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Home My Public Portal AboutFw_ O'Boyle - settlement agreement and releases -1 IPM.Note Fw: O'Boyle - settlement agreement and releases Fw: Scott Morgan SMTP scottmorgan75@gmail.com O'Boyle - settlement agreement and releases X-Vipre-Scanned: 0FC2B1F501363C0FC2B342 Received: from GSEXCH-1.GulfstreamTH.local (10.0.0.22) by GSEXCH-1.GulfstreamTH.local (10.0.0.22) with Microsoft SMTP Server (TLS) id 15.0.1130.7 via Mailbox Transport; Wed, 21 Jun 2017 13:26:04 -0400 Received: from GSEXCH-1.GulfstreamTH.local (10.0.0.22) by GSEXCH-1.GulfstreamTH.local (10.0.0.22) with Microsoft SMTP Server (TLS) id 15.0.1130.7; Wed, 21 Jun 2017 13:25:56 -0400 Received: from mail-yb0-f170.google.com (209.85.213.170) by mail.gulf-stream.org (10.0.0.22) with Microsoft SMTP Server (TLS) id 15.0.1130.7 via Frontend Transport; Wed, 21 Jun 2017 13:25:55 -0400 Received: by mail-yb0-f170.google.com with SMTP id e201so44663651ybb.1 for <TNAZZARO@gulf-stream.org>; Wed, 21 Jun 2017 10:26:04 -0700 (PDT) Received: from ScottPC ([68.235.227.87]) by smtp.gmail.com with ESMTPSA id x195sm6941763ywd.28.2017.06.21.10.25.59 (version=TLS1 cipher=ECDHE-RSA-AES128-SHA bits=128/128); Wed, 21 Jun 2017 10:26:02 -0700 (PDT) From: Scott Morgan <scottmorgan75@gmail.com> To: Bob Sweetapple <rsweetapple@sweetapplelaw.com>, "Joanne M. OConnor" <JOConnor@jonesfoster.com>, Trey Nazzaro <TNazzaro@gulf-stream.org>, Hudson Gill <hgill@jambg.com> Subject: Fw: O'Boyle - settlement agreement and releases Thread-Topic: O'Boyle - settlement agreement and releases Thread-Index: AQHS6rNzhaA4J5bIL0SuCAlBzGRbHA== Date: Wed, 21 Jun 2017 17:26:00 +0000 Message-ID: <32176BCF20304892888602291EC9A34E@ScottPC> Content-Language: en-US X-MS-Exchange-Organization-AuthAs: Anonymous X-MS-Exchange-Organization-AuthSource: GSEXCH-1.GulfstreamTH.local X-MS-Has-Attach: yes X-MS-Exchange-Organization-SenderIdResult: Pass X-MS-Exchange-Organization-SCL: 0 X-MS-Exchange-Organization-PCL: 2 X-MS-Exchange-Organization-PRD: gmail.com X-MS-TNEF-Correlator: received-spf: Pass (GSEXCH-1.GulfstreamTH.local: domain of scottmorgan75@gmail.com designates 209.85.213.170 as permitted sender) receiver=GSEXCH-1.GulfstreamTH.local; client-ip=209.85.213.170; helo=mail-yb0-f170.google.com; Content-Type: multipart/mixed; boundary="_007_32176BCF20304892888602291EC9A34EScottPC_" MIME-Version: 1.0 Scott Morgan SMTP scottmorgan75@gmail.com Bob Sweetapple; Joanne M. OConnor; Trey Nazzaro; Hudson Gill Settlement talks O'Boyle - settlement agreement and releases This just came in as I was walking out the door. I will be away from my office for several hours and haven’t had a chance to look at the attachments. Would you please review and let me know what you think? From: Marty O'Boyle <mailto:moboyle@commerce-group.com> Sent: Wednesday, June 21, 2017 1:22 PM To: Scott Morgan <mailto:scottmorgan75@gmail.com> Subject: RE: O'Boyle - settlement agreement and releases Scott – see attached. Although I would want our counsel to do a “quick” look at, the attached seems to work. If you disagree, tell me why and we will fix it. The 3rd release doesn’t work. All is open to discussion and negotiation. I draw no line in the sand. I believe that all in attached is consistent with our deal. Let’s get done. Let’s not fight. Let’s restore peace to the Town. Call me and let me know your wishes. Martin E. O'Boyle, Commerce Group, Inc 1280 W. Newport Center Drive Deerfield Beach, Fl. 33442 Direct Dial: 954-570-3505 Fax: 954-360-0807 Cell: 561 213 3486 E-mail: moboyle@commerce-group.com <mailto:moboyle@commerce-group.com> Web Page: www.commerce-group.com <http://www.commerce-group.com/> From: Marty O'Boyle Sent: Wednesday, June 21, 2017 11:34 AM To: 'Scott Morgan' Subject: RE: O'Boyle - settlement agreement and releases Scott – further to the below, I have a few moments and – before the settlement blows o pieces, I want to lay out where I’m coming from. Incidentally, there are many permutation that could work (which is why I suggested a Mediator), but below is as simple as can be. Here goes: 1 The Town and I execute Mutual Releases (including O’Boyle Law Firm and lawyers there). This includes the criminal case; or no release re criminal case. 2 We dismiss all claims, potential claims, etc. against each other. 3 Public Records requests withdrawn. Limit\restrict future requests, as I have no intention on filing any. You told me to call you if I want information, which is just what I will do. 4 You handle the situation with Jon 5 You provide the letters to the guys (integrity, ethically, professionally – all as you said). 6 Releases to any others who want – provided they give. Remember, this ends the Public Records Litigation and the Town’s hemorrhaging of the Taxpayer’s $$$. Tell me why this doesn’t work. I welcome you to call me on my cell if you wish to discuss. Re-igniting the litigation is a “Bad Move”, but you could make that call. The above serves the Town’s people well, which should be your focus. Scott, peace should be the ultimate goal. I remind out that I have several suits coming up, at least one where the Town was willing to admit liability; and I also remind you of case 4474, where we have a Judgement for liability, with fees of $500k+… a big risk for the taxpayers, that can be easily be avoided. Please also remember that the only reason for me to capitulate is based on: Jon and his team. Otherwise, there is no incentive to give up what is at least one material claim – 4474 – which the Town already lost; and maybe others “around the corner”. Why would you resist this proposal? I just don’t get it, especially since I believe that it is precisely what we agreed to. PS: The final agreement should also have innocuous and customary boiler plate provisions which “cut both ways”. Are we cool? If so, I will work with Bill to get done tonight if I can. I have an early evening flight and 2 important meetings both tomorrow and Friday, but, I, like you, want (and have wanted) to get done asap. I await hearing from you! :) Martin E. O'Boyle, Commerce Group, Inc 1280 W. Newport Center Drive Deerfield Beach, Fl. 33442 Direct Dial: 954-570-3505 Fax: 954-360-0807 Cell: 561 213 3486 E-mail: moboyle@commerce-group.com <mailto:moboyle@commerce-group.com> Web Page: www.commerce-group.com <http://www.commerce-group.com/> From: Marty O'Boyle Sent: Wednesday, June 