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Home My Public Portal AboutFw_ Proposed Settlement Agreement (redraft) from you - Gulfstream IPM.Note Fw: Proposed Settlement Agreement (redraft) from you - Gulfstream Fw: scottmorgan75@gmail.com SMTP scottmorgan75@gmail.com Proposed Settlement Agreement (redraft) from you - Gulfstream X-Vipre-Scanned: 0FA6BF6A01363C0FA6C0B7 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; Tue, 7 Nov 2017 15:43:36 -0500 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; Tue, 7 Nov 2017 15:43:28 -0500 Received: from mail-ua0-f180.google.com (209.85.217.180) by mail.gulf-stream.org (10.0.0.22) with Microsoft SMTP Server (TLS) id 15.0.1130.7 via Frontend Transport; Tue, 7 Nov 2017 15:43:23 -0500 Received: by mail-ua0-f180.google.com with SMTP id u32so397230uau.0 for <TNAZZARO@gulf-stream.org>; Tue, 07 Nov 2017 12:43:30 -0800 (PST) Received: from ScottMorganHP (c-67-191-95-86.hsd1.fl.comcast.net. [67.191.95.86]) by smtp.gmail.com with ESMTPSA id 90sm324196uar.20.2017.11.07.12.43.26 (version=TLS1 cipher=ECDHE-RSA-AES128-SHA bits=128/128); Tue, 07 Nov 2017 12:43:28 -0800 (PST) From: "scottmorgan75@gmail.com" <scottmorgan75@gmail.com> To: Trey Nazzaro <TNazzaro@gulf-stream.org>, Joanne O'Connor <joconnor@jonesfoster.com>, Robert Sweetapple <rsweetapple@sweetapplelaw.com>, Jeff Hochman <hochman@jambg.com> Subject: Fw: Proposed Settlement Agreement (redraft) from you - Gulfstream Thread-Topic: Proposed Settlement Agreement (redraft) from you - Gulfstream Thread-Index: AQHTWAkOKt4HkJpstkWo38VglPV3ig== Date: Tue, 7 Nov 2017 20:43:24 +0000 Message-ID: <0F2DE906870940C3904F24F14E9B5FA6@ScottMorganHP> 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 209.85.217.180 as permitted sender) receiver=GSEXCH-1.GulfstreamTH.local; client-ip=209.85.217.180; helo=mail-ua0-f180.google.com; Content-Type: multipart/mixed; boundary="_004_0F2DE906870940C3904F24F14E9B5FA6ScottMorganHP_" MIME-Version: 1.0 scottmorgan75@gmail.com SMTP scottmorgan75@gmail.com Trey Nazzaro; Joanne O'Connor; Robert Sweetapple; Jeff Hochman Settlement talks Proposed Settlement Agreement (redraft) from you - Gulfstream From: Marty O'Boyle <mailto:moboyle@commerce-group.com> Sent: Tuesday, November 07, 2017 3:14 PM To: scottmorgan75@gmail.com <mailto:scottmorgan75@gmail.com> Cc: Brenda Russell <mailto:brussell@commerce-group.com> Subject: RE: Proposed Settlement Agreement (redraft) from you - Gulfstream Scott: Below are the fundamental differences as I recall, without looking at my draft: 1. The Insurance Issue is alive and well. I offer a release to the Town for the records cases (all of them, except 4474 – which involves the insurance co.). That’s all I can do. Joanne and Sweetapple both agreed to this. Hochman suggested an Indemnity. Joanne said no. Thus what I offered up. Beyond that, I can offer no more. 2. CAFI is not a “Marty” issue. Please feel free to speak to Bill. Based on my short conversation with him, I don’t think that is an issue to resolution. 3. As to the OLF’s lawyer’s, that’s it. They will not agree to anything more. As I see it, they are the main events. I reattach my email to Joanne with my last draft. Based upon your own agreement, the Town clearly wants the “non-records” litigation to continue. I invite you to tweak my last version. I remind you of the benefits (see below). Please consider the below, looking at the “Big Picture” . Let’s look at what it accomplishes: * It gets rid of the Records Litigation as aforesaid. * It gets rid of the “Insurance Issue”, which I (reluctantly) take on. * It provides for the withdrawal of all existing unfulfilled requests, which eliminates the possibility of future litigation in connection therewith. * It discourages future Records Requests. Please advise where you would like to go from here. What more can I say? I remind you that this communication is for settlement purposes only and may be used for no other purpose. Additionally, I remind you that until formal docs are signed and approved by all, unfortunately, finality as to a final resolution will continue to escape us. I know you understand. 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: scottmorgan75@gmail.com [mailto:scottmorgan75@gmail.com] Sent: Tuesday, November 7, 2017 12:31 PM To: Marty O'Boyle <moboyle@commerce-group.com> Subject: Re: Proposed Settlement Agreement (redraft) from you - Gulfstream Marty----what is going on here? I worked over the weekend and yesterday on the SA you told me you wanted to use. You sent it to me (attached) with the following email: Scott – below was an “OOPS!”. Please delete, as this one is the correct one. All relevant communications are now attached. I await hearing back from you. Now you send me another SA and say that’s the one. Last week you give me a SA and I work on it. Now you say that’s the wrong one--use a new one. Give me a call please. I just opened your new attachment and frankly I just don’t understand what the problem is. Am I misreading these SA’s? Aside from some language differences, I just don’t see the differences. There are no attachments to this document that you just sent me but I assume it’s the same as the cases and parties identified in my SA. Or is there some difference? Frankly, this is ridiculous. For you and for me. I could respond to your highlights below but it isn’t important. We both get it: You feel like we backed out of an agreement; We feel like you did. OK. We have different perceptions of who did what but does it really matter? We are either going to wrap this up or not, and Marty, I keep saying it: I just don’t see what the differences are. Call me and let’s go over this latest document you sent me and the one I sent you. I really don’t care whose document we use so long as we agree on the terms. That’s what I’m trying to figure