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FW: Transcripts and Invoice 302094 - Judge Thomas Barkdull, III - Christopher O'Hare vs. Town of Gulf Stream - 12/08/2016
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Transcripts and Invoice 302094 - Judge Thomas Barkdull, III - Christopher O'Hare vs. Town of Gulf Stream - 12/08/2016
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From: "OConnor, Joanne M." <JOConnor@jonesfoster.com>
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Subject: FW: Transcripts and Invoice 302094 - Judge Thomas Barkdull, III -
Christopher O'Hare vs. Town of Gulf Stream - 12/08/2016
Thread-Topic: Transcripts and Invoice 302094 - Judge Thomas Barkdull, III -
Christopher O'Hare vs. Town of Gulf Stream - 12/08/2016
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Cynthia Miller (cmiller@sweetapplelaw.com); Macfarlane, Mary
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Trial Court
Transcripts and Invoice 302094 - Judge Thomas Barkdull, III - Christopher O'Hare vs. Town of Gulf Stream - 12/08/2016
Attached is the transcript of 13147.70, the case to be concluded at trial next week.
Joanne M. O’Connor Florida Bar Board Certified Business Litigation Attorney
Telephone: 561.650.0498 | Fax: 561.650.5300 | joconnor@jonesfoster.com <mailto:joconnor@jonesfoster.com>
Jones, Foster, Johnston & Stubbs, P.A.
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561-659-3000 | www.jonesfoster.com <http://www.jonesfoster.com/>
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To: OConnor, Joanne M. <JOConnor@jonesfoster.com>
Subject: Transcripts and Invoice 302094 - Judge Thomas Barkdull, III - Christopher O'Hare vs. Town of Gulf Stream - 12/08/2016
This message originated from outside your organization
________________________________
Attached is your invoice and transcripts.
Thank you very much!
Daughters Reporting, Inc.
101 NE 3rd Avenue, Suite 1500
Fort Lauderdale, FL 33301
954-755-6401
954-827-7778 Fax
daughtersreporting@gmail.com <mailto:daughtersreporting@gmail.com>
www.daughtersreporting.com <http://www.daughtersreporting.com>
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Attached is the transcript of 13147.70, the case to be concluded at trial next week.
Joanne M. O’Connor Florida Bar Board Certified Business Litigation Attorney
Telephone: 561.650.0498 | Fax: 561.650.5300 | joconnor@jonesfoster.com
Jo
Trey Nazzaro
Trey Nazzaro
EX
/O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=4F2A29F2B5E049B995E816021A4AFFE0-TNAZZARO
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Transcripts and Invoice 302094 - Judge Thomas Barkdull, III - Christopher O'Hare vs. Town of Gulf Stream - 12/08/2016
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Inv302094.pdf
101 NE 3rd Avenue, Suite 1500 - Fort Lauderdale, FL 33301 Office 954.755.6401 - Fax 954.827.7778 daughtersreporting@gmail.com - daughtersreporting.com INVOICE JONES FOSTER JOHNSTON &
STUBBS, P.A. ATTN: Joanne O'Connor, Esq. 505 South Flagler Drive Suite 1100 West Palm Beach, FL 33401 Invoice Number: 302094 Invoice Date: 12/29/2016 In RE: Christopher O'Hare vs.
Town of Gulf Stream Witness(s): Judge Thomas Barkdull, III Attendance Date: 12/08/2016, 9:00am Reporter: Laurie Brown Location: PALM BEACH COUNTY COURTHOUSE - 205 North Dixie Highway
- West Palm Beach, FL 33401 - 11B Description Ext Non-Jury Trial before the Honorable Thomas Barkdull, III Original & One Copy - 192 pages Volume 1 & 2 1056.00 Postage & Handling
12/29/16 18.00 Transcript(s) emailed on 12/29/16 Invoice Total: 1074.00 THANK YOU FOR YOUR BUSINESS! WE ACCEPT VISA/MASTERCARD. INVOICE DUE WITHIN 30 DAYS. Tax ID: 46-4642885
.pdf
Inv302~1.pdf
Inv302094.pdf
application/pdf
BD418ECFAFEC6148B88AAF37260C1CC1@jonesfoster.com
EnUs
101987_502014CA008142XXXXMB.O`HARE VS. TOWN OF GULF STREAM.pdf
1 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.
502014CA008142XXXXMB CHRISTOPHER O'HARE, Plaintiff, vs. TOWN OF GULF STREAM, Defendant. ___________________________/ NON-JURY TRIAL
TAKEN BEFORE THE HONORABLE THOMAS H. BARKDULL, III Pages 1 - 12 Volume I Wednesday, December 7, 2016 2:00
p.m. - 2:30 p.m. PALM BEACH COUNTY COURTHOUSE 205 North Dixie Highway, Courtroom 11B West Palm Beach, Florida 33401 Reported By: Laurie Brown Notary Public,
State of Florida 2 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 APPEARANCES: 2 ELAINE JOHNSON JAMES, ESQUIRE 3 THE O'BOYLE LAW FIRM, P.C. 1286 West
Newport Center Drive 4 Deerfield Beach, Florida 33442 Phone Number: 954-57-3501 5 Fax Number: 561-244-9580 E-Mail: Ejames@elainejohnsonjames.com 6 Appeared for the
Plaintiff 7 8 JOANNE M. O'CONNOR, ESQUIRE JONES FOSTER JOHNSON & STUBBS, P.A. 9 505 South Flagler Drive, Suite 1100 West Palm Beach, Florida 33401 10 Phone Number:
561-659-3000 Fax Number: 561-650-6300 11 E-Mail: Joconnor@jonesfoster.com 12 Appeared for the Defendant 13 14 ROBERT A. SWEETAPPLE, ESQUIRE SWEETAPPLE, BROEKER &
VARKAS, P.L. 15 20 SE 3rd Street Boca Raton, Florida 33432 16 Phone Number: 561-392-1230 Fax Number: 561-394-6102 17 E-Mail: Pleadings@sweetapplelaw.com 18 Appeared
for the Defendant 19 20 EDWARD NAZZARO, ESQUIRE TOWN OF GULF STREAM 21 100 Sea Road Gulf Stream, Florida 33483 22 Phone Number: 561-221-9008 E-Mail: Tnazzaro@gulf-stream.o
rg 23 Appeared for the Defendant 24 25 3 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 INDEX 2 PAGE
3 PROCEEDINGS 4 4 CERTIFICATE OF REPORTER 12 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 4 Fort Lauderdale, Florida
954-755-6401 Daughters Reporting, Inc. 1 PROCEEDINGS 2 THE COURT: Welcome back everyone. All 3 right. Okay. Let's chat a little bit about 4 scheduling.
We have the rest of today, which 5 is almost two hours, almost three hours, and 6 tomorrow morning. Is there any reason why we 7 can't complete our next trial and our
hearing 8 tomorrow in the time we have left? 9 MS. O'CONNOR: No. 10 MS.JOHNSON JAMES: No, sir. 11 MR. SWEETAPPLE: I'm hoping we can finish 12 today.
13 THE COURT: Well, that's what I was going 14 to ask you. If you all would like a break and 15 reconvene tomorrow, we can, or if you want to 16 push through,
and do it today, we can. 17 MS.JOHNSON JAMES: I'd love a break, but 18 Ms. Taylor -- they have a witness here. That 19 would be rude to her. 20 MR. SWEETAPPLE:
And I have a mediation 21 I'm trying to go to on a Federal case. 22 THE COURT: I will work with you all. 23 I'll give you a break if you need it, or I'll 24 go
push through. So it sounds like everybody 25 agrees we'd like to push through. I'm happy to 5 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 do that. So
let's go ahead and push through 2 with our third trial today, and then if we have 3 anything left tomorrow, we'll just start the 4 motion at 9 o'clock, and that will cut
you guys 5 free for the rest of the day. 6 MS.JOHNSON JAMES: Well, the motion is in 7 another case. 8 THE COURT: That's at 1 o'clock tomorrow. 9
MS.JOHNSON JAMES: Oh, you're saying -10 MS. O'CONNOR: Different lawyers. 11 MS.JOHNSON JAMES: Different lawyers. 12 That's not us, is all I'm saying. And
worse 13 case scenario, if we don't finish the trial 14 today, at least then Ms. Taylor has testified 15 and she won't be inconvenienced. 16 THE COURT: Okay.
All right. Okay. Then 17 let's proceed. All right. Very good. So 18 we'll start our third trial, which is case 19 number -- it's O'Hare versus Town of Gulf 20 Stream,
and correct me if I don't get it right, 21 but, it looks like it's 2014CA8142. Am I 22 correct? 23 MS.JOHNSON JAMES: Yes. May it please the 24 Court. 25
THE COURT: Let me ask - 6 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 MS.JOHNSON JAMES: Yes. 2 THE COURT: According to the pretrial 3
stip, there are two pending motions. Have 4 those been dealt with? 5 MS.JOHNSON JAMES: They have not, sir. we 6 couldn't get hearing time before the Court on
7 the motion for summary judgment. 8 THE COURT: All right. We'll just go 9 ahead and try the case. 10 MS.JOHNSON JAMES: Okay. 11 THE COURT: All
right. You may proceed. 12 MS.JOHNSON JAMES: I thought that -- I 13 didn't think we could get this heard on UMC, 14 and with no accusation meant, but, we just 15
couldn't get time on your calendar on time. 16 So Your Honor, this case involves a 17 request for public records made in May by 18 Mr. O'Hare. 19 THE COURT:
May of 2014? 20 MS.JOHNSON JAMES: Sorry. May 14, 2014. 21 THE COURT: May 16th. May 14th -22 MS.JOHNSON JAMES: No. 23 THE COURT: -- response
-24 MS.JOHNSON JAMES: Yes. Exactly right. 25 And they responded within two days 7 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 acknowledging
that they had received the 2 request, which is the first part of 3 their -- the Town's responsibility under 4 Section 109.07. The first thing they're 5 supposed to
do is acknowledge. And the second 6 thing they are supposed to do is respond. 7 After the acknowledgment on May 16th, 8 there was no further communication from the
9 Town, and six weeks later, Mr. O'Hare filed 10 suit for -- against the Town for unlawfully 11 failing to produce records responsive to his 12 request. The complaint
was served on July 7th, 13 and within minutes, the Town responded to Mr. 14 O'Hare's request saying that, you know, they 15 were providing estimated costs for production
16 of the public records, etcetera. It is our 17 position under the Hewlings (phonetic) case, 18 Your Honor, that the delay of six weeks with no 19 response, whatsoever,
is untimely. It is a 20 breach of the Town's obligations under the 21 public records laws, and this case, in 22 particular, because there are affirmative 23 defenses
alleged by the Town. 24 I want to call the Court's attention to 25 two consent judgments. We filed a request for 8 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting,
Inc. 1 judicial records. And I have copies of the 2 judgments for the Court's consideration. The 3 consent judgment entered by Judge Caracuzzo in 4 O'Hare versus the
Town of Gulf Stream. 5 MR. SWEETAPPLE: This is what you served 6 last night? 7 MS.JOHNSON JAMES: No, I served that -- I 8 served the trial memorandum last
night. 9 MR. SWEETAPPLE: Request for judicial 10 notice is what I got last night. 11 MS.JOHNSON JAMES: I think, you got it 12 during the day. 13
MR. SWEETAPPLE: Oh, you served it 14 yesterday? 15 MS.JOHNSON JAMES: I served it yesterday. 16 MR. SWEETAPPLE: I'm going to object, 17 Your Honor, to any
request for judicial notice. 18 THE COURT: Sustained as being untimely. 19 MS.JOHNSON JAMES: Okay. 20 THE COURT: Folks, this case was at 21 calendar
call weeks ago and everything is 22 supposed to be ready to go before you come to 23 calendar call. Pretrial order sets forth when 24 things need to be done. 25
MS.JOHNSON JAMES: Your Honor, they filed 9 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 a request for judicial notice three days ago, 2 so -3
THE COURT: In this case? 4 MS. O'CONNOR: Yes, Judge. 5 THE COURT: Good. I'll deny that one too. 6 MS.JOHNSON JAMES: Okay. The issues of 7 affirmative
defenses of bad faith waiver and 8 estoppel have been adjudicated against the Town 9 in several cases. 10 MR. SWEETAPPLE: Your Honor, I'm going 11 to -- is this
the opening, or are you arguing 12 from your -13 MS.JOHNSON JAMES: It's my opening. 14 THE COURT: Yeah, but, if I -- how 15 are -- what are you going to
get in to prove 16 that? 17 MS.JOHNSON JAMES: Okay. 18 THE COURT: Listen, you guys want to play 19 in this venue. Both sides have chosen to do 20 that.
You're going to do it right. If you're 21 going to take my time and the tax payer's time 22 to do this, you're going to do it right. 23 MS.JOHNSON JAMES: It certainly
isn't my 24 intention to do it wrong, Your Honor. 25 THE COURT: Day before, handing me a trial 10 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1
memo the day of trial. Giving me a request for 2 judicial notice the day before that I've never 3 seen. Three days before. Weeks after the 4 calendar call. You know
what, why don't I just 5 strike this case from the trial calendar and 6 get you ready to try your case sometime in the 7 future in front of another Judge? 8 MR.
SWEETAPPLE: Your Honor -9 THE COURT: I'm rotating out of this 10 division. 11 MR. SWEETAPPLE: I'd ask that you hear 12 this case, Your Honor, because you've
heard 13 facts that I can abbreviate because I won't 14 have to go and read transcripts again. I 15 think, I'll get -16 THE COURT: Oh, no. You're not taking
17 materials from one case and moving them to 18 another. 19 MR. SWEETAPPLE: No, I'm not doing that. 20 THE COURT: They're all going to be 21 self-contained,
because you all are going to 22 get to play in front of the Fourth DCA. 23 MR. SWEETAPPLE: Your Honor, I -24 THE COURT: They can enjoy your time. 25
MR. SWEETAPPLE: I'm not suggesting that 11 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 I'm going to do that, but, I think, Mr. O'Hare 2 will answer quickly
since I've already -3 THE COURT: You think so? 4 MR. SWEETAPPLE: I hope so since I read 5 his testimony and he heard it. I hope I don't 6 have to impeach
him -7 THE COURT: I'll see you all tomorrow 8 morning at 9 o'clock. We'll try this case on 9 the day it's supposed to be tried. I'll see 10 you at 9 o'clock
tomorrow morning. 11 MR. SWEETAPPLE: Thank you. 12 THE COURT: Be ready to go. Be prepared. 13 MR. SWEETAPPLE: We will. 14 MS.JOHNSON JAMES:
Have a good evening, 15 sir. 16 (The proceedings adjourned at 2:30 p.m.) 17 18 19 20 21 22 23 24 25 12 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1
CERTIFICATE OF REPORTER 2 3 4 THE STATE OF FLORIDA ) 5 COUNTY OF PALM BEACH ) 6 7 8 I, Laurie Brown, Shorthand Reporter, certify 9 that I was authorized to and did stenographically
10 report the foregoing proceedings, and that the 11 transcript is a true and complete record of my 12 stenographic notes. 13 Dated this 20th day of December, 2016. 14 15 16 17
18 19 20 21 ___________________________________ 22 Laurie Brown Shorthand Reporter 23 24 25 Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc. 1 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. A abbreviate 10:13 accusation 6:14 acknowledge7:5 acknowledging 7:1 acknowledgm... 7:7 adjourned
11:16 adjudicated 9:8 affirmative7:22 9:7 ago 8:21 9:1 agrees4:25 ahead 5:1 6:9 alleged 7:23 answer11:2 APPEARANC... 2:1 Appeared 2:6,12 2:18,23 arguing 9:11 attention 7:24 authorized
12:9 B back4:2 bad 9:7 BARKDULL 1:12 Beach 1:1,17,18 2:4,9 12:5 bit 4:3 Boca 2:15 breach 7:20 break4:14,17,23 BROEKER2:14 Brown 1:24 12:8 12:22 C calendar6:15 8:21,23 10:4,5 call7:24
8:21,23 10:4 Caracuzzo 8:3 case1:2 4:21 5:7 5:13,18 6:9,16 7:17,21 8:20 9:3 10:5,6,12 10:17 11:8 cases9:9 Center2:3 certainly 9:23 CERTIFICATE 3:4 12:1 certify 12:8 chat 4:3 chosen
9:19 CHRISTOPH... 1:3 CIRCUIT1:1,1 come8:22 communication 7:8 complaint 7:12 complete4:7 12:11 consent 7:25 8:3 consideration 8:2 copies8:1 correct 5:20,22 costs7:15 COUNTY1:1 1:17
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etcetera 7:16 evening 11:14 everybody 4:24 Exactly 6:24 F facts10:13 failing 7:11 faith 9:7 Fax2:5,10,16 Federal4:21 FIFTEENTH 1:1 filed 7:9,25 8:25 finish 4:11 5:13 FIRM 2:3 first
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inconvenienced 5:15 INDEX3:1 intention 9:24 involves6:16 issues9:6 J JAMES 2:2 4:10 4:17 5:6,9,11 5:23 6:1,5,10 6:12,20,22,24 8:7,11,15,19 8:25 9:6,13,17 9:23 11:14 JOANNE2:8 Joconnor@jo...
2:11 JOHNSON 2:2 2:8 JONES 2:8 Judge8:3 9:4 10:7 judgment 6:7 8:3 judgments7:25 8:2 judicial1:1 8:1,9 8:17 9:1 10:2 July 7:12 K know7:14 10:4 L Laurie1:24 12:8 12:22 2 Fort Lauderdale,
Florida 954-755-6401 Daughters Reporting, Inc. LAW 2:3 laws7:21 lawyers5:10,11 left 4:8 5:3 let's4:3 5:1,17 Listen 9:18 little4:3 looks5:21 love4:17 M M 2:8 materials10:17 meant 6:14
mediation 4:20 memo10:1 memorandum 8:8 minutes7:13 morning 4:6 11:8,10 motion 5:4,6 6:7 motions6:3 moving 10:17 MS.JOHNSON 4:10,17 5:6,9 5:11,23 6:1,5 6:10,12,20,22 6:24 8:7,11,15 8:19,25
9:6,13 9:17,23 11:14 N NAZZARO2:20 need 4:23 8:24 never10:2 Newport 2:3 night 8:6,8,10 NON-JURY 1:11 North 1:17 Notary 1:24 notes12:12 notice8:10,17 9:1 10:2 number2:4,5,10 2:10,16,16,22
5:19 O O'BOYLE2:3 o'clock5:4,8 11:8,10 O'CONNOR2:8 4:9 5:10 9:4 O'Hare1:3 5:19 6:18 7:9 8:4 11:1 O'Hare's7:14 object 8:16 obligations7:20 Oh 5:9 8:13 10:16 Okay 4:3 5:16 5:16 6:10 8:19
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10:24 Tnazzaro@gu... 2:22 today 4:4,12,16 5:2,14 tomorrow 4:6,8 4:15 5:3,8 11:7 11:10 Town 1:6 2:20 5:19 7:9,10,13 7:23 8:4 9:8 Town's7:3,20 transcript 12:11 transcripts 10:14 trial1:11
4:7 5:2 5:13,18 8:8 9:25 10:1,5 tried 11:9 3 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. true12:11 try 6:9 10:6 11:8 trying 4:21 two 4:5 6:3,25 7:25 U UMC6:13 unlawfully7:10
untimely 7:19 8:18 V VARKAS 2:14 venue9:19 versus5:19 8:4 Volume1:13 vs1:5 W waiver9:7 want 4:15 7:24 9:18 we'll5:3,18 6:8 11:8 Wednesday 1:15 weeks7:9,18 8:21 10:3 Welcome4:2 West
1:18 2:3,9 whatsoever7:19 witness4:18 work4:22 worse5:12 wrong 9:24 X Y Yeah 9:14 yesterday 8:14 8:15 Z 0 1 1 1:13 5:8 100 2:21 109.07 7:4 1100 2:9 11B 1:17 12 1:13 3:4 1286 2:3 14
6:20 14th 6:21 16th 6:21 7:7 2 2:00 1:15 2:30 1:15 11:16 20 2:15 2014 6:19,20 2014CA8142 5:21 2016 1:15 12:13 205 1:17 20th 12:13 3 33401 1:18 2:9 33432 2:15 33442 2:4 33483 2:21 3rd
2:15 4 4 3:3 5 502014CA008... 1:2 505 2:9 561-221-9008 2:22 561-244-9580 2:5 561-392-1230 2:16 561-394-6102 2:16 561-650-6300 2:10 561-659-3000 2:10 6 7 7 1:15 7th 7:12 8 9 9 5:4 11:8,10
954-57-3501 2:4
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101987_502014CA008142XXXXMB.O`HARE VS. TOWN OF GULF STREAM.pdf
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72CD9F9DF4E6E148871322A09FD6B855@jonesfoster.com
EnUs
101987_502014CA008142XXXXMB.O`HARE VS. TOWN OF GULF STREAM.V2.pdf
13 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.
502014CA008142XXXXMB CHRISTOPHER O'HARE, Plaintiff, vs. TOWN OF GULF STREAM, Defendant. ___________________________/ CONTINUATION OF NON-JURY TRIAL
TAKEN BEFORE THE HONORABLE THOMAS H. BARKDULL, III Pages 13 - 192 Volume II Thursday, December 8, 2016
9:00 a.m. - 2:15 p.m. PALM BEACH COUNTY COURTHOUSE 205 North Dixie Highway, Courtroom 11B West Palm Beach, Florida 33401 Reported By: Laurie Brown Notary
Public, State of Florida 14 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 APPEARANCES: 2 ELAINE JOHNSON JAMES, ESQUIRE 3 THE O'BOYLE LAW FIRM, P.C. 1286
West Newport Center Drive 4 Deerfield Beach, Florida 33442 Phone Number: 954-57-3501 5 Fax Number: 561-244-9580 E-Mail: Ejames@elainejohnsonjames.com 6 Appeared
for the Plaintiff 7 8 JOANNE M. O'CONNOR, ESQUIRE JONES FOSTER JOHNSON & STUBBS, P.A. 9 505 South Flagler Drive, Suite 1100 West Palm Beach, Florida 33401 10 Phone
Number: 561-659-3000 Fax Number: 561-650-6300 11 E-Mail: Joconnor@jonesfoster.com 12 Appeared for the Defendant 13 14 ROBERT A. SWEETAPPLE, ESQUIRE SWEETAPPLE, BROEKER
& VARKAS, P.L. 15 20 SE 3rd Street Boca Raton, Florida 33432 16 Phone Number: 561-392-1230 Fax Number: 561-394-6102 17 E-Mail: Pleadings@sweetapplelaw.com 18
Appeared for the Defendant 19 20 EDWARD NAZZARO, ESQUIRE TOWN OF GULF STREAM 21 100 Sea Road Gulf Stream, Florida 33483 22 Phone Number: 561-221-9008 E-Mail:
Tnazzaro@gulf-stream.org 23 Appeared for the Defendant 24 25 15 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 INDEX 2 3 WITNESS:
DIRECT CROSS REDIRECT RECROSS 4 CHRISTOPHER O'HARE 5 BY MS. JOHNSON-JAMES: 68 6 BY MR. SWEETAPPLE: 79 7 BY MS. JOHNSON-JAMES: 179 8 9 10 11
12 13 14 15 16 17 18 19 20 21 22 23 24 25 16 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 EXHIBITS 2 3 NUMBER DESCRIPTION
PAGE 4 Plaintiff Ex. No. 1 E-mail 73 5 Plaintiff Ex. No. 2 E-mail 76 6 Plaintiff Ex. No. 3 E-mail
76 7 Plaintiff Ex. No. 4 Log 184 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 17 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting,
Inc. 1 PROCEEDINGS 2 THE COURT: Welcome everyone. We're back 3 on the record for the case of O'Hare versus 4 Town of Gulf Stream. When we recessed
5 yesterday, I went back and tried to pull up the 6 motions for judicial notice on the e-service. 7 They, of course, were not there because they 8 were so recently filed
that the Clerk had not 9 gotten them on my electronic docket, neither 10 had courtesy copies been provided to me prior 11 to trial, so I was unable to review them. 12
So I reviewed general law on judicial 13 notice. When I come back, I'm going to want to 14 talk to you all about each of your notices 15 for -- or requests for judicial
notice. I need 16 copies of -- hold on. I need -- I'm telling 17 you what I'm going to talk to you about. I 18 need copies of those so I can look at them. 19
If you are requesting that I take judicial 20 notice of something that is a document in true 21 form, was that -- my first question is going to 22 be, was that document
listed on your exhibit 23 list to this case, because if you're -- even if 24 you're asking me to take judicial notice of 25 something, if it's a judgment where you need
a 18 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 certified copy or something that's going to go 2 in the record for appeal, it has to have been 3 listed
on the exhibit list. If not, it 4 was -- it's a violation of pretrial order. 5 Now, if you all agree to each others 6 motion for judicial notice, then by 7 stipulation,
I'll let the stuff in by agreement 8 of the parties. But let me take a break so you 9 all can talk to each other. Get those things 10 together. That's what I came up
with in my 11 research yesterday. I'll be back. 12 (A break was taken at this time.) 13 THE COURT: May I please have a courtesy 14 copy of the Plaintiff's
motion for judicial 15 notice and a courtesy copy of -- uh-oh, we've 16 lost some counsel -- and a courtesy copy of the 17 Defendant's motion for judicial notice? 18
MS. JOHNSON JAMES: If I may approach. 19 THE COURT: You may approach. 20 MS. JOHNSON JAMES: Your Honor, I did not 21 copy all of the attachments because
I'm only 22 going to argue from a few. 23 THE COURT: Okay. 24 MS. JOHNSON JAMES: So I -25 THE COURT: I'll give these back to you. 19 Fort Lauderdale,
Florida 954-755-6401 Daughters Reporting, Inc. 1 This is the first I've seen, so let me just 2 take a quick look. I've been handed 3 Plaintiff's request for judicial notice,
which 4 was e-filed on December 6, 2016. It has not 5 made the electronic docket sheet yet. 6 All right. Let's see. Consent final 7 judgment, complaint, final
judgment, final 8 order, complaint. 9 Okay. Do we have a copy of the 10 Plaintiff's motion for -- excuse me, Defense's 11 motion for judicial notice? 12
MR. SWEETAPPLE: Your Honor, we didn't 13 bring it based on your ruling and we're 14 not -- we're not seeking to introduce any 15 because it's not on our exhibit list.
We're 16 objecting to these as not having been on the 17 exhibit list. 18 THE COURT: Okay. So these are all -- I'm 19 requested to take judicial notice of nine
20 separate orders by the Plaintiff. Were any of 21 these contained on the exhibit list, Counsel, 22 for the Plaintiff? 23 MS. JOHNSON JAMES: They were not 24
specifically. I'm looking at the exhibit list 25 now. They did -- most of -- they did not exist 20 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 at
the time the exhibit list was filed, and I 2 could see we did not amend our exhibit list to 3 include them. My understanding, I looked at 4 the Court's pretrial order.
There was no 5 indication of when such notices should be 6 filed. 7 THE COURT: Okay. Well -8 MS. JOHNSON JAMES: Go ahead, sir. 9 THE COURT: --
the rule is 92026. Okay. 10 So it refers you to 920375 -11 MS. JOHNSON JAMES: Huh-huh. 12 THE COURT: -- which says that timely 13 written notice -14
MS. JOHNSON JAMES: Right. 15 THE COURT: -- must be provided -16 MS. JOHNSON JAMES: Yes. 17 THE COURT: -- to the Court and opposing 18 counsel.
Okay. So you're asking me to take 19 judicial notice of nine separate things. It 20 was -- I don't know -- you say it was e-filed 21 on the 6th of December, which is
the day before 22 the trial. I was not provided a courtesy copy 23 of it. What time of day was it filed? 24 MS. JOHNSON JAMES: Midday. And, 25 Your Honor, as
I just -- when I handed it to 21 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 you I said we are -- although, the notice 2 refers to nine different documents,
the two 3 sets of documents that form the basis for our 4 argument on collateral estoppel and res 5 judicata are the documents having to do with 6 O'Hare versus Town
of Gulf Stream which is 7 2014CA2311, wich was tried by Judge Caracuzzo 8 in this case -- I mean, in this court. 9 Ms. O'Connor was Counsel to Mr -10 THE COURT:
What do you want me to take 11 judicial notice for? 12 MS. JOHNSON JAMES: For the Town has, in 13 its interrogatory answers, stated that the bad 14 faith and
bad -- alleged bad faith and bad acts 15 of my client excused them from complying with 16 the public records rules. It refers to 17 the -- the interrogatory answers refer
to two 18 letters dated January, 2014 and February, 2014, 19 which the Town sent to my client telling him 20 that until he paid an administrative fee of 21 approximately
$800.00, the Town wasn't going to 22 process any more of his public records 23 requests. Those same letters that were 24 referred to in the Town's interrogatory answers
25 in this case were the subject of a lawsuit that 22 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Mr. O'Hare brought against the Town in 2 20142311,
and the Town entered into a consent 3 final judgment that those letters, and the 4 positions that they took in those letters, 5 violated the public records act. So that
is -6 THE COURT: And that was -- what was the 7 date of that consent final judgment? 8 MS. JOHNSON JAMES: September, 2016. 9 THE COURT: Okay. That
-10 MS. JOHNSON JAMES: I -- I'm sorry, sir. 11 And it is -- it is an exhibit. That consent 12 final judgment is an exhibit to our motion for 13 summary judgment
in this case. So there's no 14 question -15 THE COURT: Well, let me ask this, if 16 that's been out there for at least three, if 17 not four months, why are we
getting this the 18 afternoon the day before trial? And I'm 19 getting it for the first time the second day of 20 trial. 21 MR. SWEETAPPLE: May I respond, 22
Your Honor? 23 THE COURT: Yeah, you will. I want to 24 find out, because it goes to whether this is 25 timely written notice. 23 Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc. 1 MS. JOHNSON JAMES: I -2 THE COURT: It's violative of my pretrial 3 order, because it -- these things are not 4 listed as exhibits
on the exhibit list. So the 5 question that we now have to fall back to, 6 whether this was timely notice where I am 7 required to take judicial notice. So what case 8
law do you have that says this is timely 9 notice, you know, less than 24 hours before the 10 beginning of the trial? 11 MS. JOHNSON JAMES: Well, actually, it's
12 more than 24, because we're starting today. I 13 can see -14 THE COURT: We would have been finished 15 with this case yesterday afternoon if we hadn't 16
had to address this issue and I had to take a 17 break and go back and try and figure out what 18 to do with it. 19 MS. JOHNSON JAMES: I didn't know that 20
that was why you adjourned yesterday, Your 21 Honor. I am not trying to annoy the Court. I 22 see that I am inadvertently doing so and I 23 apologize for that. 24
THE COURT: Listen -25 MS. JOHNSON JAMES: I can see that - 24 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 THE COURT: -- this is trial
by ambush on 2 the Trial Judge. I get the day of the hearing, 3 a trial memorandum you want me to read that 4 still has not made the Court's electronic 5 filing. You
don't have the courtesy of 6 providing me with a courtesy copy prior to 7 trial. You walk in the day of trial and say we 8 filed a request for judicial notice yesterday,
9 but we didn't give you a copy of it. 10 MS. JOHNSON JAMES: Sir, I was -- I'm 11 not -- I'm not -12 THE COURT: This case has been pending for 13 years.
