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Home My Public Portal About2014CC008529:RL (7/25/14)** * ** CASE NUMBER: 2014CCO08529 DIVISION: RL * * ** Filing to 16274719 Electronically Filed 07/23/2014 05:20:57 PM IN THE COUNTY COURT IN AND FOR PALM BEACH COUNTY FLORIDA STOPDIRTYGOVERNMENT, LLC and MARTIN E O'BOYLE, CIVIL DIVISION Plaintiff, CASE NO.: me TOWN OF GULFSTREAM, Defendant. SUMMONS THE STATE OF FLORIDA To each Sheriff of the State: tlklw /9 7 W" 1141 S" 9 YOU ARE COMMANDED to serve this summons and a copy of the complaint in this law suit on defendant: Town of Gulfstream 100 Sea Road Gulf Stream, Florida 33483 Each defendant is required to serve written defenses to the complaint or petition on William Ring Plaintiffs attorney, whose address is 1286 West Newport Center Drive, Deerfield Beach, Florida 33442, within twenty (20) days after service of this summons on that defendant, exclusive of the day of service, and to file the original of the defenses with the clerk of this court either before service on plaintiffs attorney or immediately thereafter. If a defendant fails to do so, a default will be entered against the defendant for the relief demanded in the complaint or petition. JUL 24 2014 DATED on July , /v 14 Clerk of the Court Chantel Stickler The O'Boyle Law Firm P.C. Attorneys for the Plaintiff 1286 West Newport Center Drive Deerfield Beach, Florida 33442 Telephone: (954) 574 -6885 Facsimile: (954) 360 -0807 obovlecourtdocs (cr�,obovlelawfirm.com wring(cDobovlelawfirm. com SHARON R. BOCK Clerk & Comptroller P.O. Box 3406 West Palm Beach, FL 33402 Filing # 16274719 Electronically Filed 07/23/2014 05:20:57 PM IN THE COUNTY COURT IN AND FOR PALM BEACH COUNTY FLORIDA STOPDIRTYGOVERNMENT, LLC and MARTIN E. O'BOYLE, CIVIL DIVISION Plaintiff, V. TOWN OF GULFSTREAM, Defendant. CASE NO.:9zj(C�LCDI)951 ,q: I?L VERIFIED COMPLAINT TO ENFORCE FLORIDA'S PUBLIC RECORDS ACT AND FOR DECLARATORY RELIEF The Plaintiff, STOPDIRTYGOVERNMENT, LLC and MARTIN E. O'BOYLE, (the "Plaintiff'), by and through the undersigned counsel, hereby sue TOWN OF GULFSTREAM ( "Defendant ") and states: 1. This action concerns the Defendant's violation of Plaintiffs civil rights pursuant to Article I, § 24 of the Florida Constitution and Chapter 119, Florida Statutes, (the "Public Records Act "). 2. This action seeks declaratory and equitable relief. 3. Specifically, Plaintiff seeks an order declaring the Defendant to be in breach of its constitutional and statutory duty to permit access to public records, and compelling the Defendant to provide access to the requested public records, and awarding Plaintiff attorney's fees and costs. Additionally, Plaintiff requests this matter be expedited, upon motion by Plaintiff, pursuant to § 119.11 (1), Florida Statutes. PARTIES, JURISDICTION AND VENUE 4. STOPDIRTYGOVERNMENT, LLC and MARTIN E. O'BOYLE (collectively as "Plaintiff') is a Florida corporation, registered to do business in Florida, or a Florida resident and at all times relevant hereto was entitled to the inspection and copying of public records pursuant to the provisions of Chapter 119, Florida Statutes and Art. I, § 24 of the Florida Constitution. 5. Defendant is an "agency" as that term is defined in §119.011(2), Fla. Stat. 6. This Court has subject matter jurisdiction pursuant to Article V, § 6(b) of the Florida Constitution, and §119.11, Fla. Stat. 7. This Court is the appropriate venue for the vindication of the Plaintiff s civil rights because the Defendant's principal place of business is located in Palm Beach County. 8. All conditions precedent to this action have occurred or have been excused or waived. FACTS RELEVANT TO ALL COUNTS 9. Defendant, the Town of Gulf Stream, as a public agency, is required to provide access to records under Chapter 119 of Florida Statutes. 