Conference with Gerry regarding class action; Review multiple 0.70 5245.00 emails; Conference with Scott. Continued On Nest Page Client Number. 00949 Motler Number: 1679 0929/2014 Page: 2 06292014 RS Conference with Scott and Joanne; Receive and review material; 1.40 5490.00 Amend motion and prepare subpoenas; Conference; Conference; Other prospective plaintiff. 09/022014 RS Review multiple emails and prepare for settlement conference. Im 5437.50 09/022014 RS Conference with Scott, Conference with Joanne; Review files and 0.70 5245.00 prepare for settlement conference. 09102(3014 RS Receive and review emails from Skip Smith and Motion; Prepare 1.50 5525.00 for meetings. 09/032014 DS Prepare notices of depositions to J. O'Boyle, W. Ring and D. 0.60 S75.00 DeMartini. 09.032014 RS Conference with client; Settlement conference with O'Flare and 5.00 S1,750.00 counsel; Meeting with Joanne regarding case strategy (9mn - 2pm). 09/042014 RS Conference with Scott and counsel; Conference regarding RICO 1.25 5437.50 complaint; Prepare letter. (Date 09/03). 09/052014 RS Conference with Scott; Receive and review another group of 0.70 $345.00 request to SBV from O'Boyle. (Dale 09/04). 09/082014 RS Review multiple emails; Conference with Joanne regarding 0.50 5175.00 O'Boyle and O'Hare. 09/082014 RS Conference with client and counsel; Prepare emails to Manna, Skip 0.80 5280.00 Smith and Nick Taylor. 09,092014 RS Review O'Boyle'sresponse. 0.30 S105.00 091092014 RS Conference with Scott and Joanne; Provide documents to Town. 0.70 $245.00 09/I02014 RS Conference with Scott; Email. 0.40 5140.00 09!1212014 RS Conferences with Scott; Prepare for deposition; Review multiple 4.50 51,575.00 emails. 09/14/2014 RS Deposition preparation of O'Boyle; Review all Files and evidence; 11.00 53,850.00 Outline questions; Outline affirmative defenses and counterclaim. (Date 09/13). 09/15/2014 RS Prepare travel; Take deposition of Nl. O'Boyle; Conference with 11.00 S3,850.00 law clerk regarding assignments (8:30-7:30); Meeting with Scott, Joanne and Bill Thrasher. 09/16,12014 RS Conference with Gerry and Joanne; Conference with Scott 1.10 5385.00 regarding opinion letter to commission. 09/16.4014 RS Conferences with Joanne; Receive and review motions; Review 1.30 S455.00 file and research; Draft letter. (O'Hare). Continued On Next Pnge " Client Number: 00949 Natter Number: 1679 09292014 Puke: 3 09,!16.2014 AV Review Motion to Disqualify R. Sweetapple; Westlaw search 2.50 5875.00 regarding case Iasv (read and summarize); Read Bar rules (read and summarize); Draft outline for apposing affidavit. 09/17/2014 CB Research lith. Circuit website regarding allegations in Motion to 0.50 562.50 Disqualify, closed matter listing. (O'Hare). 09/17/2014 RS Conference with Scott; Conference with Nick Taylor regarding 1.75 S612.50 deposition; Conference with Kaleel; Review Motion and research O'Hare alleged representation; Conference with law clerk. (O'Hare). 09P?2014 RS Conference with Joanne; Review multiple emails; Review case law regarding motion; Conference with Cynthia regarding 1.70 5595.00 deposition; Conference with A. Varkas regarding preparation of memo. (Date 09/18, 09/19). (01 lure). 09222014 AV Draft response to Motion to Disqualify (included memo orlaw); 1.00 S350.00 Revise affidavit. (O'Hare). 09232014 RS Conference with Scott and Joanne; Conference with Berwick; 3.50 51,225.00 Conference with Cynthia regarding research; Prepare draft of report. (Date 09/18). 09.232014 AV Draft request to produce; Revise R. Sweetapple affidavit; Revise 1.00 $350.00 response to Motion to Disqualify. (O'Hare). 09/242014 RS Conference with Scott Morgan, Conference with Morgan's 3.70 SI,295.00 counsel; Conference 1with Chandler, Conference with Berwick; Work on report; Conference with Cynthia; Notice of deposition and appearance CAPI; Prepare for sleeting with Gerry, Joanne and Scott. 09.242014 AV Add additional memorandum of lmv to response (see latest P.L. 0.75 526250 weekly opinion). (O'Hare). 