21, 2017 10:08 AM To: 'Scott Morgan' Subject: RE: O'Boyle - settlement agreement and releases Scott – I am not going to sign the docs without reading them, nor would you. If you wish to “fire away”, I think it is silly, but we will oblige you in return. The one thing that I am not going to do is sign them; read them and (perhaps) withdraw them…that’ not my style. After I read them, I will either sign them or I will tell you where I think they are deficient and why. If our goals are the same, I think you are running the risk of “blowing the deal up”, which punishes the taxpayers of Gulfstream. Let me know if you want to stop negotiations and re-engage litigation (which I think it is silly). I think a Mediator puts it in the end zone in hours. Your resistance makes me suspect as to your intentions, since a Mediator is only a win, with no chance of a loss. What’s your pleasure? PS: I have eliminated all the “PS’s”. This is between you and I! :) Martin E. O'Boyle, Commerce Group, Inc 1280 W. Newport Center Drive Deerfield Beach, Fl. 33442 Direct Dial: 954-570-3505 Fax: 954-360-0807 Cell: 561 213 3486 E-mail: moboyle@commerce-group.com <mailto:moboyle@commerce-group.com> Web Page: www.commerce-group.com <http://www.commerce-group.com/> From: Scott Morgan [mailto:scottmorgan75@gmail.com] Sent: Wednesday, June 21, 2017 9:57 AM To: Marty O'Boyle Cc: OConnor, Joanne M.; hochman@jambg.com <mailto:hochman@jambg.com> ; William Ring; Hudson Gill; Bob Sweetapple; Trey Nazzaro Subject: Re: O'Boyle - settlement agreement and releases Marty, like you, I want to resolve these things with both sides dismissing its claims and signing releases against future lawsuits. I appreciate your difficult schedule but ,frankly, the terms of our agreement have really not changed, and the current set of documents reflects our agreement. At our last meeting, Jeff Hochman and I even agreed to use your proposed format for the releases instead of our forms. Marty—today is the day to end this. There is nothing more to negotiate or terms to change. There is nothing to mediate. The releases say what they should say---and everyone just walks away. I hope you and your lawyers will agree to bring this all to a conclusion. In the meantime, as I have reiterated in every conversation, there is no stay. I again ask you to sign the documents, Marty. Sign them and let me take them to the Town to add my signature. From: Marty O'Boyle <mailto:moboyle@commerce-group.com> Sent: Wednesday, June 21, 2017 6:05 AM To: scottmorgan75@gmail.com <mailto:scottmorgan75@gmail.com> Cc: William Ring <mailto:wring@commerce-group.com> ; OConnor, Joanne M. <mailto:JOConnor@jonesfoster.com> ; hochman@jambg.com <mailto:hochman@jambg.com> ; William Ring <mailto:wring@commerce-group .com> Subject: FW: O'Boyle - settlement agreement and releases Scott – I was sent the attached on Sunday afternoon by Bill Ring. As you know, I came back from my trip on Saturday night; and Sunday was Father’s day. Although I am not looking for sympathy (but I am looking to instill reality), I started this am at 4am; and I will work until 7:30am, then I will leave at 10 to 8am for an 8am meeting, then on to a 9:15am Mediation in Ft. Lauderdale; then to a flight to North Carolina, where I will than drive 150 miles to Knoxville, then on to WV, Pitt, Greensburg, Pa., Uniontown, Pa., Indiana, Pa. Clarion, Pa., Beaver Falls, Pa., Johnstown, Pa. King of Prussia, Pa., Philadelphia, Pa. and to Atlantic City for my youngest daughter’s 29th ‘surprise” Birthday Party followed by a short spell in Atlantic City with my family, where I also intend to relax and catch up on my work. I apologize that things have not taken the course of expediency that you have plotted, but I remind you that when Scott went away (whether it be on R&R or on a working trip), we leave you alone. I only ask that you respect me in that regard. I work hard; and I want to get done, but I could only address so much while traveling and with such a rigorous schedule…I know you understand. Scott, you know the deal that we made; that we shook on; and that we looked each other on the eye on. I fully intend to continue on the course to conclude that deal, but, as I see it (no – as it has become clear), there are many misunderstandings; and I am virtually certain that they emanate from your end. The “line in the sand’ that I “sign an unseen and unreviewed” agreement by yesterday was far from reasonable; and was, frankly an absurd request (no demand); and was certainly far from conducive to reaching resolution! So I now come to “what do you want to do”? Starting in a couple of hours, I am away until July 10th. I am more than happy to work on the Settlement (while traveling – but only when I have time – and time to focus). If you really want to get done, my suggestion is that we now schedule a Mediation with Fred Hazouri (you know who he is) on the earliest possible date after my return; and “bring the deal into the end zone”, as we should. (Of course – if that’s what you want to do – it’s a “no lose” proposition, which I think should bring finality – we both need to cooperate – no standing on form – no standing on ceremony – ego’s left wat the door – and a “goal” to get done); but if you want to fight (which I don’t and which I find silly), then that’s what you want to do. Your response here will be a clear signal. If you want to move forward with your threats, which start (according to your lawyers) this am, we are ready for you. Please “back off”, as such a course is not conducive to a Settlement; and will likely inflame an “almost done” settlement, which doesn’t happen will punish the taxpayers of the Town.. Scott – if you have had a change of heart and wish to renege on our agreement, I understand; and I know what to do. I hope you haven’t. I await hearing from you and only you. I will be checking my email, today. Please let me hear from you by noon if at all possible. If you call (which would be better), I will make every effort to take your call (or call you back promptly). You just need to tell me your intentions; and you just need to tell me that “Marty and Scott” are going to work together to get done. Right now, based on the threats, your side has put the Settlement on hold and have us gearing up to accommodate the threats that your lawyers say will commence this am. I will hold up taking any