10. On or about May 30, 2014 Plaintiff, STOPDIRTYGOVERNMENT LLC., submitted a Public Records Request via email to Defendant at (rtaylor @gulf - stream.org) under the provisions of Chapter 119, Florida Statutes. 11. On or about May 29, 2014 Plaintiff, Martin E. O'Boyle, submitted a Public Records Request via email to Defendant at (btlu•asher @gulf - stream.org) under the provisions of Chapter 119, Florida Statutes. 2 12. Both of the Requests advised the Defendant to provide in writing any statutory exemptions, to provide the appropriate citation for any such exemption and to clearly articulate in writing the rationale for asserting such an exemption. 13. The Requests asked for public records as that term is used and defined in Chapter 119, Florida Statutes, including § 119.011(12) Fla. Stat. and Art. I, § 24(a) of the Florida Constitution. 14. Defendant has failed to acknowledge or respond to these requests in a legally sufficient manner. 15. The only responses received are pre -typed standard Town of Gulf Stream letters stating that the Town will respond in a reasonable amount of time. 16. No further communications regarding these requests have been received from Defendant's to date. COUNT I— UNLAWFUL WITHHOLDING OF PUBLIC RECORDS 17. Plaintiff re- alleges and incorporates by reference the above numbered paragraphs 1 through 16 as if fully alleged herein. 18. Defendant, as an agency defined in §119.011(2), Fla. Stat. owes a duty to allow access to any person to all public records within its control pursuant to Fla. Stat. § 119.01(1) unless specifically exempted by the Florida Constitution. 19. Plaintiff made a public records request, request ID# 569, for "all Public Records which contain any one of the following words: "O Boyle ", 'Boyle ", "Morgan ", "Touhey ", "Drouin ", "Deemer ", "Minor ", "Randolph ", "Sweetapple ", dated startingAug:tst 1, 2013 through the date of this Request" which is attached hereto and incorporated herein as Exhibit A. 20. The only response received to date, is a pre -typed standard Town of Gulf Stream letter dated June 1, 2014, stating that the Town will respond in a reasonable amount of time. See Exhibit B. 21. Defendant violated its duty when it refused to provide Plaintiff with copies of the requested records in violation of Article I, §24 of the Florida Constitution, § 119.07(1)(a), Fla. Stat, and well - established case law. 22. The records Plaintiff requested are not exempted under Florida's Public Records Act. 23. The Defendant cited no statutory exemption applicable to the requested records. 24. Defendant's ongoing delay in providing the requested records constitute an unlawful withholding or refusal of access as contemplated by Florida's Public Records Act. 25. The denial of public records constitutes an irreparable harm and Defendant's conduct suggests a likelihood of future harm. 26. The request could have been partially completed in a short time span with a simple computer database search for the keywords. 27. Violation of Section 1] 9.07, Fla. Stat. constitutes an irreparable public injury. See Grapski v. Ciq, gfAlachua, 31 So.3d 193, 200 (Fla. 1st DCA 2010)(holding that the mere showing that the law has been violated constitutes an irreparable public injury.) 28. Plaintiff has a clear legal right to insist that Defendant perform its duties, which include providing the Plaintiff with access non - exempt public records within its control. 29. This matter must be set for immediate hearing. See Fla. Stat. Section 119.11(1). 