09252014 DV Travel and attend meeting with R. Sweetapple, Scott Morgan, Gerry Richman and Joanne O'Connors. 4.00 S800.00 09/252014 RS Travel and attend motion at Gerry Richman's office with Joanne and Scott; Receive and review subpoena and letter from Ring; 4.50 51,575.00 Work on letter to commissioner, Review rules and case late; Conference with Chandler; Receive and review emails. 091_52014 RS Receive and review responses; Receive and review letter and 0.60 5210.00 subpoena. Billable Hours / Fees: 7850 S?6,627.50 Cost Detail Dale Description Continued On Next Page Amnum Check Nn. Client Number: 00949 AIntter Number: 1679 081252014 Postage -August 2014 09/081_014 WestLmv 0 9/24 2 0 14 Photocopy Charges - September 2014 091_61_014 Postage -September 2014 Prior Valance: Payments Received: Current Pees: Advanced Costs: TOTAL AMOUNT DUG: Total Costs S27,270?5 (527,270 25) S26,627.50 $391.95 S27,019.45 56.97 323.47 55.50 6.01 5391.95 Last Payment: 09/05/-1014 PLEASE REMIT TO: SWEETAPPLE. BROL-KER & VARKAS. P.L. 20 S.E. 3rd. STREET. BOCA RATON. rL 33432 PLEASE INDICATE INVOICE NUMBER ON CHECK. THANK YOU! 0929/2014 Pace: 4 Sweetapple, Broelcer, Varkns, P.L. 20 South East 3rd. Street Boca Ralan, FL 33432 Telephone: (561)393-1230 Fax: (561)394-6102 .• • rr r •^-,ten EA Yt Town of Gulf Stream 100 Sea Road Gulf Stream, FL 33493 i2o U /0123/# Client Number. 00949 Town of GulfSacam Matter Number. 1679 O'Boyle vs. Town of GuIrStrram Far Sorvices Rendered Through 102212014. October 22, 2014 Invoice No. 10208 09292014 AV Revise response to motion for Protective Order (regarding W. 2.00 5700.00 King and J. O'Boyle); Read case Into cited; Read Motion and Amended Motion for Sanctions; Analyze issues of underlining lawsuit to issues round in Motion for Sanctions. 09292014 DV Meeting with R. Swceepple regarding instrudtions; Draft response 420 5840.00 letter for R. Swectapple review; Draft motion for A. Varkas and R. Sweetapple review; Meeting with A. Varkns to discuss motion; Research case law for A. Varkas; Edit letter per R. Sweetapple comments. Continued On Next Page reel DRIC Tmknr Daertnlinn 0926P_014 AV Westlaw search: protective order, deposition, transcript of J. dour: Amount 0.75 5262.50 Chandler front discovery (Citizens Awareness vs. J. Chandler) involving work product privilege (read and summarize ease law). 09262014 RS Work on response to Motion to Disqualify and atiidavit. (O'Hare). 0.70 S245.OD 09282014 RS Review Motion for Protective Order, Malian to Disqualify and 1.20 S420.00 emails; Conference regarding researches. 09292014 RS Revise response to subpoena; Revise letter to Ring; Revise letter 0.50 5175.00 to Town. 09292014 AV Revise affidavit, request to produce and response to Marion to 025 58750 Disqualify into final form. (O'Hare). 09292014 AV Revise response to motion for Protective Order (regarding W. 2.00 5700.00 King and J. O'Boyle); Read case Into cited; Read Motion and Amended Motion for Sanctions; Analyze issues of underlining lawsuit to issues round in Motion for Sanctions. 09292014 DV Meeting with R. Swceepple regarding instrudtions; Draft response 420 5840.00 letter for R. Swectapple review; Draft motion for A. Varkas and R. Sweetapple review; Meeting with A. Varkns to discuss motion; Research case law for A. Varkas; Edit letter per R. Sweetapple comments. Continued On Next Page Client Number: 00949 6latter Number. 1679 10222014 Page: 2 0929P_014 RS Conference with Scott and Joanne; Conference with Chandler; 1.75 $612.50 Meeting with D. Vitale and A. Vnrkas regarding response to Motion to Disqualify and Crime Fraud exception; Read all case law. 09/302014 RS Conference with Joanne; Conference with Scott; Conference with 1.75 5612.50 Gerry regarding report to Commission, depositions and Prolective Order, Meeting with A. Varkas regarding O'Boylals motion; Receive and review numerous emails. 