action until noon. I hope you could see your way clear to relaxing and I hope you could convince your lawyers to stop trying to push me around, as “that just ain’t gonna happen”! As I told you before: “I’m not Chris O’Hare”. So let’s get done! It’s up to you. I await your prompt response. Thank you; and “I can’t say it enough, embrace my desire and “let’s get done”! Martin E. O'Boyle, Commerce Group, Inc 1280 W. Newport Center Drive Deerfield Beach, Fl. 33442 Direct Dial: 954-570-3505 Fax: 954-360-0807 Cell: 561 213 3486 E-mail: moboyle@commerce-group.com <mailto:moboyle@commerce-group.com> Web Page: www.commerce-group.com <http://www.commerce-group.com/> From: William Ring [mailto:wring@oboylelawfirm.com] Sent: Sunday, June 18, 2017 5:38 PM To: Marty O'Boyle; Jonathan O'Boyle; Giovani Mesa Subject: FW: O'Boyle - settlement agreement and releases William F. Ring O'Boyle Law Firm 1286 West Newport Center Drive Deerfield Beach, FL 33442 954-570-3510 (ph) 954-328-4383 (cell) From: OConnor, Joanne M. [mailto:JOConnor@jonesfoster.com] Sent: Thursday, June 15, 2017 12:00 PM To: William Ring Cc: Hudson Gill; Randolph, John C.; Robert Sweetapple Subject: O'Boyle - settlement agreement and releases Bill – My understanding is that all parties, including the attorneys for those parties, seek a full and final resolution of the disputes between them. There are pending suits by Marty against me, Bob and our firms. And I would think the attorneys on your side would seek comfort that you will not be subject to any future claims based on past conduct. To that end, the Town has agreed to write to the Florida Bar regarding those lawyers. To confirm an end to any litigation, I have revised the settlement agreement to include a release by Marty of the Town’s contractors (there is a pending suit against Brannon & Gillespie by Mr. O’Boyle) and the its attorneys. I have changed the Town’s release of the attorneys on your side to exclude the carve-out for future litigation. I have drafted two separate releases: (1) O’Boyle Attorneys releasing Town, its agents, and attorneys and (2) Town Attorneys releasing O’Boyle, O’Boyle Entities and O’Boyle Attorneys. In Jeff’s absence, please contact me with comments, questions or concerns. I am in this afternoon and tomorrow 2pm or later (on a CLE panel in the morning) Thanks, Joanne 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. Flagler Center Tower, 505 South Flagler Drive, Suite 1100, West Palm Beach, Florida 33401 561-659-3000 | www.jonesfoster.com <http://www.jonesfoster.com/> Incoming emails are filtered which may delay receipt. This email is personal to the named recipient(s) and may be privileged and confidential. If you are not the intended recipient, you received this in error. If so, any review, dissemination, or copying of this email is prohibited. Please immediately notify us by email and delete the original message. CA9EBC429994614891CAB8800BE2D822@gulf-stream.org <32176BCF20304892888602291EC9A34E@ScottPC> This just came in as I was walking out the door. I will be away from my office for several hours and haven’t had a chance to look at the attachments. Would you please review and let me know what you think? From: Marty O'Boyle Sent: Wednesday, June 21 Trey Nazzaro Trey Nazzaro EX /O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=4F2A29F2B5E049B995E816021A4AFFE0-TNAZZARO EX /O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=4F2A29F2B5E049B995E816021A4AFFE0-TNAZZARO Scott Morgan Scott Morgan Trey Nazzaro Trey Nazzaro gmail.com scottmorgan75@gmail.com scottmorgan75@gmail.com tnazzaro@gulf-stream.org tnazzaro@gulf-stream.org II=[CID=2738a085-c896-442f-ae08-0941cc645b1c;IDXHEAD=01D2EAB373;IDXCOUNT=1];SBT=4;S2=<FFFF6E8B689F4B109B02404E44ED71A3@ScottPC>;RTP=Unrelated;TDN=Same;TFR=NotForking;Version=Version 15.20 (Build 2157.0), Stage=H5;UP=D0;DP=105 en Pass (GSEXCH-1.GulfstreamTH.local: domain of scottmorgan75@gmail.com designates 209.85.213.170 as permitted sender) receiver=GSEXCH-1.GulfstreamTH.local; client-ip=209.85.213.170; helo=mail-yb0-f170. google.com; GSEXCH-1.GulfstreamTH.local 964B9F83BB85C697 Anonymous 0FC2B1F501363C0FC2B342 Bob Sweetapple SMTP rsweetapple@sweetapplelaw.com rsweetapple@sweetapplelaw.com Bob Sweetapple Joanne M. OConnor SMTP JOConnor@jonesfoster.com JOConnor@jonesfoster.com Joanne M. OConnor Trey Nazzaro EX /o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=4f2a29f2b5e049b995e816021a4affe0-tnazzaro tnazzaro@gulf-stream.org Trey Nazzaro sip:tnazzaro@gulf-stream.org Hudson Gill SMTP hgill@jambg.com hgill@jambg.com Hudson Gill image001.jpg .jpg image001.jpg image001.jpg image/jpeg 9D2107E3DB2A4EADB3A19E4B4CE8C95E@ScottPC EnUs 1SG9068-release general town attorneys to oboyle entities attorneys 6-25-17 101pm.docx GENERAL RELEASE Jones, Foster, Johnston & Stubbs, P.A.; John C. Randolph, Esq.; Joanne O’Connor, Esq.; Sweetapple, Broeker & Varkas, PL; Robert A. Sweetapple, Esq.; Richman Greer, P.A.; Gerald F. Richman, Esq.; Eric M. Sodhi, Esq.; Johnson, Anselmo, Murdoch, Burke, Piper & Hochman, P.A.; Hudson Gill, Esq.; Christopher J. Stearns, Esq., Michael R. Piper, Esq., and Jeffrey L. Hochman, Esq. (“TOWN ATTORNEYS”), for and in consideration of the sum of $10.00 and other good and valuable consideration, the adequacy and receipt of which are acknowledged, HEREBY irrevocably discharge and release Martin E. O’Boyle, Citizens Awareness Foundation, Inc. Airline Highway, LLC, Asset Enhancement, Inc., CG Acquisition Company, Inc., Commerce GP, Inc., Commerce Group, Inc., Commerce Realty Group, Inc., CRO Aviation, Inc., Our Public Records, LLC, Stopdirtygovernment, LLC, Public Awareness Institute, Inc., and Citizens for Open Government, LLC, including all successors and assigns (collectively “O’BOYLE”), and Jonathan O’Boyle, Esq.; Giovani Mesa, Esq.; Nicklaus Taylor, Esq.; Ryan Witmer, Esq.; William F. Ring, Jr., Esq.; The O’Boyle Law Firm, P.C., Inc.; Elaine Johnson James, Esq. and Elaine Johnson James, P.A. (collectively “O’BOYLE ATTORNEYS”) from each and every action, cause of action, lawsuit, appeal, post-judgment proceeding, claim for attorney’s fees, claim for costs, claim for sanctions (whether requested or imposed), public records request, claim for any award, loss, damage, judgment, remedy, or relief whatsoever in law and in equity, including each and every claim arising under local law, state