30. All conditions precedent to this action have occurred, been excused or waived. Cl RELIEF REQUESTED WHEREFORE, Plaintiff prays tltis Court: (a) Set an immediate hearing pursuant to § 119.11, Florida Statutes; (b) Declare that the Defendant's failure to provide Plaintiff with access to the requested public records was unconstitutional and unlawful under Article I, § 24 of the Florida Constitution and the Public Records Act; (c) Order the Defendant to allow the inspection, copying and photographing of the requested records; (d) Award Plaintiff its reasonable attorney's fees, costs, and expenses incurred in this action, as provided in § 119.12, Florida Statutes; and (e) Grant such further relief as the Court deems proper. COUNT II — UNLAWFUL WITHHOLDING OF PUBLIC RECORDS 31. Plaintiff re- alleges and incorporates by reference the above numbered paragraphs 1 through 16 as if fully alleged herein. 32. Defendant, as an agency defined in §119.011(2), Fla. Stat. owes a duty to allow access to any person to all public records within its control pursuant to Fla. Stat. § 119.01 (1) unless specifically exempted by the Florida Constitution. 33. Plaintiff made a public records request, request ID# 574, for "all Public Records which contain any one of the following wards: ' fdot ", "DOT", " FLORIDA DEPARTMENT OF TRANSPORTATION (INCL UDING ANY OF THE WORDS WHICH ARE ABBREVIATED IN ANYFASHION) ", "Transfield Services ", "Brett Drouin (including any other party that is commonly known as FDOT) ", "Morgan ", "Touhey ", "Boyle ", "O'Boyle ", "Hidden ", 5 "Harbour ", dated starting August 1, 2013 through the date of this Request and which refer to objects and /or signs in the right -of -way of the Town of Gulfstream" which is attached hereto and incorporated herein as Exhibit C. 34. The only response received to date, is a pre -typed standard Town of Gulf Stream letter dated June 4, 2014, stating that the Town will respond in a reasonable amount of time. See Exhibit D. 35. Defendant violated its duty when it refused to provide Plaintiff with copies of the requested records in violation of Article I, §24 of the Florida Constitution, §119.07(1)(a), Fla. Stat. and well- established case law. 36. The records Plaintiff requested are not exempted under Florida's Public Records Act. 37. The Defendant cited no statutory exemption applicable to the requested records. 38. Defendant's ongoing delay in providing the requested records constitute an unlawful withholding or refusal of access as contemplated by Florida's Public Records Act. 39. The denial of public records constitutes an irreparable harm and Defendant's conduct suggests a likelihood of future harm. 40. The request could have been partially completed in a short time span with a simple computer database search for the keywords. 41. Violation of Section 119.07, Fla. Stat. constitutes an irreparable public injury. See Grapski v. City of Alachua, 31 So.3d 193, 200 (Fla. 1st DCA 2010)(holding that the mere showing that the law has been violated constitutes an irreparable public injury.) 42. Plaintiff has a clear legal right to insist that Defendant perform its duties, which include providing the Plaintiff with access non - exempt public records within its control. 43. This matter must be set for immediate hearing. See Fla. Stat. Section 119.11(1). 44. All conditions precedent to this action have occurred, been excused or waived. RELIEF REQUESTED WHEREFORE, Plaintiff prays this Court: (a) Set an immediate hearing pursuant to § 119.11, Florida Statutes; (b) Declare that the Defendant's failure to provide Plaintiff with access to the requested public records was unconstitutional and unlawful under Article I, § 24 of the Florida Constitution and the Public Records Act; (c) Order the Defendant to allow the inspection, copying and photographing of the requested records. (d) Award Plaintiff its reasonable attorney's fees, costs, and expenses incurred