14 MS. JOHNSON JAMES: I understand, sir. 15 Would you just let me finish though, please? 16 The failure to get it done before this week was 17 attributable to
the fact that I didn't do it a 18 month ago. I can see that, okay? But I did 19 not read the Court's pretrial order, and that 20 might have been my mistake. 21
I came into the case in September, 22 concededly, a couple of months ago. I did not 23 read the Court's pretrial order as requiring 24 notices of this sort to be filed
at a 25 particular time. There's no -- it's not a 25 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 motion, okay, so I can see that -2 THE COURT:
It is a motion. You're 3 requesting I take judicial notice, so you're 4 requesting that I do something. So it is a 5 motion. 6 MS. JOHNSON JAMES: But -- it's
not 7 a -- it's not like a motion in limine or any of 8 the things that's listed in your 9 pretrial -- your pretrial order. I simply want 10 to say to the Court, it
was not my intent to 11 ambush you. You've known me a long time. You 12 know I don't function like that. 13 THE COURT: No, I know you don't, but, you 14 know
what, given the issues in this case, one 15 of the issues is ambush. One of the issues 16 that I dealt with in the past two -- prior two 17 cases was your client says this
spending of 18 weeks putting together questions and inquiries 19 of the Town and then blasting them on a Sunday 20 afternoon. So the question of whether there's 21
good faith or not good faith, it's a central 22 issue in this case. 23 MS. JOHNSON JAMES: Okay. And the other 24 thing I wanted to say to you, I said that the 25
Caracuzzo case, 2311, was one of the basis. 26 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 The other basis is the O'Boyle litigation 2 before Judge
Haffel, which was resolved in 3 September, both the principle complaint and the 4 counter-claim that the Town filed were 5 adjudicated against the Town. 6 The amended
-- the affirmative defenses in 7 that case, the O'Boyle case, which is to -- the 8 principle case is 2014CA4474. The 9 counter-claim was severed, and the number for 10
the counter-claim was 20145437. Those 11 affirmative defenses are identical to the 12 affirmative defenses in this case. 13 Judge Oftedal -14 THE COURT: It's
not the same request, is 15 it? 16 MS. JOHNSON JAMES: What do you mean, sir? 17 THE COURT: The public records requests in 18 those cases were not the same
requests in this 19 case. 20 MS. JOHNSON JAMES: No, but what happened 21 in that case, Your Honor, is that the Town 22 filed a counter-claim against Mr. O'Boyle
and 23 many other people, including Mr. O'Hare, so he 24 was a party in that case. And so to the extent 25 that the counter-claim and the affirmative 27 Fort Lauderdale,
Florida 954-755-6401 Daughters Reporting, Inc. 1 defenses have been adjudicated against the Town 2 in that case, it would be -3 THE COURT: They were not adjudicated
on 4 the merits were they? 5 MS. JOHNSON JAMES: Yes, sir. 6 THE COURT: There was a consent judgment, 7 right? 8 MS. JOHNSON JAMES: No, no. That
was 9 Caracuzzo. There was a final judgment after 10 trial on Mr. O'Boyle's complaint in 4474, and 11 there was a final summary judgment on the 12 counter-claim in
case 5437, which is the 13 counter-claim that was severed from 44 -14 THE COURT: Was Mr. O'Hare a party to 15 those actions? 16 MS. JOHNSON JAMES: Yes, sir.
He was a 17 counter-claim defendant. 18 THE COURT: Response, Counsel. 19 MS. JOHNSON JAMES: And -- I'm sorry. 20 Just one more thing, Your Honor. Mr. 21
Sweetapple filed both the affirmative defenses 22 in the O'Boyle case that I just referenced, and 23 the affirmative defenses in this case. And 24 Ms. O'Connor was
Counsel in both of those cases 25 as well. So while I absolutely do understand, 28 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 and apologize, that I did
not give the Court 2 the notice it needed, there is no ambush on the 3 Town. 4 THE COURT: Okay. So the 5 prejudice -- you're saying there's no prejudice 6
to the Town of Gulf Stream. 7 MS. JOHNSON JAMES: That's correct. 8 THE COURT: All right. Response, 9 Mr. Sweetapple. 10 MR. SWEETAPPLE: Yes, Your
Honor. First 11 of all, Ms. James is new to the case so I'm 12 sure that her representations to the Court 13 aren't intentionally inaccurate. However, if 14 you will
look at the case that we conceded to a 15 judgment before Judge Caracuzzo, while Counsel 16 represented to you the letters were the same, 17 that's totally incorrect. There
were -- we 18 conceded a judgment in that case because the 19 Town, without understanding the law, wrote a 20 letter and said, "We're not giving you any 21 future responses
because you didn't pay or pick 22 up for the last things that you ordered." 23 And because it was a requirement that 24 something be paid with regard to a prior 25
request, my position in the case was, that's 29 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 not proper. We have to concede that we should 2 not have
coupled the requirement that a prior 3 request be paid for before a current request be 4 processed. They are two separate requests. So 5 you've been had, concede that
that has to be 6 provided. 7 This case, however, is a case where the 8 very documents that are being sought there was 9 a request for that relief. Now, what happened
10 in the case that Counsel is referring to, the 11 O'Boyle case -12 THE COURT: All right. So the first case, 13 which is the Caracuzzo case, you're saying they
14 predicated the production -- future productions 15 on payment for past outstanding bills? 16 MR. SWEETAPPLE: That's correct. 17 THE COURT: In this case,
they predicated 18 production of the existing request for payment 19 of the existing expense? 20 MR. SWEETAPPLE: Yes, sir. 21 THE COURT: Okay. So those
are totally 22 different. 23 MR. SWEETAPPLE: Totally different 24 situation. 25 THE COURT: Okay. So I understand. Now, 30 Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc. 1 let's go to the other issue. 2 MR. SWEETAPPLE: Let's talk about the 3 issue of bad faith and my attempt to bring bad 4 faith into the
litigation. When Judge Blanc 5 had this case originally, we -- the original 6 O'Boyle case that I was working on, I 7 attempted, based on activities I discovered 8
involving Kathy (phonetic) and Chandler 9 (phonetic), who worked for Mr. O'Hare, as well 10 as, Mr. O'Boyle, to bring a bad faith 11 affirmative defense. Judge Blanc allowed
me to 12 do that. Judge Oftedal issued a summary 13 judgment on the defenses and on my 14 counter-claim seeking to have the court declare 15 that some relief could
be granted in equity to 16 control the operations of the clerk's office to 17 keep it open. Judge Oftedal entered a summary 18 judgment and also -19 THE COURT:
Entered a summary judgment for 20 who? 21 MR. SWEETAPPLE: For Mr. O'Hare on the 22 counter-claim saying that based on the law, he 23 was not -- he -- this was
something the 24 legislature should deal with, and he was not in 25 a position to appoint a commissioner or set 31 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting,
Inc. 1 schedule. 2 I cited to the court the McMillan case 3 from 1905, Florida Supreme Court, that the 4 clerk's office has to stay open. I cited a 5 First
District case where the Appellate Court, 6 affirmative trial court setting schedules where 7 there were multiple, and he declined. That is 8 on appeal before the Fourth
District right now. 9 The affirmative defense of bad faith has 10 never been tried. I have -- this affirmative 11 defense was not tried at any time, and this 12
is -- you're the second Judge that, I believe, 13 I asked to have this specific affirmative 14 defense tried before. We did not bring it into 15 the other cases because
this is a -- an alleged 16 delay case. This is an alleged delay case, 17 Judge, before you were there from 18 January -- from January of -- 1 of 2014. 19 There
are 909 requests served by May 14th, 20 and I'm going to be able to show, in this case, 21 to prove my bad faith that all but a handful of 22 those requests were filed by
Mr. O'Hare, 23 Mr. Roeder -24 MS. JOHNSON JAMES: Your Honor -25 MR. SWEETAPPLE: -- Mr. Martin and 32 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting,
Inc. 1 Mr. Jonathan O'Boyle. 2 THE COURT: I'm sorry? 3 MS. JOHNSON JAMES: There's no need for 4 him to point at my client or Mr. Roeder. He 5 should
be addressing the Court, not pointing at 6 people. 7 THE COURT: All right. Well, let me ask 8 this, doesn't that go to the merits of whether 9 there -- the judicial
estoppel or res judicata 10 applies? She's asking that I take judicial 11 notice of two of the cases. If I take judicial 12 notice, that doesn't preclude you from making
13 the argument that these, as you just made, that 14 these don't apply here for the very reasons you 15 set forth on the record. So let's deal with 16 the evidentiary
issue first. 17 MR. SWEETAPPLE: Sure. 18 THE COURT: Okay. 19 MR. SWEETAPPLE: I'm sitting here -- I'm 20 sitting here without any of these files, 21
without any ability to go through. I have 20 22 or 30 boxes of litigation with Mr. O'Boyle, 23 Mr. O'Hare. I don't have the notices of appeal 24 to show you that those
are on appeal. I don't 25 have the pleadings to show you - 33 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 THE COURT: All right. So you can -2
MR. SWEETAPPLE: But -3 THE COURT: I understand. You were not 4 prepared to deal with this because we 5 got -- listen, you received it yesterday. I 6
received it this morning. And this is the sort 7 of thing when we've got this voluminous -- I 8 can understand -9 MS. JOHNSON JAMES: Your Honor, may I -10
MR. SWEETAPPLE: Let me concede something. 11 I have no problem if she wants to make a legal 12 argument post-trial. I want to try this case 13 on the facts. If she
wants to make some 14 argument that somehow there's collateral 15 estoppel or res judicata by a motion for a new 16 trial or something of that nature, just some 17 legal
argument, I'm perfectly happy to deal 18 with it because it's invalid. But I don't want 19 to -- I don't want to sit here and have to go 20 find my files and argue -21
THE COURT: Hold on. Let me ask this and 22 see if this was even ever framed by the 23 pleadings in response to their affirmative 24 defense of bad faith. Did
you file a reply 25 that said they are judicially estopped or 34 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 estopped by a res judicata because of the
2 filings in these other cases? 3 MS. JOHNSON JAMES: For two reasons I did 4 not, sir. One, I wasn't in the case at the 5 time. And two, neither of the -- neither
of 6 the three judgments, to which I have referred 7 the Court this morning, had been issued by 8 then. The earliest one was issued in September 9 of -10 THE
COURT: Right, but you can always move 11 to amend. 12 MS. JOHNSON JAMES: I -- Your Honor, 13 you're absolutely right, but I want to 14 just -- my reputation is
very important to me 15 and Mr. Sweetapple said that I had 16 inadvertently misled the Court. I'm not -- to 17 be crystal clear with you, that I did not 18 mislead
the Court. 19 THE COURT: Okay. 20 MS. JOHNSON JAMES: Please, let me just 21 finish. 22 THE COURT: But this is what I'm saying, 23 the basis is
prejudice -24 MS. JOHNSON JAMES: I under -25 THE COURT: -- and what I'm trying to 35 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 figure
out is, he said he'd be prepared to deal 2 with this, but he's -- but looking and knowing 3 the history of these parties, there have got to 4 be tons of banker's boxes of
materials to go 5 through to counter these things. So he said he 6 doesn't have any of those. 7 So I'm trying to find out if there had 8 been a motion for leave
to amend, the reply to 9 affirmative defenses that put him on notice six 10 weeks ago that this was coming up the day of 11 trial, then there could be no prejudice. 12
MS. JOHNSON JAMES: There was a motion for 13 summary judgment in this case filed on October 14 10th of 2016. It referenced Judge Caracuzzo's 15 judgment. And
it -- and it ordered -- I'm 16 sorry. And it argued -- it's inclusion. The 17 Court did not -- yesterday, the Court struck 18 our -- struck both parties' requests for
19 judicial notice and -20 THE COURT: Let me ask you this, was there 21 a request for judicial notice that was filed to 22 support the motion for summary judgment,
23 because if you want me to summary judge based 24 upon another judge's ruling, you've got to say 25 we've attached a copy of the judgment in the 36 Fort Lauderdale, Florida
954-755-6401 Daughters Reporting, Inc. 1 other court. It's res judicata. We request 2 you take judicial notice of it. 3 MS. JOHNSON JAMES: There was not. But, 4
Your Honor. Let me just finish, please. 5 THE COURT: Yes. 6 MS. JOHNSON JAMES: The other thing I 7 wanted to say is, the letters that were 8 considered
by Judge Caracuzzo were dated 9 January 23, 2014 and February 20, 2014. 10 Mr. O'Hare will testify that those are the only 11 letters that he received from the Town on those
12 dates. Those very letters are mentioned in the 13 Defendant's answers to interrogatories in this 14 case. It's interrogatory number seven, and 15 they say that
the documents, which demonstrate 16 and support their position that they're are 17 excused "Is it Defendant's position that it is 18 excused from the duty to produce public
records 19 under the Public Records Act based upon the 20 volume of requests or the intent of the 21 requester? What facts of law are known to the 22 Defendant would
support that contention as it 23 relates to this case?" 24 And in answer to that interrogatory, two 25 of the things that the Town listed in this case 37 Fort Lauderdale,
Florida 954-755-6401 Daughters Reporting, Inc. 1 are those same letters from January 23, 2014 2 and February 20, 2014. No matter what 3 else -- no matter how the Court
rules, I take 4 very, very seriously my reputation for being 5 candid before the Tribunal. I told you that I 6 absolutely should have filed these sooner. 7 I do
not believe there is any prejudice to 8 them, because you didn't strike my request for 9 judicial notice in this case yesterday. You 10 struck the one from the 6848 case
yesterday. 11 So since Monday, granted not for two 12 weeks, but since Monday, since October 10, 13 2014, the Town has been on notice that 14 Judge Caracuzzo's
ruling was relevant to this 15 case and that Mr. O'Hare's Counsel was going to 16 argue from it. Since Monday, they have been on 17 notice that the O'Boyle and -- the O'Boyle
18 summary judgment and the O'Boyle final 19 judgment -20 THE COURT: Actually, since Tuesday, 21 correct? 22 MS. JOHNSON JAMES: No. 23 THE COURT:
You filed it on the 6th. 24 MS. JOHNSON JAMES: I filed -- that was 25 Monday. Today is the 8th. Today is the 8th. 38 Fort Lauderdale, Florida 954-755-6401 Daughters
Reporting, Inc. 1 THE COURT: And today -2 MS. JOHNSON JAMES: I filed it -3 THE COURT: And today is Thursday. 4 MS. JOHNSON JAMES: I'm sorry.
5 THE COURT: Today is the 8th. It's 6 Thursday and the 6th was Tuesday. 7 MS. JOHNSON JAMES: Okay. December 6th. 8 THE COURT: We started trial yesterday.
9 MS. JOHNSON JAMES: December 6th. I'm 10 sorry. Since December 6th, they've been on 11 notice that we also thought that the O'Boyle 12 final summary judgment
on the counter-claim and 13 on the final judgment relevant. And we -- when 14 we electronically served the judicial notice, 15 we electronically served all of the documents
16 that were relevant to it except for one that 17 wouldn't go until I e-mailed that directly to 18 Ms. O'Connor and Mr. Sweetapple. So you know, 19 however you rule,
you rule, but -20 THE COURT: I just wanted to hear the 21 arguments from both sides, because when I went 22 and looked at it, and because I couldn't pull 23 the
motions, and the requests, because they 24 weren't on the electronic docket at that point, 25 and I had not received copies of them, I had to 39 Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc. 1 go back, look at the pretrial order, so I 2 didn't know what you were asking me to take 3 judicial notice of, but I'm assuming it's going 4
to be a document of some kind. Okay. So if 5 it's going to be a document, it should be 6 listed on the exhibit list. Okay. So you're 7 telling me today none of these
orders, which 8 can be reduced to written form, are documents 9 on the exhibit list. So I'm now faced with 10 92031 which talks about what is timely written 11 notice.
12 Okay. We -- it's received the day before 13 the beginning of trial by opposing Counsel, but 14 not by the Court. Counsel says he's prejudiced 15 because of
the voluminous nature of it and the 16 fact that it deals with nine different cases 17 and he needs to have boxes here to respond to 18 it. 19 MR. SWEETAPPLE:
May I -- may I -- my 20 response based on what she said for one minute, 21 please? 22 THE COURT: Okay. 23 MR. SWEETAPPLE: All right. I beg your 24 indulgence.
With regard to this whole issue of 25 the letters, the letters that were answered in 40 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 the interrogatories
were answered at the time 2 those other cases were pending. The pretrial 3 catalog makes it clear, the letter that we are 4 relying on in this case is May 16, 2014. We're
5 not relying on those letters for the prior 6 requests where those pre-conditions were 7 placed. So this is a tempest and the teapot in 8 that regard. 9 With
regard to the O'Boyle summary 10 judgment, Judge Oftedal entered that order over 11 a year ago. The final judgment was entered 12 about 90 days ago because -- I know because
my 13 daughter is working on the brief, and the 14 deadline for the brief is now, and I was asked 15 to ask Ms. James if we could get an extension. 16 So we have 30
days from the time it was 17 entered. She was involved in the case. It's 18 been 90 days since that was entered and no 19 motion to amend these pleadings at all to 20
allege any of these issues. 21 THE COURT: All right. I was trying to 22 work my way through my ruling, but -23 MR. SWEETAPPLE: I'm sorry. 24 THE
COURT: -- we're working our way 25 through the ruling at this point. Okay. The 41 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 issues were not raised
in reply to the 2 affirmative defenses, originally, because at 3 that time, decisions had not come down from the 4 trial. 5 MS. JOHNSON JAMES: Correct. 6
THE COURT: Leave to amend is freely 7 granted. At the time the decision was -- came 8 down, it would have been appropriate, not now, 9 but it would have been appropriate
to move for 10 a leave to amend to allow amendment to reply 11 stating the basis of the traverse to the 12 affirmative defense. That didn't happen. I'm 13 going to
find that the less than 24 hours 14 notice prior to trial of the voluminous list of 15 requests for judicial notice that was never 16 provided to the Court is prejudicial
to the 17 Defense in this case, and I'm going to deny the 18 request for judicial notice. 19 Counsel for the Defense has withdrawn 20 their request for judicial
notice, so that 21 issue is mute. 22 Okay. We are now at almost 9:45. I want 23 to make sure that you all have time to present 24 your case in its entirety.
I don't think we 25 can get it done by noon, so I'm going to cancel 42 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 the motion to dismiss that is scheduled
for 2 1:30 this afternoon, should we have to, in one 3 of the related O'Hare cases. 4 Lucile (phonetic), if you have the box on, 5 you're going to need to call
counsel. I think, 6 they maybe coming from out of town. 7 MS. O'CONNOR: I believe, Mr. Gill 8 (phonetic) is actually coming this morning to 9 see part of this
proceeding, and he is the 10 Counsel for the Town. 11 THE COURT: Is he here from out of town? 12 MS. O'CONNOR: No, Fort Lauderdale. 13 THE COURT: Oh,
okay. Is Mr. Gill 14 outside? If so, bring him in and let's chat 15 with him -16 MS. O'CONNOR: I don't think he's -17 THE COURT: -- and that way we can
give 18 notice to both sides that we'll cancel the 1:30 19 and just push through on this. 20 MS. O'CONNOR: I suspect he may not be 21 here yet. 22 THE
COURT: Okay. All right. If you 23 think you can complete by noon, and I'll run 24 over, like I did yesterday. Look, I'll give 25 you the time. I don't want to leave
these 43 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 cases unnecessarily with another judge, 2 because, you know, this is one you're kind of 3 stuck
in the middle of, and I'd like to go 4 ahead and get these three tried, and if 5 possible, at least, deal with the entitlement 6 of fees on the first two cases. And we'll
7 figure out who's entitled to fees on the third 8 case, but we may not do that today. 9 I'll probably set you for calendar call 10 next Friday. We'll come in
here and we'll set 11 up a hearing just on entitlement and let 12 another judge deal with the amount. 13 Okay. So let's go ahead and push on with 14 the case,
then I'll hear openings from both 15 sides. We'll try and get this completed. I 16 will not cancel the 1:30 yet, but as soon as 17 counsel for the Town gets here, we'll
chat and 18 see where we are, vis-a-vis, the progress of 19 this case. 20 Let me just ask, Ms. James, how many 21 witnesses are you going to call for the 22
Plaintiff? 23 MS. JOHNSON JAMES: Mr. O'Hare. 24 THE COURT: Just one. 25 Defense, how many witnesses are you going 44 Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc. 1 to call for the Defense? 2 MR. SWEETAPPLE: I think, just one, 3 Kelly Avery (phonetic). 4 THE COURT: We may be able to get it
done. 5 Okay. All right. All right. We'll push 6 through. 7 Ms. James, I need to return to you, since 8 you only had one copy, your request for 9 judicial
notice. 10 Pete, will you hand this back to 11 Ms. James? 12 All right. Okay. Let me grab my notepad. 13 Okay. We are now trying case number 2014CA1, 14
excuse me, 8142. Make sure we're all on the 15 same page. Is that correct, counsel? 16 MR. SWEETAPPLE: Yes, sir. 17 MS. JOHNSON JAMES: Yes, sir. 18
THE COURT: Okay. And let me find my 19 pretrial stip for 8142. 8142 pretrial stip. I 20 have it right here. Okay. Very good. Let's 21 begin with openings on
behalf of the Plaintiff. 22 Ms. James, you may proceed. 23 MS. JOHNSON JAMES: Thank you. Your 24 Honor, the issue, the principle issue in this 25 case is whether
a six week delay in responding 45 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 to a public records request is timely under 2 Chapter 119, Florida Statutes.
This is a 3 different case from the other ones that the 4 Court has heard, because in this instance, it 5 wasn't the Town who had to review the requests 6 and determine
whether the request was clear and 7 understandable. It was the Town's lawyers, the 8 Jones Foster Law Firm, because the request was 9 directed to the Jones Foster Law Firm,
which 10 rather, was directed to documents created by 11 the Jones Foster Law Firm. I misspoke. I'm 12 sorry. 13 The document request was, "All records in 14
any way related to any correspondence between 15 Jones Foster on behalf of the Town and Martin 16 O'Boyle, and created or received during the 17 period of time from
March 1, 2014 through the 18 moment you receive this request," which was May 19 14, 2014. 20 THE COURT: Let me make sure I get the 21 dates. 22 MS. JOHNSON
JAMES: Sure. 23 THE COURT: The documents related to any 24 correspondence? 25 MS. JOHNSON JAMES: Between Jones Foster 46 Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc. 1 and Martin O'Boyle created or received between 2 March 1, 2014 and May 14, 2014. 3 THE COURT: Okay. So we're talking about 4 May 1,
2014? 5 MS. JOHNSON JAMES: It was May 14 -6 THE COURT: May 14, 2014. 7 MS. JOHNSON JAMES: 10 weeks about. 10 8 weeks. 9 THE COURT: Okay.
10 MS. JOHNSON JAMES: Okay. 11 THE COURT: Yeah, I'm just trying to get 12 the time period to figure out how much maybe -13 MS. JOHNSON JAMES: Yes,
sir. 14 THE COURT: Okay. 15 MS. JOHNSON JAMES: Okay. And -16 THE COURT: Any documents related to 17 Martin O'Boyle. Okay. 18 MS. JOHNSON
JAMES: Any correspondence 19 between Jones Foster. It's paragraph C on the 20 joint pretrial stip. 21 THE COURT: Okay. 22 MS. JOHNSON JAMES: The first
page. It's 23 probably -- if you're -24 THE COURT: Oh, I've got it right here. 25 MS. JOHNSON JAMES: There you are. Okay. 47 Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc. 1 So there's the request, sir. The -2 THE COURT: Hold on. Created or received 3 during the period of March 1st through the 4 moment
you received. Okay. Is it stipulated 5 when this was received? 6 MS. JOHNSON JAMES: Yes, May 14th. 7 THE COURT: Okay. Great. Perfect. 8 MS. JOHNSON
JAMES: Okay. 9 THE COURT: Okay. So we have -10 MS. JOHNSON JAMES: By e-mail. It's 11 stipulated that it's by e-mail. 12 THE COURT: Okay. All right.
That's 13 fine. 14 MS. JOHNSON JAMES: Okay. 15 THE COURT: All right. I'm just trying to 16 get the time period. All right. Do we have 17 any ideas
how many cases were pending between 18 Mr. O'Boyle and the Town of Gulf Stream at that 19 time? 20 MS. JOHNSON JAMES: I do not know. I am 21 aware of only the
one that I was handling. 22 THE COURT: Okay. 23 MS. JOHNSON JAMES: Oh, wait. No, no. 24 I'm sorry. I believe, the Town's case against 25 Mr. O'Boyle and
Mr. O'Hare and others in 48 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 alleging RICO violations was pending, but I 2 don't belief Jones Foster was Counsel
then. I 3 believe, that was Richman and -- Richman and 4 Greer. I don't -- I wouldn't want to make a 5 mistake, but I'm fairly sure Jones Foster was 6 not Counsel
-7 THE COURT: Okay. 8 MS. JOHNSON JAMES: -- in that case. 9 THE COURT: All right. 10 MS. JOHNSON JAMES: As far as I know, 11 Your Honor,
the only case -12 THE COURT: All right. So the documents 13 are -- would have necessarily been required to 14 be reviewed for attorney/client privilege -15
MS. JOHNSON JAMES: Sure. 16 THE COURT: -- in those matters that are 17 exempt under 119. 18 MS. JOHNSON JAMES: Okay. 19 THE COURT: Okay. So the
question is, is 20 six weeks a reasonable time to do that review 21 and get the response back. 22 MS. JOHNSON JAMES: Well, no, it's 23 not -- the question -- they
didn't even 24 respond. They acknowledged. 25 THE COURT: They acknowledged they 49 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 received -2
MS. JOHNSON JAMES: They acknowledged -3 THE COURT: -- they received it on the 4 16th. 5 MS. JOHNSON JAMES: Exactly right. And 6 then having heard
-- and they said, "We've got 7 a lot of document requests. We'll get back to 8 you in a reasonable time." 9 THE COURT: Okay. 10 MS. JOHNSON JAMES: That's
what they said 11 on May 16th. 12 THE COURT: They filed suit, right? 13 MS. JOHNSON JAMES: July -- I didn't. 14 Mr. O'Hare did. July 1, 2014, Mr. O'Hare
filed 15 a suit. 16 The complaint is served -- this is all 17 stipulated. The complaint is served on the 18 Town on July 7th of 2014. At just before 11:00 19
and like within minutes, the Town sent a letter 20 to Mr. O'Hare saying, "This letter provides the 21 estimated costs for the production of public 22 records that the
Town understands you have 23 requested. You have failed to sufficiently 24 identify all of the public records that you 25 seek, so this letter also requests 50 Fort Lauderdale,
Florida 954-755-6401 Daughters Reporting, Inc. 1 clarification of the several items referencing 2 your request." 3 And our position, Your Honor, is even if 4 it
took a week, two weeks, three weeks for the 5 documents to be reviewed, and for -- to be 6 redacted for attorney/client privilege, it 7 didn't take six weeks for the Town
and Jones 8 Foster to know that they deemed the request to 9 be unclear. 10 So this response, it comes after the 11 complaint. There's just no explanation for
why 12 that takes six weeks. I mean, you know law 13 firms. I know law firms. We have to respond 14 in 30 days to document requests all the time. 15 So it is
our view that just as a matter of 16 law, that's untimely. And for that 17 proposition, we rely on the Tribune versus 18 Canola (phonetic) case, Florida Supreme Court 19
case that says, "The only delay in introducing 20 records that's permissible is the limited time 21 needed to locate them and produce them." 22 That's one of the cases
I provided the Court on 23 Tuesday morning. I have another copy today if 24 the Court needs it. 25 And we believe that the evidence is going 51 Fort Lauderdale, Florida
954-755-6401 Daughters Reporting, Inc. 1 to show that there was no justification for the 2 delay in at least advising Mr. O'Hare that they 3 deemed the response to be unclear.
4 THE COURT: Okay. The request. 5 MS. JOHNSON JAMES: The request. I'm 6 sorry. 7 THE COURT: All right. Mr. Sweetapple, 8 are you going to be
arguing this one? 9 MR. SWEETAPPLE: Yes, sir. 10 THE COURT: Okay. Six weeks to say we 11 don't understand a question seems like a long 12 time. 13
MR. SWEETAPPLE: Not when you see the 14 facts of the case, Your Honor. 15 THE COURT: Okay. What are the facts that 16 take this outside of a simple response
that 17 says -18 MR. SWEETAPPLE: If I can approach with 19 a -20 THE COURT: Have you provided -- have you 21 provided Ms. James a copy of what you're
22 approaching with? 23 MS. JOHNSON JAMES: What is it? 24 MS. O'CONNOR: Our trial exhibits. 25 MR. SWEETAPPLE: Exhibits - 52 Fort Lauderdale, Florida
954-755-6401 Daughters Reporting, Inc. 1 MS. JOHNSON JAMES: Electronically, but 2 not in hard copy. 3 THE COURT: Okay. Well, I don't accept 4 electronically
-- are these identical to what 5 have been provided to Ms. James? 6 MS. O'CONNOR: Correct. Yes, Your Honor. 7 MS. JOHNSON JAMES: Electronically. 8
THE COURT: Okay. Do you have the ability 9 to pull them up on your computer? 10 MS. JOHNSON JAMES: I can, but the -- if 11 I'm not violating the notice -12
THE COURT: Oh, absolutely. 13 MS. JOHNSON JAMES: Okay. 14 THE COURT: You're free to use computers 15 for trial if you need to -16 MS. JOHNSON JAMES:
Okay. 17 THE COURT: -- absolutely. 18 MS. JOHNSON JAMES: There's a note on your 19 door that says I can't turn it on, so -20 THE COURT: Is there?