law, federal law, the Florida Constitution or the United States Constitution (collectively “CLAIMS”) which the TOWN ATTORNEYS ever had, now have, or may have against O’BOYLE or the O’BOYLE ATTORNEYS for, upon, or by reason of any matter, cause, or thing whatsoever, from the beginning of the world to the day of the execution of this Release and the TOWN ATTORNEYS also hereby knowingly waive all such CLAIMS. The TOWN ATTORNEYS have read this General Release and understand its terms, obligations, operation and effect; and, the TOWN ATTORNEYS further acknowledge that the agreement herein to release, discharge, and waive all CLAIMS is intended to resolve disputes and to avoid litigation, and that this General Release shall not be deemed or considered to be any admission or acceptance of blame, liability, or responsibility by the TOWN ATTORNEYS in any way or in any manner. This General Release may be executed and delivered in any number of counterparts, each of which, when so executed and delivered, shall be and constitute an original and one and the same document. A facsimile or electronic copy of this instrument and any signatures hereon shall be considered for all purposes as originals. [SIGNATURES ON FOLLOWING PAGES] JONES, FOSTER, JOHNSTON & STUBBS, P.A. By:________________________________ Print Name:____________________ Its:___________________________ _____________________________________John C. Randolph, Esq. _____________________________________Joanne O’Connor, Esq. Sweetapple, Broeker & Varkas, PL By:________________________________ Print Name:____________________ Its:___________________________ _____________________________________Robert A. Sweetapple, Esq. Richman Greer, P.A. By:________________________________ Print Name:____________________ Its:___________________________ _____________________________________Gerald F. Richman, Esq. _____________________________________Eric M. Sodhi, Esq. Johnson, Anselmo, Murdoch, Burke, Piper & Hochman, P.A. By:________________________________ Print Name:____________________ Its:___________________________ _____________________________________Hudson Gill, Esq. _____________________________________Christopher J. Stearns, Esq. _____________________________________Michael R. Piper, Esq. _____________________________________Jeffrey L. Hochman, Esq. 3 .docx 1SG906~1.doc 1SG9068-release general town attorneys to oboyle entities attorneys 6-25-17 101pm.docx application/vnd.openxmlformats-officedocument.wordprocessingml.document F00F32AF18AF164D9C2C1C49B4C9C1F5@gulf-stream.org EnUs 1SG9892-agreement settlement town oboyle (3) 6-21-17 1pm.rtfSETTLEMENT AGREEMENT For and in consideration of the sum of $10.00 and other good and valuable consideration, the adequacy and receipt of which are acknowledged, Martin E. O’Boyle, individually and also in his representative capacity for and on behalf of Airline Highway, LLC; Asset Enhancement, Inc.; CG Acquisition Company, Inc.; Commerce GP, Inc.; Commerce Group, Inc.; Commerce Realty Group, Inc.; CRO Aviation, Inc.; Our Public Records, LLC; Stopdirtygovernment, LLC; Public Awareness Institute, Inc.; and, Citizens for Open Government, LLC, including all successors and assigns (collectively “O’BOYLE”) fully and forever hereby irrevocably discharges and releases the TOWN OF GULF STREAM, including the TOWN OF GULF STREAM’s current and past employees, agents, representatives, officials, officers, and insurance carriers (, including the Florida Municipal Insurance Trust and the Florida League of Cities, Inc.), contractors (including Brannon & Gillespie, LLC; Danny P. Brannon, P.E.; Urban Design Kilday Studios; Marty R.A. Minor) and attorneys (including Jones, Foster, Johnston & Stubbs, P.A.; John C. Randolph, Esq.; Joanne O’Conner, Esq.; Sweetapple, Broeker & Varkas, PL; Robert A. Sweetapple, Esq.; Richman Greer, P.A.; Gerald F. Richman, Esq.; Eric M. Sodhi, Esq.; Johnson, Anselmo, Murdoch, Burke, Piper & Hochman, P.A.; Hudson Gill, Esq.; Christopher J. Stearns, Esq., Michael R. Piper, Esq., and Jeffrey L. Hochman, Esq.) (collectively the “TOWN”) from each and every action, cause of action, lawsuit, appeal, post-judgment proceeding, claim for attorney’s fees, claim for costs, claim for sanctions (whether requested or imposed), public records request, claim for any award, loss, damage, judgment, remedy, or relief whatsoever in law and in equity, including each and every claim arising under local law, state law, federal law, the Florida Constitution or the United States Constitution (collectively “CLAIMS”), which O’BOYLE ever had, now has, or which any personal representative, successor, heir, or assign can or may have against the TOWN for, upon, or by reason of any matter, cause, or thing whatsoever, from the beginning of the world to the day of the execution of this Settlement Agreement and O’BOYLE also hereby knowingly waives all such CLAIMS. [Who ever wants – gives – it must “cut both ways”.] For and in consideration of the sum of $10.00 and other good and valuable consideration, the adequacy and receipt of which are acknowledged, Citizens Awareness Foundation, Inc. (“CAFI”), fully and forever hereby irrevocably discharges and releases the TOWN from all CLAIMS which CAFI ever had, now has, or which any successor or assign can or may have against the TOWN for, upon, or by reason of any matter, cause, or thing whatsoever, from the beginning of the world to the day of the execution of this Settlement Agreement, and CAFI also hereby knowingly waives all such CLAIMS. 