HomeMy Public PortalAboutJOANN OCONNER 1-21-2017IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA.
CASE NO: 502014CA006112XXXXMB AG
CITIZENS AWARENESS FOUNDATION,
INC.,
Plaintiff,
V.
THE TOWN OF GULF STREAM and
BRANNON & GILLESPIE, LLC,
Defendants.
DEFENDANT BRANNON & GILLESPIE, LLC' S NOTICE OF SERVICE OF
ANSWERS TO PLAINTIFF'S NOVEMBER 2016 INTERROGATORIES
WE HEREBY CERTIFY that the original and one copy of the Answers to Plaintiff's
November 2016 Interrogatories propounded to Defendant, BRANNON & GILLESPIE LLC, on
November 29, 2016 (Nos. 1 through 3) have been furnished by U. S. Mail and Email to:
Jonathan O'Boyle, Esquire, the O'Boyle Law Firm, P.C. 1286 West Newport Center Drive,
Deerfield Beach, Florida 33442 (joboylekoboylelaw-fin-n.com) and by Email to Nick Taylor,
Esquire, the O'Boyle Law Firm, P.C. 1286 West Newport Center Drive, Deerfield Beach,
Florida 33442 (ptaylorkoboylelawfirm.com) and Robert Sweetapple, Esquire, Sweetapple
Broeker & Varkas, PL, 20 S. E. Third Street, Boca Raton, FL 33432
(pleadingsksweetapplelaw.com, rsweetappleg sweetapplelaw.com, cmillerAsweetapplelaw.com), this
day of January, 2017.
JONES, FOSTER, JOHNSTON & STUBBS, P.A.
Attorneys for Defendant Town of Gulf Stream
505 South Flagler Drive, Suite 1100
Post Office. Box 3475
West Palm Beach, FL 33402-3475
Telephone: (561) 659-3000
Facsimile: (561) 650-5300
By: /s/ Joanne M. O'Connor
Joanne M. O'Connor
Florida Bar No. 0498807
i oconnor(dj onesfoster.com
ANSWERS TO INTERROGATORIES
1. Please identify all facts relating to Defendant Town's Third Affirmative Defense (Bad
Faith).
ANSWER: This defendant has no personal knowledge of any facts to support the
Town's. Third. Affirmative Defense (Bad Vaith).
2. Please identify all facts support Defendant Town's First Affirmative Defense (Standing).
ANSWER: This defendant has no personal knowledge of any facts to support the
Town's First Affirmative Defense (standing).
3. Please identify all facts support Defendant Town's Second Affirmative Defense (Lack of
Authorization).
ANSWER: This defendant has no personal knowledge of any facts to support the
Town's Second Affirmative Defense (Lack of Authorization).
VERIFICATION
Pursuant to Section 92.525, Florida Statutes, I declare under penalty of perjury that I have
read the foregoing Answers and Objections to Plaintiff's Interrogatories and know the content
thereof. The information contained therein, which is not entirely derived from my personal
knowledge but, rather, has been collected from corporate records and made available to me by
others, is true and correct to the best of my knowledge and belief based upon my own knowledge
and information made available to me.
This day of January, 2016.
Danny P. Brannon P.E.
Brannon &Gillespie, LLC
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