21 MS. JOHNSON JAMES: Yes. It says, "No 22 computers." 23 THE COURT: Oh, no. 24 THE BAILIFF: I'm going to check, Judge. 25 THE COURT: Yeah,
double check, because I 53 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 always allow Counsel to use their computer for 2 trial. We have to do research.
I use mine to 3 do research while I'm sitting up here. I just 4 ask that you turn the volume off. 5 MS. JOHNSON JAMES: Oh, it's off. 6 THE COURT: That's
all. Yeah, no, that's 7 all I ask is when we're doing a jury trial, so 8 the jury doesn't -- yeah. 9 MS. JOHNSON JAMES: Okay. All right. 10 Yes, sir. 11
MR. SWEETAPPLE: Your Honor, the first 12 thing that I would tell you that the evidence 13 is going to establish with regard to the issue 14 you just framed is that
the Town attorney for 15 the Town of Gulf Stream, is the firm of Jones 16 Foster. And what that has done for Mr. O'Hare 17 is -- and Mr. O'Boyle, is it has put them in
18 the position where they have bombarded the law 19 firm with requests on weekends, Thanksgiving, 20 every lawyer in the firm, employees of the 21 firm, so that in
order to not be in another 22 situation where they are facing gotcha, because 23 the biggest problem with public records 24 compliance is that there are often people that
25 aren't asked. There are whole bodies of 54 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 documents that no one even thinks about. Very 2 rarely,
in my experience, does a government get 3 it perfect. And the law is designed so that if 4 you don't get it perfect, the other side can 5 get fees. 6 So you're
going to see that in this case, 7 with regard to this request, there 8 were -- prior to -- just prior to the request, 9 prior to May 14th, through Mr. O'Hare and his 10
cohorts that were all clients of the O'Boyle 11 Law Firm, there were 909 requests. There were 12 11 on May 14th alone. And these are complex 13 convoluted requests
that require the Town -14 THE BAILIFF: That was put up by Court 15 Administration. It's in all the courtrooms. 16 It's been there quite a while. 17 THE COURT:
We were unaware that it's been 18 placed on our -19 MS. JOHNSON JAMES: Your Honor, I was on 20 my computer yesterday in the courtroom, and so 21 when I noticed
it this morning, I had a moment. 22 THE COURT: All electronic -- okay. Well, 23 anyway -- yeah this is new to me. I don't come 24 in that door, so I didn't see it,
but, no, you 25 are free to use your computer to do research 55 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 and pull up documents, whatever you need to,
to 2 prepare and prosecute your case. 3 MS. JOHNSON JAMES: Thank you. 4 THE COURT: I mean, let's not have 5 everybody just doing their video games and 6
stuff, but if it's related to the case -- if 7 it's related to the case, you're free to use 8 whatever computer you've got there. Okay. I 9 apologize for the interruption.
10 MR. SWEETAPPLE: No problem, Your Honor. 11 So -12 THE COURT: So you got 909 requests. 13 MR. SWEETAPPLE: Just from January through 14 May 14th.
There were 11 requests on May 14th. 15 THE COURT: January, 2014 through May. In 16 five months. Okay. 17 MR. SWEETAPPLE: And I'm going to show 18 these
are all related to Mr. O'Hare and his 19 attorney's, or other clients, the father, for 20 instance, largely. 21 Then on the day, May 14th, there are 11 22 requests.
Just two weeks before May 14th, 23 there are 48 requests. Now, keep in mind that 24 the way the Plaintiff and his cohorts play this 25 game is two-fold. One is the volume
is so 56 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 heavy that the clerks quit, which you'll hear 2 from Ms. Avery. She quit. She couldn't deal 3
with it. 4 They are working over-time. They are in 5 over their heads. They come in Mondays and 6 there's hundreds of requests, not just from 7 Mr. O'Hare,
but from his accomplices. And that 8 dovetails into the idea of trick requests, 9 gotcha requests, requests that are so 10 convoluted or complex that you couldn't 11
possibly anticipate all of the possible 12 responses. 13 But then, when you take the position, as 14 Mr. O'Hare has done, that, oh, you said at a 15 meeting that
Mr. Randolph is not the Town 16 Attorney, Jones Foster is the Town Attorney, 17 therefore, I can go ahead. You are going to 18 have to give me any records from anyone in
the 19 law firm that e-mailed anyone at the Town, or 20 any of the Town's representatives. 21 MS. JOHNSON JAMES: Your Honor -22 MR. SWEETAPPLE: So -23
MS. JOHNSON JAMES: -- excuse me. I 24 object to Mr. Sweetapple testifying about 25 issues that are not going to be placed before 57 Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc. 1 this Court. If the Court looks at the witness 2 list, there are Rita Taylor, Freda DeFosse and 3 Kelly Avery, all of whom worked for the city
-4 the Town of Gulf Stream. I'm told by Ms. 5 O'Connor that the only person who's going to 6 testify today is Kelly Avery. 7 So there's no one who's going to testify
8 to what Mr. O'Hare -- I mean, to what 9 Mr. Sweetapple was just describing to the 10 Court, nor is there anyone on the witness list 11 from Jones Foster to testify
about how it was 12 bombarded with records. So that's just 13 inappropriate opening. 14 MR. SWEETAPPLE: I'm going to be calling 15 the Plaintiff. 16
THE COURT: Yeah. So your position is 17 you're going to get that testimony from the 18 Plaintiff. 19 MR. SWEETAPPLE: Absolutely. 20 THE COURT: Okay. 21
MR. SWEETAPPLE: Absolutely. You know, I 22 have -- I have every intention to go through 23 this in great detail with the Plaintiff. 24 THE COURT: It's one
of the issues that we 25 ran into yesterday where there was a statement 58 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 made in opening statement, but there
was never 2 any testimony to that effect. So please, if 3 you will -- and I know you're going to do this, 4 because I'm going to rule you need to do this, 5 please,
limit your opening statement to those 6 facts that are going to be elicited at trial. 7 MR. SWEETAPPLE: I'm going to show at 8 trial, through Mr. O'Hare, the full
extent of 9 his endeavors to bombard the Town with public 10 records requests in a volume that essentially 11 closes the office of our clerk from functioning 12 on anything
other than the requests that are 13 propounded by he, his attorney's, and other 14 clients of the law firm that he uses that is 15 counsel in this case that are not here.
The 16 O'Boyle Law Firm is the Counsel in this case. 17 Ms. James is coming in late. But there's still 18 Counsel of record. They just choose not to be 19 here. 20
So I'm also going to bring out from 21 Mr. O'Hare all of the aliases he used, not only 22 the ones that I brought out previously, but 23 ones that he testified
to in another case that 24 will show that he has been to the O'Boyle Law 25 Firm. It's located in the Commerce Group 59 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting,
Inc. 1 Building, where Mr. O'Boyle conducts his 2 business. And the Commerce Group is on 3 hundreds of the requests that are coming from 4 the same location as the
O'Boyle Law Firm, as 5 is "Kathy," which is an alleged not for profit. 6 I'm going to show you in the book, that the 7 Commerce Group that he's been at, that he knows 8
his lawyers operate out of, is where Kathy 9 operates out of, and they sent hundreds of 10 requests, hundreds of requests in days, in a 11 period of days, just bombarded
the Town. 12 After the 5-14 -- the May 14 request, 13 until the time that the lawyers were able to 14 even finalize, which they rushed to finalize it 15 because
they were in the process of working on 16 that letter with dozens of other projects, the 17 bill, you're going to hear from Ms. Avery, was 18 $60,000.00 for Jones Foster
in one month. And 19 $60,000.00 the next month dealing with 234 20 requests that came in from the time Mr. O'Boyle 21 served the request in this case -22 MS. JOHNSON
JAMES: O'Boyle? 23 MR. SWEETAPPLE: Mr. O'Hare served the 24 requests in this case, until the time that the 25 Town was able to give him an estimate of what 60 Fort
Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 it would cost to go find all of those 2 documents, assuming the request was limited in 3 scope as the lawyers
deemed it to interpret it 4 to be limited. 5 So this is a case, Your Honor, where I had 6 been able to plead, and it will be the first 7 time I'll be able to argue
and present a 8 Defense which is Plaintiff's bad faith. And I 9 don't know if the Court has had a chance to 10 review that before the trial. It's been 11 sometime
since I argued a motion for leave on 12 this, but -13 THE COURT: Okay. Let me just ask, 14 Counsel, are you here for the 1:30? 15 MR. GILL: Well, it's 1:00
p.m., I think, 16 Your Honor. 17 THE COURT: Is it 1:00 p.m? 18 MR. GILL: Yes. 19 THE COURT: Are you opposing Counsel? 20 MR. GILL: I'm for
the Town. 21 THE COURT: You're for the Town. Okay. 22 There is a good chance you will not be reached 23 today on your case. We are running behind in 24 the trial
of this case. 25 MR. GILL: Okay. 61 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 THE COURT: Okay. You are free to watch 2 the proceedings
today. I will tell you, I had 3 an hour set aside from 1:00 to 2:00 for you 4 all. If we can hear you in that time, we will. 5 I have other things scheduled that I've
got to 6 get to at 2:00. 7 So if we're not completed, and if we -- we 8 may have to reschedule, but we're going to push 9 through this in as much as we can. I
do have 10 something I have to take a break for at lunch. 11 I have a meeting I have to go to, so we are 12 going to have to take a regular lunch break 13 today. 14
MR. ROEDER: If it's better for the 15 Court's schedule, we would be amendable to 16 rescheduling. I don't know if -17 MR. GILL: Your Honor, if the Court
18 doesn't feel we'll get to it, we're here 19 prepared to argue though. 20 THE COURT: Are you from like Orlando 21 or -22 MR. GILL: I'm from Fort Lauderdale.
23 THE COURT: That's an easy drive. Okay. 24 Good. Let's do this, I'm going to reschedule 25 that. Whether I hear it or another judge hears 62 Fort Lauderdale,
Florida 954-755-6401 Daughters Reporting, Inc. 1 it, I don't know. But what I will do is that 2 will let you all know you can breathe easy. 3 I will be frank, I was
researching another 4 issue last night on the case I'm trying right 5 now, so I did not get a chance to really go 6 through the motion to dismiss and I'm not as 7 prepared
as I would like to be for that. So I 8 will tell you right now, we'll reschedule that. 9 We'll get you on a calendar call, if not -- it 10 maybe as early as next Friday.
11 MR. GILL: Yes, Your Honor. 12 THE COURT: And then we'll get you reset 13 for that time, because I want to give you the 14 time. It's a separate end case.
I want to 15 give you the time that needs to be devoted to 16 it. 17 MR. GILL: One thing that may help with 18 that, Your Honor, we scheduled an hour. I'm 19
not sure if it requires an hour. I'm not sure 20 if Counsel feels it still does. 21 THE COURT: Well, remember, I'm going 22 to -23 MR. GILL: The Town
-24 THE COURT: -- because I have not reviewed 25 your materials because I was preparing for - 63 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1
MR. GILL: I said for rescheduling 2 purposes. I completely understand, Your Honor. 3 THE COURT: Okay. Okay. 4 MR. GILL: Rescheduling purposes, we may
5 be able to do it in less time. 6 THE COURT: Well, you all go out and chat 7 with each other and -- but you're -- you can 8 breathe easy today. And you're free
to watch 9 the rest of the proceedings today, if you want 10 to, as long as you're not a witness. 11 And sir, you're not a witness are you, 12 sir? 13
MALE SPECTATOR: No, Your Honor. 14 THE COURT: Okay. Very good. All right. 15 And -- but you're cut free for 1 o'clock today. 16 MR. GILL: Yes, Your Honor.
17 THE COURT: Okay. Very good. All right. 18 Counsel, you may proceed. I'm sorry for the 19 interruption, but I wanted to give them an 20 opportunity to go
do what they need to do. 21 MR. SWEETAPPLE: Oh, I understand, 22 Your Honor. So as the Court is familiar with 23 what the law regarding the Town's duty and the 24
requirement of good faith that applies to my 25 client with regard to no unlawful delay in 64 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 providing
a record, this is a declaratory 2 judgment equitable proceeding. And the law is 3 very clear and the motivation of a plaintiff in 4 bringing a public record request, a
particular 5 request is not relevant. And however the times 6 they are changing as a man who I think just won 7 the Pulitzer Prize in 1965 was saying -8 THE COURT:
But doesn't the times they are 9 changing need to take place in Tallahassee? 10 MR. SWEETAPPLE: No, not at all, 11 because -12 THE COURT: Do you have any
case law that 13 says that the motivation -14 MR. SWEETAPPLE: That's not what I'm going 15 to argue. 16 THE COURT: What are you going to argue? 17
MR. SWEETAPPLE: That's not what I'm going 18 to argue. 19 THE COURT: You're going to argue you want 20 to make some case law. 21 MR. SWEETAPPLE: No.
I'm going to argue 22 something that's not even that subtle. What 23 I'm going to argue is that when you deal with 24 good faith and equitable proceeding, the 25 Plaintiff's
bad faith conduct, not in making 65 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 the particular request, the motivation of 2 making the request, but their
conduct that's 3 bad faith can even go further. I want to -- I 4 want this Court to go so far as to say, not 5 only was my client, at all times, acting in 6 good faith
and there was no unreasonable delay, 7 this is no different than as if they had 8 kidnapped a clerk, put glue in the keys so we 9 can't get into the door. She had 80 people
10 enter the clerk's office. 11 In the McMillan case, which we'll provide 12 to the Court, in 1905, so many people were 13 getting into the clerk's office that
14 nobody -- they were monopolizing the clerk's 15 office, and the Supreme Court of Florida said, 16 wait a minute, there's a public out there. You 17 don't have the
right to come in and monopolize 18 a clerk's office. Yes, you have the right to 19 get the documents. 20 In this case, the conduct is so 21 outrageous. And the
times that are changing is 22 this, Your Honor, there are, frankly, too many 23 lawyers, apparently, to handle legitimate 24 business. We now have a situation where we
are 25 creating a new industry that, frankly, just 66 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 rips off governments, charities that work for 2 the
government, and you're not -3 MS. JOHNSON JAMES: Is there going to be 4 evidence about this? 5 MR. SWEETAPPLE: Yes, there will be from 6 Mr. O'Hare, Your
Honor. 7 MS. JOHNSON JAMES: Charities that rip off 8 the government? 9 MR. SWEETAPPLE: No, charities -- they rip 10 off charities. They make claims 11
against -- Mr. O'Hare will testify he hired a 12 Mr. Chandler because he goes around the state 13 and makes requests to the state agencies and to 14 private contractors,
including charities that 15 have contracts with the state and he hired him. 16 He had Mr. Roeder hire him because he did such 17 a good job he wanted training in how he
could 18 make his public records requests like 19 Mr. Chandler. He's also going to admit, I 20 believe, that he knows that Mr. O'Boyle hired 21 Mr. Chandler and was
working for the Kathy 22 Entity that is operating out of the same 23 premises where Mr. O'Hare has visited to see 24 his attorney, Mr. O'Boyle's son, 25 Jonathan O'Boyle,
who works at the very same 67 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 premises. 2 Mr. Roeder and Jonathan O'Boyle make 3 dozens of requests
on the Town during this 4 time. Mr. O'Hare is going to admit, based on 5 his testimony, that Mr. Roeder was making those 6 requests with his knowledge and his approval.
7 So we don't just have Mr. O'Hare making 8 hundreds of requests. We now have his 9 attorney's and other clients of the attorney's 10 who are operating out of the same
location 11 using real names of people that exist, 12 fictitious names and entities that have been 13 formed, one of which is purporting to be a 14 non-for-profit agency.
15 Mr. O'Hare is up to his eyeballs in this 16 scheme and I have never had an opportunity yet 17 to present this evidence involving Mr. O'Hare 18 to a court. And
I'm looking forward to the 19 Court carefully listening to Mr. O'Hare's 20 testimony, including his impeachment from 21 various transcripts he's provided me, as well 22
as, reviewing the log that is going to 23 be -- that's provided in that notebook, which 24 I'll be going over with Mr. O'Hare to see, not 25 only the volume of these
requests, but the 68 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 sheer cleverness and over-reaching and 2 burdensomeness of these requests, which has 3
cost the Town of Gulf Stream millions 4 of -- well, I'm going to have her testify, 5 Ms. Kelly Avery testify as to the fees that 6 were paid monthly to deal with this
-- this 7 barrage, this onslaught, this scam. 8 THE COURT: All right. Ms. James, you may 9 call your first witness. 10 MS. JOHNSON JAMES: I call Mr. O'Hare.
11 MR. O'HARE: Your Honor, any chance you've 12 got your headphones? Thank you so much. 13 THE BAILIFF: Yep. 14 Thereupon, 15 (CHRISTOPHER O'HARE)
16 Having been first duly sworn or affirmed by the 17 Court, was examined and testified as follows: 18 DIRECT EXAMINATION 19 BY MS. JOHNSON JAMES: 20 Q Good morning.
Please, state your full 21 name for the record. 22 A Christopher Francis O'Hare. 23 Q And in what town do you reside? 24 A Town of Gulf Stream, Florida. 25
Q Since when? 69 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A December, 2003. 2 Q Is it fair to say that you have a keen -3 A I'm sorry.
Not working. 4 Q Oh, okay. Is it fair to say that you have 5 a keen interest in public records law and that you 6 developed that interest over the last few years? 7
MR. SWEETAPPLE: Objection. Leading. 8 THE COURT: Sustained. 9 BY MS. JOHNSON JAMES: 10 Q Are you interested in public records law? 11 A Absolutely. 12
Q When did you become interested in public 13 records law? 14 A 1999. 15 Q Have you been particularly interested in 16 public records law with regard to the Town
of Gulf 17 Stream? 18 A Spring of 2012. 19 Q Tell the Court what happened to spawn your 20 interest with regard to the Town? 21 A Oh, thank you, sir. 22
I was working on my house when a 23 police officer made a racist comment to me and I 24 called him out on it and weeks later he came into my 25 house over the objections of my
housekeeper and I 70 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 was retaliated against by him over and over the 2 course of a few months. When I tried to get
to the 3 bottom of that, because I don't think anybody wants 4 a policeman coming into their house, even though 5 most of the police from the Town seem to be very 6 reasonable and honest
people, this particular one 7 didn't appear that way to me. I tried to get to the 8 bottom of it. I wanted to know why this policeman 9 came into my house. 10 I wanted
to know why Mr. Thrasher, 11 the Town Manager sent him there, whether it was a 12 communication. Then I experienced a series of 13 retaliations, permits that were allowed for my 14
neighbors were denied to me. Fictitious code 15 enforcements were brought against me. I planted 16 lady palms in my yard that the late mayor Bill Coke 17 (phonetic) had given me.
I was cited for having 18 objects there, even though they are all over town. 19 I was being retaliated against and I 20 wanted to get to the bottom of it. Every single
one 21 of those things. The only way I could do it, 22 because when I go to a commission meeting, the mayor 23 says, "We're not answering questions here," and when 24 I sent a letter
to the town manager, he says -- he 25 just doesn't reply. The only way I could legally 71 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 find out what's going on
is to ask for a public 2 records. 3 THE COURT: Sir. 4 THE WITNESS: And I asked for many of 5 them. 6 THE COURT: Sir. I am not deaf. 7 THE
WITNESS: I'm sorry, sir. 8 THE COURT: Lower your voice. 9 THE WITNESS: I didn't hear. 10 BY MS. JOHNSON JAMES: 11 Q He said, I'm not -- the Judge said, "I'm
12 not deaf. Lower your voice." 13 A I'm sorry. My ear thing, I can't tell how 14 high I'm talking because it all sounds loud inside 15 here. But I'll try to do better. 16
Q Okay. 17 A So if I can finish answering your 18 question. 19 Q Sure. 20 A Over the past four years, I've been 21 falsely accused, selectively enforced
against, 22 ignored, told they wouldn't answer my questions. 23 The only legitimate way I could get any kind of 24 information was to ask for requests. I found that 25 when I made
those requests, multiple requests at one 72 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 time, they were partially responded to, confusing 2 answers, so I split
them up into individual 3 requests. 4 Q So to make sure I understand, I and the 5 Court understand, when you initially started making 6 public records requests, there might be
several 7 requests -- requests for several different kinds of 8 documents in one request? 9 A Yes, that's right. 10 Q And subsequently, you started sending 11 one -- a
separate request for each kind of document 12 you want? 13 A Right. I would send a request for a 14 single record and another request for a single 15 record so I could keep
track with the e-mail threads 16 that the response was connected to the specific 17 records request and there wasn't any confusion. 18 Q Okay. I'm going to show you what we've
19 marked as Plaintiff's Exhibit 1, if I can approach 20 the witness. 21 THE COURT: You may freely approach. 22 MS. JOHNSON JAMES: Thank you. 23 It's your
Defendant's Exhibit 11, Counsel. 24 MR. SWEETAPPLE: Thank you. 25 73 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 BY MS. JOHNSON JAMES: 2 Q You're
welcome. 3 It's -- this is an e-mail from 4 Review.content.apply dated -- dated March 14, 2014 5 to Rita Taylor. Is that a document that you sent, 6 sir? 7 A Yes,
this is my -- one of my requests. 8 Q Is it, in fact, the request that's at 9 issue in this lawsuit? 10 A Yes, it is. 11 MS. JOHNSON JAMES: Okay. I'd move for
12 the admission of Exhibit 1. 13 THE COURT: Any objection? 14 MR. SWEETAPPLE: No, Your Honor. 15 THE COURT: Okay. That will come in as 16 Plaintiff's
Exhibit 1. 17 (Plaintiff's Exhibit Number 1 entered into 18 evidence.) 19 BY MS. JOHNSON JAMES: 20 Q Did there come a time when the Town 21 started refusing
to send -- to respond to your 22 requests for public records? 23 A Yes. 24 Q Tell the Court what happened. 25 A I believe, it was around January of 2014, 74 Fort
Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 the Town sent me a letter. Attached to the letter 2 was a list of records requests I had made with 3 estimates the Town
had provided to me, estimates 4 that I chose not to take the Town up on. The Town 5 said, "We are not going to respond to any more 6 records requests until you pay for all these 7
estimates, which we made to you." I think, the 8 figure was about $800.00. 9 Q I'm going to show you what we've marked as 10 Plaintiff's Exhibit 2 of January 23, 2014 letter
11 from the Town of Gulf Stream to you and ask if you 12 can identify that for the Court. 13 This is your Defendant's Exhibit 5. 14 A Yes, I can identify this.
15 Q Tell the Court what that is. 16 A This is a letter, an e-mail that was 17 attached to an e-mail, which I received from the 18 Town and clerk, who is also the custodian
of records 19 informing me that -- what I just testified to. 20 Q And I'm going to show you what we've 21 marked as Plaintiff's Exhibit 3, a February 20, 2014 22 e-mail to you
from the Town of Gulf Stream and ask 23 if you can identify this. 24 This is Defendant's Exhibit 6. 25 MR. SWEETAPPLE: That's the complete 75 Fort Lauderdale,
Florida 954-755-6401 Daughters Reporting, Inc. 1 exhibit? 2 MS. JOHNSON JAMES: Yes. Did you want to 3 see? 4 THE COURT: Why don't you -- make sure you 5
all are on the same page. 6 MR. SWEETAPPLE: Can I see 5, please? 7 THE COURT: And the one exhibit that's 8 been admitted, will you please make sure the 9
Clerk gets that so she can mark it in? 10 MS. JOHNSON JAMES: Yes, sir. 11 THE COURT: Great. Thank you. 12 He just brought a new set of headphones?
13 THE BAILIFF: The one that the witness has 14 right now is working just fine. 15 THE COURT: Is it working okay? 16 THE WITNESS: Yes, they're super
loud, but 17 I can hear. Thank you. 18 THE COURT: Do you need me to turn the 19 volume down? 20 THE WITNESS: I'll try that, thanks. I 21 apologize
for the inconvenience. 22 THE COURT: No, no, no, no. Absolutely. 23 Take your time, please. We're here to -- we'll 24 make any accommodation we can. 25
THE WITNESS: Yeah, it's working fine. 76 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 THE COURT: Okay. 2 BY MS. JOHNSON JAMES: 3 Q Can you identify
what we've marked as 4 Exhibit 3? 5 A This is an e-mail letter that was -- I'm 6 sorry. A letter attached to a e-mail that I 7 received on February 20th, which seems to be a
8 follow-up to the previous months e-mail, which says 9 basically the same thing. It includes even more 10 records and requires even more money be paid. 11 MS. JOHNSON JAMES:
I move for the 12 admission of Exhibits 2 and 3, Your Honor. 13 MR. SWEETAPPLE: No objection. 14 THE COURT: 2 and 3 will come in for the 15 Plaintiff without
objection. 16 (Plaintiff's Exhibit Numbers 2 and 3 17 entered into evidence.) 18 Let's make sure the Clerk gets those -19 MS. JOHNSON JAMES: Yes, sir.
20 THE COURT: -- so she can mark those. 21 MS. JOHNSON JAMES: I'm taking those to 22 her right now, sir. 23 THE COURT: Yep. 24 BY MS. JOHNSON JAMES:
25 Q For how long a period of time did the Town 77 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 refuse to respond to your public records requests? 2
A I believe, that some of their records 3 listed in the attachments to those prior exhibits 4 started -- the responses started to trickle in maybe 5 six, eight months later. 6
Q So for -7 A Most of them still haven't been responded 8 to. 9 Q So starting in February of 10 2000 -- starting in January of 2014, there was a 11 bar, for lack
of a better word? 12 A To the requests that were in the letter. 13 Q Okay. 14 A I had subsequently, a while later, made 15 another request, I seem to remember,
that they might 16 have responded to that, and I was surprised given 17 what they had already told me in those two e-mails. 18 Q But there was some period of time during 19 which
you were not getting responses, period? 20 A Yes, and there was no official notice to 21 me that we've changed our mind. It just started to 22 happen again slowly. 23 Q
When you say, "It started to happen 24 again," you mean the Town started to respond again? 25 A To any subsequent requests. 78 Fort Lauderdale, Florida 954-755-6401 Daughters
Reporting, Inc. 1 Q Okay. Looking -- may I have Exhibit 1 2 back, please, ma'am? Thanks. Excuse me. 3 The Town did acknowledge -- with 4 regard to Plaintiff's
Exhibit 1, the Town 5 acknowledged having received that, what, two days 6 later? 7 A I got a, what I call a standard delay form 8 letter a few days later with the same language
that 9 they always give me, same we'll get to it when we 10 get to it. 11 Q A delay form is what you said? 12 A That's how I characterized it. It's just 13 the same language
like a boiler plate that's sent 14 out automatically it seems. 15 Q And did -- and after you got that delay 16 form e-mail, as you described it, a couple of days 17 later, did
you get any other indication from the 18 Town that, you know, it didn't understand what you 19 had asked, that it was still working on the request, 20 anything? 21 A No, nothing.
22 Q And you filed suit in -- on when, July 1, 23 2014? 24 A After I thought a reasonable amount of 25 time had gone by. I don't know the exact date, but 79 Fort Lauderdale,
Florida 954-755-6401 Daughters Reporting, Inc. 1 it was probably around then. 2 Q And after you filed suit, did you get a 3 notice from the Town? 4 A Yes. 5 MS.
JOHNSON JAMES: I have nothing 6 further. 7 THE COURT: Okay. 8 MS. JOHNSON JAMES: Thank you. 9 THE COURT: Cross? 10 CROSS-EXAMINATION
11 BY MR. SWEETAPPLE: 12 Q Yes, Your Honor. 13 Good morning, Mr. O'Hare. I've taken 14 your deposition in -15 THE COURT: Be sure and use the 16 microphone,
Counsel. 17 BY MR. SWEETAPPLE: 18 Q I've taken your deposition in a few cases, 19 have I not, sir? 20 A Many, many times. 21 MS. JOHNSON JAMES: Relevance, Your
Honor. 22 THE COURT: What's the relevance, Counsel? 23 MR. SWEETAPPLE: I just want to see if he 24 recalls that. Testing his memory. 25 THE COURT:
Objection is overruled. 80 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 BY MR. SWEETAPPLE: 2 Q I've taken your deposition on several 3 occasions, have I
not? 4 A I'm sorry. You didn't hear me the first 5 time? The answer is yes. 6 Q Okay. And with regard to the Town of Gulf 7 Stream, when is the first time that you
made a 8 public records request? 9 A I don't recall. 10 Q And do you know how many requests you made 11 in 2013? 12 A Not as many as I probably composed, but, 13
quite a few. 14 Q Well, do you have any idea how many? 15 A No, I don't. 16 Q Do you know if it's more than 10? 17 A If you want to try to break me, I can't
18 give you an estimate. 19 Q You don't know if you filed more than 10 20 public records requests? 21 A I imagine I did. 22 Q Do you know if you filed more than
a 23 hundred? 24 A Maybe. 25 Q Do you know? 81 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A I can't give you an answer. I don't know 2 the
exact number. I can give an approximation. 3 Maybe one every other day, one a day, two a week, 4 three a week. Something like that on average. 5 Q Well, how many -- how many
public records 6 requests do you believe you filed in 2013 on the 7 Town of Gulf Stream? 8 A I don't believe anything. You asked me a 9 a question and I don't know the answer,
sir. 10 Q Do you have any idea? Any estimate you 11 could give us? 12 A You've got a log. I'll be happy to look 13 at the log and write -- read you the number off of
14 it. 15 Q What's the most you've ever filed on a 16 day? 17 A I don't know that answer either. 18 Q Have you ever filed 80 on a day? 19 A You give me the
log, I'll tell you if it's 20 accurate or not. I don't -21 Q Have you ever filed 50 on a day? 22 A Same answer, sir. 23 Q Have you ever made any public records
24 requests on the firm of Jones Foster? 25 A Through the Town, I believe, I have, but I 82 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 can't recall the
circumstances. 2 Q And haven't you asked for -- didn't you 3 send requests to the lawyers at Jones Foster after 4 your complaint against the Town Attorney, 5 Skip Randolph, was
dismissed? 6 A I sent requests to all town attorney's, 7 yes. 8 Q And your position -- and Mr. Randolph took 9 the position at a meeting that he wasn't the town 10 attorney
-11 MS. JOHNSON JAMES: Objection. Hearsay. 12 BY MR. SWEETAPPLE: 13 Q Strike that. 14 Did you -- did you ever understand 15 that the attorney's for the
Town were the entire 16 firm of Jones Foster? 17 A If I can recall, the testimony of 18 Mr. Alexander (phonetic), Mr. Wilkins (phonetic), 19 Mr. Randolph, they all said the entire
firm is the 20 Town Attorney at the Commission on Ethics hearing. 21 Q And so as a result of that, there are 22 requests you made -- you have made on the Town that 23 aren't
even in the log, including hundreds of 24 requests you've made on the lawyers and staff at 25 Jones Foster, right? 83 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc.