out. Do we agree on the terms? From: Marty O'Boyle <mailto:moboyle@commerce-group.com> Sent: Tuesday, November 07, 2017 11:50 AM To: scottmorgan75@gmail.com <mailto:scottmorgan75@gmail.com> ; smorgan@gulf-stream.org <mailto:smorgan@gulf-stream.org> Cc: Brenda Russell <mailto:brussell@commerce-group.com> Subject: RE: Proposed Settlement Agreement (redraft) from you - Gulfstream CONTINUING ON RE BELOW Below was a “misfire”, in that it was unfinished, unreviewed, unedited and incomplete. A new version will follow. Please disregard. As requested, please work from my doc, as I believe it “rings the bell. Your doc doesn’t work, for a host of reasons, all of which have been explained in emails over the last few months (if not few weeks). See areas “highlighted” below. [Despite your hyperbole and restatement and inaccurate recitation of history, I look for a fair and amicable settlement, as I have preached for years. What you propose is a “Giant step backwards”; and if you keep it up, we will just continue to spin wheels as in the Mississippi Mud without a posi-traction differential” What’s your pleasure? Again, if you wish to “tweak”, please do so from my last draft.] This email is sent for settlement purposes only and may not be iused for any other purpose. UNFORTUNATELY, I RECEIVE TOO MANY EMAILS ON A DAILY BASIS. THE RESULT IS THAT I DO NOT HAVE A CHANCE TO REVIEW THEM ALL; AND MANY I DO NOT SEE AT ALL. I ENCOURAGE YOU TO CONTINUE TO SEND ME EMAILS; AND, IF YOU DON’T HEAR FROM ME WITHIN 48 HOURS, I URGE YOU TO CALL ME. I ALSO ASK YOU TO CC MS. BRENDA RUSSELL (BRUSSELL@COMMERCE-GROUP.COM <mailto:BRUSSELL@COMMERCE-GROUP.COM> ) OR TO CALL HER (954 570 3513). THANK YOU FOR YOUR COOPERATION. 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: scottmorgan75@gmail.com <mailto:scottmorgan75@gmail.com> [mailto:scottmorgan75@gmail.com] Sent: Tuesday, November 7, 2017 10:35 AM To: Marty O'Boyle <moboyle@commerce-group.com <mailto:moboyle@commerce-group.com> > Subject: Re: Proposed Settlement Agreement (redraft) from you - Gulfstream Marty—you apparently didn’t read or understand the SA because paragraph 3 specifically addresses “Fatal Area 1”, which provides a release of the lawyers by the town without a reciprocal release by them of the town. [The Release is conditional. That is unacceptable to the lawyers. We both know (and knew that), your lawyers agreed to my language. The Lawyers don’t trust you. Take it or leave it. Moving on.] Your second “Fatal Area” suggests that we must use your release---I suppose you mean the release with the highlighted portions. That cannot be done because that document includes several incomplete paragraphs, several redundant ones, additional “joining” parties, and some mis-numbered sections. That is why I revised it-- to fill in the blanks, get rid of unrelated joining parties, and to make it more understandable. Our SA is your SA—just with tighter, clearer language. It is not the Town’s SA vs. O’Boyle SA. This contains the terms we both already agree on. [The release I provided is a release from the Town to me and not the other way, there are too many exclusions to deal with, all of which we gave you a right to cure and some of which your attorneys agreed to. You now do another “about face”. Take it or leave it”.] CAFI is your third “Fatal Area.” Your position: “ I don’t see CAFI as an issue.” This is absurd. If you think “CAFI can be resolved without fuss” then do it. If you can resolve it, resolve it. Don’t just say it isn’t an issue. [CAFI listed as a “Fatal Issue” was in error. The operative language there follows: I spoke to Bill briefly and he thinks CAFI can be resolved without fuss.] I worked on this with you several months ago and it went nowhere. Recently, I felt you were sincere when you reached out to me to nail down this SA. So I compared the SA’s and concluded they are the same, at least in intentions if not in exact language. I cleaned up the language and prepared a SA that provides the terms you set forth. These are the same terms that we agreed to before. {You got it wrong. Generally stated, you insisted that we deal with your counsel. We did. They agreed, didn’t agree, one changed their mind, the other then offered and alternate result, and we (as I said before) ended up playing the “Mole game”. A lot has happened since you backed out of your last agreement (see emails). I’m trying to get done, but you must deal with reality. Please go back and read the history and speak to your attorneys that you had handle things for you, starting with Hudson Gil who gave us an ultimate with a “Bogus Agreement” and then when we tried to work with him, he wouldn’t return phone calls; and perhaps, upon doing so, you will then better understand. What I offer is a “Big Win” for the Town, as I state in my email to you of yesterday at 5:52pm. You just need to decide whether the offer on the table is “good for the taxpayers of Gulfstream economically”. Of course, I am always open to “tweaking”, as I’m not that good.] We are both busy men, Marty. I have a business to run and I’m not going to spend more time going back and forth with you on terms that are already agreed to by both sides. The only issue I see is CAFI. It’s an issue for you and an issue for us. You seem confident that “CAFI can be resolved without fuss” so go ahead and resolve it. Once that’s done, I’ll recommend the Commission accept this SA. Also, you probably know that you have a Stopdirtygovernment case that is on the trial schedule and can be called as early as Monday. Your lawyers and ours’ are currently preparing for a Monday call. [Wasn’t it you who said in the CG Case that until a settlement is reached that we go forward. I assume that your position remains the same. Having said that, “let’s get done”! :)] Now is the time to wrap this up, Marty. Our November Commission meeting is this Friday. That’s the time to get the SA approved. [I agree] [Scott – I agree that we are both busy. You know where I’m coming from. Given the totality of the circumstances, you should “jump all over” my offering. In lieu of an agreement, I will (with great reluctance) continue to litigate the other cases. Do you really see that as beneficial to the taxpayers? Really?] From: Marty O'Boyle <mailto:moboyle@commerce-group.com> Sent: Monday, November 06, 2017 5:52 PM To: scottmorgan75@gmail.com <mailto:scottmorgan75@gmail.com> Cc: Brenda Russell <mailto:brussell@commerce-group.com> Subject: FW: Proposed Settlement Agreement (redraft) from you - Gulfstream Scott – I briefly reviewed your email. Initially, I see 3 fatal areas, that we need to overcome before going any further. 