09130=4 AV Revise motion for Protective Order regarding documents and 0.25 587.50 deposition transcript of Chandler. (Citizen Awareness vs. Chandler lawsuit). IWO 2014 AV Review verified motion to disqualify R. Swectopple (O'Boyle); 4.00 SI,400.00 Revise late on verification, procedure for disqualification (discovery right and evidentiary hearing); Read treatise and read and summarize relevant case law. 10101/2014 DV Meeting with A. Vnrkas to discuss verified motion; Cnll with R. 1.60 $320.00 Sweetapple; Research case law cited by opposing counsel and statutory provisions regarding privilege. 10/0211014 AV Revise affidavit; Drnft response to motion to disqunlify. 5.00 $1,750.00 10/022014 RS Conference with attorneys and Scott; Work on responses and 2.20 5770.00 disqualification of O'Boyle and suit; Revise reports. (Date 10/01). 10/032014 AV Westlaw search: deposing opposing counsel (read and summarize 4.00 51,400.00 cases); Revisc nMdavit; Westlaw search: evidentiary hearing on motion for protective ander. 10/062014 AV Revise response to motion to disqualify; Dictate response to 3.50 51,225.00 motion for protective order. 101002014 RS Conference with Joanne and Scott; Conference with Gerry; 1.40 S190,00 Conference with D. Vitale; Work on response to motions. 10/072014 RS Work on Request to produce; Conference with Hanna regarding 0.20 570.00 deposition. 10/07t-7014 RS Receive and review now request for records; Review new DCA 0.60 5210.00 opinion and correspondence; Conference with Scott and Joanne. 10/072014 AV Review first draft of response to motion for Protective Order. 2.00 5700.00 1002014 RS Conference with Scott; Revise report draft. 0.70 $245.00 10/082014 RS Work on responses. 0.50 $175.00 10/082014 RS Work on disqualification; Prepare letter to De Souza and Hnnna. 0.60 5210.00 Continued On Nest Page Client Number. 00949 Matter Number. 1679 10222014 Page: 3 10/092014 RS Conference with Joanne regarding meetings end depositions of 1.50 5525.00 O'Hare and secretary; Revise letters; Work on affidavit; Review Fla disqualification cases. 10/092014 AV Continue to revise response to Motion for Prnleclive Order; 430 S1,575.00 Westlaw search 1) Ethical and legal objections regarding receipt of documents to which opposing counsel may assert a privilege (read and summarize cases regarding inadvertent receipt of privilege documents 2) Rules of Professional conduct; Phone call to Fla. Bar, Review ethics opinion 07.1. 10/102014 AV Continue research on attorneys ethical duties regarding when 3.50 SI,225.00 obtains documents possible subject to protection by privilege or giving unfair advantage; Read ethics opinions; U.S. Supreme Court opinion (Hickman/Taylor); Revise affidavit. 10/122014 RS Conference with Scott; Conference with Joanne; Work on affidavit 2.70 5945.00 and disqualification of O'Hare and O'Boyle; Conference with Chandler; Review suit and case conference. 10112f-)014 AV (At home research) Westlaw search 1) Common interest 1.00 5350.00 exemption to atlomcylclient privilege (read and summarize cases) (see 687/888; 585/461); Search: Non-party privilege exercised by party (no cases found). 10/132014 RS Conference with Scott; Outline all projects in pending cases. 0.60 5210.00 10/132014 RS Conference Willi Joanne and Scott; Work on requests, subpoena 230 5875.00 and notices; Review multiple entails. (Date 10110). 10/142014 RS Conference with Scott; Meeting with A. Vnrkas regarding 1.40 S49D.00 disqualification, affidavit and case scheduling order regarding deposition of Ring, O'Boyle, DeMartini and law regarding public indecency regarding S. Morgan's banners. 10/142014 DV Research case law regarding factual disputes requiring evidentiary 0.20 540.00 hearing; Affidavit from non -lawyer issue. 10/162014 ILS Travel and attend meetings at Richman's office regarding research 230 5875.00 motion and town hall trip regarding public record's research (O'Hare); Conference with D. Vitale regarding deposition and research. 10/1612014 RS Prepare affidavit and dmR motion; Review Naga memo regarding 1.50 5525.00 Sober House. 