1 A Over a long period of time, I asked for 2 disclosures of -- financial disclosures required by 3 the State on every single attorney, which there 4 aren't any. And perhaps
some other records, but I 5 don't think it was very frequently. 6 Q And you did it over the holidays, like 7 Thanksgiving and different holidays you would send 8 those in, right?
9 A I use a lot of government services after 10 hours expecting that they'll be responded to during 11 business hours. 12 Q Okay. And who is Mr. Chandler? 13 A
Are you referring to Mr. Joel Chandler -14 Q Yes, sir. 15 A -- of FOGWatch? 16 Q Huh-huh. 17 A He is, I believe, a self-acclaimed civil 18 rights activist.
He's associated with the First 19 Amendment Foundation through Barbara Petersen. He's 20 active in the state politics, an advocate for public 21 records, and, I believe, I sought
his help to make 22 sure I was acting properly and appropriately to get 23 a record when I asked for a request. 24 Q And you were aware that previously 25 Mr. Chandler traveled
the state making public 84 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 records requests on governments and filing suits, 2 right? 3 A From his website,
that's what I understand 4 is part of his civil activism. 5 Q And you and Mr. Roeder, or Mr. Roeder on 6 your behalf, hired Mr. Chandler, right? 7 A No, we didn't hire
him, but if you're 8 asking me if we ever compensated him, the answer is, 9 I don't ask anybody to do anything for me for free. 10 Q And Mr. Chandler came to Gulf Stream, 11
right? 12 A I have no knowledge of that. Are you 13 talking about the Town or to my house? 14 Q The Town of Gulf Stream. 15 A I seem to recall a commission meeting
16 where they had a executive session to pay him off 17 because he asked for a record and they didn't give 18 it to him, if that's what you meant by going to the 19 Town of Gulf Stream.
20 Q Well, he -- where did you meet with 21 Mr. Chandler, in Palm Beach County? 22 A I believe, he came to my office in Boynton 23 Beach. 24 Q And Mr. Roeder is
your Attorney, is he 25 not? 85 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A Yes, he is. 2 Q How long has he been your attorney? 3 A I've
gotten legal advice from him since 4 maybe 1983. 5 Q Okay. And he's in your employ -- has he 6 not been in your employ for sometime? 7 A Well, like I said, I don't get
anything 8 for free from anybody. 9 Q And you are aware that not only 10 Mr. Chandler was making public records requests in 11 2014 on the Town of Gulf Stream, but Mr. Roeder
was 12 going to the Town of Gulf Stream and making requests 13 also, right? 14 A He was participating in the discovery 15 process, and I think, he was asking for public 16 records,
yes. 17 Q And who is Jonathan O'Boyle? 18 A Jonathan O'Boyle is an Attorney at the 19 O'Boyle Law Firm. 20 Q And Jonathan O'Boyle was making dozens of 21 requests
on the same days you were making requests, 22 wasn't he? 23 A I have no knowledge of that. There was no 24 coordination. He doesn't call me up and say, I'm 25 going to do this,
and I don't ask him if he's done 86 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 that, so I don't know. 2 Q And you have been to the Commerce Group 3 location,
have you not? 4 A Commerce Group owns property all over the 5 Country. Which location are you talking about? 6 Q Well, which Commerce Group locations have 7 you been
to? 8 A I've been to Office Park in -- I think, 9 it's in Hillsboro. 10 Q Is that the only one? 11 A I've been to some others, but I can't 12 identify them by name.
I'm not that familiar with 13 that real estate firm. 14 Q Well, isn't that Mr -- isn't that where 15 your lawyer, Jonathan O'Boyle has his office? 16 A I'm not sure.
I think, he's got offices 17 in Philadelphia and New Jersey. He's probably got 18 one in Hillsboro too. That's where I've seen him 19 sometimes. 20 Q All right. So you've
been to that office, 21 and that's where his father has the Commerce Group, 22 right? 23 MS. JOHNSON JAMES: Relevance, Your Honor. 24 THE COURT: What's the relevance?
25 MR. SWEETAPPLE: Your Honor, I'm going to 87 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 show him the log that these requests that are 2 being
sent in on dozens and dozens of occasions 3 with multiple filings the same day as 4 Mr. O'Hare's, are coming from the Commerce 5 Group where his lawyers have their offices
and 6 Mr. O'Boyle has his offices. 7 MS. JOHNSON JAMES: Relevance. 8 MR. SWEETAPPLE: Well, it's going to go to 9 my -- my affirmative defense talks about
them 10 all working in concert. 11 THE COURT: Objection is overruled. 12 THE WITNESS: Repeat the question, please. 13 BY MR. SWEETAPPLE: 14 Q You have
-- you've seen Mr. O'Boyle at the 15 Commerce Group office haven't you? 16 A No. 17 Q And are you aware that Mr. O'Boyle is 18 affiliated with the Commerce Group? 19
A Yeah, I think I am. Yes. 20 Q And are you aware that Mr. O'Boyle has 21 hired Mr. Chandler just as you have -22 A No. 23 Q -- to travel the state and make
public 24 records requests? 25 A I've never hired Mr. Chandler to travel 88 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 the state and make public record
requests, sir. 2 Q Let me rephrase. Are you aware that 3 Mr. O'Boyle has hired Mr. Chandler, or any of his 4 entities has hired Mr. Chandler to travel the state 5 and make public
records requests? 6 A No, absolutely not. 7 Q You've never spoken with Mr. Chandler 8 about his involvement with Mr. O'Boyle? 9 A That I can't recall what conversations
I 10 had with him and Mr. O'Boyle. 11 Q And you filed over two dozen public 12 records requests against the Town of Gulf Stream, 13 right? 14 A Are you talking about complaints?
15 Q Yes. 16 A Oh, I thought you said requests. 17 Q Public records requests complaints, 18 lawsuits. 19 A It's probably over two dozen so far. 20 Q
And one of them you're a co-plaintiff with 21 Mr. O'Boyle? 22 A No. 23 Q What case are you a co-plaintiff with 24 Mr. O'Boyle? 25 A That was a circumstance where
we both 89 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 showed up at a commission meeting and were denied 2 the opportunity to speak, and, I believe, I was 3 going
to file an anti-shush complaint. I think, 4 that's what it's called. And for the sake of 5 judicial expediency and consideration of the court's 6 time, someone suggested that Mr.
O'Boyle and I join 7 forces so not to waste the court. That's the only 8 time I've ever joined forces, to use your phrase, 9 with Mr. O'Boyle as an anti-shush case where the 10 mayor
refused to let us speak. 11 Q And you were represented by the O'Boyle 12 Law Firm in that case? 13 A There's so many lawyers, I can't say who 14 was doing that one. 15
Q Okay. And you use gmail addresses for 16 your public records requests don't you? 17 A Some of them. 18 Q And you use Mail.com? 19 A I think, I might have
done that once. 20 Q You use fictitious names like 21 Amaricodesputchy (phonetic) don't you? 22 A Aliases, yes. 23 Q So you've used Amaricodesputchy? 24 A
I think, that might be the name attached 25 to the gmail url. If I remember right, if you open 90 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 up a gmail account,
they prompt you to enter stuff 2 and that might have just popped into my head. 3 Q All right. So you've used that name, 4 right? 5 A I can't recall. If you've got an
e-mail 6 like that, I can look at it and tell you if it's 7 mine or not. 8 Q Well, did you make up the name 9 Amaricodesputchy? 10 A Didn't he discover -- no, didn't he
draw 11 the map of America? I don't remember where I got 12 that name, if it is, in fact, a name I came up with. 13 Q But isn't that your creation on the 14 e-mail? 15 A
Again, if you have the e-mail, I'll be 16 happy to comment on it. I don't recall it. 17 Q Well, do you recall I took your deposition 18 on February 19, 2015, and on page
66, I asked you at 19 line 5, "Okay. And did you make up the name 20 Amaricodesputchy?" Your answer was, "Yes. That is 21 my creation." Do you recall that question and that 22 answer?
23 A I don't recall that, but if I said it at 24 the time, it's probably because my memory was 25 fresher at that time than it is now on that 91 Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc. 1 particular item. 2 Q And what about the name June Ellis 3 (phonetic)? Do you use the name June Ellis? 4 A It's possible. If you can give
me a 5 document, I'd be happy to comment on it. But I 6 don't recall exactly the names. It was a long time 7 ago. 8 Q Well, didn't you -- didn't you make up the 9 name June
Ellis? 10 A I think, she was married to 11 Jackie Gleason. 12 Q Pardon? 13 A I think, that's somebody else. These are 14 just names. 15 Q Well, did you
make up -16 A -- did use the name, if I did, they sound 17 just like arbitrary names. 18 Q Did you make up that name to use in 19 requests with the Town of Gulf Stream?
20 A I can't testify exactly because I don't 21 know. It might have been June Ellis. It could have 22 been something else. 23 Q Okay. Let me ask you if you recall this
24 question on page 67, line 19. "Who is June Ellis?" 25 "ANSWER: Made up name. 92 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 "QUESTION:
Okay. That you made up? 2 "ANSWER: Yes." 3 A If I said that, then that's what I 4 remembered at the time. 5 Q Okay. So you don't remember, though, as
6 you're sitting here today, that last year you 7 testified to that? 8 A I don't remember my testimony in 9 deposition. I just tell the truth then and I tell 10 the truth now.
11 Q And what about William Bendicks 12 (phonetic)? Is that -- did you ever use the name 13 William Bendicks? 14 A Yeah, probably. 15 Q Okay. In public records
requests, right? 16 A Yeah, probably. 17 Q Okay. And what -- and what about 18 John Brewer (phonetic)? 19 A Geeze, I don't remember. 20 Q What about Harry
Latharge (phonetic)? 21 A Do you have a date when I supposedly used 22 those? 23 Q I just want to know if you remember using 24 that name. 25 A I would say I probably
do, yeah. 93 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Probably. That sounds like one of mine. 2 Q And what about Nevada Smith (phonetic)? 3 A
Yeah. 4 Q Okay. And you asked Mr. Roeder to make 5 public records requests on your behalf, right? 6 A Not in those many words, but I expected 7 that he was going to
do whatever he could to get 8 records. 9 Q Well, let me see, do you recall this 10 question on page 55, line 19, same deposition date? 11 Line 9. 12 "QUESTION:
Have you ever -- have you 13 ever authorized Mr. Roeder to make public records 14 requests for you? 15 "ANSWER: Requests? 16 "QUESTION: You've asked him
to. 17 "ANSWER: Yes." 18 A Well, that's what I did then. 19 Q In fact, Mr. Roeder made 16 requests on 20 your behalf in March of 2014, right before you
made 21 the request in this case, right? 22 A If you say so. Do you want me to refer to 23 a document? But I don't have any real recollection 24 of any number or dates. 25
Q Do you remember how many times you 94 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 directed Mr. Roeder to go in and make public records 2 requests in his
name? 3 A No. 4 Q More than 50? 5 A No, I don't remember. 6 Q Do you know how many occasions Mr. Roeder 7 went in and made public records requests on your
8 behalf? 9 A I know he's made requests. I know he's 10 gone and picked up records. I can't remember an 11 exact number. 12 Q So we'll have to look at the log to see
13 that. 14 A If the log is accurate. I don't know that 15 it is. 16 Q Okay. Now, did it ever occur to you that 17 filing more than 50 requests in a day would not 18
facilitate getting a response back? 19 A Never. Matter of fact, I think, the 20 largest request the Town ever got was for 720 21 requests that came in in one day that they answered
22 within a week with no problem at all. It happened 23 to be a TV station though. They obviously treat TV 24 stations differently than they do people they don't 25 like. 95 Fort
Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q So you thought -- so you didn't think you 2 were burdening the clerk at all? 3 A When I go to the library
to check out a 4 bunch of books, I figure if they know this is 5 coming, they should prepare for it. I've never been 6 told that anyone that went to the Town and was 7 refused service
because of me. 8 Q Okay. Well, let's take a look -- let's 9 take a look at -- well, before I do that, because 10 this is a different case number. I read some of 11 your testimony
yesterday. Let me make sure that 12 those submissions are in the record. The name 13 Wyattburk@okaycorralrecordsgmail, that was you, 14 right? 15 A I think so. 16 Q
You answered yes on page 30 in your 17 deposition that you gave in August of 2015. Do you 18 specifically recall that you used the name 19 Wyattburk@okaycorralrecords to make public
records 20 requests from the Town? 21 A Well, let me clarify. When you create a 22 gmail account, sometimes the name is taken. You 23 have to change a letter or so to make
it work, to go 24 on, because there's so many gmail accounts out 25 there. So when you ask me a specific name, I could 96 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting,
Inc. 1 say in general that sounds familiar. The spelling 2 might be a little different than the way I'm 3 thinking, but it sounds like one I made. 4 Q Okay. And what about
5 Craigshypocrities@craigshypocritiesgmail? That's 6 one you've used also, right? 7 A If I testified I did, then I did, but I 8 don't remember. 9 Q You don't remember
that name? 10 A Like I said, I don't remember exactly all 11 those names. It was a long time ago. 12 Q Okay. In your deposition you were asked 13 at line 30, "Craigshypocrities,"
and your answer 14 was, "Yeah." 15 What about James Baker? Do you 16 remember James Baker, using that name? 17 A Yeah, I remember that one. That used to 18 be
-- my attorney used to be Secretary of State, I 19 think. 20 Q Okay. So you used that name? 21 A James Baker? 22 Q Right. 23 A That sounds familiar, but
that sounds like 24 the name in the account and not the gmail address. 25 Q It's Jamesbaker@recordsmaker@gmail.com. 97 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting,
Inc. 1 Is that the address you used? 2 A It's got a nice ring to it. I think, that 3 was one. 4 Q Okay. And you also use Mail.com in your 5 addresses, don't you? 6
A I think, I already answered that, yes. 7 Q Okay. And Emailfinder@mailgmail.com, you 8 used that, right? 9 A Yeah, that was -- those are experiments to 10 see
which account worked best for my purpose. 11 Q And publicdocsearch@gmail.com. That's an 12 address you use, right? 13 A That sounds familiar. 14 Q I'm going to
ask you to take a look at 15 just the log for 2014. 16 It's Exhibit 17, if I could have 17 trial Exhibit 17. 18 Your Honor, it's 17 in your notebook. 19
THE COURT: I have it. 20 MR. SWEETAPPLE: If I can approach, 21 Your Honor. 22 THE COURT: You may approach. 23 BY MR. SWEETAPPLE: 24 Q Thank
you. 25 If you look at January 3rd, number 98 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 466, all of those requests, on the first page of the 2
log, you just used your name and your e-mail 3 address, right? 4 A That's what it says here. 5 Q Other than Jonathan O'Boyle, all the 6 requests during January -- during
-- on page one are 7 from you, correct? 8 A Yeah, there's one from Jonathan and eight 9 from me. 10 Q And Jonathan was your Attorney at the time 11 he made this request,
right? 12 A I don't know if he was or not. 13 Q Well, he was representing you in 2013, 14 wasn't he not, as pro hac vice, even though he 15 wasn't an attorney in the State?
16 A If you say so. I don't recall the exact 17 dates. 18 Q Do you recall when Mr. Jonathan O'Boyle 19 was representing you in cases pro hac vice before he 20 became
a Florida Attorney? 21 A Yeah, I remember that. 22 Q Okay. And on the next page, January 14th, 23 number 475 through 483 on that page, those are all 24 the same day,
right? 25 A That's what this says. I don't know if 99 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 it's accurate. 2 Q Okay. And those were all from
you, 3 correct? 4 A That's what it says. Again, I don't know 5 if it's accurate. 6 Q And did you make these up on that day, or 7 do you spend time storing them up and
then dumping 8 large numbers on the Town? 9 A Well, I don't dump. I don't blast. I 10 just make record requests, sir. 11 Q Well, do you ever serve 50 at one time, 12
like on a Sunday? 13 A I don't recall that exactly. If you say 14 so, could possibly be true. 15 Q Ever served 80 on one day? 16 A I know I've done multiple.
I don't know 17 numbers. 18 Q And when you serve 50 or 80 on one day, 19 like over a weekend, do you typically prepare all 20 those requests the day you send them, or does it
21 take you weeks to prepare those requests? 22 A Well, I don't agree that I've done 50 or 23 80 a day. 24 Q Pardon? 25 A I don't agree that I've done 50 or 80
a 100 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 day. Your question seems to insinuate that I did. 2 Q Okay. So you don't know that you've 3 served 50
requests on one day and 80 requests on one 4 day on different -- using different addresses? 5 A No, I don't know if those numbers are 6 accurate. 7 Q What's the most you
think you've ever 8 served on one day, Mr. O'Hare? 9 A I don't recall. I just know I've done 10 multiple requests. 11 Q You can't tell us if you've ever served 12 more
than 12 on a day? 13 A That's weird. I thought I just answered 14 that. 15 Q Well, I'm trying to get a little more 16 specific to help see if you can recall for us. 17
A I can't recall. 18 Q Can you recall if you've ever 19 served -- what about on -- well, let's just go 20 through these days. Here's January 14th. Let's 21 turn the
page and you see you have more for January 22 14th, but then let's look at January 16th. You see 23 it starts at number 488? 24 A Yes, sir, according to this. 25 Q And
then let's go to the next page. 101 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 That's January 16th, right? 2 A That's what this says. 3 Q Let's
go to the next page. That's January 4 16th, isn't it, sir? 5 A That's what this says. 6 Q Let's go to the next page. That's January 7 16th, isn't it, sir? 8 A
Yes, sir. 9 Q Let's go to the next page. That's 10 January 16th, isn't it, sir? 11 A That's what it says in this document. 12 Q Let's go to the next page. That's
January 13 16th, isn't it, Mr. O'Hare? 14 A Yes, sir. 15 Q And the next page, that's January 16th 16 also, isn't it, Mr. O'Hare? 17 A Yep. There's a few there
as well. 18 Q A few? 19 MS. JOHNSON JAMES: Your Honor -20 BY MR. SWEETAPPLE: 21 Q Let's count that page, Mr. O'Hare. One, 22 two, three, four, five, six, seven,
eight, nine, 23 ten, eleven. Do you see that on the page that I 24 have you directed to, numbers 530 to 540, that there 25 are eleven requests on that page? 102 Fort Lauderdale, Florida
954-755-6401 Daughters Reporting, Inc. 1 A I'm sorry. What page was that? There's a 2 number on the right side. Could you tell me -3 Q That's five. Numbers five 4
through -- requests 530 through 540. 5 A Oh, okay. 530 through 540. I'm sorry. 6 What was the number you counted? 7 Q Eleven. 8 A If you say there's eleven, there's
9 probably eleven on here. 10 MS. JOHNSON JAMES: Your Honor, in the 11 interest of time, we're happy to stipulate that 12 Mr. O'Hare made several hundred public records
13 requests of the Town of Gulf Stream between 14 2013 and the date of the request at issue here. 15 The log is going to be in evidence, so -16 THE COURT: Well
-17 MS. JOHNSON JAMES: It is a bit 18 repetitive. 19 THE COURT: -- do you wish to accept that 20 stipulation, or do you wish to allow this 21 gentleman
to continue answering the way he's 22 been answering? 23 MR. SWEETAPPLE: I prefer to have him 24 continue answering. 25 THE COURT: I thought you might, and
so 103 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 did Ms. James. 2 BY MR. SWEETAPPLE: 3 Q Do you happen to know what day of the week 4 January 16th
was? 5 A I don't. 6 Q Do you know if it was a Sunday? 7 A It could have been Sunday, maybe a Monday. 8 It could have been Tuesday. Maybe a Wednesday. 9 Q
Let's count out how many -10 A Maybe a Friday or a Saturday, sir. 11 Q You served all these requests on January 12 16th by e-mail, right? 13 A Well, according
to this log, and as I 14 recall, there are columns to the right that are 15 missing, which actually shows the date that the 16 request was opened. I'm assuming that these are all 17
received, meaning, the e-mail was date stamped on 18 the 16th, but I don't know when they were actually 19 received. 20 Q Let me just say you e-mailed them all at 21 the same
time, right? 22 A They probably left my account headed for 23 the Town at the same time. 24 Q Can you tell us how you do that? Do you 25 have it set up automatically,
so it just robo dials, 104 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 or do you have to actually manually send all these 2 e-mails? How do you have that set
up, Mr. O'Hare? 3 MS. JOHNSON JAMES: Relevance, Your Honor. 4 THE COURT: Overruled. 5 THE WITNESS: I'm sorry. I didn't hear 6 that. 7 BY MR. SWEETAPPLE:
8 Q How do you have -- can you explain -9 A No, I heard that. I didn't hear the 10 Judge. Did he say go ahead? 11 THE COURT: I overruled the objection. 12
I'm sorry. I'll speak up. 13 THE WITNESS: Okay. Thank you. 14 I'll tell you exactly how I do it. When I 15 read something in the paper, hear something
in 16 a meeting, something peaks my interest, or 17 perhaps there's something in discovery I want 18 to know about, I write the request. Then, when 19 I have the time,
from family and business, 20 which usually happens on Sunday, because I'm 21 busy the rest of the time, I will read each 22 request, make sure there's no clerical errors,
23 make sure -- try to be as clear as possible, 24 make sure I didn't misspell anything, because I 25 don't want to be thought of as sloppy, and then 105 Fort Lauderdale,
Florida 954-755-6401 Daughters Reporting, Inc. 1 I go ahead and hit send. Then I go to the next 2 one. I peruse it equally. 3 Sometimes I peruse them in advance,
and 4 then I'll hit send. And then I'll go to the 5 next one, I'll hit send. Then I'll go to the 6 next one, maybe number four, I'll hit send on 7 that. And then
I'll go to number five and I'll 8 hit send. 9 Then six, I might look at that one and 10 look for spelling errors or something and I'll 11 hit send. And then seven,
I'll go to seven, 12 hit send. 13 BY MR. SWEETAPPLE: 14 Q Do you remember -15 A And then to number eight. I'm sorry. Let 16 me finish answering your question -17
Q Okay. 18 A -- because obviously there's a lot here 19 sent on a Sunday. You want to know why, because 20 that's my day off and when I devote most time to 21 civil activity.
Civic activity. 22 So when it comes to number nine, I'll 23 look at that one and see if it's clerically accurate 24 and hit send. And on and on and on. 25 Q So
how long -- do you recall how long it 106 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 took you on January 16th to send all these e-mails 2 to the Town of Gulf
Stream? 3 A No, I do not. 4 Q How long did it take you to come up with 5 all these topics that are in the column there? 6 A How long did it take to come up with
the 7 topics? 8 Q Right, on January 16th. Did you do those 9 that day, or did you spend weeks coming up with 10 those and writing those? 11 A No, this is over a course
of time, I 12 believe. 13 Q How many weeks did it take you to write 14 these? 15 A You know, I don't keep a log of that. I 16 don't know. 17 Q But these -- this
is -- Mr. Chandler 18 trained you how to write these, right? 19 A No, not at all. 20 Q Did he give you any training on how to 21 make public records requests? 22 A
He told me the State Statutes. He 23 recommended that I cite the statutes in my requests 24 so that there's no doubt about what the Town is 25 supposed to do, since so many times
the Town doesn't 107 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 seem to know what to do and I want to eliminate the 2 possibility that they wouldn't comply with
the laws. 3 So under his guidance, and from his website, from 4 the First Amendment website, I found how, what I 5 thought was an effective way to bring my requests to 6 the Town's
attention in a way that they would -- it 7 would be the best chance for a response. 8 Q So you were sending these hoping to get a 9 response. When you sent out all these requests,
you 10 were hoping to get a quick response for all these 11 requests, right? 12 A Reasonable response. 13 Q What did you think was a reasonable time 14 for the Town to
respond to your e-mail -- your 15 e-mails of January 16th? 16 A I don't know if I thought that at the 17 time. 18 Q Well, have you since thought of it? 19 A Yes,
I've thought about it quite a bit. 20 Q Okay. And what do you think is a -- what 21 do you think would have been a reasonable response? 22 Just for the record, you stopped at
number 547. You 23 started at 488, if my math is correct, which it not 24 always is, that would be 59 requests that you sent 25 on January 16th. How long -- how long did you - 108
Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 THE COURT: January 16th? 2 BY MR. SWEETAPPLE: 3 Q January 14th, I'm sorry. 4 January -- January 16th.
5 A Well, I didn't have a collective opinion. 6 I had an opinion on each one. If a record was for a 7 single document, maybe something I even created in 8 the past few days,
or the past week, I expected I 9 might get that in a few hours. If it was a record 10 that perhaps they had to go look in a file cabinet 11 in the next room, where most of the records
are 12 kept, I thought perhaps it might take a week, or 13 less, but given the circumstances, because I know 14 people have other things to do, but I also know how 15 important it is
for open government and responding 16 to records requests, at least as far as the 17 legislature is concerned, I expected I would get 18 requests within certainly a shorter period of
time 19 than six weeks, especially when it's to a law firm, 20 who has -- who is the Town Attorney and has these 21 records at their immediate disposal on their 22 computer. Just a
push of a button, I think. 23 Q Mr. O'Hare, so you say when you ask for a 24 specific document, that would be quicker than if you 25 asked for more than a specific document,
right? 109 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A Well, I don't know what responsive records 2 they would be, because I'm not the custodian. When
3 I ask for records related to a topic and it only 4 happens to be one document, I would think it would 5 be reasonable to expect that would be produced 6 pretty quickly. If it's something
that would 7 be -- take more time, would be perhaps a more 8 expansive request that would require some research, 9 and, of course, the Town's entitled to charge me for 10 some research,
and I'm entitled to decide whether I 11 want to pay that or not. 12 Q But you're aware -- you were aware that 13 any time you made a request, the Town would have to 14 inquire
of its employees, its elected officials, its 15 attorney's in order to respond to your request, 16 right? 17 A You know what, that would depend on the 18 request. If it was
something that was an e-mail by 19 the custodian of records, I wouldn't expect her to 20 go ask the dog catcher if he happens to have it. 21 That doesn't seem reasonable to me. 22
Q Let's go -- and your request on the first 23 page starting at 484, that's "Any and all," right? 24 A Give me a second, please. 25 Q And the next page says "Any
and all," and 110 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 then it goes on to describe categories of things. 2 You used the term -- when you look at January
16th, 3 almost all of these requests, or a large part of the 4 requests start with any and all documents, don't 5 they? 6 A Can you tell me which page you're talking 7 about?
8 Q Well, let's look at -- starting at 484, 9 you see every one starts any and all, any and all, 10 any and all, then it says, "Gulf Stream's check 11 ledger." You wanted the
check ledger on number 47, 12 from January 1, 2008 to December 31, 2013, including 13 all fields, check number, date of check, vendor 14 name, vendor code, check status, check amount,
15 right? 16 A I'm sorry. Which one are you reading? 17 I'd be happy to -18 Q Number 487. That's the only one on the 19 first page where you don't ask for any and all
20 documents. 21 A Well, there are times when I've just asked 22 for the first three responsive documents, and 23 there's times when I ask for any and all. Again, I 24 do not
know what records are in the custody of the 25 custodian, and I'm still learning and figuring out 111 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 how to ask to
make sure I get all the responsive 2 records. 3 Q And you're not asking in a way that's 4 going to facilitate you and the O'Boyle Law Firm 5 filing lawsuits to get attorney fees?
6 A I have nothing to do with the O'Boyle Law 7 Firm, except when they represent me. 8 Q Well, you're represented by them on over a 9 dozen cases, right? 10 A There's
been a number of attorney's, but, 11 I think so, yes. 12 Q Well, let's turn -- let's start now on the 13 next day, 548. 14 A I'm sorry 548? 15 Q Yeah, number 548.
It's January 17th. You 16 made a request on January 17th. 17 A My documents start at 566. I don't see a 18 548. 19 Q Keep going. Keep going. You'll see 548. 20 Number
548. It's on January 17th. 21 A Can you give me a page number, sir? 22 Q It's page nine. 23 A Oh, I'm sorry, 548. I was thinking 448. 24 Yes, I see 548 now, sir.
25 Q Okay. So you've now made requests on the 112 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 7th, the 9th, the 14th, the 16th, the 17th, the 2 18th.