in this action, as provided in § 119.12, Florida Statutes; and (e) Grant such further relief as the Court deems proper. Respectfully submitted, Dated: July 23 , 2014 THE O'BOYLE LAW FIRM, P.C. Attorneys for Plaintiff 1286 West Newport Center Drive Deerfield Beach, FL 33442 Telephone: (954) 570 -3510 Facsimile: (954) 360 -0807 For Service of Court Documents: 0 0 le urtdocs obo lelawfinn.com By: William Ring, Esq. Florida Bar #961759 wring a oboylelawfirm.com VERIFICATION STATE OF FLORIDA COUNTY OF BROWARD BEFORE ME, the undersigned authority, personally appeared Martin E. O'Boyle, who, being first duly identified and sworn, deposes and says that this VERIFIED COMPLAINT is based on records and information known to him, and is true and correct to the best of his knowledge, information, and belief. By: Name: Martin E. O'Boyle STATE OF FLORIDA ) )SS COUNTY OF BROWARD ) r Sworn to, affirmed, and subscribed before me this 2drJ day of III&W , 2014 by Martin E. O'Boyle. NOTARY PUBLIC STATE OF FLORIDA t� JILL R MOHLER Sign: V... MY COMMISSION k EE081214 EXPIRES April 12, 2015 (aD7179]dt5] FbtiOaNOteryServke.com Print; (SEAL) Please indicate: Personally Known: /OR Produced Identification: Type of Identification Produced: 0 Exhibit A RECORDS REQUEST (the "Request ") Date of Request: 5/29/2014 Requestor's Request ID #: 569 REQUESTEE: Custodian of Records Town of Gulfstream REQUESTOR: Martin E. O'Boyle REQUESTOR'S CONTACT INFORMATION: E -Mail: records @commerce- grottp.com Fax: 954- 360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Provide copies of all Public Records which contain any one of the following words: "O'Boyle ", "Boyle ", " Morgan ", "Touhey', "Drouin ", 'Deemer', "Minor', "Randolph ", "Sweetapple" dated starting August 1, 2013 through the date of this Request. ADDITIONAL INFORMATION REGARDING REQUEST: 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 REQUESTED 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 11997(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. 1:P/NPR/FRR 04.22.13 FORM WorkCentre 5230A Transmission Report 03 10 L..al Islam¢ L.O. GOCUmOn[ h.. been ..., DOCUmen[ SIX. 8.5%11-SEF Martin E. O'Boyle 1280 West Newport Center Drive Deerfield Beach, FL 33442 Telephone: 954 -570 -3505 Telecopy :954- 360 -0807 l.VAIBER O£PA6F5 AIZI/OIAIS TAANJAaTTA[ PAEF 2 if YOl/00 NOrRE cTVF AfL PA6F5 F(FASFGlL pPJ1- JA -)Jf) X a'Y^IIInYmr /eYv.r on9% mi / /albs w: RtiA�•A!al _ Lmrnl+. ;f0c nrry _ olhirr lhrry _ Olhrr 0acO /TIm0:C'S /29/201A:04:34PM P.ve:I ILafi[ Pagel TOial P.1, SeanneO: 2 T.i.I Pag36 $ani 1 - 1.10. DO C. RCmO[e $SaTIOn 5[e!C Time D,11.,01\ P.... (NOUe COI \T ¢IICfi $TatU6 1 6392 5817370188 5 -2P: 4:33PM 296 2! 2 SG3 CP II.TO: RE: RecenU bIB: Sentl TO Llal lbort BC: Br.aticapT NIP: IAUISi P.I l lnq RV: R¢mae Servi.e PG: Polling RB: Relay B10.0.afic RS: Relay SenU BF: 90.. Far ForwarU CP: COInUIeCetl SA: $¢nU Apaln EM: Engafl etl A$: AVCO Send TM: Termineced TELECOPIER TRANSMITTAL PAGE DATE-- /ra n, 2elr TO: I%OM: rl,m„car,.l. l.VAIBER O£PA6F5 AIZI/OIAIS TAANJAaTTA[ PAEF 2 if YOl/00 NOrRE cTVF AfL PA6F5 F(FASFGlL pPJ1- JA -)Jf) X a'Y^IIInYmr /eYv.r on9% mi / /albs w: RtiA�•A!al _ Lmrnl+. ;f0c nrry _ olhirr lhrry _ Olhrr 0acO /TIm0:C'S /29/201A:04:34PM P.ve:I ILafi[ Pagel TOial P.1, SeanneO: 2 T.i.I Pag36 $ani 1 - 1.10. DO C. RCmO[e $SaTIOn 5[e!C Time D,11.,01\ P.... (NOUe COI \T ¢IICfi $TatU6 1 6392 5817370188 5 -2P: 4:33PM 296 2! 