2. For and in consideration of the sum of $10.00 and other good and valuable consideration, the adequacy and receipt of which are acknowledged, the TOWN OF GULF STREAM fully and forever hereby irrevocably discharges and releases Martin E. O’Boyle, CAFI, Airline Highway, LLC, Asset Enhancement, Inc., CG Acquisition Company, Inc., Commerce GP, Inc., Commerce Group, Inc., Commerce Realty Group, Inc., CRO Aviation, Inc., Our Public Records, LLC, Stopdirtygovernment, LLC, Public Awareness Institute, Inc., and Citizens for Open Government, LLC, from all CLAIMS which the TOWN OF GULF STREAM ever had, now has, or which any successor or assign can or may have against O’BOYLE for, upon, or by reason of any matter, cause, or thing whatsoever, from the beginning of the world to the day of the execution of this Settlement Agreement, and the TOWN OF GULF STREAM also hereby knowingly waives all such CLAIMS. [I didn’t read – but should “ok” if paralleled to #1 above] For and in consideration of the sum of $10.00 and other good and valuable consideration, the adequacy and receipt of which are acknowledged, the TOWN OF GULF STREAM fully and forever hereby irrevocably discharges and releases Jonathan O’Boyle, Esq.; Giovani Mesa, Esq.; Nicklaus Taylor, Esq.; Ryan Witmer, Esq.; William F. Ring, Esq.; and The O’Boyle Law Firm, P.C., Inc., (collectively “O’Boyle Attorneys”) from all CLAIMS which the TOWN OF GULF STREAM ever had, now has, or which any successor or assign can or may have against the O’Boyle Attorneys arising from their representation of O’BOYLE, for, upon, or by reason of any matter, cause, or thing whatsoever, from the beginning of the world to the day of the execution of this Settlement Agreement, and the TOWN OF GULF STREAM also hereby knowingly waives all such CLAIMS; except that, in the event that Jonathan O’Boyle, Esq.; Giovani Mesa, Esq.; Nicklaus Taylor, Esq.; Ryan Witmer, Esq.; William F. Ring, Esq.; or The O’Boyle Law Firm, P.C., Inc., seek any from of judicial relief against TOWN OF GULF STREAM on his or its own behalf (“New Attorney Lawsuit”), then this paragraph 4 will not apply to, will not limit, and will not otherwise be effective against any claims, any defenses, or any other matter raised by or raised on behalf of the TOWN OF GULF STREAM in any way associated with or related to that New Attorney Lawsuit. [I didn’t read – but should “ok” if paralleled to #1 above] 5. By way of clarification and not limitation, this Settlement Agreement, includes, but is not limited to, a mutual release, discharge, and waiver of each of the CLAIMS, facts, circumstances, and matters that were or which could have been raised in or addressed in any of the following matters: Case No.14-CA-000834; Case No. 14-CA-001572; Case No. 14-2CA-02607; Case No. 14-CA-002728; Case No. 14-CA-003396; Case No. 14-003721; Case No. 14-CA-004474/Case No. 4D16-3634; Case No. 14-CA-005189; Case No. 4D 15-1762; Case No. 14-CA-005628; Case No. 14-CA-6112; Case No. 14-CA0006360; Case No 14-CA-007123; Case No. 14-CA-008076; Case No. 14-CC-008529; Case No. 14-CA-010216; Case No. 14-CA-011940; Case No. 14-CC-014780 (17th Cir. County Court); Case No. 14-CC-015050; Case No. 16-CA-004546; Case No. 16-CA-005437/Case No. 4D16-3386; Case No. 14-cv-80317/11th Cir. Case No. 15-13964; Case No. 15-13964; Case No. 14-cv-81250-KAM; Case No. 14-cv-81248-DTKH/11th Cir. Case No. 15-10997; Case No. 15-CA-001498; Case No. 15-CA-001498; Case No. 15-CA-001737; Case No. 14-CA-011941, and Case No. 15-CA-005226 and Case No. 17-CA-005226 (collectively “Litigated Matters”). 6. By way of further clarification and not limitation, except for cases which have already concluded by virtue of the entry of an appropriate final order or judgment, the TOWN OF GULF STREAM, O’BOYLE, and CAFI will file stipulations for the dismissal with prejudice of the Litigated Matters in the appropriate court to secure a final order of dismissal of each case with each party to the Litigated Matters to bear its own attorney’s fees and costs, even if a party is otherwise entitled to seek attorney’s fees and costs from another under a fee or cost shifting provision. All sanctions claims made, ordered, or granted, including, without limitation, those made or granted pursuant to section 57.105, Florida Statutes, the inherent authority of any court, or any other law (whether statutory or common law) shall be withdrawn and dismissed with prejudice. 7. By way of further clarification and not limitation, this Settlement Agreement amounts to an immediate written withdrawal of each and every public records request issued as of the date of the execution of this Settlement Agreement to the TOWN OF GULF STREAM by Martin E. O’Boyle, CAFI, Airline Highway, LLC, Asset Enhancement, Inc., CG Acquisition Company, Inc., Commerce GP, Inc., Commerce Group, Inc., Commerce Realty Group, Inc., CRO Aviation, Inc., Our Public Records, LLC, Stopdirtygovernment, LLC, Public Awareness Institute, Inc., Citizens for Open Government, LLC, those acting behalf of Martin E. O’Boyle, and those participating with Martin E. O’Boyle, including, without limitation, each public records request issued through a relative, employee, associate, agent, or attorney of Martin E. O’Boyle, but only to the exten that such requests were authorized my O’Boyle [This could be handled concominantly with the execution – also – we will insist that the dismissals and allother docs be handled all at once “no dangling loose ends”.] (collectively “O’Boyle Requestors”). The O’Boyle Requestors separately release, discharge, and waive all CLAIMS arising from, connected with, related to, or associated with each such public records request. 8. Notwithstanding anything to the contrary herein, excluded from the scope, operation, and effect of this Settlement Agreement is that certainThe settlement agreement entered into by and between the TOWN OF GULF STREAM, Martin E. O’Boyle, Commerce Group, Inc., N984AC Caravan, LLC, and Airline Highway, LLC, on July 26, 2013 (“Prior Settlement Agreement”), which Prior Settlement Agreement shall remain in full force and effect. 9. In connection with any litigation between the TOWN OF GULF STREAM and O’BOYLE and/or between TOWN OF GULF STREAM and CAFI filed after the day of the execution of this Settlement Agreement, the TOWN OF GULF STREAMand, O’BOYLE, and CAFI hereby waive all rights to secure prevailing party attorney’s fees and costs from the other party (including the O’Boyle Attorney’s) in such litigation, even if a state or federal statute or rule provides such a remedy. Nonetheless, each party hereby retains its respective rights to apply for and to secure court-awarded sanctions from any other, even if the sanction award is in the form of an award of attorney’s fees, costs, or both. This prevailing party fee and cost waiver provision is intended to eliminate the incentive to initiate litigation based upon the existence of fee-shifting and cost-shifting provisions. 