See the 18th there, starting at 549 on page 3 nine? 4 A 549. Yes, I see that. 5 Q Okay. And then the 19th at number 559. 6 So you've -- you've made -- you don't just
make 7 requests on the weekend, when you're not doing other 8 things, you pretty much make requests -9 A Sorry. 10 Q -- you make requests a lot more frequently 11 than
every weekend, don't you, or on the weekend? 12 A I believe, I also sometimes make requests 13 at 6:00 in the morning before I'm heading to work, 14 or 11 o'clock at night when
I get done working. 15 Yeah, different times of day, or maybe lunch hour or 16 a break. I might do a final review of a request and 17 then send it to the Town. 18 Q And all
the requests that were made on 19 page nine, those were made by you, right, 541 20 through 552? 21 A Well, according to this document. I can't 22 attest to its accuracy. 23
Q And then the next page, page ten, those 24 are made by you, numbers 553 through 559, and then 25 Mr. Roeder makes one on 560. And then there's 113 Fort Lauderdale, Florida
954-755-6401 Daughters Reporting, Inc. 1 another one that says, 2 "Martinoboylerecords@commercegroup." See that, dot 3 com? 4 A Yes, I see. That's what it says here. 5
Q Right. That's the same Commerce Group 6 location where Jonathan O'Boyle's located, your 7 lawyer that you talked about going to, right? 8 MS. JOHNSON JAMES: Asked and
answered, 9 Your Honor. We discussed 10 Mr. Jonathan O'Boyle's address. We discussed 11 where his dad works. 12 MR. SWEETAPPLE: I just want to tie it 13
into this. 14 THE COURT: Overruled. Overruled. 15 BY MR. SWEETAPPLE: 16 Q That's the -- that e-mail address is the 17 actual -- that's the name of the physical location
18 where you go to see Mr. Martin O'Boyle and 19 Mr. Jonathan O'Boyle, right? 20 A Well, that's an assumption you're making, 21 but that's also the assumption that my e-mails
from 22 okay corral so it came from the okay corral. But as 23 far as the Commerce Group, I'm not familiar with all 24 their properties, but I do know -- I think, I know 25 that they
have offices there. I've never seen 114 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Mr. O'Boyle in his office there. 2 Q You've seen Mr. O'Boyle -- Martin
O'Boyle 3 at his office at the Commerce Group Building, 4 haven't you? 5 A No, I have not. 6 Q Have you seen Jonathan O'Boyle there? 7 A At the office at the Commerce
Group? No, 8 I have not. 9 Q The law offices that are at the Commerce 10 Group Building. 11 A I've seen Mr. Jonathan O'Boyle in his 12 Florida offices which are located
in Hillsboro. 13 Q And they are in the same suite as his 14 father's offices aren't they? 15 A I don't know that. 16 Q And then right after that, we have 17 Lou
Roeder, 562. You -- Mr. Roeder was there making 18 that request on your behalf, right? 19 A Was where, sir? 20 Q At -- sending e-mails to the Town, or 21 physically at
the Town? 22 A I'm sorry. I thought you meant the 23 Commerce Group. 24 Q I'm now on 562. That's Mr. Roeder, right, 25 your lawyer? 115 Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc. 1 A You're asking me where he was making the 2 records request from. I don't really know. 3 Q Well, did you set up those gmail accounts 4 for
him or did he set them up himself? 5 A Which one are you talking about? 6 Q Well, let's start with the one that's 560, 7 but there's also 562, and then there's 563. And
is 8 this a situation where you used Mr. Roeder's name 9 like you did with -- strike that. You've used 10 employees' real names to make requests on the Town 11 of Gulf Stream repeatedly,
haven't you? 12 A I've used employee's names to make gmail 13 accounts, but I didn't make requests on their 14 behalf, never have, despite what the Judge might 15 have said yesterday.
16 Q Well, haven't you put your employee's 17 names as requester on the actual forms, the public 18 records request forms that you've e-mailed? 19 A There's no form.
I don't know what you're 20 talking about. 21 Q Well, on your actual -- when you make the 22 request, when you type up the request, you type in 23 requester and then an employee's
name, don't you? 24 A No, I do not, sir. 25 Q You haven't typed in the name requester 116 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 and a name?
2 A I don't believe so. I think, the name was 3 entered when the gmail account was created when you 4 send it gmail, the name sometimes, maybe all the 5 time, pops up, but I
don't recall actually typing in 6 someone's name there. I might be mistaken, but I 7 don't recall that. 8 Q So next to requester, the way you set up 9 the account is you have
the employee's name, like 10 let's take one that's easy to pronounce. Who's an 11 employee that you've used his name and then an 12 e-mail address to make a request to the Town of
Gulf 13 Stream, an actual person? 14 A Okay. That would be Janto Djajaputra. 15 Q Well, I was going to use Mr. Tajara, 16 because I thought that would be easier, but
we'll 17 use Janto. 18 A Well, if you want to answer the questions 19 for me, go ahead. 20 Q You've used Janto Djajaputra. 21 A I'm sorry if I've mispronounced
it. It's 22 Djajaputra. 23 Q Okay. And -24 THE COURT: Can you spell that for the 25 Court Reporter, please? 117 Fort Lauderdale, Florida 954-755-6401 Daughters
Reporting, Inc. 1 THE WITNESS: Yeah. D -- although, I 2 think that might be silent. 3 J-a-j-a-p-u-t-r-e-a. I'm sorry, t-e-r-a. 4 BY MR. SWEETAPPLE: 5 Q And
the first name is Janto; J-a-n-t-o? 6 A Pronounced Janto. 7 Q Okay. And you -8 A With a Y. With a Y. 9 Q And you opened up a gmail account using 10 his
name and then the name is part of a gmail 11 address, right? 12 A I opened a gmail account. It asked for a 13 name. I stuck the name in there. 14 Q Right. And you've
done that for 15 Mr. Tajara as well, right? 16 A Rodrigo Tajara, yeah. 17 Q And what other employees have you used -18 A D-e-j-r-a. 19 Q What other employees
have you used their 20 name and then opened a gmail account with their 21 name, and then an e-mail address that you've used to 22 make requests to the Town? 23 A I think, Irnataway
Djajaputra (phonetic). 24 Frank Nevada (phonetic). I can't recall right now. 25 There might be more. 118 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q
Okay. Mr. Nevada, did you have 2 Mr. Nevada's permission to use his name? 3 A Of course. 4 Q And did you have his permission to make 5 public records requests? 6
A I don't think I ever asked him. 7 Q Never asked him. 8 Okay. What about -- how do you spell 9 the name -- the other name you mentioned before 10 Mr. Nevada?
11 A Irnataway? 12 Q Yes. 13 A I-r-n-a-t-a-w-y. No, I'm sorry. W-a-y. 14 Something like that. 15 Q And did you ask that individual if you 16 could make
public records requests in their name? 17 A I didn't make any in their names, so no, I 18 didn't ask them that. 19 Q Did you ever use their name as part of an 20 e-mail
address that you provided to the Town of Gulf 21 Stream? 22 A It's possible. 23 Q And with -24 A Again, the reason I did that is you're 25 creating a gmail account
and you have to think of 119 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 something that's not been used before. First thing 2 that popped in my mind. 3 Q
Were employee's names? 4 A That and Wireearth and any number of other 5 names just to pick from the air. 6 Q Well, let's talk about the use of 7 Lou.roeder@gmail.com.
Did you open that e-mail 8 account, or did Mr. Roeder open that gmail account? 9 A I don't think I ever opened an e-mail 10 account for anybody else to use, but -11 Q
Did you create Lou.roeder@gmail.com on 12 your electronic device, or did -- was it created in 13 some other fashion? 14 A Well, you have to understand, at the time 15 we were
sharing office space when he would come into 16 town occasionally, and what computer is there, I 17 don't know if his was down, but if he had to use 18 mine, I don't know. 19 Q
So it's possible that your computer was 20 used to open up the Louroedergmail.com account? 21 A Well, I'm just saying it's possible. My 22 computer is being used by a number
of people, and I 23 can't say whether I created it or he did. It was a 24 long time ago. If he asked me to create an account 25 for him, I might have, but I don't recall. 120 Fort
Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q Well, isn't it a fact, sir, that every one 2 of these Lou Roeder e-mails were sent from your 3 computer? 4
A No, I don't think so. I don't think I 5 ever sent a request on behalf of Lou Roeder. 6 Q Well, did you ever -- were any -- was 7 Lou Roeder, Lou.roeder@gmail.com, did that
-- did an 8 e-mail using that address ever emanate from any 9 device that you owned? 10 A I've got so many computers. I mean, there 11 must be 20 computers, laptops. I couldn't
say. I 12 don't know. 13 THE COURT: Mark your spot. Let's take 14 our morning break at this time. 15 Sir, you're in the middle of 16 cross-examination,
so please, do not discuss 17 your testimony with anyone at this time, 18 including your Counsel. 19 We will reconvene at 11:15 by that clock 20 there. And everyone,
enjoy your break and 21 we'll be back at 11:15. 22 MS. O'CONNOR: Your Honor, for our next 23 witness, what do you expect to be the lunch 24 break that you -25
THE COURT: I don't know how much longer 121 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 the -- I was planning on breaking at noon. I 2 don't
know how much longer the 3 cross-examination will take. We'll break at 4 noon and we'll reconvene probably at 1:00 or 5 1:30 depending on where we fall. 6 MS.
O'CONNOR: Great. 7 THE COURT: All right? 8 (A break was taken at this time.) 9 THE COURT: Welcome back, everyone. Okay. 10 Pete, will you see if you
can find Mr. O'Hare 11 for us? 12 (A discussion was held off the record.) 13 THE COURT: All right. We'll pick up 14 right where we left off. Counsel, you may
15 proceed. 16 BY MR. SWEETAPPLE: 17 Q Thank you, Your Honor. May it please the 18 Court. 19 Mr. O'Hare, I want to go back on 20 something that I just want
to clear up. This whole 21 issue of getting estimates from the Town, how many 22 times have you gotten estimates from the Town for 23 documents that have been searched? 24 A
I don't know what -- before I answer that, 25 I haven't spoken to anyone, but I would just like to 122 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 say that one
of your prior questions, on reflection, 2 I didn't quite accurately answer. I'd like an 3 opportunity to do that over again. 4 Q Fine. What question was that? 5 A Well,
you asked me if I made any record 6 requests on behalf of other people and the answer is 7 actually, yes, I think, I remember twice. 8 Q And who were those on behalf of? 9
A First one was a woman named Becky 10 (phonetic), who lives a few blocks from me, who had 11 a -- has a house that I since bought adjacent to a 12 vacant lot in town that was
overgrown with nuisance 13 and rats, and she asked me to make a record request 14 on that lot on her behalf to see if the nuisances 15 would be cleaned up. She was afraid to make it
16 herself. 17 Q Any others? 18 A Another one was for Mr. Julio Martinez 19 (phonetic), who told me about a Social Security 20 Number on the Town's website that he saw
and asked 21 me if I'd look into it. 22 Q All right. So you know what it means to 23 actually make a request on someone's behalf and to 24 have permission and get permission,
right? 25 A Well, I'm not stupid, sir. Yes, of 123 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 course, I know that. 2 Q Well, did it occur to you
that when you 3 used other real people's names you should have their 4 permission? 5 A Well, let me clarify. I didn't use their 6 names. I made the record request on their
behalf. 7 Q I'm saying in the situation with Nevada 8 Smith and Mr. Tajara, and others whose real names 9 you've used, your employees I'm referring to, did it 10 ever occur to
you that you should ask them to have 11 their permission to do the same thing you did for 12 this woman who had the lot? 13 A Well, they gave me permission to create 14 the account.
I didn't ask them permission to make a 15 record request. I didn't make it on their behalf, 16 to answer your question again like I did before. 17 Q Did it ever occur to you,
before using 18 their real names with the Town of Gulf Stream to 19 make a request, that you should ask them for their 20 permission? 21 A Well, they are not the only possessor
of 22 those names, I'm sure. There's lots of people with 23 those names. I didn't ask all those people for 24 their permission. I just asked for permission to 25 use their names
to make the gmail account. 124 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q So let's go back to page 11. On January 2 21, Mr -- it shows Lou Roeder as
563, and also on 3 January 21, Mr. O'Boyle is making approximately 4 eight requests, and you're making requests on the 5 same day. Do you see that? 6 A That's what it says on
this document. 7 Q Right. Were -- you monitored the website 8 of the Town, did you not? 9 A I would go to it occasionally to look for 10 records or information, but I
didn't monitor it. 11 Q You knew that the -- this log was on-line, 12 right? 13 A I've seen this log sometimes, yes. 14 Q Right. And you knew that Mr. O'Boyle
was 15 making requests the same days you were making 16 requests, right? 17 A Well, I need to go back and reanswer that 18 other question. I've seen this portion of the full
19 log on-line at different times. This is not 20 representative of that full log. 21 Q But you had knowledge that your actions 22 with the Town, your public records requests
were in 23 concert with other clients of the O'Boyle Law Firm, 24 right? 25 A That's absolutely not true. 125 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc.
1 Q Okay. Let me see if you recall your 2 testimony at page 114 of the deposition that I took 3 of you on February 19, 2015. It's line -- starting 4 at line four. 5
"QUESTION: And it never occurred to 6 you that your actions were in concert with the other 7 clients of the O'Boyle Law Firm? 8 "ANSWER: In concert? I'm sorry?
9 "QUESTION: That the O'Boyle Law Firm 10 clients were doing the same thing you were doing to 11 Gulf Stream at the same time and on the same day you 12 were doing it.
13 "ANSWER -- Mr. Hanna, object to form. 14 "QUESTION: That never occurred to 15 you? 16 "ANSWER: Well, I had knowledge of 17 that." 18
A Yeah, well, that's not the question you 19 just asked me, sir. If you'd like to read it back, 20 I'll answer the question again due to the reference 21 you just made, but that's
not what you just asked 22 me. 23 Q You had knowledge that the public records 24 requests you were making were being made at the same 25 time and in the same manner as other
clients of the 126 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 O'Boyle Law Firm? 2 A Now, again, I don't mean to split hairs 3 here, but I don't know what
you mean by the same 4 manner or the same time. Are you talking about 5 within the same century, year, month, week, hour? 6 Could you be more specific? 7 Q Let's let the log
be specific for us. In 8 fact, you and Mr. O'Hare go in person to the clerk 9 on the same day. 10 THE COURT: You mean Mr. O'Boyle? 11 BY MR. SWEETAPPLE: 12 Q You and
Mr. O'Boyle -- I'm sorry, thank 13 you. 14 You and Mr. O'Boyle went to the clerk 15 in person on the same day and asked for records. 16 You've done that, haven't you?
17 A There's been a number of times I went to 18 Town Hall -19 MS. JOHNSON JAMES: Which Mr. O'Boyle? 20 THE COURT: Yes. 21 THE WITNESS: -- with
Mr. O'Boyle. 22 BY MR. SWEETAPPLE: 23 Q Martin O'Boyle. You and Martin O'Boyle 24 have gone to Town Hall together to ask for public 25 records, correct? 127 Fort Lauderdale,
Florida 954-755-6401 Daughters Reporting, Inc. 1 A Absolutely not. 2 Q Haven't you been there at the same time 3 with him? 4 A I was just about to testify to that,
yes. 5 Q Okay. So you didn't travel together, you 6 just met there? 7 A Well, I've been there at commission 8 meetings with him. The gentleman in the back of the 9 room
here, a bunch of people in the Town at the same 10 time. There's no telling who's going to be in the 11 Town Hall when I show up. 12 Q And have you and he ever gone into the
13 clerk on the same day and made requests in person? 14 A If I had a camera in the clerk's office, I 15 could answer that accurately, but I can't tell you 16 that that's --
every time that's happened -17 Q Can you tell me -18 A -- or any time it has happened. 19 Q Are you aware it has happened and it shows 20 in the log? 21 A
That I would be in the Town Hall and in 22 that same day, Mr. O'Boyle would be in the Town 23 Hall? 24 Q Well -25 A Can you tell me in the log where you're 128 Fort
Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 talking about? 2 Q Sure. Why don't you turn to page 27, 3 numbers 767, 768, 769, Martin O'Boyle verbal, Martin 4
O'Boyle verbal, Chris O'Hare verbal, in person. See 5 that? 6 A I'm sorry. What page was that? 7 Q 27. 8 A Okay. Yes, I see that. 9 Q Does that refresh
your recollection as to 10 the fact that you were in the clerk's office with 11 Mr. O'Boyle making public records requests in person 12 in April -13 A Well, wait a second. Let
me ask you a 14 question. The request was made to 15 Mr. -- Ms. Freda DeFosse -16 THE COURT: Gentlemen -17 THE WITNESS: I'm sorry. 18 THE COURT: Please,
stop. Our poor Court 19 Reporter has the hardest job of anybody in 20 here, because she's trying to take down a clean 21 record and she can only take down one voice at
22 a time. And when you all are talking over each 23 other, she can't do that. 24 So let's start from scratch. Please, ask 25 your question. Let him finish his
question. 129 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Respond to the question. Let him finish his 2 answer. 3 MR. SWEETAPPLE: Yes, sir.
4 THE WITNESS: I apologize, Your Honor. 5 I'll try to be less zealous. 6 BY MR. SWEETAPPLE: 7 Q All right. Mr. O'Hare, have you ever been 8 at the clerk's office
while Mr. O'Boyle was there 9 and both made public records requests at or about 10 the same time? 11 A I believe, that's occurred. 12 Q How many times has that occurred?
13 A I have no recollection of how many times. 14 I don't think it's that many. 15 Q And let's go back then to page 12. You 16 see on the 24th you're making a request
and 17 Martin O'Boyle -- from records -- and Commerce Group 18 is making requests, page 12. Do you see that? 19 A I'm on page 12 of this exhibit. 20 Q And on 124, both
you and Mr. O'Boyle are 21 making public records requests, right? 22 A That's what this exhibit says. 23 Q And on that page, the only ones making 24 public records requests
are you and Mr. O'Boyle, 25 right? 130 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A I made eight. He made two. 2 Q Okay. And that's page -3
THE COURT: I'm sorry, Counsel. What 4 number is the next page? 5 MR. SWEETAPPLE: 13. 6 THE COURT: No, no. My page is both. 7 MR. SWEETAPPLE:
Look at the tiny 8 numbers -9 THE COURT: Oh, yes. I do see them now. 10 MR. SWEETAPPLE: Yeah, it strains your 11 eyes. That's why I'm wearing my glasses.
12 THE COURT: Okay. Eleven, twelve, 13 thirteen. Yes, sir. I'm there. Thank you. 14 I apologize. 15 BY MR. SWEETAPPLE: 16 Q So you see that Martin O'Boyle,
and 17 Jonathan O'Boyle, and Citizens Awareness Foundation 18 are all making requests from records at Commerce 19 Group, don't you? 20 A I see a record request from Scott Morgan
21 here. I'm sorry. What page are you on, 25? 22 Q I'm on page 13. 23 A Oh, I'm sorry. 24 Q And what I'm trying to get you to -- seek 25 your knowledge about
is that number 589 is 131 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Martinoboyle@records@commercegroup, then 2 Jonathanoboyle -- strike that. Then 3 Citizensawarenessfoundat
ion@records@commercegroup. 4 See that? 5 A I don't know. 6 Q Same address. 7 A Which -- which line is that? 8 Q 597. 9 A Okay. I see that. 10
Q And Jonathanroboyle@gmail is -- why does 11 he use -- do you know why he's using a gmail account 12 like you use gmail accounts? Did you use his name, 13 or is that -- did he
make that request himself? 14 A That's not one of mine. 15 Q Pardon? 16 A That's not one of mine. 17 Q And all of the requests on page 13 are 18 either by
-- either from the Commerce Group, 19 Jonathan O'Boyle or you, right? Actually, I don't 20 know that you have any on this one. 21 A Yeah, I don't see my name on this page, 22
sir. 23 Q So it's all O'Boyle's, right? 24 A That's what this says, but I have no 25 knowledge of their records requests. 132 Fort Lauderdale, Florida 954-755-6401 Daughters
Reporting, Inc. 1 Q Okay. And then on the next page 14, 2 February 11th, starting at 610, number 610. 3 A Yes, I see number 610. 4 Q And through 617, that's all
you on the 5 11th, right? 6 A Are you talking about the one from 7 Bill Coke, or Bill Boardman (phonetic)? 8 Q From 610 to 617, do you see that? 9 A Oh, yeah, where
my name is, yes. 10 Q That's you, right? You made all those? 11 A Well, that's what it says here, yes. 12 Q And then Jonathan O'Boyle made one at or 13 about the
same time. 14 A I'm sorry. Which one is that? 15 Q 618. 16 A It says 21014, but I don't see any time 17 date. 18 Q Okay. 19 A So I'm assuming it's
the same date, 20 according to this document, but I don't know if the 21 document is accurate. 22 Q And then we start again with you at number 23 617, right -- 619? 24 A
I see 619. 25 Q Then you go to the next page, you've made 133 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 requests, more requests on the 11th, number
620, 2 621, 622, see that? 3 A I'm sorry. Would you give me a moment to 4 read this? 5 Q It's page 15. It concerns -6 A It looks like it's recording a couple
of 7 my requests. 8 Q Do you see on page 15, it's only you and 9 Mr. O'Boyle are making requests on the Town? 10 THE COURT: Please, specify for the 11 record -12
BY MR. SWEETAPPLE: 13 Q Martin O'Boyle. Thank you. 14 Do you see that? 15 A I acknowledge that's what this piece of 16 paper says. I don't know if it's
accurate. 17 Q And Mr. Martin O'Boyle is making public 18 records requests on February 12th, the same day 19 you're making public records requests, right? 20 A I wonder
if we both had lunch that day 21 too. Yes, I see that. 22 Q Pardon? 23 A I see that. 24 Q What did you say about lunch? I missed 25 that. 134 Fort Lauderdale,
Florida 954-755-6401 Daughters Reporting, Inc. 1 A I said of all the things we did that day, 2 yes, this paper seems to say we both did that on 3 that day. 4 Q Did you
have lunch together with 5 Mr. O'Boyle at any time? 6 A No. I don't recall having lunch ever with 7 Mr. O'Boyle. Well, maybe once or twice. 8 Q You've been to his house
before? 9 A I was invited once to a political party at 10 his house. 11 Q Mr. Chandler was there also, right? 12 A I can't recall. Joan Orthwein might have 13
been there, but I'm not sure. 14 Q And then the next page, 16, those are on 15 the 13th and the 14th of February. All those 16 requests are yours, right, 633 through 646? 17
A Well, my name is here, but if you want me 18 to read these requests to verify them and take the 19 Court's time, I'll be happy to do it, but I don't 20 know if this is accurate
or not. 21 Q Do you recognize these requests just 22 looking at them as requests you prepared? 23 A Well, let me read them. I'm not sure this 24 one about Mayor Orthwein
is mine. It might be, but 25 I can't recall exactly. 135 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q Okay. Let's go to the next page starting 2 at 654,
number 654, February 15th, February 17th, 3 654 through 660, that's -- those are your requests, 4 right? 5 A All of this looks like the ones I made on 6 behalf of Becky. Elizabeth
Wooly (phonetic). Yeah, 7 these look like mine. 8 Q Let's go to the next page, number 18. 9 Numbers 661 through 678, those are all yours, right? 10 A Wow, these are --
I'm sorry, more records 11 I forgot to mention before that were made for other 12 residents in the Town. 13 Q Do you recognize those as being records 14 requests you made, right?
15 A Yeah, some of them for other residents in 16 the Town. 17 Q And then -- so you're making requests on 18 the 17th of February, the 18th of February, the 19th 19 of
February. When you turn to page 19, you're 20 making them on the 19th of February still, correct? 21 A It says, "Citizen Awareness Foundation." 22 Q 681, 682, that's
you. 23 A 682, 682. It has my name on it, so I'm 24 assuming if this is an accurate document, that's -25 Q And then we go to the next page, 20. 136 Fort Lauderdale, Florida
954-755-6401 Daughters Reporting, Inc. 1 That's you on -- well, the Glen Miccos (phonetic) 2 Architecture, that's not you, right? 3 A That is a neighbor who was also subject
to 4 a ridiculous code enforcement action. 5 Q So you made that on his behalf? 6 A No, I believe, that's from him. 7 Q Okay. And then the next one, did you 8 discuss
that with him? 9 A During his code enforcement action I think 10 I did. 11 Q Okay. So you helped him make that 12 request? 13 A No, not at all. I didn't know
he was 14 making this request. Just happened to be -- it was 15 a request I saw and then I saw him at his code 16 enforcement action. I asked him about this request 17 because it
seemed so important and significant, I 18 wondered if he'd gotten a response, which he hadn't. 19 Q Okay. So then 690 through 694, and 696, 20 on page 20 are yours, right? 21
A Again, there's requests in here from 22 Mr. Boardman that's not mine. 23 Q I didn't use that number. I eliminated 24 that number. 25 A Oh, I'm sorry. I'm not
following you. 137 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Could you repeat the numbers again, please? 2 Q Let's keep going. Next page, 21, that's
3 all you and Mr. Roeder, right, number 697 through 4 710? And that's all on March 3rd. That's -- one on 5 February 28th and 698 through 710 on that page are 6 all the same day, March
3rd, Mr. Roeder, right? 7 A I can't confirm the e-mails from 8 Mr. Roeder because I didn't write these or see -- I 9 don't have any recollection of those, but the ones 10 with
my name on them look like they would have been 11 ones I made. 12 Q The e-mails that actually are dated 13 3-3-2014 that say request for Lou Roeder, they 14 actually were sent
by you from your device weren't 15 they? 16 A Oh, I don't know that at all. 17 Q Did you send any of these from your 18 device, any of these Roeder e-mails? 19 A
The ones from Louis Roeder, no. No. 20 That's not to say it didn't come from any of my 21 devices. I'm just saying I didn't send the e-mails. 22 Q You're saying Mr. Roeder
sent those? 23 A I don't know who sent them. 24 Q Well, if you didn't send them, who else 25 could have sent them? 138 Fort Lauderdale, Florida 954-755-6401 Daughters
Reporting, Inc. 1 A Well, let me go ask everybody in town. I 2 don't know who sent them. They are not from me. 3 Q So you deny that you sent these from your 4 devices
or you admit it? 5 A Are we talking about 698 through 710? 6 Q Yes, any of those on that page. Of 7 course, they continue to the next page, but let's 8 just stick with
page 21 for now. 9 A Yeah, I didn't send these. They might 10 have come from a device in my office, but, I didn't 11 send any of these. 12 Q So if they came from a device
in your 13 office, who in your office was authorized to use 14 your devices to send the e-mails? 15 A There's so many people, and I haven't told 16 anyone in my office you cannot
use this computer. 17 Q Well, have you -- have you -- does anyone 18 else have access to e-mails in your office that have 19 been sent to the Town, or are you the only one that
20 uses your computer to send e-mails to the Town? 21 A I have no knowledge of what other people 22 do or have knowledge of -- I don't know. 23 Q Okay. So let's turn
to page 22, 24 Mr. O'Hare. You see those also on March 3rd are 25 from Lou Roeder, right? That's number 711 through 139 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting,
Inc. 1 716. 2 A That's what this document says. 3 Q All right. And then let's turn the page. 4 And that page is full of Lou Roeder requests 724 5 through 732, correct?
6 A That's what this page says -7 Q Did you -8 A -- from requester Lou Roeder. 9 Q Did any of those come from your devices? 10 A I don't know. 11
Q Did you e-mail any of those requests? 12 A No. 13 Q Do you use staff to e-mail requests? 14 A I'm sorry. Repeat that. 15 Q Do you ever use staff
to e-mail requests? 16 A Staff. You mean people that work for me? 17 Q Yes. 18 A Yes. 19 Q Who do you use to e-mail requests? 20 A Whoever is within
earshot. 21 Q So you use all your staff to e-mail 22 requests for you? 23 A No, I don't think I've used all of them. 24 Q Who have you used of your staff to send
25 e-mails? 140 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A Probably Irnataway, Tina Martin. I think, 2 Rodrigo sends e-mails sometimes. I think, everybody
3 sends e-mails. Since they work for me, I guess, 4 they're doing it on behalf of me. 5 Q And what about to the Town of Gulf Stream? 6 A Oh, no. No. These would be
-- well, 7 e-mails are e-mails, but if you're referring to a 8 request for records, I think, I might have asked 9 Irnataway to go to the Palm Beach County website and 10 pull records
off that, or the Boynton Beach Police, 11 or the Sheriff's Office, or the State Attorney's 12 Office, the Attorney General. Sometimes I ask 13 people to make requests to other agencies.
I think, 14 that's more accurately answering your question. 15 Q So have you ever asked Irnataway to make 16 requests to the Town of Gulf Stream? 17 A No, never. 18
Q Okay. So turn the page. I'm going to 19 move this a little quicker. Number 25. Look at 20 746, 747, 748. You made those requests that refer 21 to Irnataway Djajaputra,
right? 22 A Yes, because her e-mail account is 23 Irnataway@planetgrove.com and these are from 24 Irnataway@gmail.com. So these -- so it would look 25 like mine. 141 Fort Lauderdale,
Florida 954-755-6401 Daughters Reporting, Inc. 1 Q And then on the next page where it says 2 Tina Martin at 754, Lou Roeder verbal, 755, Janto 3 Djajaputra for April 1, Rodrigo
Tajara, April 2, 4 Rodrigo Tajara, April 2, those are all related to 5 you, right? 6 A Well, they all came from e-mail accounts 7 that I created. The name put down here for
8 requester was the Town's choice to put down. It 9 wasn't me. 10 Q And so also when we turn to the next page 11 and we see Nevada Smith at 765, we see 12 Rodrigo Tajara, Frank
Smith, Janto Djajaputra, those 13 are all related to you, right? 14 A Yeah, these look like gmail accounts I 15 created to ask for records. 16 Q Next page, 28, 787, 788,
Irnataway and 17 Mr. Roeder, those are related to you, right? 18 A I'm sorry. Which ones? 19 Q 787 and 788 at the bottom of the page. 20 A Well, I don't know what
you mean by 21 related. 22 Q Well, that's either an e-mail account or 23 someone that you authorized to do it. 24 A No, that's not accurate. It says here, 25 "In person."
There's no e-mail accounts next to Lou 142 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Roeder, so if this document is accurate, like you 2 assert it is, then
I assume Mr. Roeder went in to 3 see Rita Taylor in person. 4 Q On your behalf? 5 A I don't know what the record was for. I 6 don't know how many clients he's got. 7
Q You don't recall sending him there that 8 day? 9 A I don't tell him what to do every day. I 10 wish I did. 11 Q Okay. Let's skip over -- let's skip over. 12
The Court can -- I think, the Court knows what names 13 are at issue here. I don't need to go through all 14 these pages. Let me go -- let me go right to 514. 15 I don't want to go
past noon, so I'm skipping quite 16 a number of them, Your Honor, but I've identified 17 the record what names he's used. 18 So on 514 -19 A Are you on page 6?