10/192014 RS Review case law and statute regarding O'Hare deposition; Prepare 3.70 SI1195.00 motion; Dmf affidavit for Chandler review; Read Chandler statement. (Date 10118). 10202014 RS Conference with Scott; Conference with Joanne; Conference and 2.10 5735.00 Meeting with Gerry; Conference with Chandler; Revise affidavit and response. (Chandler). Continued On Nest Page Client Number: 00949 Matter No in 1679 10222014 Page' 4 10212014 DV Index M. O'Boyle deposition by going through discs 1 and 2 part 5.60 S1,120.00 of 3 per R. Swectnpple instructions; Create word documents in support. 10222014 RS Conference with D. Vitale; Prepare letter to Chandler, \Nark on 1.60 S560.00 law regarding Ring and 0"Boyle P.O.; Revise motions and affidavit; Conference with Scott and Gerry's office. RIIlnble flours / Fees: 74.55 524,352.50 Prior Balance: 527,019.45 Payments Received: (527,019.45) Last Payment: 10/032014 Current Fees: $24,352.50 Advanced Costs: 50.00 TOTAL AMOUNT DUE: 524,352,50 PLEASE REMIT TO: SWEETAPPLE. BROEKER & VARKAS. P.L. 20 S.E, 3rd. STREET. BOCA RATON. FL 33432 PLEASE INDICATE INVOICE NUMBER ON CHECK. THANK YOU! Swectapple, Broeker, Varkas, P.L. 20 South East 3rd. Street Boca Raton, FL 33432 Telephone: (561)392-1230 Fax:(561)394-6102 TOWN OF GULF SIRE t� PAYMENT APPROVED a Town of Gulf Stream 100 Sea Road Gulf Stream, FL 33483 Client Number. 00949 Townof Gulfstream Matter Number. 1679 anoyie vs. Torn afGuirstmam Por Services Rendered Through 11212014. Continued On Next Page November 21, 2014 Invoice No. 10216 112 Amouy 2.20 5770.00 200 5700.00 2.60 5520.00 6.0D 52,100.00 6.00 52,100.00 1.00 5350.00 DID S70.00 1.30 5455.00 OAD 5160.00 0.50 5175.00 Fees Dale TmGnr neterintion I O1_22014 RS Conference with Scott regarding new public records request; Conference with Joanne; Prepare for O'Hare deposition; Review all documents regarding O'l fare; Conference with p4organ's counsel. 10/222014 RS Conference with Scott; Conference with A. Varkns; Call to Chandler, Prepare forO'Hare's deposition. l0n?n_O 14 OV Complete index of deposition testimony for R. Swcetapple. IOP -41-7014 AV Attend deposition of Chris O'Hare. IO242D 14 RS Travel and take O'Hare deposition. IOP�P-014 RS Conference with Scott; Receive and review emails; Meeting with law clerk regarding projects (O'Boyle and O'Hare). 101_62014 RS Review Chandler's edits. 10272014 RS Revise Motion; Call to Chandler; Conference with Joanne; Review litigation privilege regarding RICO, stale and federal; Prepare for conference with Gerry. 101_72014 DV Research statutes and case taw re: MOB'S banners. I O1_82014 RS Conference with clerk; Review O'Hare website. Continued On Next Page November 21, 2014 Invoice No. 10216 112 Amouy 2.20 5770.00 200 5700.00 2.60 5520.00 6.0D 52,100.00 6.00 52,100.00 1.00 5350.00 DID S70.00 1.30 5455.00 OAD 5160.00 0.50 5175.00 Client Number: 00949 61ntier Number. 1679 11212014 Page 2 10282014 RS Conference with Joanne, Gerry and Scott regarding pending cases; 1.75 5612.50 Work on files, Conference with Chandler, Call to opposing counsel. IO2R2014 AV Westawscarch;Draft and revise motion. 1.00 5350.00 10/_92014 RS Research regarding fee entitlement; Proposal forsettlement; Read 1.60 5560.00 Morgan's letter and latest documents request; Multiple emails with opposing counsel. 1 013 02 0 1 4 RS Work on request to produce; Conference. 030 S105.00 10/312014 RS Conference with Morgan, Chandler and Joanne; Conference will, 1.60 5560.00 A. Varkas regarding disqualification and 57.105 letters and entails will, opposing counsel; Mecting with law clerk regarding research. 10/312014 AV Draft motion 57.105; Demand letter, Revise response to motion to 1.50 5525.00 disqualify, notice of filing motion; Westlaw search procedure. 10/312014 AV Draft motion 57.105; Demand letter; Revise response to motion to ISO 5525.00 disqualify, notice of filing motion; Westlaw search procedure. (O'Flare). 