1. The lawyers at the firm, will not release the Town. The “Chris O’Hare” extortion statement and the Town’s refusal for a Non-Disparagement killed that; and the Town’s agreement as in my doc and now what you propose creates more distrust and they just won’t agree to it. 2. I offered a Release, if it works, cool. If not, we need to address the other issues, which my draft “snuffed”. 3. I don’t see CAFI as an issue. I spoke to Bill briefly and he thinks CAFI can be resolved without fuss. That’s where we start. Please consider the below, looking at the “Big Picture” . Let’s look at what it accomplishes: * It gets rid of the Records Litigation as aforesaid. * It gets rid of the “Insurance Issue”, which I (reluctantly) take on. * It provides for the withdrawal of all existing unfulfilled requests, which eliminates the possibility of future litigation in connection therewith. * It discourages future Records Requests. Please advise where you would like to go from here. UNFORTUNATELY, I RECEIVE TOO MANY EMAILS ON A DAILY BASIS. THE RESULT IS THAT I DO NOT HAVE A CHANCE TO REVIEW THEM ALL; AND MANY I DO NOT SEE AT ALL. I ENCOURAGE YOU TO CONTINUE TO SEND ME EMAILS; AND, IF YOU DON’T HEAR FROM ME WITHIN 48 HOURS, I URGE YOU TO CALL ME. I ALSO ASK YOU TO CC MS. BRENDA RUSSELL (BRUSSELL@COMMERCE-GROUP.COM <mailto:BRUSSELL@COMMERCE-GROUP.COM> ) OR TO CALL HER (954 570 3513). THANK YOU FOR YOUR COOPERATION. 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: scottmorgan75@gmail.com <mailto:scottmorgan75@gmail.com> [mailto:scottmorgan75@gmail.com] Sent: Monday, November 6, 2017 5:12 PM To: Marty O'Boyle <moboyle@commerce-group.com <mailto:moboyle@commerce-group.com> > Subject: Re: Proposed Settlement Agreement (redraft) from you - Gulfstream Marty, Fortunately, I didn’t get called up so my one day of jury service is over. But the time there did give me a chance to review and prepare the SA for you to review. Attached is the SA. I took your comments and Joanne’s and matched them. Some of the clauses or paragraphs I thought were redundant so took those out and I cleaned up some of the language in the remaining paragraphs to cover the points being made. You will see my notes of explanation in Red beneath the important paragraphs. I am not hiding anything here. There is no tricky language or legal gymnastics. This SA is for you and your entities as well as your attorneys. It is for the Town and its employees and attorneys. I specifically avoid including joint parties or ancillary parties or adding more people for signatures. This is you and this is the Town. It is also your people and our people and your attorneys and our attorneys. Regarding attorneys, although the Town releases your attorneys, your attorneys don’t have to release the Town. Instead, if they take action in the future, then our release of them is void. But at the outset, they don’t need to get involved to sign a release of claims. We dismiss the cases and you withdraw the PRR’s. Then we add the rights you retain from the prior settlement, the criminal matter, and the Hidden Harbor issues. And that’s it. Regarding CAFI, Joanne told me that Bill is no longer a board member or officer. This is important. CAFI needs to be addressed so if you can put CAFI into this SA, and either you or Bill sign for it, then we need to do that. If you cannot do that, then our settlement needs to be conditioned on those three CAFI cases being voluntarily dismissed. They can’t be left hanging out there and I won’t take the agreement to the Commission without it being addressed. If you have another suggestion, I’m open to it but this is the best I could come up with. I think we are both on the same page Marty. Let me know if you agree. And let me know your thoughts on handling CAFI. Scott From: Marty O'Boyle <mailto:moboyle@commerce-group.com> Sent: Monday, November 06, 2017 2:32 PM To: scottmorgan75@gmail.com <mailto:scottmorgan75@gmail.com> Subject: RE: Proposed Settlement Agreement (redraft) from you - Gulfstream Scott – I know you will address when you can. PS: Don’t get on a 2 month trial! :) UNFORTUNATELY, I RECEIVE TOO MANY EMAILS ON A DAILY BASIS. THE RESULT IS THAT I DO NOT HAVE A CHANCE TO REVIEW THEM ALL; AND MANY I DO NOT SEE AT ALL. I ENCOURAGE YOU TO CONTINUE TO SEND ME EMAILS; AND, IF YOU DON’T HEAR FROM ME WITHIN 48 HOURS, I URGE YOU TO CALL ME. I ALSO ASK YOU TO CC MS. BRENDA RUSSELL (BRUSSELL@COMMERCE-GROUP.COM <mailto:BRUSSELL@COMMERCE-GROUP.COM> ) OR TO CALL HER (954 570 3513). THANK YOU FOR YOUR COOPERATION. 