20 Q I'm on page 37. 21 A You said 514. 22 Q The date 5-14. 23 A Oh, the date. 24 Q The date, which is the date of the request 25 in this case. You
are Review.net.apply@gmail.com, 143 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 right? 2 A I haven't gotten there yet, sir. Okay. 3 514. I see Airline
Highway. I'm not sure what that 4 is. Which one are you looking at? Which number? 5 Q So you are Review.apply@gmail.com, aren't 6 you? 7 A Oh, yes, sir. 8 Q
Okay. So all of those requests, the date 9 of the requests in this case, that are at 902 10 through 911, were made by you, right? 11 A Yes, this looks accurate. 12 Q
And when you made the request number 909, 13 which is the subject of this case, you knew that 14 Jones Foster had more than two dozen lawyers, right? 15 A I think, it's closer
to 50, but, yes. 16 Q Okay. In fact, you knew the names of the 17 lawyers because you had e-mailed each of the lawyers 18 individually on more than one occasion, right? 19
A I believe, that's on their website, yes. 20 Q Okay. So you used the website to get the 21 lawyer's names to e-mail them direct public records 22 requests before the
Statute changed and changed the 23 procedure for that, correct? 24 A I think it was my right. 25 Q And so when you wanted all records that 144 Fort Lauderdale, Florida
954-755-6401 Daughters Reporting, Inc. 1 were in any way related to any correspondence of 2 Jones Foster on behalf of the Town to or from 3 Martin O'Boyle, you knew that the Town was
involved 4 in a RICO case with Mr. O'Boyle, right? 5 A And me. 6 Q All right. And you knew that the Town had 7 other Federal cases with Mr. O'Boyle that he had 8 brought,
right? 9 A Pardon me. Let me refresh my memory. 10 Q Do you know how many cases Mr. O'Boyle had 11 pending against the Town in May of 2014? 12 A No idea. 13
Q You were aware he was involved in 14 litigation, right? 15 A Yeah, I imagine his firm is involved in a 16 lot of litigation. 17 Q And you knew that Jones Foster
was the 18 attorney involved in that litigation. 19 MS. JOHNSON JAMES: What litigation, 20 Your Honor? 21 BY MR. SWEETAPPLE: 22 Q With Mr. O'Boyle. Litigation
with 23 Mr. O'Boyle. 24 A I'm not sure who makes notices of 25 appearances on those cases. 145 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q Well,
when you asked for any and 2 all -- all records in any way related to any 3 correspondence of Jones Foster on behalf of the Town 4 to or from Martin O'Boyle, you knew that that 5 involved
numerous records that might have to be 6 redacted for lawyer/client privilege, didn't you? 7 A I'm not sure what the job of the custodian 8 of records for Jones Foster is, but
I imagine if 9 there was anything that was supposed to be exempt, 10 it would get redacted. 11 Q And you've asked for legal bills before, 12 haven't you, from the Town? 13
A We talked about that yesterday. Sure. 14 Q Right. 15 THE COURT: I'm sorry. We have to combine 16 or make sure that all the evidence in this case 17
is in this case. We're not accepting material 18 from the other trial. 19 BY MR. SWEETAPPLE: 20 Q Thank you. 21 You've requested public records of 22 bills
of my firm haven't you? 23 A Your firm, Mr. Richmond, Jerry Richmond's 24 firm, Randolph's firm, yeah, any of those public 25 records. 146 Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc. 1 Q And you're aware that there's -- that 2 those bills typically are redacted to remove 3 lawyer/client or work product, right? 4 A No, I think
I've only seen that once when 5 you redacted your bills, and then they were 6 unredacted, for whatever reason, but I don't 7 think -- normally, I don't think those bills have 8 been
redacted. 9 Q And at the time you made this request for 10 any records at the Jones Foster -- any 11 correspondence of Jones Foster on behalf of the 12 Town, two are from Martin
O'Boyle or any records 13 created by Jones Foster and forwarded to 14 Martin O'Boyle, etcetera, how many open requests had 15 you served on the Town that they were working on 16 that
had not been responded to yet? 17 A Oh, I don't know that answer. 18 Q Did you have over 50 requests open at any 19 one time? 20 A I don't know the answer, sir.
21 Q How many times have you not picked up 22 records that have been made available for you? 23 A You know, the Town mentioned once when I 24 made half a dozen requests
for those, because I 25 thought I picked them all up, and the Town has never 147 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 come back to me and said, you didn't
pick these up. 2 So I don't think I've ever not picked up any 3 records. 4 Q Have you ever paid for an estimate? 5 A Oh, many times. Matter of fact, the last 6 time I
paid, they took the money and said, no 7 record. And it didn't come back with any change. 8 They just said, well, you used it all up. Couldn't 9 find it, so c'est la vie. 10 Q
And how much did you pay to have that 11 search done? 12 A I think, that was $57.00 for a record that 13 I gave them the exact date, the exact participants, 14 and it's probably
going to be a future public record 15 complaint. 16 Q And in your request you said, "Created by 17 Jones and Foster and forwarded to Martin O'Boyle." 18 What did you mean forwarded
to Martin O'Boyle? 19 A Let me read the whole thing in its entire 20 context. Which number is that, sir? 21 Q That is -22 THE COURT: 909. 23 BY MR. SWEETAPPLE:
24 Q -- 909. 25 A I think, what I meant was -- in fact, I 148 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 know what I meant was I wanted records
that were 2 created and sent directly to him, or perhaps he was 3 cc'd on them, or a record that had been sent to 4 someone else and then forwarded to him. 5 Q All right. And
not just records of the 6 Town's attorney's, but any records that might have 7 been sent from the Town attorney's to Town 8 employees, correct? 9 A I believe, my intention was
clear here. I 10 wanted anything that was eventually sent to 11 Martin O'Boyle during that time period. 12 Q Well, you said related to any 13 correspondence. You didn't say
just sent. You said 14 anything that's related to any correspondence. That 15 would be if a record -- if a billing record 16 referenced a correspondence, that's related to it, 17
right? 18 A Well, that would be up to the custodian to 19 decide what's reasonable and responsive. 20 Q Well, you've taken the position before 21 that something on a bill
should have been produced 22 because it was related to something that you asked 23 for, haven't you? 24 A I'm not sure I understand the question. 25 Q You've taken the
position -- your 149 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 position, your view of public records is, if you ask 2 for something that's related to any correspondence,
3 that means if it's referenced in any other public 4 record, you're entitled to it. 5 A Well, sir, yesterday I was criticized 6 because I didn't put the word related in it because
7 my complaint was denied, so I think, related is a 8 reasonable word to have inside a record request. 9 Q So if there's correspondence of Jones 10 Foster of one of those 50
lawyers, you also have to 11 look at the bills of all those lawyers to see 12 whether or not bills refer to any correspondence on 13 behalf of the Town to or from Martin O'Boyle, 14
correct? 15 A Well, I guess, with that logic, anything 16 related could mean their birth certificates, their 17 high school grades. I'm not sure where you draw the 18 line on
that, except what a reasonable person would 19 do. 20 Q Well, you said related to any 21 correspondence. So you want notes, memos. You want 22 billing records. You want text
messages. And if 23 you don't get one of those things, then you play 24 gotcha and file suit, right Mr. O'Hare? 25 A No, I never play gotcha, sir. 150 Fort Lauderdale, Florida
954-755-6401 Daughters Reporting, Inc. 1 Q You didn't ask the Town to produce 2 pictures of all bicycles on A1A in the Town's 3 records? 4 A No, I don't recall that. 5
Q Oh, well, it's in the log. You don't 6 recall -7 A Which one is that one? I'd be happy to 8 comment on it. 9 Q Do you -- it's -- I'm going to put the log 10
in evidence. I want to know whether or not you 11 recall it. 12 A No, I never asked for all bicycles. 13 Q Never asked for pictures of bicycles? 14 A I've asked
for pictures of people riding 15 bicycles on A1A, I believe. 16 Q Any pictures of people riding bicycles on 17 A1A? 18 A Yes, I needed that picture in high 19 definition,
which I did not get. I was told it 20 doesn't exist, but, in fact, it was right there on 21 the Town's website the whole time. 22 Q You've seen it on the website, which is 23
why you asked for it. 24 A On the front page. I found that out 25 later. 151 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q Did you file suit over
that? 2 A Yes, I did. 3 Q So then after you made your request on 4 5-14, you didn't stop. Let's look at the next page 5 here. Let's look at page 39. On April -- on
May 6 18th, we have numbers 915, 916, 917, 918, 919, 920, 7 921, all on page 39 from Irnataway, correct? 8 A No, this is from me. 9 Q Right, but you used -- you used her
name? 10 A That's the name of the gmail account. 11 Q And then when you turn to the next page on 12 May 23rd, you file on behalf of Irnataway at number 13 922. And then
the -- and then from 923 through 932, 14 you use filefolder@records@gmail.com, correct? 15 A That's what this says. 16 Q So you wanted those Jones Foster records 17 immediately,
but as soon as you filed the request 18 that you're litigating over in this case, you 19 barrage the Town on May 27th with all of the 20 requests that are on page 40, correct? 21
A No, I didn't barrage anybody. 22 Q You made those requests didn't you? 23 A I made requests on those dates. I'm not 24 sure how accurate this log is. And if I
might add, 25 this was an early attempt of mine to keep my 152 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 requests organized so the responses came back from a
2 particular account. It was the only purpose at all 3 in creating all these accounts, so it's not to be 4 confused. 5 Q Well, let's go to page 42. Two weeks 6 after you make
the request on June 4, you barrage 7 the Town with requests 944, 945, 946, 947, 948, 949, 8 950, 951, 952, 953, 954, 955, 956, 957 and 958 in 9 the name of file folder. And then you
-- is that 10 correct? I'll break it down. That's just June 4. 11 A That's Filefolderrecord@gmail.com. 12 Q That's you, right? 13 A That is one of my e-mail accounts.
14 Q And then on May 18th, this applied where 15 it is in the log, that's you using your name. 960 16 is you using your name. And then on June 6th, two 17 days after the June
4th barrage, you start another 18 barrage in the name of Irnataway at 961. Then we 19 turn to page 42, 962, 963, 964, 965, 966. That's 20 you, right? 21 A Well, I don't consider
those a barrage, 22 but those look like my e-mail accounts. 23 Q And also on 6-6, you at 969, number 969, 24 filed using your name, and number 970, you filed 25 using your name,
correct? 153 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A That's what it says on this document, if 2 it's accurate. 3 Q And then on 6-11, let's
turn to 4 four -- page 44. And you saw the bills for Jones 5 Foster on the -- you saw some Jones Foster bills on 6 the web, right? 7 A They seem to come and go. 8 Q Right.
You've seen them though? 9 A I'm trying to recall. I can't testify to 10 that. I don't recall. 11 Q Do you remember seeing how much the Town 12 was spending with Jones
Foster in May of 2014 13 dealing with public records requests? 14 A May, 2014. I don't know on that date if I 15 saw those bills. 16 Q But those bills -- those bills,
did you 17 ever look at the bills and take pleasure in how much 18 you were costing the Town in dealing with your 19 activities? 20 A No, I've already told the Town on numerous
21 occasions that I found those costs intolerable, and 22 I hated the fact that the Town was spending all that 23 money. And I've hated the fact that I was spending 24 all that money.
I just want to get the record and 25 the Town dug in its heals. I had no control over 154 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 that, but I just had to
let this follow its course, 2 and hopefully get before a judge some day. And 3 believe me, if this could have come to trial years 4 ago, if it was up to me, we -- this would have been
5 old history. 6 Q Let's turn to page -7 THE COURT: Mark your spot. We're going 8 to take a break and go to lunch. I'm going to 9 give you a little time today,
since we cut you 10 short yesterday. So we will continue at 1:30 11 and we will continue the testimony at that 12 time. All right. 13 (A break was taken at this
time.) 14 THE COURT: You may continue with your 15 examination, sir. 16 BY MR. SWEETAPPLE: 17 Q Thank you, Your Honor. May it please the 18 Court. 19
Mr. O'Hare, if I could get you to go 20 back to page 38, so I can discuss -21 A I'm sorry. I don't think your microphone 22 is on. 23 Q Pardon? 24 A I don't
think your microphone is on. I 25 can't hear you. 155 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q You can't hear me? 2 A Yeah, I can hear that.
Thank you. 3 Q Do you have the exhibit in front of you 4 still? 5 A No, I do not. 6 Q Do you know where it is? 7 A I gave it to the Clerk. 8 Q Thank
you. Is there any objection to 9 moving this in through this witness, or do I have to 10 wait until -11 MS. JOHNSON JAMES: Yes, Your Honor. I do 12 object because this
is not the -13 MR. SWEETAPPLE: I'm going to move it -14 MS. JOHNSON JAMES: -- website. 15 MR. SWEETAPPLE: I won't move it in now 16 then. 17
THE COURT: All right. 18 MR. SWEETAPPLE: All right. Can you turn 19 to page 38? 20 THE COURT: Just so you know, Counsel, 21 we'll need to brake at 2:30
and we'll reconvene 22 on Monday. 23 MR. SWEETAPPLE: Okay. I'm going to try 24 to wrap up in ten minutes, five minutes, and 25 then - 156 Fort Lauderdale, Florida
954-755-6401 Daughters Reporting, Inc. 1 THE COURT: Yes, ma'am. 2 MS. JOHNSON JAMES: Your Honor, I will be 3 out of town. 4 THE COURT: Actually, no,
you'll be here 5 in trial. 6 MS. JOHNSON JAMES: We were scheduled, 7 Your Honor, from December 7th to December 8th 8 at 1 o'clock. I have commitments in 9
Washington, New York and Boston for the next -10 THE COURT: I suggest that at the break, 11 you make arrangements. We will continue this 12 trial at 1 o'clock on
Monday. We will finish 13 this case. I'm not leaving this case for 14 another judge to have to deal with. I've 15 rearranged my schedule to be available Monday 16
afternoon, so everyone else will be available 17 here. 18 MR. SWEETAPPLE: Mr. O'Hare -- may I 19 proceed? 20 THE COURT: You may proceed. 21 BY MR. SWEETAPPLE:
22 Q Thank you. 23 Mr. O'Hare, do you see that on 24 February 14th, the day of the request that's at 25 issue in this case, in request number 905, can you 157 Fort
Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 look at that? 2 A Would you mind telling me the page again? 3 Q Yes, 38. 4 A Okay. I'm on page 38,
sir. 5 Q 905, do you see that, sir? 6 A Yes, I do, sir. 7 Q Okay. "Provide all public records related 8 to, concerning, reflecting, mentioning or referring 9 to
any dredging authorized by, performed by, or paid 10 for by the Town of Gulf Stream, its agents, 11 employees, contractors or associates from May 1, 12 2004 until the date of this request."
Do you see 13 that? 14 A Well, that's not what it says. 15 Q What did I miss? 16 A It says, "Lawsuits, 7-10-14" after that. 17 Q Well, that wasn't part
of the request. 18 That just shows there was a lawsuit filed. 19 A I have no idea what that is. You just 20 asked me if that's what it says. I'm telling you it 21 says what
you wrote, plus it says, "Lawsuit 22 7-10-14." 23 Q Are you aware that the part before it says 24 lawsuit, it says the actual request, and I'm asking 25 you about the request.
Do you see that request? 158 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A I understand you're asking me about the 2 request. 3 Q Okay. That was
for a period of 10 years, 4 was it not? 5 A 2004 to 2014. Four from 14 is -- yeah, I 6 think you're right. That's 10 years. 7 Q And you wanted records, not only of the
8 Town, but any of its contractors, anyone that was 9 associated with, employees or agents for that whole 10 10 year period, right? 11 A That's what it says, yes. 12 Q
And you ended up filing a lawsuit on July 13 10th concerning that request, right? 14 A No, I don't think so. 15 Q Well, it says lawsuit 7-10-14. 16 A Well, if
you're asking me to interpret 17 what the Town intended when they wrote that, since I 18 didn't write that, I believe, that relates to the 19 lawsuit against me for parking my boat
behind the 20 mayor's house on navigable water, which the Town 21 says is open to all residents except me. 22 Q Huh-huh. So you didn't file a lawsuit on 23 that date? 24
A I believe, I answered that question. 25 Q Okay. And the -- and wasn't 7-10 the date 159 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 that you filed
-- 7-7 the date you filed the lawsuit 2 in this case? 3 A No, it wasn't. It was not the date I 4 filed this lawsuit. 5 Q What date did you file this lawsuit? 6 A
I believe, it was July 1, 2014. 7 Q And served on the 7th, right? 8 A I don't recall that. 9 Q You filed it on the 1st, but it was served 10 on the 7th. I want
you to look at number 909, and 11 you see where after the request, the clerk has 12 written lawsuit 7-7-14 because that's the date the 13 lawsuit was served? Are you aware of that?
14 A I'm sorry. I'm still confused. Are you 15 testifying it was served on the 7th, or asking me if 16 it was served on the 7th? 17 Q It's a matter of record that the
lawsuit 18 is in the Court file, so if -19 THE COURT: Actually, no it's not. We 20 didn't -- I didn't take judicial record 21 of -- or judicial notice of any other
lawsuits. 22 MR. SWEETAPPLE: No, this lawsuit. I'm on 23 this lawsuit. 24 THE COURT: Okay. If you want to ask him 25 if he knows, please do, but - 160
Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 BY MR. SWEETAPPLE: 2 Q I will. 909 is this lawsuit, Mr. O'Hare. 3 Do you see that? The lawsuit that emanated
from 4 this lawsuit -- from this request. Do you see 909? 5 A You're referring to a request that the 6 Town numbered 909? 7 Q Yes, sir. And you see it's any -- "It's
8 all records in any way related to any correspondence 9 of Jones Foster." Do you see that? 10 A "All records in any way related to any 11 correspondence of Jones Foster on
behalf of the Town 12 to or from Martin O'Boyle." Are you talking about 13 that request? 14 Q Are you aware that's the request we're 15 here in Court on today? 16 A Well,
of course I am. 17 Q And do you see at the bottom it says, 18 "Lawsuit 7-7-14." Are you aware that that's because 19 that's the date the clerk of Gulf Stream obtained a 20 copy
of the lawsuit you filed? 21 A So you say. I don't know that. I know 22 that my lawsuit was filed on July 1st. 23 Q Do you know what day it was served on the 24 Town?
25 A No. 161 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 MS. JOHNSON JAMES: Your Honor, I object 2 because this is cumulative. We've stipulated
3 that the Town was served on July 7, 2014. 4 THE COURT: Is that a stipulation? If so, 5 it's cumulative. 6 And we'll make arrangements to allow you 7
to go to DC on Monday. What I'll have you do, 8 can you be at calendar call next Friday? I'll 9 work you in my calendar. 10 MS. JOHNSON JAMES: Thank you, sir.
11 THE COURT: Absolutely. I'm sorry. I 12 thought I had mentioned earlier today that we 13 would continue on Monday if we didn't finish 14 today. 15
MS. JOHNSON JAMES: I made these plans 16 weeks ago. 17 THE COURT: You'll get to go. 18 MS. JOHNSON JAMES: Thank you. 19 THE COURT: You'll get to
go. Absolutely. 20 We'll make arrangements to -- can either you or 21 someone be at calendar call not tomorrow, but a 22 week from tomorrow -23 MS. JOHNSON JAMES:
Yes, sir. I return on 24 Thursday. I'll be there -- be here. Thank 25 you, sir. 162 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 THE COURT:
We'll work -- absolutely. I 2 apologize for the interruption, but I didn't 3 want that weighing on you. 4 MS. JOHNSON JAMES: Did you see -5 THE COURT:
I didn't want that weighing on 6 your mind. We'll get it so we have enough time 7 then we'll work it out. 8 MS. JOHNSON JAMES: Thank you very much, 9 sir. 10
BY MR. SWEETAPPLE: 11 Q So seeing the 7-7-14 at number 909 doesn't 12 refresh your recollection that as to -- as to 905 13 that the reference to lawsuit is actually a lawsuit
14 you served on 7-10-14? 15 A I didn't -- I didn't serve a lawsuit on 16 7-10-14. 17 Q Okay. So you don't -- your testimony is 18 you didn't file a lawsuit with regard
to request 19 number 905 against the Town? 20 A Of course not. I already testified I 21 filed a lawsuit regarding the copy of the request, 22 which is indicated on this page.
23 Q It's your testimony that you didn't file a 24 lawsuit in regards to number 906? 25 A 906. I believe, because I don't know -- I 163 Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc. 1 didn't create this document, but I believe, what 2 they're referencing here is the lawsuit in 3 Judge Gillen's courtroom for my trespassing 4 supposedly
on navigable waters in the Town of Gulf 5 Stream. 6 Q And number 907, you didn't file a lawsuit 7 with regard to that request? 8 A I can't comment on it because I don't
9 remember. 10 Q And the next one, 908, you didn't file a 11 lawsuit with regard to that request? 12 A Again, I'd have to refer to the lawsuits. 13 I don't recall the
exact language. 14 Q Okay. And so in 906, you asked for 1.5 15 years worth of records, right? 16 A Pardon me while I read this. 17 Q You want it from January 1,
2012. And you 18 wanted all communications between the Palazzo Sole 19 Homeowner's Association (phonetic) or its agents the 20 Town of Gulf Stream. It's agents or employees. 21
A No, this is January 1, 2013 through to the 22 date you receive this request. 23 Q Which was July 14, 2014, right? 24 A Well, that's what it says here. 25 Q
Right. And the next request - 164 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A No, it doesn't. It says May 14, 2014. 2 Q And the next request
is you want 3 two-and-a-half years worth of records. 4 A The next being 907, sir? 5 Q And that was for all communications 6 between the Little Club or its agents and the
Town 7 of Gulf Stream, its agents or employees. Who are 8 the agents of the Little Club? 9 MS. JOHNSON JAMES: Relevance, Your Honor. 10 THE COURT: Overruled. 11
THE WITNESS: I'm sorry. I'm still 12 reading this to understand your question. 13 BY MR. SWEETAPPLE: 14 Q Who are the agents of the Little Club? 15 A Well,
can you define what you mean by 16 agents, or do you want me to tell you what I meant 17 by agents? 18 Q I want to know who they are. Do you know 19 who they are? 20 A
Anyone associated with the club. 21 Q Any member? 22 A Whoever runs the Little Club would be an 23 agent of the club. 24 Q Just running it? Working there? Is
that 25 an agent? 165 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A Well, that's something if the custodian of 2 records was unclear of, she had an obligation,
I 3 believe, to ask me what I meant. 4 Q And the Town of Gulf Stream, its agents, 5 who do you mean as agents of the Town of Gulf 6 Stream? Anybody that does work for them?
7 A I use the word agent the way it's normally 8 understood to me. Someone who acts or works on 9 their behalf. Someone who produces something that 10 would be, by legislative
definition, a public 11 record. 12 Q And then number 910, you asked for 13 two-and-a-half years worth of records regarding 14 testing and maintenance of all police firearms,
15 radar guns and defibrillators for the period of 16 January 1, 2012 to the date you received the 17 request, right? 18 A I'm sorry. Which number is that? 19 Q 910.
20 A Yeah, from January 1, 2012 until the date 21 of the request, yes. 22 Q And then the next one, that day, the same 23 day as the request in this case, is for all public
24 records regarding the testing, maintenance, 25 recharging, replacing or purchasing of fire 166 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 extinguishers on
the Town property. 2 A That's what it says here. 3 Q So you weren't just asking for one 4 document in these requests, were you? 5 A Each of these is a single request.
6 Q Right. But you were asking for detailed 7 searches in your request that you filed. 8 A I'm trying to be as accurate and thorough 9 as possible. I have no idea what
responsive records 10 there might be. If there's one record or a thousand 11 records, I don't know. 12 Q Okay. I'd like to finish up through July 13 7, when you received the
letter from the Town. 14 Let's go back to page 44, which is where, I believe, 15 we were when we broke. On page 44, the requests 980 16 through 987 are all you, right? 17 A
Those are all identifying a e-mail address 18 that I used. 19 Q Right. And then on page 45, that's you, 20 988 through 992, correct? 21 A Again, that's an e-mail address
I've used 22 what's on this page. 23 Q And what about 995, is that a e-mail 24 address you've used, Bojuro@gmail.com? 25 A Bojuro as -- yeah, that looks familiar. 167
Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 That's one of mine, at least as I recall today. 2 Q And then let's go to page 45, you see 3 Bojuro again. And
then there's Hagenp.waterstop. 4 That's you also isn't it? 5 A I'm sorry. What's the number? 6 Q 1006. 7 THE COURT: That's Bojuro. 8 BY MR. SWEETAPPLE: 9
Q Oh, I'm sorry, Your Honor. 1008. 10 1007 is the first one. 11 A Yes, that looks familiar, as far as an 12 e-mail address. I'd have to examine the record
if 13 you're asking me if those are my requests. 14 Q What about Jordanmentor, is that a name 15 you used also? 16 A Yeah, I think so. 17 Q And the next page, which
is 47, Buffyhowl, 18 you, right? 19 A Page 47. Let's see. Buffyhowl. 20 Q 1017. 21 A Oh, Buffyhowl@gmail.com. Yeah, I made 22 that up. 23 Q Right. And
then we have Jordanmentor. 24 Again, that's you. 25 A That's one of my inventions, yes. 168 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q And then
Freddiefarnsworth, those are all 2 you, right? 3 A Frederick.freddie.farnsworth@gmail.com. 4 That's one of mine. 5 Q So on page 47, all those requests were 6 yours except
for 1016, which was Mr. O'Boyle, right? 7 A On page 47, I see Jordanmentor repeatedly 8 and Freddie -- Frederickfreddiefarnsworth and 9 Buffyhowl. I don't see any O'Boyle. 10
Q Well, the one up top is records, it says 11 Martin -12 A Oh, Commerce Group. It says it's 13 Martin E. O'Boyle. I don't know if that's true or 14 not. 15 Q
Okay. So everything on the page other 16 than 1016 is you, right? 17 A That's an e-mail address that I've used. 18 Q Right. And number 1028 you asked for any 19 records
of itemized billing from any law firm 20 providing services to the Town for the time period 21 from January 1, 2014 to the date you receive this 22 request, right? 23 A That's
what it says here. 24 Q And did you get those? 25 A I'd have to go back and look. I don't 169 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 recall.
I mean, I don't have anything to reference 2 to, and I don't remember right now. 3 Q Next page, 48, we're still on June 22nd. 4 And you're using -- you have 1031, 1032, 1035,
1036, 5 1037, 1038, 1039 and 1040 that you also provided on 6 6-22, correct? 7 A Those numbers correspond to 8 Frederickfreddiefarnsworth@gmail. I can't attest to 9 the accuracy
of this document though. 10 Q And you're also Gillgladstone, right? 11 A I'm sorry. I'm not Gillgladstone. What 12 are you talking about? 13 Q That's a name you
used, synonym you used? 14 A I don't know which page you're on. 15 Q I'm on page 50. 16 A Let me see, Commerce Group. Oh, I see 17 down here at the bottom. Yeah,
that's a name I 18 created. 19 Q All right. And so from 1069 -- number 20 1069 on June 25, 2014, you continued to use that 21 name one, two, three, four, five, six, seven, eight,
22 nine, nine times on the 25th of June, right? 23 A Yeah, that's pretty typical. I've used 24 these other accounts for about ten requests each. 25 Q Okay. And then
on 6-27, you made 170 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 requests -- a request in just a 2 Chrisoharegulfstream, correct? That's number 1077? 3 A
Number 1077. It says 4 Chrisoharegulfstream@gmail.com. That's one of 5 my -- that's the one I use the most, the account 6 used the most. 7 Q And then let's go to page 52.
Do you also 8 use the gmail address and name Kimbadwestra? 9 A Yep, that's one of my creations. 10 Q Is Kimbadwestra a real person, or just a 11 pseudonym? 12 A
I just saw the Lion King. I think, it was 13 that movie. 14 Q All right. And so on the 28th of June, 15 you filed one, two, three, four, five, six, seven, 16 eight requests
in the name of the Lion King figure? 17 A Well, yeah, that was my average, about 18 eight or ten per alias file. 19 Q Meanwhile, on the next page, Commerce 20 Group on
the 27th and 29th is filing requests 1103 21 to 1118, correct? 22 A Well, I see the e-mail address on this 23 piece of paper, but I don't know what they do. 24 Q And then
when you go to 54, number 1125, 25 we pick up Freddiefarnsworth, 1126, Chrisohare, 171 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 1127, Freddiefarnsworth. And
then we have another 2 alias you used, Jimbroom, right? 3 A Yeah, I recall creating that one. 4 Q And you make eight requests in the name of 5 Jimbroom on July 3rd. 6
A Yep, like I said, that was typically the 7 number I would use per gmail account, eight or ten. 8 Q And did it occur to -- did you have a 9 sense that the clerk of Gulf
Stream was behind in 10 keeping up with all of these public records requests 11 when you went on-line, for instance, and reviewed 12 their progress? 13 A When you say "behind,"
do you mean do I 14 think there was inadequate manpower put to the task? 15 I'd say yes. 16 Q So you thought they were taking too long 17 to respond to you? 18 A No, I
thought they weren't allocating 19 sufficient revenues and resources to fulfill their 20 obligations by State Statute. 21 Q And did you ever tell the Town that? 22 A I'm
sorry. I didn't hear that. 23 Q Did you ever tell anyone at the Town that? 24 A At the Town? Oh, yeah. As a matter of 25 fact, numerous times. 172 Fort Lauderdale,
Florida 954-755-6401 Daughters Reporting, Inc. 1 Q So how many employees in the Town were 2 employed in May of 2014 at the Town Hall? 3 A I don't know. 4 Q Well,
you thought it was inadequate, 5 right, the number? 6 A I was judging by the response. 7 Q How many of the employees in the Town were 8 actually working on responding
to these public 9 records requests? 10 A Not enough, in my opinion. 11 Q So you don't know how many were there and 12 how many were working, but you weren't getting your
13 records fast enough? 14 A I think, 16 months in some cases and in 15 some cases two years is too long to wait. 16 Q So which request did you wait two years 17 for?