2 SG3 CP II.TO: RE: RecenU bIB: Sentl TO Llal lbort BC: Br.aticapT NIP: IAUISi P.I l lnq RV: R¢mae Servi.e PG: Polling RB: Relay B10.0.afic RS: Relay SenU BF: 90.. Far ForwarU CP: COInUIeCetl SA: $¢nU Apaln EM: Engafl etl A$: AVCO Send TM: Termineced Exhibit B TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail June 1, 2014 Martin E. O'Boyle [mailto: records @commerce- group.coml Re: PRR #569 Provide copies of all Public Records which contain any of the following words: "O'Boyle ", "Boyle" "Morgan" "Touhey" 'Drouin" "Deemer" "Allinor" "Randolph ", "Sweetapple" dated starting August 1, 2013 through the date of this Request. Dear Martin E. O'Boyle [mailto: records @commerce- group.com], The Town of Gulf Stream has received your public records request dated May 29, 2014. If your request was received in writing, then the first page of that request is attached to this cover letter. If your request was verbal, then the description of your public records request is set forth in the space below. 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 respond to you in a reasonable amount of time with the appropriate response or an estimated cost to respond. Sincerely, Town Clerk Custodian of the Records Your original request dated May 29 2014 is reproduced in the space below: 0•„.:T 05-29-'4 :04 :ou; RECORDS REQUEST (the "Regacse") Data of Rcq•. ,t 5/29/2014 Requestor's Requm TDk: 569 REQUESTER Custadlan of Records Town of Gulfgream REQUESTOR: Martin E. O'Boyle REOUESTOR'SCON*TACrINFORMATION: !:!Mall: r=rdsrycom. i. c- ymup.mm Fax: 954 - 36140807; Addrur.. 1260 Wcsl Neupon C:cotcr Drive, Deerfield Beach, FL 33442 REQUEST: Provide caples of all Public Records which contain any one of the following words: "O'Boyle ", "Boyle ", "Morgan ", "Touhey ". "Drouin", "Dsvmor' ", "hlinor ", - Randolph ", "Swaalopple" doled darting August 1, 2017 through the date of this ADDITIONAL DIFORM.ATION REGARDINO REQUEST: THIS REQUEST IS MADE P[R'AUANY TO PUBLIC RECORDS ACT, CHAPTER 119 OF THE FLORIDA STATUTES AND IS ALSO REQUESTED UNDER THE CO7,MON LAW RIGHT TO KNOW, THE CO,YIDION LAW RIGHT OF ACCESS; AND ANY STATUTORY RIGHT TO "OW (INCLUDING, WITHOUT LIMITATION, ANY STATUTORY RIGHT OF ACCESS, AS APPLICABLE). THIS REQUEST IS ALSO MADE PURSUAKI' TO 7HE 10GHT5 OF THE REQUESTOR PROVIDED IN nIE FLORIDA CONSTITUTION. r l Iii i [ 1.5 MIA i I A M!I 1' L 1 • •r •s Is 1• e• 1 1 aD_. is !' it 1 1' s TR 19• n• _ • e s e yI� s • 1 11 "1 1 31 1• 91' U 1'1 Af s LL :1 1>! LL I PLEASE PROVIDE =APPROKRTATE COSTS (IF ANY) TO FULFILL THIS PUBLIC RECORDS REQUEST IN ADVANCE. It will he required that the Rtquestor approve at any costs, merlcd by the Agency (m defined In Florida Statute, Chapter 119.01(Dafinitions)), in advnace or any costs Imposed to the Requestorby tha ARenry. LPM MRA aa12O1VR.N Exhibit C RECORDS REQUEST (the "Request ") Date of Request: 6/4/2014 Requester's Request ID #: 574 REQUESTEE: Custodian of Records Town of Gulfslream REQUESTOR: STOPDIRTYGOVERNMENT, LLC REQUESTOR'S CONTACT INFORMATION: E -Mail: records@commerce-group.com Fax: 954- 360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Provide copies of all Public Records which contain any one of the following words: "fdot ", "DOT ", "FLORIDA DEPARTMENT OF TRANSPORTATION (INCLUDING ANY OF THE WORDS WHICH ARE ABBREVIATED IN ANY FASHION) ", "Transfield Services ", "Brett Drouin (including any other party at what is commonly known as FDOT) ", "Morgan ", "Touhey ", "Boyle ", "O'Boyle ", "Hidden ", "Harbour' dated slarting August 1. 2013 through the date of this Request and which refer to obiects and /or signs in the right -of -way of the Town of Gulfslream. ADDITIONAL INFORMATION REGARDING REQUEST: THIS REQUEST IS MADE PURSUANT TO PUBLIC RECORDS ACT, CHAPTER 119 OF THE FLORIDA STATUTES AND IS ALSO REQUESTED UNDER THE COMMON LAW RIGIIT 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 REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED IN ELECTRONIC FORM. IF NOT AVAILABLE IN ELECTRONIC FORM IT IS REQUESTED TI4AT THIS R_ ECORDS 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 T14E 