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: scottmorgan75@gmail.com <mailto:scottmorgan75@gmail.com> [mailto:scottmorgan75@gmail.com] Sent: Monday, November 6, 2017 9:16 AM To: Marty O'Boyle <moboyle@commerce-group.com <mailto:moboyle@commerce-group.com> > Subject: Re: Proposed Settlement Agreement (redraft) from you - Gulfstream Marty— am at jury duty!! Not sure when I’ll be able to get you a copy. I’ll try tomorrow. Sent from my iPhone On Nov 6, 2017, at 6:43 AM, Marty O'Boyle <moboyle@commerce-group.com <mailto:moboyle@commerce-group.com> > wrote: Scott – I am working\preparing for a major meeting today. I assuming you can get me the revised doc this am, I could likely get an hour of “quiet time” during the lunch break and maybe (just maybe) – assuming the comments shown on the markup (or annotated or enumerated) are minimal respond to you during the lunch break. No guarantee’s by way of timing given. All is still fresh in my mind regarding the content of my last draft, so it should be easy for me to respond; and do so quickly, despite being “on the move”. Time is not our friend for a host of reasons, including my schedule; and, with the passing of time, my memory. The issues should be non-existent (save – perhaps – some tweaking. Now is our chance. Let’s do it! :) Of course, until formal docs are signed and approved by all, unfortunately, finality as to a final resolution will continue to escape us. I know you understand. Thanks! :) UNFORTUNATELY, I RECEIVE TOO MANY EMAILS ON A DAILY BASIS. THE RESULT IS THAT I DO NOT HAVE A CHANCE TO REVIEW THEM ALL; AND MANY I DO NOT SEE AT ALL. I ENCOURAGE YOU TO CONTINUE TO SEND ME EMAILS; AND, IF YOU DON’T HEAR FROM ME WITHIN 48 HOURS, I URGE YOU TO CALL ME. I ALSO ASK YOU TO CC MS. BRENDA RUSSELL (BRUSSELL@COMMERCE-GROUP.COM <mailto:BRUSSELL@COMMERCE-GROUP.COM> ) OR TO CALL HER (954 570 3513). THANK YOU FOR YOUR COOPERATION. 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/> 4A81963DD46A244D9DA2787FB1F2A39C@gulf-stream.org <0F2DE906870940C3904F24F14E9B5FA6@ScottMorganHP> From: Marty O'Boyle Sent: Tuesday, November 07, 2017 3:14 PM To: scottmorgan75@gmail.com Cc: Brenda Russell Subject: RE: Proposed Settlement Agreement (redraft) from you - Gulfstream Scott: Below are the fundamental differences as I recall, wi 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 scottmorgan75@gmail.com scottmorgan75@gmail.com Trey Nazzaro Trey Nazzaro gmail.com scottmorgan75@gmail.com scottmorgan75@gmail.com tnazzaro@gulf-stream.org tnazzaro@gulf-stream.org II=[CID=9007de2a-6c9a-45b6-a8df-c56094f5778a;IDXHEAD=01D358090E;IDXCOUNT=1];SBT=3;S2=<1A76298A7C71428B8A8A9A1776667D9F@ScottMorganHP>;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 209.85.217.180 as permitted sender) receiver=GSEXCH-1.GulfstreamTH.local; client-ip=209.85.217.180; helo=mail-ua0-f180. google.com; GSEXCH-1.GulfstreamTH.local AAD3F05101F74F64 Anonymous 0FA6BF6A01363C0FA6C0B7 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 Joanne O'Connor SMTP JOConnor@jonesfoster.com JOConnor@jonesfoster.com Joanne O'Connor Robert Sweetapple SMTP rsweetapple@sweetapplelaw.com rsweetapple@sweetapplelaw.com Robert Sweetapple Jeff Hochman SMTP hochman@jambg.com hochman@jambg.com Jeff Hochman Gulfstream\O'Boyle - Settlement Agreement IPM.Note Gulfstream\O'Boyle - Settlement Agreement Marty O'Boyle SMTP moboyle@commerce-group.com Gulfstream\O'Boyle - Settlement Agreement X-Vipre-Scanned: 0FA6BF0D01363C0FA6C05A From: Marty O'Boyle <moboyle@commerce-group.com> To: Joanne O'Connor <JOConnor@jonesfoster.com> CC: Jonathan O'Boyle <joboyle@oboylelawfirm.com>, William Ring <wring@commerce-group.com>, Brenda Russell <brussell@commerce-group.com>, Nick Taylor <ntaylor@oboylelawfirm.com>, Giovani Mesa <gmesa@oboylelawfirm.com>, "'robertrivas@comcast.net'" <robertrivas@comcast.net> Subject: Gulfstream\O'Boyle - Settlement Agreement Thread-Topic: Gulfstream\O'Boyle - Settlement Agreement Thread-Index: AdNRzryh8QogWJmKSbKMsmnP/a6L2A== Date: Tue, 31 Oct 2017 00:34:35 +0000 Message-ID: <DM5PR16MB145184C1599FA379BC75C712855E0@DM5PR16MB1451.namprd16.prod.outlook.com> Content-Language: en-US X-MS-Has-Attach: yes X-MS-TNEF-Correlator: Content-Type: multipart/mixed; boundary="_005_DM5PR16MB145184C1599FA379BC75C712855E0DM5PR16MB1451namp_" MIME-Version: 1.0 Marty O'Boyle SMTP moboyle@commerce-group.com Jonathan O'Boyle; William Ring; Brenda Russell; Nick Taylor; Giovani Mesa; 'robertrivas@comcast.net' Joanne O'Connor Gulfstream\O'Boyle - Settlement Agreement Joanne: Attached is a redraft of the Settlement Agreement (the “SA”) which you sent to Bill Ring by email on October 26, 2017. It may be a bit rough. I need to go over it again. I am sending it to counsel for any comments that they may have. After much thought and considering all factors, including the carve-outs, I have simplified the SA. IN that connection, I point out the below, which I believe are the substantive changes to your draft (utilizing the same numbered paragraphs as in the attached): 2. I have provided a release to the Town, the Commissioners, etc. and the other Defendants in the various records suits. The schedule of open records cases (a draft is attached – please review) excludes Case #4474 as discussed. In this connection, I ask you to begin the preparation of Dismissals with prejudice with each party bearing its own fees and costs. 3. I have provided for a General Release from (what I have defined as) the “Gulf Stream Parties” to (what I have defined as) the “O’Boyle Parties”. The above changes emanate from my thoughts regarding the following: A. The issue with my Insurer. Assuming the attached draft works, that issue now goes away as an open issue. An alternative, suggested by Jeff Hochman, which you seemed to reject, would be an Indemnity. B. I have eliminated the concept of the “Joining Parties”. After much thought, it made the agreement much more complex than necessary. Any extraneous cases (e.g.: the Sweetapple Slander Case (the “SSC”)) could be handled separately. So that you know, I am open to discussing the SSC and any other extraneous cases, at any time, if requested to do so. Joanne, the attached should work. Let’s look at what it accomplishes: * It gets rid of the Records Litigation as aforesaid. * It gets