10. In the event that any O’Boyle Requestors submit a public records request to the TOWN OF GULF STREAM at any time after the day of the execution of this Settlement Agreement, Martin E. O’Boyle hereby agrees to pay, at the time that the public records request is made, a facilitation fee of $250 to the Town Clerk of the TOWN OF GULF STREAM (“Facilitation Fee”). Failure to pay the Facilitation Fee will conclusively render such public records request withdrawn. In the event the costs associated with responding to the applicable public records request are less than the corresponding Facilitation Fee, the balance of the Facilitation Fee (after reduction of the costs associated with responding to the request) will be refunded to Martin E. O’Boyle in a timely manner. Otherwise, the conduct of the O’Boyle Requestors and the TOWN OF GULF STREAM will be governed by Chapter 119, Florida Statutes, and Florida law. [I don’t care about this for the reasons in my email to Scott below] 11. The TOWN OF GULF STREAM, and O’BOYLE, and CAFI have read this Settlement Agreement with the assistance of counsel and understand its terms, obligations, operation, and effect. The TOWN OF GULF STREAM,and O’BOYLE, and CAFI acknowledge that their entry into this Settlement Agreement is intended to resolve pending litigation and shall not be deemed or considered to be any admission or acceptance of blame, liability, or responsibility. The TOWN OF GULF STREAM, and O’BOYLE, CAFI have entered into this Settlement Agreement voluntarily and without having been threatened, coerced, or intimidated. No provision of this Settlement Agreement shall be construed presumptively against any party hereto. 12. Each party to this Settlement Agreement warrants (a) that it has not sold, assigned, transferred or otherwise disposed of any of the CLAIMS which are being released and waived hereunder, (b) that it has the full right, power, legal capacity, and authority to enter into this Settlement Agreement and to consummate the transactions described herein, and (c) that this Settlement Agreement has been duly and validly executed and delivered and constitutes a legal, valid and binding obligation in accordance with its terms. 13. In the event of an alleged default of any obligation under this Settlement Agreement, the party declaring any such default shall provide the party allegedly in default with a notice explaining the default by email and by U.S. Mail (“Notice”). The failure to cure a default by the 10th day after such Notice was provided shall constitute a breach of this Settlement Agreement. Such breach, however, shall not be construed as a breach between all parties, and any such breach shall be enforceable only against the breaching party by the party providing the Notice. Notice to the TOWN OF GULF STREAM shall be made to the Town Clerk at the Town Clerk’s official address for email and by U.S. Mail to Town Clerk, Town of Gulf Stream, 100 Sea Road, Gulf Stream, FL 33483. Notice to O’BOYLE shall be made by email to moboyle@commerce-group.com and by U.S. Mail to Commerce Group, Inc., 1280 W. Newport Center Drive, Deerfield Beach, FL, 33442. Notice to CAFI shall be made by email to wring@oboylelawfirm.com and by U.S. Mail to William Ring, Esq., O’Boyle Law Firm, 1286 West Newport Center Drive, Deerfield Beach, FL 33442. 14. This Settlement Agreement is deemed to have been made, executed, and delivered in the State of Florida and shall be construed in accordance with the laws of the State of Florida. Accordingly, the TOWN OF GULF STREAM,and O’BOYLE, and CAFI consent to the exclusive jurisdiction of the Circuit Court for the 15th Judicial Circuit for the State of Florida for all purposes related to this Settlement Agreement and forgo all other venues. 15. This Settlement Agreement shall be binding upon and inure to the benefit of the TOWN OF GULF STREAM,and O’BOYLE, and CAFI’s respective heirs, successors and assigns. No party may assign its rights or delegate its obligations under this Settlement Agreement without the express prior written consent of the other affected party. 16. This Settlement Agreement may be executed in counterparts, each of which shall be an original and all of which taken together shall constitute a single agreement, with the same effect as if the signatures thereto and hereto were upon the same instrument. Any facsimiles, photographs or photocopies of this Settlement Agreement shall be considered, for all purposes, as if it were an executed original. 17. This Settlement Agreement contains the entire agreement of the TOWN OF GULF STREAM,and O’BOYLE, and CAFI with respect to all matters covered and the transactions contemplated hereby; any prior writing or oral discussion shall be considered merged into this Settlement Agreement and only the text shall be considered indicative of the parties intent. No modification or waiver of any provision of this Settlement Agreement shall be effective unless the same shall be in writing and signed by TOWN OF GULF STREAM, Martin E. O’Boyle, and a duly authorized representative of CAFI. 18. If any term, covenant, or condition Settlement Agreement or the application thereof shall, to any extent, be invalid or unenforceable, the remaining terms, conditions, and covenants shall remain valid and enforceable. Each term, covenant, or condition shall be enforced to the fullest extent permitted by law. IN WITNESS WHEREOF, the undersigned have executed this Settlement Agreement as of June 16, 2017. ___________________________ MARTIN E. O’BOYLE individually, and also as the duly authorized representative on behalf of Airline Highway, LLC, Asset Enhancement, Inc., CG Acquisition Company, Inc., Commerce GP, Inc., Commerce Group, Inc., Commerce Realty Group, Inc., CRO Aviation, Inc., Our Public Records, LLC, Stopdirtygovernment, LLC, Public Awareness Institute, Inc., and Citizens for Open Government, LLC, [All docs to be done concominantly including all dismissals, etc., so when everything is signed it is all over] _________________________________ CITIZENS AWARENESS FOUNDATION, INC. By: _____________________________ As its duly authorized representative _______________________________ TOWN OF GULF STREAM By Scott Morgan as Mayor .rtf 1SG989~1.rtf 1SG9892-agreement settlement town oboyle (3) 6-21-17 1pm.rtf application/msword A45BA4218D8F044A912ED1435201F9AF@gulf-stream.org EnUsThis just came in as I was walking out the door. I will be away from my office for several hours and haven’t had a chance to look at the attachments. Would you please review and let me know what you think? From: HYPERLINK "mailto:moboyle@commerce-group.com"Marty