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 1 19.01 (Definitions)), in advance of any costs imposed to the Requestor by the Agency. I:PMPR/FRR 04.22.13 FORM Records From: Records Sent Tuesday, June 03, 2014 5:29 PM To: rtaylor @gulf - stream.org Subject: Public Records Request #574 Attachments: GS RECORDS REQUEST #574 6.03.14.PDF Please see attached Public Records Request Exhibit D TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail June 4, 2014 Stopdirtygovernment, LLC [mailto: records @commerce- group.coml Re: PRR #574 Provide copies of all Public Records which contain any one of thefollowing words: ' dot ", "DOT ", "FLORIDA DEPARTMENT OF TRANSPORTATION (INCLUDING ANY OF THE WORDS WHICHAREABBREVIA TED INANYFASHION ) ", TransfieldSenices ", BrettDrouin (inchrding any other party at what is commonly known as FDOT) ", "Morgan", "Touhey ", "Boyle ", "O'Boyle ", "Hidden ", "Harbour" dated starting August 1, 2013 through the date of this Request and which refer to objects and /or signs in the right -of -way of the Town of Gulfstream.. Dear Stopdirtygovemment, LLC [mailto: records @commerce- group.com], The Town of Gulf Stream has received your public records request dated June 3, 2014. If your request was received in writing, then the first page of that request is attached to this cover letter. If your request was verbal, then the description of your public records request is set forth in the space below. 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 respond to you in a reasonable amount of time with the appropriate response or an estimated cost to respond. Sincerely, Town Clerk Custodian of the Records Your original request. dated June 3 2014 is reproduced in the space below: RECORDS REQUEST (the `Req=t ) Dim ofRequex 6/3/2014 Requrtor': $equea II)=: 574 R_Q()rSI'EE; Custodian of Records Town of Gulfstmom REQUESTER: STOPOIRTYGOVERNMENT, LLC REQUESTOR'S CONTACT LN'FORVULTION: EALrE reeord;i_t commeree- 1:roup.com Fax: 954- 360 -OS07: Addrr.:: 13SO 1Ve:t Nen-pon Cemer Drive. Deerfield Be.* FL 33443 REQUEST: Provide copies of all Public Records which contain anyone of the following wards: "Idol ", "DOT", "FLORIDA DEPARTMENT OF TRANSPORTATION (INCLUDING ANY OF THE WORDS WHICH ARE ABBREVIATED IN ANY FASHION) ", "Truncfield Services ", "BreH Drouin (including any other party at what is commonly known as FDOT) ", "Morgan ", "Touhey ", "Boyle ", "O'Boyle ", "Hidden ", "Harbour" dated 1 rY g A.. t / 1013 16 gh lh -4-1, of Ihic Rea,,o and which -( 1 6;,d. and /or signs in the right -of -way of The Town of Gulfsheam. ADDMON.4I. INFORMATION REGARDLNG REQUEST: THIS REQUEST L NI UE: PL7tST :A-NT TO PL BLIC RECORDS ACT, CHAPTER 119 OF THE FLORIDA STATLTES AND 15 ALSO REQUESTED L.NDER THE CO -ALMON LAR' RIGHT TO K OT1', THE CONIA10\ LAR' RIGHT OF ACCESS: ANT) AN V STATUTORY RIGHT TO IC- OVP (LNCLUDLNG, RTIHOL -I' LL1ffIATION...iNT STATUTORY RIGHT OF ACCESS, AS APPLICABLE). THUS REQU'E.ST IS AL50 \LADE PLRSL ?AN"F TO THE RIGHTS OF THE REQLESTOR PROVIDED L\ THE FLORIDA CONSTFIUTION. IT 15 REQUESTED THAT THIS RECORDS REOT -EST BE F- LIMLED LN ELECTRONIC FORIf. IFNOTAV :AE_ABLE IN ELECTRONIC FORD IT IS REQUESTED THAT THIS RECORDS REOLEST BE FLLFTr LED ON 111-17 PAPER, NOTE Lai ALL CASES a7N E -S IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED AND SHOULD BE BELLED IN ACCORDANCE 117TH S «Hop 119.0 7(4) (a) fl) ALL ELECTRONIC COPIES ARE REQUESTED TO BE SENT BY E -11AM DELTT'ERI' PLEASE PROVIDE THE APPROIMIATE COSTS (Tf ANTI TO FULFILL THIS PUBLIC RECORDS REQUEST LN ADV :ANCE. It will be required that the Requeaor approve of any coot;, =erred by the ASeney (a: defined in Florida Statute, Chapter 119.01 (Defmitiom)), iu adrauce of am corn imposed to the Requeaor by the ASena; . LANPR-IRA M.1 2.l3 FORM