rid of the “Insurance Issue”, which I (reluctantly) take on. * It provides for the withdrawal of all existing unfulfilled requests, which eliminates the possibility of future litigation in connection therewith. * It discourages future Records Requests. I am prepared to address any issues or items which you may raise to the extent not addressed or unsatisfactorily addressed in the attached document. Assuming (conceptually) that the attached is acceptable, as I see it, the only remaining issue is what we have been referring to as the “Jon” issue, which I hope to work out with your side and Judge Hazouri on Friday. Let’s get done! :) Of course, the content of this email and the attached document are sent for discussion purposes; and neither party shall be bound by any settlement until the SA is properly signed by me and the Town. Thank you for working with me toward our common goal. UNFORTUNATELY, I RECEIVE TOO MANY EMAILS ON A DAILY BASIS. THE RESULT IS THAT I DO NOT HAVE A CHANCE TO REVIEW THEM ALL; AND MANY I DO NOT SEE AT ALL. I ENCOURAGE YOU TO CONTINUE TO SEND ME EMAILS; AND, IF YOU DON’T HEAR FROM ME WITHIN 48 HOURS, I URGE YOU TO CALL ME. I ALSO ASK YOU TO CC MS. BRENDA RUSSELL (BRUSSELL@COMMERCE-GROUP.COM <mailto:BRUSSELL@COMMERCE-GROUP.COM> ) OR TO CALL HER (954 570 3513). THANK YOU FOR YOUR COOPERATION. 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/> 7AAA552FF97C4F499B0444EB436F2A58@namprd09.prod.outlook.com <DM5PR16MB145184C1599FA379BC75C712855E0@DM5PR16MB1451.namprd16.prod.outlook.com> Joanne: Attached is a redraft of the Settlement Agreement (the “SA”) which you sent to Bill Ring by email on October 26, 2017. It may be a bit rough. I need to go over it again. I am sending it to counsel for any comments that they may have. Afte 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 Marty O'Boyle Marty O'Boyle Trey Nazzaro Trey Nazzaro moboyle@commerce-group.com moboyle@commerce-group.com tnazzaro@gulf-stream.org tnazzaro@gulf-stream.org II=[CID=58200af1-8a99-b249-8cb2-69cffdae8bd8;IDXHEAD=D351CEBCA1;IDXCOUNT=1];TFR=NotForking;Version=Version 15.20 (Build 2157.0), Stage=H4;UP=10;DP=1C5 Joanne O'Connor SMTP JOConnor@jonesfoster.com JOConnor@jonesfoster.com Joanne O'Connor Jonathan O'Boyle SMTP joboyle@oboylelawfirm.com joboyle@oboylelawfirm.com Jonathan O'Boyle William Ring SMTP wring@commerce-group.com wring@commerce-group.com William Ring Brenda Russell SMTP brussell@commerce-group.com brussell@commerce-group.com Brenda Russell Nick Taylor SMTP ntaylor@oboylelawfirm.com ntaylor@oboylelawfirm.com Nick Taylor Giovani Mesa SMTP gmesa@oboylelawfirm.com gmesa@oboylelawfirm.com Giovani Mesa 'robertrivas@comcast.net' SMTP robertrivas@comcast.net robertrivas@comcast.net 'robertrivas@comcast.net' GulfStreamSettlementAgreement10.30.17536pm.pdf .pdf GulfSt~1.pdf GulfStreamSettlementAgreement10.30.17536pm.pdf application/pdf 575E082AEC8FD84393BB8E181E3848B8@namprd09.prod.outlook.com EnUs Ex A Case List10.30.17.pdf .pdf ExACas~1.pdf Ex A Case List10.30.17.pdf application/pdf BA8EED80A7C07D4B99A207AE27AD3F15@namprd09.prod.outlook.com EnUsJoanne: Attached is a redraft of the Settlement Agreement (the “SA”) which you sent to Bill Ring by email on October 26, 2017. It may be a bit rough. I need to go over it again. I am sending it to counsel for any comments that they may have. After much thought and considering all factors, including the carve-outs, I have simplified the SA. IN that connection, I point out the below, which I believe are the substantive changes to your draft (utilizing the same numbered paragraphs as in the attached): I have provided a release to the Town, the Commissioners, etc. and the other Defendants in the various records suits. The schedule of open records cases (a draft is attached – please review) excludes Case #4474 as discussed. In this connection, I ask you to begin the preparation of Dismissals with prejudice with each party bearing its own fees and costs. I have provided for a General Release from (what I have defined as) the “Gulf Stream Parties” to (what I have defined as) the “O’Boyle Parties”. The above changes emanate from my thoughts regarding the following: The issue with my Insurer. Assuming the attached draft works, that issue now goes away as an open issue. An alternative, suggested by Jeff Hochman, which you seemed to reject, would be an Indemnity. I have eliminated the concept of the “Joining Parties”. After much thought, it made the agreement much more complex than necessary. Any extraneous cases (e.g.: the Sweetapple Slander Case (the “SSC”)) could be handled separately. So that you know, I am open to discussing the SSC and any other extraneous cases, at any time, if requested to do so. Joanne, the attached should work. Let’s look at what it accomplishes: It gets rid of the Records Litigation as aforesaid. It gets rid of the “Insurance Issue”, which I (reluctantly) take on. It provides for the withdrawal of all existing unfulfilled requests, which eliminates the possibility of future litigation in connection therewith. It discourages future Records Requests. I am prepared to address any issues or items which you may raise to the extent not addressed or unsatisfactorily addressed in the attached document. Assuming (conceptually) that the attached is acceptable, as I see it, the only remaining issue is what we have been referring to as the “Jon” issue, which I hope to work out with your side and Judge Hazouri on Friday. Let’s get done! J Of course, the content of this email and the attached document are sent for discussion purposes; and neither party shall be bound by any settlement until the SA is properly signed by me and the Town. Thank you for working with me toward our common goal. UNFORTUNATELY, I RECEIVE TOO MANY EMAILS ON A DAILY BASIS. THE RESULT IS THAT I DO NOT HAVE A CHANCE TO REVIEW THEM ALL; AND MANY I DO NOT SEE AT ALL. I ENCOURAGE YOU TO CONTINUE TO SEND ME EMAILS; AND, IF YOU DON’T HEAR FROM ME WITHIN 48 HOURS, I URGE YOU TO CALL ME. I ALSO ASK YOU TO CC MS. BRENDA RUSSELL (HYPERLINK "mailto:BRUSSELL@COMMERCE-GROUP.COM"BRUSSELL@COMMERCE-GROUP .COM) OR TO CALL HER (954 570 3513). THANK YOU FOR YOUR COOPERATION. 