18 A Oh, I couldn't tell you now from memory. 19 I just know I have some I've asked for over and over 20 and over and it's been two years, sometimes not at 21 all. 22 Q
So you've had some two years and some 16 23 months? 24 A Yes. 25 Q So these were documents that you remember 173 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting,
Inc. 1 because they were very important and you had to wait 2 so long for them, right? 3 A Well, I can recall composing e-mails 4 saying it's been 16 months. This is the third
time 5 I've asked, can I ask again? Will I hear from you 6 soon? Things to that nature. 7 Q So these must have been documents you 8 deemed important, right, Mr. O'Hare? 9
A They are all important. 10 Q Can you tell the Court one of these 11 documents that -- the specifics of one of these 12 requests that you say you waited two years for?
13 A Well, they are all important to me. Do 14 you want me to put them in prioritized order, or 15 just one at all? 16 Q Just name, under oath, one request that 17 you're
going to testify under oath was sent to the 18 Town and you waited two years for and had to send 19 multiple e-mails about. What was the document you 20 were requesting? 21 A
I wanted the hard drive used by the police 22 officer who trespassed into my house, because he 23 filed, in my opinion, and I'm sure of this, a police 24 report about it that was
fictitious, had fraudulent 25 information on it. I wanted to get to the bottom of 174 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 it. I still have not gotten
that hard drive, even 2 though I've got a spoliation letter in regard to 3 that thing. I'm waiting still. That's probably the 4 most important one. 5 Q So has anyone told you
there is a hard 6 drive? 7 A Of course there's a hard drive. You don't 8 have a computer without a hard drive. I don't know 9 what planet you're -- I'm sorry. Forgive me.
I'm 10 losing my temper. I don't know of a computer 11 without a hard drive. I assume there's a hard 12 drive. 13 Q So you asked for the hard drive? Do you 14 have that request?
15 A Oh, yes. Multiple times. 16 Q When was that request filed? 17 A Filed? You mean sent to the Town? 18 Q Yes. 19 A I can't give you the date.
There were 20 multiple occasions. The earliest one was probably 21 in 2012. 22 Q Okay. And have you filed -- and of your 23 two dozen lawsuits that you've filed, have you
filed 24 suit with regard to that? 25 A Not yet. 175 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q And the first request was 2012? 2 A There
abouts. Soon after all this stuff 3 started happening. 4 Q And what other documents do you claim that 5 the Town hasn't given you? 6 A You have me at a disadvantage.
If I had 7 access to my computer I could spit them all out, but 8 right now with everything I'm thinking about, I 9 can't recall. 10 Q But I'm sure these -- you spend a lot
of 11 your time doing this, Mr. O'Hare, I'm sure these are 12 documents that are very important to you. Can you 13 just tell us one other document that you've 14 requested and you
say you haven't received? 15 A Yes. 16 Q What would that be? 17 A The Town attorney sent an e-mail to the 18 Town manager saying here's all the records I've 19
gotten from Mr. Roeder regarding 20 Mr -- Officer Ginsberg (phonetic). Please, forward 21 it to Chief Ward so that he can conduct his 22 investigation. I asked for records regarding
that 23 investigation. Haven't gotten squat. 24 Q So you've asked for records 25 regarding -- do you keep track on your computer of 176 Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc. 1 requests you've made and the responses? 2 A Well, they're all on my gmail accounts. 3 Q But do you keep a log of what responses 4 you've gotten
or not gotten? 5 A Well, gmail has certain aspects to it 6 where you can label requests, archive them, tag them 7 this way or that, organize them in different ways, 8 and, I
believe, I have labels on some that tell me 9 I'm still waiting, tell me the record was refused, 10 the record doesn't exit, pay us a bunch of money and 11 you'll get it. I usually
label the accounts that 12 way so then when I need to go back, I just do a 13 search for that topic and it will all pop up. 14 Q And these records that you say about the 15 investigation,
you filed a formal public records 16 request? 17 A Well, they are all formal, yes. 18 Q And did you get a response? 19 A Yeah, typically, within a few days to a
20 week I would get a form letter saying we're working 21 on it. It used to say in the next three days we'll 22 get back to you with either the record or an 23 estimate. Now, I think,
it says we'll get back to 24 you when we get back to you, or something like that. 25 177 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q It says that we're
experiencing an 2 inordinate amount of public records requests, right? 3 A I'm sorry. I didn't hear you. 4 Q Doesn't it make reference to an inordinate 5 number of public
records requests the Town is 6 processing? 7 A No, I didn't reference that at all in my 8 e-mails. 9 Q No, but doesn't the Town reference that in 10 its letter to you
in this case? 11 A No, they would say we're -- maybe we're 12 experiencing an overload. It's always the same 13 language, but it doesn't reference my request. It 14 just says
in general, I think. 15 Q So with regard to these records with the 16 investigation, have you -- when did you make 17 those -- that request? 18 A I think, I already testified
to that. 19 Around the end of 2012. 20 Q Okay. We're in the end of 2016. Have you 21 filed suit on that? 22 A No, ever since the RICO, I've been so 23 preoccupied that
I haven't filed any suits. So 24 basically, those are all being held for further 25 consideration. 178 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q And
with regard to the Town's -- so your 2 position is the Town is just not staffed adequately 3 to respond to the requests it should be responding 4 to, is that your position? 5 A
Well, that's my opinion on one aspect of 6 the entire situation. 7 Q And you're still filing public records 8 requests regularly, aren't you? 9 A Not regularly, but
often. And there still 10 are records I'd like to see. I'd like to find out 11 why I was charged $3,000.00 for whatever wasn't 12 used, and it took months and months and months for
13 the Town to finally say, oh, woops, sorry, our 14 fault. Never got a record on that yet. But I don't 15 think more than two months has gone by, so I'm 16 giving the Town more time
to respond. 17 Q So your position is the Town -- the Town 18 just needs more staff to deal with these request? 19 A It's one of the richest towns in the 20 Country. I've
asked numerous times at commission 21 meetings, and even in depositions of Chief Ward, 22 Bill Thrasher, the Manager, I said, is anyone 23 telling you not to spend this money? Does
anybody 24 tell you hold back, we don't have the money? So 25 yes, I've made it known quite often that I think the 179 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc.
1 Town should be hiring enough people to meet their 2 legislative responsibilities. 3 Q And do you recognize that your conduct, 4 and the conduct of Mr. Roeder, and Jonathan
O'Boyle, 5 and Martin O'Boyle is interfering with the ability 6 of the Town to timely respond to public records 7 requests? 8 A No, absolutely not. Why would it? 9
MR. SWEETAPPLE: No further questions. 10 THE COURT: Redirect? 11 REDIRECT EXAMINATION 12 MS. JOHNSON JAMES: May I approach, 13 Your Honor? 14
THE COURT: Certainly. You may freely 15 approach. 16 BY MS. JOHNSON JAMES: 17 Q Thank you. 18 Mr. O'Hare -19 A Yes, ma'am. 20 Q --
I'm going to show you a document that 21 we've marked as Plaintiff's Exhibit 5. 22 THE CLERK: You need the next one? 23 MS. JOHNSON JAMES: Yes, please. 24 Plaintiff's
Exhibit 4. Thank you, ma'am. 25 THE CLERK: You're welcome. 180 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 BY MS. JOHNSON JAMES: 2 Q It is --
and I'm going to ask you if you 3 can identify this for the Court? 4 This would be one page for your 5 Exhibit 3. 6 Can you -- I've got to go back. And
7 Your Honor, I'll give you one just so you can follow 8 along. 9 MS. O'CONNOR: That's not our exhibit. 10 MS. JOHNSON JAMES: Isn't your -- your 11 Exhibit 3
is the web -- the web? 12 MS. O'CONNOR: I don't think we did. 13 MS. JOHNSON JAMES: If you look on the 14 pretrial stipulation, 2014 public records log 15
available on the website. Yes? 16 MS. O'CONNOR: It's listed. Huh-huh. 17 MS. JOHNSON JAMES: Yes, thank you. 18 Excuse me. You might want to -19
MS. O'CONNOR: Exhibit 4, 2014? 20 MS. JOHNSON JAMES: 2014, yes, ma'am. 21 THE COURT: Okay. Thank you so much. 22 MS. JOHNSON JAMES: You're welcome,
sir. 23 THE COURT: How has this been marked for 24 ID? 25 MS. JOHNSON JAMES: Number 4, sir. 181 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc.
1 THE COURT: Plaintiff's 4 for ID. Okay. 2 Very good. 3 BY MS. JOHNSON JAMES: 4 Q Can you tell the Court what that is, 5 please, Mr. O'Hare? 6 A Yes. This
looks like a replica or a 7 printed page from the Town's on-line website where 8 they keep the public records request log, which is 9 the title at the top. 10 Q Okay. And this
particular page, if you 11 look down at item 909. 12 A Well, it's really tiny. 13 Q I know. Do you want me to read it to you? 14 A Yeah, because I can't -15
Q Okay. "909 date requested is May 14, 16 2014, received by Rita Taylor, requester 17 Review.content.apply respond to 18 Review.content.apply@gmail.com," and then under the 19
public records requested it says, "Public records 20 request Jones+Foster-Oboyle." Under public records 21 requested it says, "All records in any way related 22 to any correspondence
of Jones+Foster on behalf of 23 the Town to or from Martin O'Boyle or any record 24 created by Jones+Foster and forwarded to Martin 25 O'Boyle, which was created or received during
the 182 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 period of time from March 1, 2014 through to the 2 moment you receive this request. 3 "Records
requested include, but are 4 not limited to notes, memos, letters, e-mails, phone 5 logs, phone messages, photos, files, folders, 6 labels, sketches, drawings, layouts, client's 7 invoices,
statements, reports, correspondence," I'm 8 not going to read the whole thing, but do you 9 recognize that as the request you made in this case? 10 A Yes, I do. 11 Q Okay.
And then at the end it says, 12 "Lawsuit 7-7-14?" 13 A That's what it says. 14 Q And then under date of intake it says, 15 "May 16, 2014." Under date of estimate it
says, 16 "7-7-2014." Then the next column says, 17 "Administratively closed, 12-15-14." And then under 18 the last column it says, "Notes (due deposit 19 reinstated)." No, "(Deposit
requested)." I'm 20 sorry. And then -21 MR. SWEETAPPLE: Where are you reading 22 from? 23 BY MS. JOHNSON JAMES: 24 Q "(Unpaid and debt)." And under that 25 column
for 909 it says, "Given to Jones Foster May 183 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 15, 2014, alias for O'Hare." 2 A I'm sorry. Did you say date
of intake 3 5-16-2014? 4 Q That's what it says, date of intake, 5-16. 5 A Well, and then given to Jones Foster the 6 day before on 5-15. May I see that? 7 Q Yes.
So is this a page from the website 8 that we downloaded together? 9 A Yes. 10 Q Okay. I would move for the admission of 11 our Exhibit 4. 12 THE COURT: Any
objection? 13 MR. SWEETAPPLE: Your Honor, the 14 objection, the document says it was 15 acknowledged on the 16th. It shows it was 16 intake on the 14th, and given
to Jones Foster 17 on the 15th. I don't think she's accurately 18 characterized it. 19 THE COURT: Okay. Well, I understand you 20 may argue about what it says,
but do you have 21 an objection to -22 MR. SWEETAPPLE: No, no. No objection, 23 Your Honor. 24 THE COURT: Okay. Then Plaintiff's 25 Exhibit 4 for ID
is hereby admitted into 184 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 evidence without objection. 2 (Plaintiff's Exhibit Number 4 entered into 3
evidence.) 4 BY MS. JOHNSON JAMES: 5 Q Mr. O'Hare, during cross-examination, you 6 were asked whether you and Martin O'Boyle had ever 7 been at Town Hall at the
same time or made requests 8 on the same day. Do you remember that testimony? 9 A Yes, I do. 10 Q Did you ever consult with Martin O'Boyle 11 or and agree to go to Town
Hall at the same time to 12 make public records requests? 13 A No, that never happened. 14 Q Did you ever consult with Jonathan O'Boyle 15 and agree to deluge -- no, no.
Did I say 16 Martin O'Boyle or John O'Boyle? 17 MR. SWEETAPPLE: You said Jonathan. 18 MS. JOHNSON JAMES: I'm sorry. Did you -19 THE COURT: Go ahead and
strike and 20 restate that. 21 BY MS. JOHNSON JAMES: 22 Q Yes, I'm going to. I just wanted to be 23 sure I was in the right place. Thank you, sir. 24 Did
you ever agree with 25 Martin O'Boyle to deluge the Town of Gulf Stream 185 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 with public records? 2 A Absolutely
not. 3 Q Have you conspired with anybody to 4 disadvantage the Town of Gulf Stream? 5 A Never. 6 MS. JOHNSON JAMES: I have no further 7 questions. 8
THE COURT: Okay. Thank you for your time 9 and testimony, sir. You may step down and sit 10 with your Counsel. 11 Ms. James, you may call your next witness.
12 MS. JOHNSON JAMES: We rest, Your Honor. 13 THE COURT: Okay. The Plaintiff has 14 rested. We will begin the trial of the 15 Defense's case at our next
congregation. 16 Let's -- let me get on -- so I'll reserve on 17 any ruling or motions that could have been made 18 at the close of the Plaintiff's case today. If 19
any are made, I'll deal with those at the next 20 hearing and then we'll hear the Defense's case. 21 So let me tell you when I need you all to 22 come back and you'll
take priority, since we're 23 in the middle of this trial. I'm not about to 24 tell Ms. James that she can't go to DC. I hope 25 it's something fun. 186 Fort Lauderdale,
Florida 954-755-6401 Daughters Reporting, Inc. 1 MS. JOHNSON JAMES: Several fun things and 2 some work, sir. 3 THE COURT: Good. DC is always a good 4 town.
5 Not this Friday, tomorrow, but, I believe, 6 it's December the 16th -- yeah, it's Friday, 7 December 16th, which is next Friday, at 9:00 8 a.m. we will put you
at the top of our calendar 9 call. Let me get a feel, so we know how much 10 time to allocate on our calendar. In a perfect 11 world, how much time would you all like
to 12 present the remainder of the case, including 13 your legal arguments? And this will also give 14 you time to bring any closings you want to do, 15 if you want
to do a written closing, but I'm 16 happy to hear oral closings too, whatever is 17 your preference. 18 Let's start with the Plaintiff. It's 19 your -- well, you
don't know how much they're 20 going to present. You presented your case. 21 You initially said this morning you were 22 going to call one witness. Is that correct?
23 MS. O'CONNOR: We anticipate only one 24 witness. I don't expect she would take more 25 than an hour, including cross-examination. 187 Fort Lauderdale, Florida
954-755-6401 Daughters Reporting, Inc. 1 THE COURT: Can we tell the Plaintiff's 2 Counsel who that witness is, so they can get 3 it -4 MS. O'CONNOR: Kelly
-5 THE COURT: I'm sorry. 6 MS. O'CONNOR: Kelly Avery, the former 7 deputy clerk. 8 THE COURT: Kelly Avery. 9 MS. O'CONNOR: Correct. 10
THE COURT: So you -- I'm sure you've 11 deposed her? 12 MS. JOHNSON JAMES: We have not, but I 13 know who she is -14 THE COURT: Okay. 15
MS. JOHNSON JAMES: -- and I'll certainly 16 be prepared to cross-examine. 17 THE COURT: Okay. And so my question is, 18 they think it's going to be an hour. Knowing
19 who the witness is, do you think you need more 20 than an hour? 21 MS. JOHNSON JAMES: No, sir. Do I need 22 more than an hour, no. 23 THE COURT:
No, but what I think I'll do, 24 just to be safe, is try and find you at least 25 two hours, or close to a half day, because 188 Fort Lauderdale, Florida 954-755-6401 Daughters
Reporting, Inc. 1 we're going to deal with -- if there are any 2 motions, I'm not saying there will be, but if 3 there are motions at the closing of Plaintiff's 4 case,
I've got to deal with those. Take the 5 witness, cross, redirect, then I want to give 6 you all the time you want for your closings. 7 Let me ask now, what do you
think you need 8 for your closing, Ms. James? 9 MS. JOHNSON JAMES: 45 minutes maximum, 10 sir. 11 THE COURT: Okay. What do you think you 12 need for
your closing? 13 MR. SWEETAPPLE: I would think 20 to 30 14 minutes. 15 THE COURT: Okay. So we're looking at 16 probably three hours. We're looking at a
half 17 day. Okay. So we need -18 MR. SWEETAPPLE: -- half day. 19 THE COURT: That's fine. 20 MR. SWEETAPPLE: What is your calendar? I 21 mean,
when is the actual trial period 22 because -23 THE COURT: The trial period actually 24 starts the following week. 25 MR. SWEETAPPLE: I have a mediation in
189 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Boston on the 20th, and I'm leaving for Montana 2 on the 21st. 3 THE COURT: Well, listen, I know
you all 4 have things pre-planned. We all thought this 5 case would be over today. 6 MR. SWEETAPPLE: Right. 7 THE COURT: That's why I'm not requiring 8
us to go on Monday. We thought the case would 9 be over today. It's not. I'm going to work 10 with your calendars, and you're going to have 11 to work with mine.
I've already got stuff 12 set -13 MR. SWEETAPPLE: I understand. 14 THE COURT: -- I'm gone. 15 MR. SWEETAPPLE: When do you rotate out? 16
THE COURT: I rotate out Monday after 17 Martin Luther King's holiday. I think, it's 18 the 17th. 19 MR. SWEETAPPLE: Oh, okay. So it's not -20 THE COURT:
It's not on the -- I'm 21 actually setting trial weeks. I'm setting at 22 least three our four trial weeks. 23 MR. SWEETAPPLE: Okay. 24 THE COURT: And
so I've got to try and 25 find a place to work you in, you know, because 190 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 I don't want to mistry the case,
because then 2 you've got to start from scratch with somebody 3 else and that's going to cost you all 4 unnecessary money, so this will be at the top 5 of my calendar
to get it finished for a half 6 day. What else can I help you with, guide you? 7 You know -- and I know -- I know there are a 8 lot of hard feelings between members of
this 9 Town. It came out today why, I think, some of 10 this maybe motivated. I'm sure you've been 11 sent to mediation before. Some cases have been 12 resolved.
Some cases have not been resolved. 13 The only thing that I can see, if you 14 aren't able to come to a global resolution on 15 this case, given the fact that it sounds
like 16 there are a lot of other cases pending, and to 17 me, it sounds like there are a lot more in the 18 pipeline, and all it is is going to be is a 19 wonderful
annuity for the attorney's on both 20 sides, maybe. I was a mediator long before I 21 was a Judge. I say this in every case. If 22 there's any way you all can work towards
a 23 resolution, a global resolution, that would be 24 in the best interest of everybody involved in 25 this case, as well as, in the Town. I don't 191 Fort Lauderdale,
Florida 954-755-6401 Daughters Reporting, Inc. 1 know that that is possible. It may just 2 require the parties to continue on until they 3 are both exhausted and the Bar
has become 4 wealthy, or not. 5 So we'll finish this one up before I 6 rotate out. The remaining issues as to fees, I 7 don't know that I'm going to be able to
reach 8 those entitlement or amount. All right. Thank 9 you all. Excellent job today. I appreciate 10 it. Have a good and safe trip to DC. 11 MS. JOHNSON JAMES:
Thank you. 12 THE COURT: I'll see you all, not 13 tomorrow, but a week from tomorrow and we'll 14 figure it out. 15 (The proceedings adjourned at 2:15 p.m.)
16 17 18 19 20 21 22 23 24 25 192 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 CERTIFICATE OF REPORTER 2 3 4 THE STATE OF FLORIDA ) 5 COUNTY OF PALM
BEACH ) 6 7 8 I, Laurie Brown, Shorthand Reporter, certify 9 that I was authorized to and did stenographically 10 report the foregoing proceedings, and that the 11 transcript is
a true and complete record of my 12 stenographic notes. 13 Dated this 20th day of December, 2016. 14 15 16 17 18 19 20 21 ___________________________________ 22
Laurie Brown Shorthand Reporter 23 24 25 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc. A a.m13:15 186:8 A1A150:2,15,17 ability 32:21 52:8 179:5 able31:20 44:4 59:13,25 60:6 60:7 63:5 190:14 191:7 abouts175:2 absolutely 27:25 34:13 37:6 52:12,17
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158:18,24 3 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 159:6 162:25 163:1 165:3 166:14 176:8 186:5 Bendicks92:11 92:13 best 97:10 107:7 190:24 better61:14 71:15
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179:14 187:15 CERTIFICATE 192:1 certificates 149:16 certified 18:1 certify 192:8 chance60:9,22 62:5 68:11 107:7 Chandler30:8 66:12,19,21 83:12,13,25 84:6,10,21 85:10 87:21,25 88:3,4,7
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183:2,4 dated 21:18 36:8 73:4,4 137:12 192:13 6 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. dates36:12 45:21 93:24 98:17 151:23 daughter40:13 day 20:21,23 22:18,19
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explain 104:8 explanation 50:11 extension 40:15 extent 26:24 8 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 58:8 extinguishers 166:1 eyeballs67:15 eyes130:11 F faced
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148:4 181:24 Foster14:8 45:8 45:9,11,15,25 46:19 48:2,5 50:8 53:16 56:16 57:11 59:18 81:24 82:3,16,25 143:14 144:2 144:17 145:3,8 146:10,11,13 147:17 149:10 151:16 153:5,5 153:12 160:9
160:11 182:25 183:5,16 found 71:24 107:4 150:24 153:21 Foundation 83:19 130:17 135:21 four22:17 71:20 101:22 105:6 9 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc.
125:4 153:4 158:5 169:21 170:15 189:22 Fourth 31:8 framed 33:22 53:14 Francis68:22 frank62:3 117:24 141:12 frankly65:22,25 fraudulent 173:24 Freda57:2 128:15 Freddie168:8 Freddiefarnsw...
