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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 P:\DOCS\13147\00064\DEPO\IRC7052.DOCX