10,312014 AV Draft request to produce to Plaintiff' O'Harc. 0.50 5175.00 11/022014 RS Conference with Scott (Sal) ;Prepare request to produce regarding 1.50 5525.00 RICO claims; Emails.. 11103206! RS Prepare multiple emails to opposing counsel; Work on RICO suit; L50 5525.00 Conference ,vitt, Scott; Conference with law clerk regarding project. 11/032014 RS Work on O'Hare request and 57.105 package; Conference with G. 125 5437.50 Richman; Work on O'Boyle 57.105 package; Work on O'Flare 57.105 package. 11/042014 RS Prepare letter and notice; Conference. 0.30 5105.00 11/052014 RS Review Wensive request to produce from O'Boyle; Conference 0.60 5210.00 will, opposing counsel. 11/052014 RS Meeting with law clerk; Work on RICO case. 0.70 5245.00 11/052014 RS Conference with Scott and Chandler; Receive and review emails; 2.00 5700.00 Conference regarding RICO and work on discovery request. 111072014 RS (11/7/14 - 11/9/14) Conferences and emails. Review article and 1.60 5560.00 work on discovery. 11/102014 RS Conference with NJ counsel. Email. Work on RICO. Work on and 2.75 5962.50 review responses to request to produce. Conference with Scott Morgan. 1111P7014 RS Conference wits co -counsel and Scott Morgan and Clerk 0.40 5140.00 Continued On Nnt Page Cllenl Number: 00949 Mauer Number. 1679 11212014 Page. 3 11/122014 RS Conference with Gerry Richman, Joanne O'Connor and Scott Morgan regarding settlement offer and strategy on RICO suit. Work on discovery for RICO suit. ISO 5525.00 11113P-01,1 RS Meet with law clerk regarding settlement proposal and strategy. Initial review of NJ transcript and witness conference. Revise motion. 1.60 5560.00 11/132014 RS (O'Hare) Conference with Paul Nicoletti. Prepare affidavit and letter. 0.70 5245.00 11117P-014 DV Conference w. Robert Sweetapple and Alexander Varkas re; status and responsive motion. 0.10 620.00 11/17%'014 RS Conference re: all pending cases 0.25 567.50 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. Conference with Scott Morgan. Meet with David Vitale regarding R Sweetapple appearance on allettcr O'Boyle and O'Hare matters. Meeting with Gerry Richman to: drafting RICO case; conference Wath co -counsel. 3.00 S1,050.00 11/162014 RS Cunfcrence w. Gerry Richman re: Bergersettlement conference. 0.20 S70.00 11/162014 Its Work on lawsuits (eve); Review pending cases to appear 0.50 S175.00 I (/162014 DV Conference w. R. Sweetapple re: motion to disquallfy 0.20 5411.00 11/162014 DV Conference with It. Sweetapple re: case status 0.50 SI0D.00 11/192014 RS Receipt and review of emails. Conference with Joanne O'COnnor and law clerk re: additional cases Mayor Morgan has asked R. Swcetnpple 10 appear in and strategy. 0.75 5262.50 111191_014 RS Receipt and review of entails; conference with Joanne O'Connor and Scott Morgan 0.50 5175.00 111_01_014 DV Index Martin O'Boyle deposition from prior case per R. Sweetapple; create word document in support. 2.00 S400.00 11202014 DV COnference call with R. Sweetapple, G. Richman, J. O'Connor and S. Morgan 0.60 5120.00 11212014 RS Conference with Scott Morgan; Conference with late clerk re: Motion to Compel and Request to Produce in sanctions case. Work on O'Hare cases. 115 S437.50 11212014 DV Parse O'Hare deposition for facts/material to be inserted into responsive motion to disqualify; Insert into A. Varkas's initial draft abd print for A. Varkas's review.; Conference with Cynthia Bailey re: request for expedited hearing per R. Sweetapple's instruction 2.30 5460.00 Cantinued On Neat Page Clicm Number. 00949 Mutter Numher. 1679 COS( Detail Bate Bescrinttnn 10272014 Postage -October 2014 10272014 P11010cuPy Charges - October 2014 1121 /2014 Pasc: 4 Billable Hours/Fees: 61.60 5_0,195.00 Amount Check Nn. S2.88 8.00 Total Casts S10.88 Prior Balance: S14,352.50 Payments Receiver!: (514,351.50) Last Payment: 10272014 Current Fees: 510,195.00 Advanced Costs: 510.88 TOTALAMOUNT DUE: 530,105.88 PLEASE REMIT TO: SWEETAPPLE. BROEKER & VARKAS. P.L. 20 S.E. 3rd. STREET. BOCA RATON. FL 33432 PLEASE INDICATE INVOICE NUMBER ON CHECK. THANK YOU!