168:1 170:25 171:1 Frederick.fred... 168:3 Frederickfred... 168:8 Frederickfred... 169:8 free52:14 54:25 55:7 61:1 63:8 63:15 84:9 85:8 freely41:6 72:21 179:14 frequently 83:5 112:10
fresher90:25 Friday 43:10 62:10 103:10 161:8 186:5,6 186:7 front 150:24 155:3 fulfill171:19 full58:8 68:20 124:18,20 139:4 fun 185:25 186:1 function 25:12 functioning 58:11 further65:3
79:6 177:24 179:9 185:6 future28:21 29:14 147:14 G game55:25 games55:5 Geeze92:19 general17:12 96:1 140:12 177:14 gentleman 102:21 127:8 Gentlemen 128:16 getting 22:17,19 65:13 77:19
94:18 121:21 172:12 Gill42:7,13 60:15,18,20,25 61:17,22 62:11 62:17,23 63:1 63:4,16 Gillen's163:3 Gillgladstone 169:10,11 Ginsberg 175:20 give18:25 24:9 28:1 42:17,24 56:18 59:25 62:13,15
63:19 78:9 80:18 81:1,2,11,19 84:17 91:4 106:20 109:24 111:21 133:3 154:9 174:19 180:7 186:13 188:5 given 25:14 70:17 77:16 108:13 175:5 182:25 183:5 183:16 190:15 giving 28:20 178:16
glasses130:11 Gleason 91:11 Glen 136:1 global190:14,23 glue65:8 gmail89:15,25 90:1 95:22,24 96:24 115:3,12 116:3,4 117:9 117:10,12,20 118:25 119:8 123:25 131:11 131:12 141:14 151:10
170:8 171:7 176:2,5 go 18:1 20:8 23:17 30:1 32:8,21 33:19 35:4 38:17 39:1 43:3,13 56:17 57:22 60:1 61:11 62:5 63:6,20 65:3,4 70:22 87:8 94:1 95:3 95:23 100:19 100:25 101:3,6 101:9,12
104:10 105:1,1 105:4,5,7,11 108:10 109:20 109:22 113:18 116:19 121:19 124:1,9,17 126:8 129:15 132:25 135:1,8 135:25 138:1 140:9 142:13 142:14,14,15 152:5 153:7 154:8,19 161:7 161:17,19
166:14 167:2 168:25 170:7 170:24 176:12 180:6 184:11 184:19 185:24 189:8 goes22:24 66:12 110:1 going 17:13,17 17:21 18:1,22 21:21 31:20 37:15 39:3,5 41:13,17,25 42:5 43:21,25 50:25
51:8 52:24 53:13 54:6 55:17 56:17,25 57:5 57:7,14,17 58:3,4,6,7,20 59:6,17 61:8 61:12,24 62:21 64:14,16,17,19 64:21,23 66:3 66:19 67:4,22 67:24 68:4 71:1 72:18 74:5,9,20 84:18 85:12,25
86:25 87:8 89:3 93:7 97:14 102:15 111:4,19,19 113:7 116:15 127:10 137:2 140:18 147:14 150:9 154:7,8 155:13,23 173:17 179:20 180:2 182:8 184:22 186:20 186:22 187:18 188:1 189:9,10 190:3,18
191:7 good 25:21,21 44:20 60:22 61:24 63:14,17 63:24 64:24 65:6 66:17 68:20 79:13 181:2 186:3,3 191:10 gotcha 53:22 56:9 149:24,25 gotten 17:9 85:3 121:22 136:18 143:2 174:1 175:19,23
176:4,4 government 54:2 66:2,8 83:9 108:15 governments 66:1 84:1 grab 44:12 grades149:17 granted 30:15 37:11 41:7 great 47:7 57:23 75:11 121:6 Greer48:4 Group 58:25 59:2,7 86:2,4,6
86:21 87:5,15 87:18 113:5,23 114:3,7,10,23 129:17 130:19 131:18 168:12 169:16 170:20 guess140:3 149:15 guidance107:3 guide190:6 Gulf13:6 14:20 14:21 17:4 21:6 28:6 47:18 53:15 57:4
68:3,24 69:16 74:11,22 80:6 81:7 84:10,14,19 85:11,12 88:12 91:19 102:13 106:2 110:10 115:11 116:12 118:20 123:18 125:11 140:5 10 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting,
Inc. 140:16 157:10 160:19 163:4 163:20 164:7 165:4,5 171:9 184:25 185:4 guns165:15 H H 13:12 hac98:14,19 Haffel26:2 Hagenp.water... 167:3 hairs126:2 half146:24 187:25 188:16 188:18
190:5 Hall126:18,24 127:11,21,23 172:2 184:7,11 hand 44:10 handed 19:2 20:25 handful31:21 handle65:23 handling 47:21 Hanna 125:13 happen 41:12 77:22,23 103:3 happened 26:20 29:9 69:19
73:24 94:22 127:16,18,19 136:14 184:13 happening 175:3 happens104:20 109:4,20 happy 33:17 81:12 90:16 91:5 102:11 110:17 134:19 150:7 186:16 hard 52:2 173:21 174:1,5 174:7,8,11,11 174:13
190:8 hardest 128:19 Harry 92:20 hated 153:22,23 head 90:2 headed 103:22 heading 112:13 headphones 68:12 75:12 heads56:5 heals153:25 hear38:20 43:14 56:1 59:17 61:4,25 71:9 75:17 80:4
104:5,9,15 154:25 155:1,2 171:22 173:5 177:3 185:20 186:16 heard 45:4 49:6 104:9 hearing 24:2 43:11 82:20 185:20 hears61:25 Hearsay 82:11 heavy 56:1 held 121:12 177:24 help 62:17 83:21
100:16 190:6 helped 136:11 high 71:14 149:17 150:18 Highway 13:17 143:3 Hillsboro 86:9 86:18 114:12 hire66:16 84:7 hired 66:11,15 66:20 84:6 87:21,25 88:3 88:4 hiring 179:1 history
35:3 154:5 hit 105:1,4,5,6,8 105:11,12,24 hold 17:16 33:21 47:2 178:24 holiday 189:17 holidays83:6,7 Homeowner's 163:19 honest 70:6 Honor18:20 19:12 20:25 22:22 23:21 26:21 27:20 28:10
31:24 33:9 34:12 36:4 44:24 48:11 50:3 51:14 52:6 53:11 54:19 55:10 56:21 60:5,16 61:17 62:11,18 63:2 63:13,16,22 65:22 66:6 68:11 73:14 76:12 79:12,21 86:23,25 97:18 97:21 101:19 102:10
104:3 113:9 120:22 121:17 129:4 142:16 144:20 154:17 155:11 156:2,7 161:1 164:9 167:9 179:13 180:7 183:13,23 185:12 HONORABLE 13:12 hope185:24 hopefully 154:2 hoping 107:8,10 hour61:3
62:18 62:19 112:15 126:5 186:25 187:18,20,22 hours23:9 41:13 83:10,11 108:9 187:25 188:16 house69:22,25 70:4,9 84:13 122:11 134:8 134:10 158:20 173:22 housekeeper 69:25 Huh-huh 20:11
83:16 158:22 180:16 hundred 80:23 102:12 hundreds56:6 59:3,9,10 67:8 82:23 I I-r-n-a-t-a-w-y 118:13 ID180:24 181:1 183:25 idea 56:8 80:14 81:10 144:12 157:19 166:9 ideas47:17 identical26:11
52:4 identified 142:16 identify 49:24 74:12,14,23 76:3 86:12 180:3 identifying 166:17 ignored 71:22 II13:13 III13:12 imagine80:21 144:15 145:8 immediate 108:21 immediately 151:17 impeachment
67:20 important 34:14 108:15 136:17 173:1,8,9,13 174:4 175:12 inaccurate28:13 inadequate 171:14 172:4 inadvertently 23:22 34:16 inappropriate 57:13 include20:3 182:3 includes76:9 including
26:23 66:14 67:20 82:23 110:12 120:18 186:12 186:25 inclusion 35:16 inconvenience 75:21 incorrect 28:17 INDEX15:1 indicated 162:22 indication 20:5 78:17 individual72:2 118:15 individually
143:18 indulgence 39:24 industry 65:25 information 71:24 124:10 173:25 informing 74:19 initially 72:5 186:21 inordinate 177:2 177:4 inquire109:14 inquiries25:18 inside71:14 149:8 insinuate100:1
11 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. instance45:4 55:20 171:11 intake182:14 183:2,4,16 intended 158:17 intent 25:10 36:20 intention 57:22 148:9 intentionally
28:13 interest 69:5,6 69:20 102:11 104:16 190:24 interested 69:10 69:12,15 interfering 179:5 interpret 60:3 158:16 interrogatories 36:13 40:1 interrogatory 21:13,17,24 36:14,24 interruption
55:9 63:19 162:2 intolerable 153:21 introduce19:14 introducing 50:19 invalid 33:18 inventions 167:25 investigation 175:22,23 176:15 177:16 invited 134:9 invoices182:7 involved 40:17
144:3,13,15,18 145:5 190:24 involvement 88:8 involving 30:8 67:17 Irnataway 117:23 118:11 140:1,9,15,21 141:16 151:7 151:12 152:18 Irnataway@g... 140:24 Irnataway@pl... 140:23 issue23:16
25:22 30:1,3 32:16 39:24 41:21 44:24,24 53:13 62:4 73:9 102:14 121:21 142:13 156:25 issued 30:12 34:7,8 issues25:14,15 25:15 40:20 41:1 56:25 57:24 191:6 item91:1 181:11 itemized 168:19
items50:1 J J-a-j-a-p-u-t-r... 117:3 J-a-n-t-o 117:5 Jackie91:11 James14:2 18:18,20,24 19:23 20:8,11 20:14,16,24 21:12 22:8,10 23:1,11,19,25 24:10,14 25:6 25:23 26:16,20 27:5,8,16,19
28:7,11 31:24 32:3 33:9 34:3 34:12,20,24 35:12 36:3,6 37:22,24 38:2 38:4,7,9 40:15 41:5 43:20,23 44:7,11,17,22 44:23 45:22,25 46:5,7,10,13 46:15,18,22,25 47:6,8,10,14 47:20,23 48:8
48:10,15,18,22 49:2,5,10,13 51:5,21,23 52:1,5,7,10,13 52:16,18,21 53:5,9 54:19 55:3 56:21,23 58:17 59:22 66:3,7 68:8,10 68:19 69:9 71:10 72:22 73:1,11,19 75:2,10 76:2 76:11,19,21,24
79:5,8,21 82:11 86:23 87:7 96:15,16 96:21 101:19 102:10,17 103:1 104:3 113:8 126:19 144:19 155:11 155:14 156:2,6 161:1,10,15,18 161:23 162:4,8 164:9 179:12 179:16,23 180:1,10,13,17
180:20,22,25 181:3 182:23 184:4,18,21 185:6,11,12,24 186:1 187:12 187:15,21 188:8,9 191:11 Jamesbaker@... 96:25 Janto 116:14,17 116:20 117:5,6 141:2,12 January 21:18 31:18,18 36:9 37:1
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165:16 165:20 168:21 Jerry 145:23 Jersey 86:17 Jimbroom171:2 171:5 Joan 134:12 JOANNE14:8 job 66:17 128:19 145:7 191:9 Joconnor@jo... 14:11 Joel83:13 John 92:18 184:16 JOHNSON 14:2
14:8 18:18,20 18:24 19:23 20:8,11,14,16 20:24 21:12 22:8,10 23:1 23:11,19,25 24:10,14 25:6 25:23 26:16,20 27:5,8,16,19 28:7 31:24 32:3 33:9 34:3 34:12,20,24 35:12 36:3,6 37:22,24 38:2
38:4,7,9 41:5 43:23 44:17,23 45:22,25 46:5 46:7,10,13,15 46:18,22,25 47:6,8,10,14 47:20,23 48:8 48:10,15,18,22 49:2,5,10,13 51:5,23 52:1,7 52:10,13,16,18 52:21 53:5,9 54:19 55:3 56:21,23
59:22 66:3,7 68:10 68:19 69:9 71:10 72:22 73:1,11,19 75:2,10 76:2 76:11,19,21,24 79:5,8,21 82:11 86:23 87:7 101:19 102:10,17 104:3 113:8 126:19 144:19 155:11,14 156:2,6 161:1 161:10,15,18
161:23 162:4,8 164:9 179:12 179:16,23 180:1,10,13,17 180:20,22,25 181:3 182:23 184:4,18,21 185:6,12 186:1 187:12,15,21 188:9 191:11 JOHNSON-J... 15:5,7 join 89:6 joined 89:8 joint 46:20
Jonathan 32:1 66:25 67:2 85:17,18,20 12 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 86:15 98:5,8 98:10,18 113:6 113:10,19 114:6,11 130:17 131:19 132:12 179:4 184:14,17
Jonathanoboyle 131:2 Jonathanrobo... 131:10 Jones14:8 45:8 45:9,11,15,25 46:19 48:2,5 50:7 53:15 56:16 57:11 59:18 81:24 82:3,16,25 143:14 144:2 144:17 145:3,8 146:10,11,13 147:17 149:9
151:16 153:4,5 153:12 160:9 160:11 182:25 183:5,16 Jones+Foster 181:22,24 Jones+Foster-... 181:20 Jordanmentor 167:14,23 168:7 judge21:7 24:2 26:2,13 28:15 30:4,11,12,17 31:12,17 35:14
35:23 36:8 37:14 40:10 43:1,12 52:24 61:25 71:11 104:10 115:14 154:2 156:14 163:3 190:21 judge's35:24 judging 172:6 judgment 17:25 19:7,7 22:3,7 22:12,13 27:6 27:9,11 28:15 28:18 30:13,18
30:19 35:13,15 35:22,25 37:18 37:19 38:12,13 40:10,11 64:2 judgments34:6 judicata 21:5 32:9 33:15 34:1 36:1 judicial13:1 17:6,12,15,19 17:24 18:6,14 18:17 19:3,11 19:19 20:19 21:11
23:7 24:8 25:3 32:9 32:10,11 35:19 35:21 36:2 37:9 38:14 39:3 41:15,18 41:20 44:9 89:5 159:20,21 judicially 33:25 Julio 122:18 July 49:13,14,18 78:22 158:12 159:6 160:22 161:3 163:23
166:12 171:5 June91:2,3,9,21 91:24 152:6,10 152:16,17 169:3,20,22 170:14 jury 53:7,8 justification 51:1 K Kathy 30:8 59:5 59:8 66:21 keen 69:2,5 keep 30:17 55:23 72:15 106:15 111:19,19
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113:24 114:15 115:2,19 119:17,18 120:12,25 121:2,24 122:22 123:1 126:3 131:5,11 131:20 132:20 133:16 134:20 136:13 137:16 137:23 138:2 138:22 139:10 141:20 142:5,6 144:10 146:17 146:20,23
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knowing 35:2 187:18 knowledge67:6 84:12 85:23 124:21 125:16 125:23 130:25 131:25 138:21 138:22 known 25:11 36:21 178:25 knows59:7 66:20 142:12 159:25 L la 147:9 label176:6,11 labels176:8
182:6 lack77:11 lady 70:16 language 78:8 78:13 163:13 177:13 laptops120:11 large99:8 110:3 largely 55:20 largest 94:20 late58:17 70:16 Latharge92:20 Lauderdale 42:12 61:22 Laurie13:24
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125:7,9 126:1 168:19 laws107:2 lawsuit 21:25 73:9 157:18,21 157:24 158:12 158:15,19,22 159:1,4,5,12 159:13,17,22 159:23 160:2,3 160:4,18,20,22 162:13,13,15 162:18,21,24 163:2,6,11 182:12
lawsuits88:18 111:5 157:16 13 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 159:21 163:12 174:23 lawyer53:20 86:15 113:7 114:25 lawyer's143:21 lawyer/client 145:6
146:3 lawyers45:7 59:8,13 60:3 65:23 82:3,24 87:5 89:13 143:14,17,17 149:10,11 layouts182:6 Leading 69:7 learning 110:25 leave35:8 41:6 41:10 42:25 60:11 leaving 156:13 189:1 ledger110:11,11
left 103:22 121:14 legal33:11,17 85:3 145:11 186:13 legally 70:25 legislative 165:10 179:2 legislature30:24 108:17 legitimate65:23 71:23 let's19:6 30:1,2 32:15 42:14 43:13 44:20 55:4
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180:23 married 91:10 Martin 31:25 45:15 46:1,17 113:18 114:2 14 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 126:23,23 128:3,3 129:17 130:16 133:13 133:17 140:1 141:2
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169:13 169:17,21 170:8,16 171:4 173:16 named 122:9 names67:11,12 89:20 91:6,14 91:17 96:11 115:10,12,17 118:17 119:3,5 123:3,6,8,18 123:22,23,25 142:12,17 143:16,21 nature33:16 39:15
173:6 navigable 158:20 163:4 NAZZARO 14:20 necessarily 48:13 need 17:15,16,18 17:25 32:3 42:5 44:7 52:15 55:1 58:4 63:20 64:9 75:18 124:17 142:13 155:21 176:12 15 Fort Lauderdale, Florida
954-755-6401 Daughters Reporting, Inc. 179:22 185:21 187:19,21 188:7,12,17 needed 28:2 50:21 150:18 needs39:17 50:24 62:15 178:18 neighbor136:3 neighbors70:14 neither17:9 34:5,5 Nevada
93:2 117:24 118:1 118:10 123:7 141:11 Nevada's118:2 never31:10 41:15 58:1 67:16 87:25 88:7 94:19 95:5 113:25 115:14 118:7 125:5,14 140:17 146:25 149:25 150:12 150:13 178:14 184:13 185:5
new28:11 33:15 54:23 65:25 75:12 86:17 156:9 Newport 14:3 nice97:2 night 62:4 112:14 nine19:19 20:19 21:2 39:16 101:22 105:22 111:22 112:3 112:19 169:22 169:22 non-for-profit 67:14
NON-JURY 13:11 noon 41:25 42:23 121:1,4 142:15 normally 146:7 165:7 North 13:17 Notary 13:24 note52:18 notebook67:23 97:18 notepad 44:12 notes149:21 182:4,18 192:12 notice17:6,13 17:15,20,24
18:6,15,17 19:3,11,19 20:13,19 21:1 21:11 22:25 23:6,7,9 24:8 25:3 28:2 32:11,12 35:9 35:19,21 36:2 37:9,13,17 38:11,14 39:3 39:11 41:14,15 41:18,20 42:18 44:9 52:11 77:20 79:3 159:21
noticed 54:21 notices17:14 20:5 24:24 32:23 144:24 nuisance122:12 nuisances 122:14 number14:4,5 14:10,10,16,16 14:22 16:3 26:9 36:14 44:13 73:17 81:2,13 93:24 94:11 95:10 97:25 98:23
100:23 102:2,6 105:6,7,15,22 107:22 110:11 110:13,18 111:10,15,20 111:21 112:5 119:4,22 122:20 126:17 130:4,25 132:2 132:3,22 133:1 135:2,8 136:23 136:24 137:3 138:25 140:19 142:16
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99:8,17 100:5 101:24 102:3 112:24 128:3 130:8 135:9 137:1 151:6 169:7 numerous145:5 153:20 171:25 178:20 O O'Boyle14:3 26:1,7,22 27:22 29:11 30:6,10 32:1 32:22 37:17,17 37:18 38:11
40:9 45:16 46:1,17 47:18 47:25 53:17 54:10 58:16,24 59:1,4,20,22 66:20,25 67:2 85:17,18,19,20 86:15 87:6,14 87:17,20 88:3 88:8,10,21,24 89:6,9,11 98:5 98:18 111:4,6 113:18,19 114:1,2,2,6,11
124:3,14,23 125:7,9 126:1 126:10,12,14 126:19,21,23 126:23 127:22 128:3,4,11 129:8,17,20,24 130:16,17 131:19 132:12 133:9,13,17 134:5,7 144:3 144:4,7,10,22 144:23 145:4 146:12,14 147:17,18
148:11 149:13 160:12 168:6,9 168:13 179:4,5 181:23,25 184:6,10,14,16 184:16,25 O'Boyle's27:10 66:24 113:6,10 131:23 o'clock63:15 112:14 156:8 156:12 O'Connor14:8 21:9 27:24 38:18 42:7,12
42:16,20 51:24 52:6 57:5 120:22 121:6 180:9,12,16,19 186:23 187:4,6 187:9 O'Hare13:3 15:4 17:3 21:6 22:1 26:23 27:14 30:9,21 31:22 32:23 36:10 42:3 43:23 47:25 49:14,14,20 51:2 53:16
54:9 55:18 56:7,14 57:8 58:8,21 59:23 66:6,11,23 67:4,7,15,17 67:24 68:10,11 68:15,22 79:13 100:8 101:13 101:16,21 102:12 104:2 108:23 121:10 121:19 126:8 128:4 129:7 138:24 149:24
154:19 156:18 156:23 160:2 173:8 175:11 179:18 181:5 183:1 184:5 O'Hare's37:15 67:19 87:4 oath 173:16,17 object 56:24 125:13 155:12 161:1 objecting 19:16 objection 69:7 73:13 76:13,15
79:25 82:11 87:11 104:11 155:8 183:12 183:14,21,22 184:1 objections69:25 objects70:18 obligation 165:2 obligations 171:20 obtained 160:19 16 Fort Lauderdale, Florida 954-755-6401 Daughters
Reporting, Inc. obviously 94:23 105:18 occasion 143:18 occasionally 119:16 124:9 occasions80:3 87:2 94:6 153:21 174:20 occur94:16 123:2,10,17 171:8 occurred 125:5 125:14 129:11 129:12
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175:20 offices86:16 87:5,6 113:25 114:9,12,14 official77:20 officials109:14 Oftedal26:13 30:12,17 40:10 oh 42:13 46:24 47:23 52:12,23 53:5 56:14 63:21 69:4,21 88:16 102:5 111:23 130:9
130:23 132:9 136:25 137:16 140:6 142:23 143:7 146:17 147:5 150:5 167:9,21 168:12 169:16 171:24 172:18 174:15 178:13 189:19 okay 18:23 19:9 19:18 20:7,9 20:18 22:9 24:18 25:1,23 28:4
29:21,25 32:18 34:19 38:7 39:4,6,12 39:22 40:25 41:22 42:13,22 43:13 44:5,12 44:13,18,20 46:3,9,10,14 46:15,17,21,25 47:4,7,8,9,12 47:14,22 48:7 48:18,19 49:9 51:4,10,15 52:3,8,13,16
53:9 54:22 55:8,16 57:20 60:13,21,25 61:1,23 63:3,3 63:14,17 69:4 71:16 72:18 73:11,15 75:15 76:1 77:13 78:1 79:7 80:6 83:12 85:5 89:15 90:19 91:23 92:1,5 92:15,17 93:4 94:16 95:8 96:4,12,20
97:4,7 98:22 99:2 100:2 102:5 104:13 105:17 107:20 111:25 112:5 113:22,22 116:14,23 117:7 118:1,8 121:9 125:1 127:5 128:8 130:2,12 131:9 132:1,18 135:1 136:7,11,19 138:23 140:18 142:11
143:2,8 143:16,20 155:23 157:4,7 158:3,25 159:24 162:17 163:14 166:12 168:15 169:25 174:22 177:20 180:21 181:1 181:10,15 182:11 183:10 183:19,24 185:8,13 187:14,17 188:11,15,17 189:19,23
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146:14,18 158:21 opened 103:16 117:9,12,20 119:9 opening 57:13 58:1,5 openings43:14 44:21 operate59:8 operates59:9 operating 66:22 67:10 operations30:16 opinion 108:5,6 172:10 173:23
178:5 opportunity 63:20 67:16 89:2 122:3 opposing 20:17 39:13 60:19 oral186:16 order18:4 19:8 20:4 23:3 24:19,23 25:9 39:1 40:10 53:21 109:15 173:14 ordered 28:22 35:15 orders19:20
39:7 organize176:7 organized 152:1 original30:5 originally 30:5 41:2 Orlando 61:20 Orthwein 134:12,24 outrageous 65:21 outside42:14 51:16 outstanding 29:15 over-reaching 68:1 over-time56:4
overgrown 122:12 overload 177:12 overruled 79:25 87:11 104:4,11 113:14,14 164:10 owned 120:9 owns86:4 P P.A14:8 P.C14:3 P.L14:14 p.m13:15 60:15 60:17 191:15 page16:3 44:15 46:22 75:5
90:18 91:24 93:10 95:16 98:1,6,22,23 100:21,25 101:3,6,9,12 101:15,21,23 101:25 102:1 109:23,25 110:6,19 111:21,22 112:2,19,23,23 124:1 125:2 128:2,6 129:15 129:18,19,23 130:2,4,6,21
130:22 131:17 131:21 132:1 132:25 133:5,8 134:14 135:1,8 135:19,25 136:20 137:2,5 138:6,7,8,23 139:3,4,6 140:18 141:1 141:10,16,19 142:19,20 150:24 151:4,5 151:7,11,20 152:5,19 153:4
154:6,20 155:19 157:2,4 162:22 166:14 166:15,19,22 167:2,17,19 168:5,7,15 169:3,14,15 170:7,19 180:4 181:7,10 183:7 pages13:13 17 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting,
Inc. 142:14 paid 21:20 28:24 29:3 68:6 76:10 147:4,6 157:9 Palazzo 163:18 Palm13:1,17,18 14:9 84:21 140:9 192:5 palms70:16 paper104:15 133:16 134:2 170:23 paragraph 46:19 Pardon 91:12
99:24 131:15 133:22 144:9 154:23 163:16 Park86:8 parking 158:19 part 42:9 84:4 110:3 117:10 118:19 157:17 157:23 partially 72:1 participants 147:13 participating 85:14 particular24:25
64:4 65:1 70:6 91:1 152:2 181:10 particularly 69:15 parties18:8 35:3 191:2 parties' 35:18 party 26:24 27:14 134:9 pay 28:21 74:6 84:16 109:11 147:10 176:10 payment 29:15 29:18 peaks104:16
pending 24:12 40:2 47:17 48:1 144:11 190:16 people26:23 32:6 53:24 65:9,12 67:11 70:6 94:24 108:14 119:22 122:6 123:22 123:23 127:9 138:15,21 139:16 140:13 150:14,16 179:1 people's123:3
perfect 47:7 54:3 54:4 186:10 perfectly33:17 performed 157:9 period 45:17 46:12 47:3,16 59:11 76:25 77:18,19 83:1 108:18 148:11 158:3,10 165:15 168:20 182:1 188:21 188:23 permissible
50:20 permission 118:2,4 122:24 122:24 123:4 123:11,13,14 123:20,24,24 permits70:13 person 57:5 116:13 126:8 126:15 127:13 128:4,11 141:25 142:3 149:18 170:10 peruse105:2,3 Pete44:10
121:10 Petersen 83:19 Philadelphia 86:17 phone14:4,10 14:16,22 182:4 182:5 phonetic30:8,9 42:4,8 44:3 50:18 70:17 82:18,18 89:21 91:3 92:12,18 92:20 93:2 117:23,24 122:10,19 132:7 135:6
136:1 163:19 175:20 photos182:5 phrase89:8 physical113:17 physically 114:21 pick28:21 119:5 121:13 147:1 170:25 picked 94:10 146:21,25 147:2 picture150:18 pictures150:2 150:13,14,16
piece133:15 170:23 pipeline190:18 place64:9 184:23 189:25 placed 40:7 54:18 56:25 plaintiff13:4 14:6 16:4,5,6,7 19:20,22 43:22 44:21 55:24 57:15,18,23 64:3 76:15 185:13 186:18 Plaintiff's18:14
19:3,10 60:8 64:25 72:19 73:16,17 74:10 74:21 76:16 78:4 179:21,24 181:1 183:24 184:2 185:18 187:1 188:3 planet 174:9 planning 121:1 plans161:15 planted 70:15 plate78:13 play 55:24
149:23,25 plead 60:6 pleadings32:25 33:23 40:19 Pleadings@sw... 14:17 please18:13 24:15 34:20 36:4 39:21 58:2,5 68:20 75:6,8,23 78:2 87:12 109:24 116:25 120:16 121:17 128:18 128:24
133:10 137:1 154:17 159:25 175:20 179:23 181:5 pleasure153:17 plus157:21 point 32:4 38:24 40:25 pointing 32:5 police69:23 70:5 140:10 165:14 173:21,23 policeman 70:4 70:8 political134:9
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possessor123:21 possibility 107:2 possible43:5 56:11 91:4 104:23 118:22 119:19,21 166:9 191:1 possibly 56:11 99:14 post-trial33:12 pre-conditions 40:6 pre-planned 189:4 preclude32:12
predicated 29:14,17 prefer102:23 preference 186:17 prejudice28:5,5 34:23 35:11 37:7 prejudiced 39:14 prejudicial 41:16 premises66:23 67:1 preoccupied 177:23 prepare55:2 95:5 99:19,21
prepared 33:4 35:1 61:19 62:7 134:22 187:16 preparing 62:25 present 41:23 18 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 60:7 67:17 186:12,20 presented 186:20 pretrial18:4
20:4 23:2 24:19,23 25:9 25:9 39:1 40:2 44:19,19 46:20 180:14 pretty 109:6 112:8 169:23 previous76:8 previously 58:22 83:24 principle26:3,8 44:24 printed 181:7 prior17:10 24:6 25:16
28:24 29:2 40:5 41:14 54:8,8,9 77:3 122:1 prioritized 173:14 priority 185:22 private66:14 privilege48:14 50:6 145:6 Prize64:7 pro 98:14,19 probably 43:9 46:23 79:1 80:12 86:17 88:19
90:24 92:14,16,25 93:1 102:9 103:22 121:4 140:1 147:14 174:3,20 188:16 problem33:11 53:23 55:10 94:22 procedure 143:23 proceed 44:22 63:18 121:15 156:19,20 proceeding 42:9 64:2,24 proceedings
17:1 61:2 63:9 191:15 192:10 process21:22 59:15 85:15 processed 29:4 processing 177:6 produce36:18 50:21 150:1 produced 109:5 148:21 produces165:9 product 146:3 production 29:14,18
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153:13 157:7 165:10 165:23 171:10 172:8 176:15 177:2,5 178:7 179:6 180:14 181:8,19,19,20 184:12 185:1 publicdocsear... 97:11 Pulitzer64:7 pull17:5 38:22 52:9 55:1 140:10 purchasing
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question 17:21 22:14 23:5 25:20 48:19,23 51:11 71:18 81:9 87:12 90:21 91:24 92:1 93:10,12 93:16 100:1 105:16 122:4 123:16 124:18 125:5,9,14,18 125:20 128:14 128:25,25 129:1 140:14 148:24
158:24 164:12 187:17 questions25:18 70:23 71:22 116:18 122:1 179:9 185:7 quick19:2 107:10 quicker108:24 140:19 quickly109:6 quit 56:1,2 quite54:16 80:13 107:19 122:2 142:15 178:25 R
racist 69:23 radar165:15 raised 41:1 ran 57:25 Randolph 56:15 82:5,8,19 Randolph's 145:24 rarely 54:2 Raton 14:15 rats122:13 reach 191:7 reached 60:22 read 24:3,19,23 81:13 95:10 104:15,21
125:19 133:4 134:18,23 147:19 163:16 181:13 182:8 reading 110:16 164:12 182:21 real67:11 86:13 93:23 115:10 123:3,8,18 170:10 really 62:5 115:2 181:12 reanswer124:17 rearranged 156:15
reason 118:24 146:6 reasonable 48:20 49:8 70:6 78:24 107:12,13,21 109:5,21 148:19 149:8 149:18 reasons32:14 34:3 recall80:9 82:1 19 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting,
Inc. 82:17 84:15 88:9 90:5,16 90:17,21,23 91:6,23 93:9 95:18 98:16,18 99:13 100:9,16 100:17,18 103:14 105:25 116:5,7 117:24 119:25 125:1 134:6,12,25 142:7 150:4,6 150:11 153:9 153:10
159:8 163:13 167:1 169:1 171:3 173:3 175:9 recalls79:24 receive45:18 163:22 168:21 182:2 received 33:5,6 36:11 38:25 39:12 45:16 46:1 47:2,4,5 49:1,3 74:17 76:7 78:5 103:17,19 165:16
166:13 175:14 181:16 181:25 recessed 17:4 recharging 165:25 recognize134:21 135:13 179:3 182:9 recollection 93:23 128:9 129:13 137:9 162:12 recommended 106:23 reconvene 120:19 121:4
155:21 record 17:3 18:2 32:15 58:18 64:1,4 68:21 72:14,15 83:23 84:17 88:1 95:12 99:10 107:22 108:6,9 121:12 122:5 122:13 123:6 123:15 128:21 130:20 133:11 142:5,17 147:7 147:12,14
148:3,15,15 149:4,8 153:24 159:17,20 165:11 166:10 167:12 176:9 176:10,22 178:14 181:23 192:11 recording 133:6 records21:16,22 22:5 26:17 36:18,19 45:1 45:13 49:22,24 50:20 53:23 56:18
57:12 58:10 66:18 69:5,10,13,16 71:2 72:6,17 73:22 74:2,6 74:18 76:10 77:1,2 80:8,20 81:5,23 83:4 83:21 84:1 85:10,16 87:24 88:5,12,17 89:16 92:15 93:5,8,13 94:1 94:7,10 95:19 102:12
106:21 108:11,16,21 109:1,3,19 110:24 111:2 115:2,18 118:5 118:16 124:10 124:22 125:23 126:15,25 128:11 129:9 129:17,21,24 130:18 131:25 133:18,19 135:10,13 140:8,10 141:15 143:21 143:25
145:2,5 145:8,21,25 146:10,12,22 147:3 148:1,5 148:6 149:1,22 150:3 151:16 153:13 157:7 158:7 160:8,10 163:15 164:3 165:2,13,24 166:9,11 168:10,19 171:10 172:9 172:13 175:18 175:22,24
176:14,15 177:2,5,15 178:7,10 179:6 180:14 181:8 181:19,19,20 181:21 182:3 184:12 185:1 RECROSS 15:3 redacted 50:6 145:6,10 146:2 146:5,8 redirect 15:3 179:10,11 188:5 reduced 39:8
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54:7 63:25 69:16,20 78:4 80:6 162:18 163:7 163:11 174:2 174:24 177:15 178:1 regarding 63:23 162:21 165:13 165:24 175:19 175:22,25 regards162:24 regular61:12 regularly 178:8 178:9 reinstated
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86:23,24 87:7 104:3 164:9 relevant 37:14 38:13,16 64:5 relief29:9 30:15 rely50:17 relying 40:4,5 remainder 186:12 remaining 191:6 remember62:21 77:15 89:25 90:11 92:5,8 92:19,23 93:25
94:5,10 96:8,9 96:10,16,17 98:21 105:14 122:7 153:11 163:9 169:2 172:25 184:8 remembered 92:4 remove146:2 repeat 87:12 137:1 139:14 repeatedly 115:11 168:7 repetitive 102:18 rephrase88:2
replacing 165:25 replica 181:6 reply33:24 35:8 41:1,10 70:25 report 173:24 192:10 Reported 13:23 Reporter116:25 128:19 192:1,8 192:22 reports182:7 represent 111:7 20 Fort Lauderdale,
Florida 954-755-6401 Daughters Reporting, Inc. representations 28:12 representative 124:20 representatives 56:20 represented 28:16 89:11 111:8 representing 98:13,19 reputation 34:14
37:4 request 19:3 24:8 26:14 28:25 29:3,3,9 29:18 35:21 36:1 37:8 41:18,20 44:8 45:1,6,8,13,18 47:1 50:2,8 51:4,5 54:7,8 59:12,21 60:2 64:4,5 65:1,2 72:8,11,13,14 72:17 73:8 77:15 78:19
80:8 83:23 93:21 94:20 98:11 102:14 103:16 104:18 104:22 109:8 109:13,15,18 109:22 111:16 112:16 114:18 115:2,18,22,22 116:12 120:5 122:13,23 123:6,15,19 128:14 129:16 130:20 131:13
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165:21,23 166:5,7 168:22 170:1 172:16 173:16 174:14 174:16 175:1 176:16 177:13 177:17 178:18 181:8,20 182:2 182:9 requested 19:19 49:23 145:21 175:14 181:15 181:19,21 182:3,19 requester36:21
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112:7,8,10,12 112:18 115:10 115:13 117:22 118:5,16 122:6 124:4,4,15,16 124:22 125:24 127:13 128:11 129:9,18,21,24 130:18 131:17 131:25 133:1,1 133:7,9,18,19 134:16,18,21 134:22 135:3
135:14,17 136:21 139:4 139:11,13,15 139:19,22 140:13,16,20 143:8,9,22 146:14,18,24 151:20,22,23 152:1,7 153:13 166:4,15 167:13 168:5 169:24 170:1 170:16,20 171:4,10 172:9 173:12 176:1,6
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162:11 seek49:25 22 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 130:24 seeking19:14 30:14 seen 19:1 86:18 87:14 113:25 114:2,6,11 124:13,18 146:4 150:22 153:8 selectively
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.pdf
101987~1.pdf
101987_502014CA008142XXXXMB.O`HARE VS. TOWN OF GULF STREAM.V2.pdf
application/pdf
6E153A6C2CD30946A3DA8F85AECF1523@jonesfoster.com
EnUsAttached is the transcript of 13147.70, the case to be concluded at trial next week.
Joanne M. O’Connor Florida Bar Board Certified Business Litigation Attorney
Telephone: 561.650.0498 | Fax: 561.650.5300 | HYPERLINK "mailto:joconnor@jonesfoster.com"joconnor@jonesfoster.com
Jones, Foster, Johnston & Stubbs, P.A.
Flagler Center Tower, 505 South Flagler Drive, Suite 1100, West Palm Beach, Florida 33401
561-659-3000 | HYPERLINK "http://www.jonesfoster.com/"www.jonesfoster.com
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From: DAUGHTERSREPORTING@GMAIL.COM [mailto:DAUGHTERSREPORTING@GMAIL.COM]
Sent: Thursday, December 29, 2016 12:55 PM
To: OConnor, Joanne M. <JOConnor@jonesfoster.com>
Subject: Transcripts and Invoice 302094 - Judge Thomas Barkdull, III - Christopher O'Hare vs. Town of Gulf Stream - 12/08/2016
This message originated from outside your organization
_____
Attached is your invoice and transcripts.
Thank you very much!
Daughters Reporting, Inc.
101 NE 3rd Avenue, Suite 1500
Fort Lauderdale, FL 33301
954-755-6401
954-827-7778 Fax
HYPERLINK "mailto:daughtersreporting@gmail.com"daughtersreporting@gmail.com
HYPERLINK "http://www.daughtersreporting.com"www.daughtersreporting.com