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 message/rfc822 01504F67373B1D4DAE6FC4AFF1F74144@gulf-stream.org EnUs From: HYPERLINK "mailto:moboyle@commerce-group.com"Marty O'Boyle Sent: Tuesday, November 07, 2017 3:14 PM To: HYPERLINK "mailto:scottmorgan75@gmail.com"scottmorgan75@gmail.com Cc: HYPERLINK "mailto:brussell@commerce-group.com"Brenda Russell Subject: RE: Proposed Settlement Agreement (redraft) from you - Gulfstream Scott: Below are the fundamental differences as I recall, without looking at my draft: The Insurance Issue is alive and well. I offer a release to the Town for the records cases (all of them, except 4474 – which involves the insurance co.). That’s all I can do. Joanne and Sweetapple both agreed to this. Hochman suggested an Indemnity. Joanne said no. Thus what I offered up. Beyond that, I can offer no more. CAFI is not a “Marty” issue. Please feel free to speak to Bill. Based on my short conversation with him, I don’t think that is an issue to resolution. As to the OLF’s lawyer’s, that’s it. They will not agree to anything more. As I see it, they are the main events. I reattach my email to Joanne with my last draft. Based upon your own agreement, the Town clearly wants the “non-records” litigation to continue. I invite you to tweak my last version. I remind you of the benefits (see below). Please consider the below, looking at the “Big Picture” . Let’s look at what it accomplishes: It gets rid of the Records Litigation as aforesaid. It gets rid of the “Insurance Issue”, which I (reluctantly) take on. It provides for the withdrawal of all existing unfulfilled requests, which eliminates the possibility of future litigation in connection therewith. It discourages future Records Requests. Please advise where you would like to go from here. What more can I say? I remind you that this communication is for settlement purposes only and may be used for no other purpose. Additionally, I remind you that until formal docs are signed and approved by all, unfortunately, finality as to a final resolution will continue to escape us. I know you understand. 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: scottmorgan75@gmail.com [mailto:scottmorgan75@gmail.com] Sent: Tuesday, November 7, 2017 12:31 PM To: Marty O'Boyle <moboyle@commerce-group.com> Subject: Re: Proposed Settlement Agreement (redraft) from you - Gulfstream Marty----what is going on here? I worked over the weekend and yesterday on the SA you told me you wanted to use. You sent it to me (attached) with the following email: Scott – below was an “OOPS!”. Please delete, as this one is the correct one. All relevant communications are now attached. I await hearing back from you. Now you send me another SA and say that’s the one. Last week you give me a SA and I work on it. Now you say that’s the wrong one--use a new one. Give me a call please. I just opened your new attachment and frankly I just don’t understand what the problem is. Am I misreading these SA’s? Aside from some language differences, I just don’t see the differences. There are no attachments to this document that you just sent me but I assume it’s the same as the cases and parties identified in my SA. Or is there some difference? Frankly, this is ridiculous. For you and for me. I could respond to your highlights below but it isn’t important. We both get it: You feel like we backed out of an agreement; We feel like you did. OK. We have different perceptions of who did what but does it really matter? We are either going to wrap this up or not, and Marty, I keep saying it: I just don’t see what the differences are. Call me and let’s go over this latest document you sent me and the one I sent you. I really don’t care whose document we use so long as we agree on the terms. That’s what I’m trying to figure out. Do we agree on the terms? From: HYPERLINK "mailto:moboyle@commerce-group.com"Marty O'Boyle Sent: Tuesday, November 07, 2017 11:50 AM To: HYPERLINK "mailto:scottmorgan75@gmail.com"scottmorgan75@gmail.com ; HYPERLINK "mailto:smorgan@gulf-stream.org"smorgan@gulf-stream.org Cc: HYPERLINK "mailto:brussell@commerce-group.com"Brenda Russell Subject: RE: Proposed Settlement Agreement (redraft) from you - Gulfstream CONTINUING ON RE BELOW Below was a “misfire”, in that it was unfinished, unreviewed, unedited and incomplete. A new version will follow. Please disregard. As requested, please work from my doc, as I believe it “rings the bell. Your doc doesn’t work, for a host of reasons, all of which have been explained in emails over the last few months (if not few weeks). See areas “highlighted” below. [Despite your hyperbole and restatement and inaccurate recitation of history, I look for a fair and amicable settlement, as I have preached for years. What you propose is a “Giant step backwards”; and if you keep it up, we will just continue to spin wheels as in the Mississippi Mud without a posi-traction differential” What’s your pleasure? Again, if you wish to “tweak”, please do so from my last draft.] This email is sent for settlement purposes only and may not be iused for any other purpose. UNFORTUNATELY, I RECEIVE TOO MANY EMAILS ON A DAILY BASIS. THE RESULT IS THAT I DO NOT HAVE A CHANCE TO REVIEW THEM ALL; AND MANY I DO NOT SEE AT ALL. I ENCOURAGE YOU TO CONTINUE TO SEND ME EMAILS; AND, IF YOU DON’T HEAR FROM ME WITHIN 48 HOURS, I URGE YOU TO CALL ME. I ALSO ASK YOU TO CC MS. BRENDA RUSSELL (HYPERLINK "mailto:BRUSSELL@COMMERCE-GROUP.COM"BRUSSELL@COMMERCE-GROUP .COM) OR TO CALL HER (954 570 3513). THANK YOU FOR YOUR COOPERATION. 