O'Boyle Sent: Wednesday, June 21, 2017 1:22 PM To: HYPERLINK "mailto:scottmorgan75@gmail.com"Scott Morgan Subject: RE: O'Boyle - settlement agreement and releases Scott – see attached. Although I would want our counsel to do a “quick” look at, the attached seems to work. If you disagree, tell me why and we will fix it. The 3rd release doesn’t work. All is open to discussion and negotiation. I draw no line in the sand. I believe that all in attached is consistent with our deal. Let’s get done. Let’s not fight. Let’s restore peace to the Town. Call me and let me know your wishes. Martin E. O'Boyle, Commerce Group, Inc 1280 W. Newport Center Drive Deerfield Beach, Fl. 33442 Direct Dial: 954-570-3505 Fax: 954-360-0807 Cell: 561 213 3486 E-mail: HYPERLINK "mailto:moboyle@commerce-group.com"moboyle@commerce-group.com Web Page: HYPERLINK "http://www.commerce-group.com/"www.commerce-group.com From: Marty O'Boyle Sent: Wednesday, June 21, 2017 11:34 AM To: 'Scott Morgan' Subject: RE: O'Boyle - settlement agreement and releases Scott – further to the below, I have a few moments and – before the settlement blows o pieces, I want to lay out where I’m coming from. Incidentally, there are many permutation that could work (which is why I suggested a Mediator), but below is as simple as can be. Here goes: 1 The Town and I execute Mutual Releases (including O’Boyle Law Firm and lawyers there). This includes the criminal case; or no release re criminal case. 2 We dismiss all claims, potential claims, etc. against each other. 3 Public Records requests withdrawn. Limit\restrict future requests, as I have no intention on filing any. You told me to call you if I want information, which is just what I will do. 4 You handle the situation with Jon 5 You provide the letters to the guys (integrity, ethically, professionally – all as you said). 6 Releases to any others who want – provided they give. Remember, this ends the Public Records Litigation and the Town’s hemorrhaging of the Taxpayer’s $$$. Tell me why this doesn’t work. I welcome you to call me on my cell if you wish to discuss. Re-igniting the litigation is a “Bad Move”, but you could make that call. The above serves the Town’s people well, which should be your focus. Scott, peace should be the ultimate goal. I remind out that I have several suits coming up, at least one where the Town was willing to admit liability; and I also remind you of case 4474, where we have a Judgement for liability, with fees of $500k+… a big risk for the taxpayers, that can be easily be avoided. Please also remember that the only reason for me to capitulate is based on: Jon and his team. Otherwise, there is no incentive to give up what is at least one material claim – 4474 – which the Town already lost; and maybe others “around the corner”. Why would you resist this proposal? I just don’t get it, especially since I believe that it is precisely what we agreed to. PS: The final agreement should also have innocuous and customary boiler plate provisions which “cut both ways”. Are we cool? If so, I will work with Bill to get done tonight if I can. I have an early evening flight and 2 important meetings both tomorrow and Friday, but, I, like you, want (and have wanted) to get done asap. I await hearing from you! J Martin E. O'Boyle, Commerce Group, Inc 1280 W. Newport Center Drive Deerfield Beach, Fl. 33442 Direct Dial: 954-570-3505 Fax: 954-360-0807 Cell: 561 213 3486 E-mail: HYPERLINK "mailto:moboyle@commerce-group.com"moboyle@commerce-group.com Web Page: HYPERLINK "http://www.commerce-group.com/"www.commerce-group.com From: Marty O'Boyle Sent: Wednesday, June 21, 2017 10:08 AM To: 'Scott Morgan' Subject: RE: O'Boyle - settlement agreement and releases Scott – I am not going to sign the docs without reading them, nor would you. If you wish to “fire away”, I think it is silly, but we will oblige you in return. The one thing that I am not going to do is sign them; read them and (perhaps) withdraw them…that’ not my style. After I read them, I will either sign them or I will tell you where I think they are deficient and why. If our goals are the same, I think you are running the risk of “blowing the deal up”, which punishes the taxpayers of Gulfstream. Let me know if you want to stop negotiations and re-engage litigation (which I think it is silly). I think a Mediator puts it in the end zone in hours. Your resistance makes me suspect as to your intentions, since a Mediator is only a win, with no chance of a loss. What’s your pleasure? PS: I have eliminated all the “PS’s”. This is between you and I! J Martin E. O'Boyle, Commerce Group, Inc 1280 W. Newport Center Drive Deerfield Beach, Fl. 33442 Direct Dial: 954-570-3505 Fax: 954-360-0807 Cell: 561 213 3486 E-mail: HYPERLINK "mailto:moboyle@commerce-group.com"moboyle@commerce-group.com Web Page: HYPERLINK "http://www.commerce-group.com/"www.commerce-group.com From: Scott Morgan [mailto:scottmorgan75@gmail.com] Sent: Wednesday, June 21, 2017 9:57 AM To: Marty O'Boyle Cc: OConnor, Joanne M.; HYPERLINK "mailto:hochman@jambg.com"hochman@jambg.com; William Ring; Hudson Gill; Bob Sweetapple; Trey Nazzaro Subject: Re: O'Boyle - settlement agreement and releases Marty, like you, I want to resolve these things with both sides dismissing its claims and signing releases against future lawsuits. I appreciate your difficult schedule but ,frankly, the terms of our agreement have really not changed, and the current set of documents reflects our agreement. At our last meeting, Jeff Hochman and I even agreed to use your proposed format for the releases instead of our forms. Marty—today is the day to end this. There is nothing more to negotiate or terms to change. There is nothing to mediate. The releases say what they should say---and everyone just walks away. I hope you and your lawyers will agree to bring this all to a conclusion. In the meantime, as I have reiterated in every conversation, there is no stay. I again ask you to sign the documents, Marty. Sign them and let me take them to the Town to add my signature. From: HYPERLINK "mailto:moboyle@commerce-group.com"Marty O'Boyle Sent: Wednesday, June 21, 2017 6:05 AM To: HYPERLINK "mailto:scottmorgan75@gmail.com"scottmorgan75@gmail.com Cc: HYPERLINK "mailto:wring@commerce-group.com"William Ring ; HYPERLINK "mailto:JOConnor@jonesfoster.com"OConnor, Joanne M. ; HYPERLINK "mailto:hochman@jambg.com"hochman@jambg.com ; HYPERLINK "mailto:wring@commerce-group.com"William Ring Subject: FW: O'Boyle - settlement agreement and releases Scott – I was sent the attached on Sunday afternoon by Bill Ring. As you know, I came back from my trip on Saturday night; and Sunday was Father’s day. Although I am not looking for sympathy (but I am looking to instill reality), I started this am at 4am; and I will work until 7:30am, then I will leave at 10 to 8am for an 8am meeting, then on to a 9:15am Mediation in Ft. Lauderdale; then to a flight to North Carolina, where I will than drive 150 miles to Knoxville, then on to WV, Pitt, Greensburg, Pa., Uniontown, Pa., Indiana, Pa. Clarion, Pa., Beaver Falls, Pa., Johnstown, Pa. King of Prussia, Pa., Philadelphia, Pa. and to Atlantic City for my youngest daughter’s 29th ‘surprise” Birthday Party followed by a short spell in Atlantic City with my family, where I also intend to relax and catch up on my work. I apologize that things have not taken the course of expediency that you have plotted, but I remind you that when Scott went away (whether it be on R&R or on a working trip), we leave you alone. I only ask that you respect me in that regard. I work hard; and I want to get done, but I could only address so much while traveling and with such a rigorous schedule…I know you understand. Scott, you know the deal that we made; that we shook on; and that we looked each other on the eye on. I fully intend to continue on the course to conclude that deal, but, as I see it (no – as it has become clear), there are many misunderstandings; and I am virtually certain that they emanate from your end. The “line in the sand’ that I “sign an unseen and unreviewed” agreement by yesterday was far from reasonable; and was, frankly an absurd request (no demand); and was certainly far from conducive to reaching resolution! So I now come to “what do you want to do”? Starting in a couple of hours, I am away until July 10th. I am more than happy to work on the Settlement (while traveling – but only when I have time – and time to focus). If you really want to get done, my suggestion is that we now schedule a Mediation with Fred Hazouri (you know who he is) on the earliest possible date after my return; and “bring the deal into the end zone”, as we should. (Of course – if that’s what you want to do – it’s a “no lose” proposition, which I think should bring finality – we both need to cooperate – no standing on form – no standing on ceremony – ego’s left wat the door – and a “goal” to get done); but if you want to fight (which I don’t and which I find silly), then that’s what you want to do. Your response here will be a clear signal. If you want to move forward with your threats, which start (according to your lawyers) this am, we are ready for you. Please “back off”, as such a course is not conducive to a Settlement; and will likely inflame an “almost done” settlement, which doesn’t happen will punish the taxpayers of the Town.. Scott – if you have had a change of heart and wish to renege on our agreement, I understand; and I know what to do. I hope you haven’t. I await hearing from you and only you. I will be checking my email, today. Please let me hear from you by noon if at all possible. If you call (which would be better), I will make every effort to take your call (or call you back promptly). You just need to tell me your intentions; and you just need to tell me that “Marty and Scott” are going to work together to get done. Right now, based on the threats, your side has put the Settlement on hold and have us gearing up to accommodate the threats that your lawyers say will commence this am. I will hold up taking any action until noon. I hope you could see your way clear to relaxing and I hope you could convince your lawyers to stop trying to push me around, as “that just ain’t gonna happen”! As I told you before: “I’m not Chris O’Hare”. So let’s get done! It’s up to you. I await your prompt response. Thank you; and “I can’t say it enough, embrace my desire and “let’s get done”! Martin E. O'Boyle, Commerce Group, Inc 1280 W. Newport Center Drive Deerfield Beach, Fl. 33442 Direct Dial: 954-570-3505 Fax: 954-360-0807 Cell: 561 213 3486 E-mail: HYPERLINK "mailto:moboyle@commerce-group.com"moboyle@commerce-group.com Web Page: HYPERLINK "http://www.commerce-group.com/"www.commerce-group.com From: William Ring [mailto:wring@oboylelawfirm.com] Sent: Sunday, June 18, 2017 5:38 PM To: Marty O'Boyle; Jonathan O'Boyle; Giovani Mesa Subject: FW: O'Boyle - settlement agreement and releases William F. Ring O'Boyle Law Firm 1286 West Newport Center Drive Deerfield Beach, FL 33442 954-570-3510 (ph) 954-328-4383 (cell) From: OConnor, Joanne M. [mailto:JOConnor@jonesfoster.com] Sent: Thursday, June 15, 2017 12:00 PM To: William Ring Cc: Hudson Gill; Randolph, John C.; Robert Sweetapple Subject: O'Boyle - settlement agreement and releases Bill – My understanding is that all parties, including the attorneys for those parties, seek a full and final resolution of the disputes between them. There are pending suits by Marty against me, Bob and our firms. And I would think the attorneys on your side would seek comfort that you will not be subject to any future claims based on past conduct. To that end, the Town has agreed to write to the Florida Bar regarding those lawyers. To confirm an end to any litigation, I have revised the settlement agreement to include a release by Marty of the Town’s contractors (there is a pending suit against Brannon & Gillespie by Mr. O’Boyle) and the its attorneys. I have changed the Town’s release of the attorneys on your side to exclude the carve-out for future litigation. I have drafted two separate releases: (1) O’Boyle Attorneys releasing Town, its agents, and attorneys and (2) Town Attorneys releasing O’Boyle, O’Boyle Entities and O’Boyle Attorneys. In Jeff’s absence, please contact me with comments, questions or concerns. I am in this afternoon and tomorrow 2pm or later (on a CLE panel in the morning) Thanks, Joanne 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 Incoming emails are filtered which may delay receipt. This email is personal to the named recipient(s) and may be privileged and confidential. If you are not the intended recipient, you received this in error. 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