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: HYPERLINK "mailto:scottmorgan75@gmail.com"scottmorgan75@gmail.com [mailto:scottmorgan75@gmail.com] Sent: Tuesday, November 7, 2017 10:35 AM To: Marty O'Boyle <HYPERLINK "mailto:moboyle@commerce-group.com"moboyle@commerce-group.com> Subject: Re: Proposed Settlement Agreement (redraft) from you - Gulfstream Marty—you apparently didn’t read or understand the SA because paragraph 3 specifically addresses “Fatal Area 1”, which provides a release of the lawyers by the town without a reciprocal release by them of the town. [The Release is conditional. That is unacceptable to the lawyers. We both know (and knew that), your lawyers agreed to my language. The Lawyers don’t trust you. Take it or leave it. Moving on.] Your second “Fatal Area” suggests that we must use your release---I suppose you mean the release with the highlighted portions. That cannot be done because that document includes several incomplete paragraphs, several redundant ones, additional “joining” parties, and some mis-numbered sections. That is why I revised it-- to fill in the blanks, get rid of unrelated joining parties, and to make it more understandable. Our SA is your SA—just with tighter, clearer language. It is not the Town’s SA vs. O’Boyle SA. This contains the terms we both already agree on. [The release I provided is a release from the Town to me and not the other way, there are too many exclusions to deal with, all of which we gave you a right to cure and some of which your attorneys agreed to. You now do another “about face”. Take it or leave it”.] CAFI is your third “Fatal Area.” Your position: “ I don’t see CAFI as an issue.” This is absurd. If you think “CAFI can be resolved without fuss” then do it. If you can resolve it, resolve it. Don’t just say it isn’t an issue. [CAFI listed as a “Fatal Issue” was in error. The operative language there follows: I spoke to Bill briefly and he thinks CAFI can be resolved without fuss.] I worked on this with you several months ago and it went nowhere. Recently, I felt you were sincere when you reached out to me to nail down this SA. So I compared the SA’s and concluded they are the same, at least in intentions if not in exact language. I cleaned up the language and prepared a SA that provides the terms you set forth. These are the same terms that we agreed to before. {You got it wrong. Generally stated, you insisted that we deal with your counsel. We did. They agreed, didn’t agree, one changed their mind, the other then offered and alternate result, and we (as I said before) ended up playing the “Mole game”. A lot has happened since you backed out of your last agreement (see emails). I’m trying to get done, but you must deal with reality. Please go back and read the history and speak to your attorneys that you had handle things for you, starting with Hudson Gil who gave us an ultimate with a “Bogus Agreement” and then when we tried to work with him, he wouldn’t return phone calls; and perhaps, upon doing so, you will then better understand. What I offer is a “Big Win” for the Town, as I state in my email to you of yesterday at 5:52pm. You just need to decide whether the offer on the table is “good for the taxpayers of Gulfstream economically”. Of course, I am always open to “tweaking”, as I’m not that good.] We are both busy men, Marty. I have a business to run and I’m not going to spend more time going back and forth with you on terms that are already agreed to by both sides. The only issue I see is CAFI. It’s an issue for you and an issue for us. You seem confident that “CAFI can be resolved without fuss” so go ahead and resolve it. Once that’s done, I’ll recommend the Commission accept this SA. Also, you probably know that you have a Stopdirtygovernment case that is on the trial schedule and can be called as early as Monday. Your lawyers and ours’ are currently preparing for a Monday call. [Wasn’t it you who said in the CG Case that until a settlement is reached that we go forward. I assume that your position remains the same. Having said that, “let’s get done”! J] Now is the time to wrap this up, Marty. Our November Commission meeting is this Friday. That’s the time to get the SA approved. [I agree] [Scott – I agree that we are both busy. You know where I’m coming from. Given the totality of the circumstances, you should “jump all over” my offering. In lieu of an agreement, I will (with great reluctance) continue to litigate the other cases. Do you really see that as beneficial to the taxpayers? Really?] From: HYPERLINK "mailto:moboyle@commerce-group.com"Marty O'Boyle Sent: Monday, November 06, 2017 5:52 PM To: HYPERLINK "mailto:scottmorgan75@gmail.com"scottmorgan75@gmail.com Cc: HYPERLINK "mailto:brussell@commerce-group.com"Brenda Russell Subject: FW: Proposed Settlement Agreement (redraft) from you - Gulfstream Scott – I briefly reviewed your email. Initially, I see 3 fatal areas, that we need to overcome before going any further. The lawyers at the firm, will not release the Town. The “Chris O’Hare” extortion statement and the Town’s refusal for a Non-Disparagement killed that; and the Town’s agreement as in my doc and now what you propose creates more distrust and they just won’t agree to it. I offered a Release, if it works, cool. If not, we need to address the other issues, which my draft “snuffed”. I don’t see CAFI as an issue. I spoke to Bill briefly and he thinks CAFI can be resolved without fuss. That’s where we start. Please consider the below, looking at the “Big Picture” . Let’s look at what it accomplishes: It gets rid of the Records Litigation as aforesaid. It gets rid of the “Insurance Issue”, which I (reluctantly) take on. It provides for the withdrawal of all existing unfulfilled requests, which eliminates the possibility of future litigation in connection therewith. It discourages future Records Requests. Please advise where you would like to go from here. UNFORTUNATELY, I RECEIVE TOO MANY EMAILS ON A DAILY BASIS. THE RESULT IS THAT I DO NOT HAVE A CHANCE TO REVIEW THEM ALL; AND MANY I DO NOT SEE AT ALL. I ENCOURAGE YOU TO CONTINUE TO SEND ME EMAILS; AND, IF YOU DON’T HEAR FROM ME WITHIN 48 HOURS, I URGE YOU TO CALL ME. I ALSO ASK YOU TO CC MS. BRENDA RUSSELL (HYPERLINK "mailto:BRUSSELL@COMMERCE-GROUP.COM"BRUSSELL@COMMERCE-GROUP .COM) OR TO CALL HER (954 570 3513). THANK YOU FOR YOUR COOPERATION. 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: HYPERLINK "mailto:scottmorgan75@gmail.com"scottmorgan75@gmail.com [mailto:scottmorgan75@gmail.com] Sent: Monday, November 6, 2017 5:12 PM To: Marty O'Boyle <HYPERLINK "mailto:moboyle@commerce-group.com"moboyle@commerce-group.com> Subject: Re: Proposed Settlement Agreement (redraft) from you - Gulfstream Marty, Fortunately, I didn’t get called up so my one day of jury service is over. But the time there did give me a chance to review and prepare the SA for you to review. Attached is the SA. I took your comments and Joanne’s and matched them. Some of the clauses or paragraphs I thought were redundant so took those out and I cleaned up some of the language in the remaining paragraphs to cover the points being made. You will see my notes of explanation in Red beneath the important paragraphs. I am not hiding anything here. There is no tricky language or legal gymnastics. This SA is for you and your entities as well as your attorneys. It is for the Town and its employees and attorneys. I specifically avoid including joint parties or ancillary parties or adding more people for signatures. This is you and this is the Town. It is also your people and our people and your attorneys and our attorneys. Regarding attorneys, although the Town releases your attorneys, your attorneys don’t have to release the Town. Instead, if they take action in the future, then our release of them is void. But at the outset, they don’t need to get involved to sign a release of claims. We dismiss the cases and you withdraw the PRR’s. Then we add the rights you retain from the prior settlement, the criminal matter, and the Hidden Harbor issues. And that’s it. Regarding CAFI, Joanne told me that Bill is no longer a board member or officer. This is important. CAFI needs to be addressed so if you can put CAFI into this SA, and either you or Bill sign for it, then we need to do that. If you cannot do that, then our settlement needs to be conditioned on those three CAFI cases being voluntarily dismissed. They can’t be left hanging out there and I won’t take the agreement to the Commission without it being addressed. If you have another suggestion, I’m open to it but this is the best I could come up with. I think we are both on the same page Marty. Let me know if you agree. And let me know your thoughts on handling CAFI. Scott From: HYPERLINK "mailto:moboyle@commerce-group.com"Marty O'Boyle Sent: Monday, November 06, 2017 2:32 PM To: HYPERLINK "mailto:scottmorgan75@gmail.com"scottmorgan75@gmail.com Subject: RE: Proposed Settlement Agreement (redraft) from you - Gulfstream Scott – I know you will address when you can. PS: Don’t get on a 2 month trial! J UNFORTUNATELY, I RECEIVE TOO MANY EMAILS ON A DAILY BASIS. THE RESULT IS THAT I DO NOT HAVE A CHANCE TO REVIEW THEM ALL; AND MANY I DO NOT SEE AT ALL. I ENCOURAGE YOU TO CONTINUE TO SEND ME EMAILS; AND, IF YOU DON’T HEAR FROM ME WITHIN 48 HOURS, I URGE YOU TO CALL ME. I ALSO ASK YOU TO CC MS. BRENDA RUSSELL (HYPERLINK "mailto:BRUSSELL@COMMERCE-GROUP.COM"BRUSSELL@COMMERCE-GROUP .COM) OR TO CALL HER (954 570 3513). THANK YOU FOR YOUR COOPERATION. 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: HYPERLINK "mailto:scottmorgan75@gmail.com"scottmorgan75@gmail.com [mailto:scottmorgan75@gmail.com] Sent: Monday, November 6, 2017 9:16 AM To: Marty O'Boyle <HYPERLINK "mailto:moboyle@commerce-group.com"moboyle@commerce-group.com> Subject: Re: Proposed Settlement Agreement (redraft) from you - Gulfstream Marty— am at jury duty!! Not sure when I’ll be able to get you a copy. I’ll try tomorrow. Sent from my iPhone On Nov 6, 2017, at 6:43 AM, Marty O'Boyle <HYPERLINK "mailto:moboyle@commerce-group.com"moboyle@commerce-group.com> wrote: Scott – I am working\preparing for a major meeting today. I assuming you can get me the revised doc this am, I could likely get an hour of “quiet time” during the lunch break and maybe (just maybe) – assuming the comments shown on the markup (or annotated or enumerated) are minimal respond to you during the lunch break. No guarantee’s by way of timing given. All is still fresh in my mind regarding the content of my last draft, so it should be easy for me to respond; and do so quickly, despite being “on the move”. Time is not our friend for a host of reasons, including my schedule; and, with the passing of time, my memory. The issues should be non-existent (save – perhaps – some tweaking. Now is our chance. Let’s do it! J Of course, until formal docs are signed and approved by all, unfortunately, finality as to a final resolution will continue to escape us. I know you understand. Thanks! J UNFORTUNATELY, I RECEIVE TOO MANY EMAILS ON A DAILY BASIS. THE RESULT IS THAT I DO NOT HAVE A CHANCE TO REVIEW THEM ALL; AND MANY I DO NOT SEE AT ALL. I ENCOURAGE YOU TO CONTINUE TO SEND ME EMAILS; AND, IF YOU DON’T HEAR FROM ME WITHIN 48 HOURS, I URGE YOU TO CALL ME. I ALSO ASK YOU TO CC MS. BRENDA RUSSELL (HYPERLINK "mailto:BRUSSELL@COMMERCE-GROUP.COM"BRUSSELL@COMMERCE-GROUP .COM) OR TO CALL HER (954 570 3513). THANK YOU FOR YOUR COOPERATION. 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