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HomeMy Public PortalAboutPRR 14-1179REQUESTEE: RECORDS REQUEST (the "Request ") Date of Request: 7/31/14 Requestor's Request ID#: 665 Custodian of Records Town of Gulf Stream REQUESTOR: Airline Highway, LLC REQUESTOR'S CONTACT INFORMATION: E -Mail: records @commerce- group.com Fax: 954 -360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Provide all Public Records which would confirm that Jonathan R. O'Boyle was a permanent resident of the State of Florida on May 30, 2014, as stated in the Defendant's Motion To Disqualify The O'Boyle Law Firm, P.C., Inc. And, In The Alternative, For An Evidentiary Hearing. ADDITIONAL INFORMATION REGARDING REQUEST: THIS REQUEST IS MADE PURSUANT TO PUBLIC RECORDS ACT, CHAPTER 119 OF THE FLORIDA STATUTES AND IS ALSO REQUESTED UNDER THE COMMON LAW RIGHT TO KNOW, THE COMMON LAW RIGHT OF ACCESS; AND ANY STATUTORY RIGHT TO KNOW (INCLUDING, WITHOUT LIMITATION, ANY STATUTORY RIGHT OF ACCESS, AS APPLICABLE). THIS REQUEST IS ALSO MADE PURSUANT TO THE RIGHTS OF THE REQUESTOR PROVIDED IN THE FLORIDA CONSTITUTION. IT IS REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED IN ELECTRONIC FORM. IF NOT AVAILABLE IN ELECTRONIC FORM, IT IS REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED ON 11 X 17 PAPER. NOTE: IN ALL CASES (UNLESS IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119.07(4) (a) (2) ALL ELECTRONIC COPIES ARE REQUESTED TO BE SENT BY E -MAIL DELIVERY. PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC RECORDS REQUEST IN ADVANCE. It will be required that the Requestor approve of any costs, asserted by the Agency (as defined in Florida Statute, Chapter 119.01 (Definitions)), in advance of any costs imposed to the Requestor by the Agency. I:P/NPPJFRR 04.22.13 FORM .. TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail August 23, 2014 Airline Highway, LLC [mail to: records @commerce - group.com] Re: GS #1178 (664), #1179 (665), #1183 (663), #1195 (730), #1201 (731), #1202 (732), #1203 (733) Provide all Public Records demonstrating that Jonathan R. O'Boyle was domiciled in Florida on May 30, 2014, as stated in the Defendant's Motion to Disqualify The O'Boyle Law Firm, P.C., Inc. And, In The Alternative, For An Evidentiary Hearing. Provide all Public Records which would confirm that Jonathan R. O'Boyle was a permanent resident ofthe State ofFlorida on May 30, 2014, as stated in the Defendant's Motion To Disqualify The O'Boyle Law Firm, P.C., Inc. And, In The Alternative, For An Evidentiary Hearing. Provide all Public Records which would confirm the statement made by Attorney Sweetapple in the Introductory Paragraph on Page 1 of the Defendant's Motion To Disqualify The O'Boyle Law Firm, P.C., Inc. And in The Alternative, For An Evidentiary Hearing which reads as follows: "Jonathan R. O'Boyle has used the Pennsylvania professional corporation to establish an office or other regular presence in the State of Florida without being admitted to practice here generally and is thereby engaged in the unlicensed practice of law. Please provide all Public Records which confirm Attorney Sweetapple's statement in the first sentence of numbered paragraph 14 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was fled by Attorney Sweetapple. Please provide all Public Records which confirm Attorney Sweetapple's statement in the second sentence of membered paragraph 14 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. In paragraph 15 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, Attorney Sweetapple states (in the last sentence) "It should not be the subject of harassment, intimidation and air raids by opposing counsel and their client." We would askfor any Public Records confirming that both Plaintiffs Counsel and Plaintiff' (both) engaged in harassment, intimidation and air raids. In numbered paragraph 16 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C., Jonathan O'Boyle And William Ring, Esquire, Attorney Sweetapple uses the word "misconduct ". Please provide all Public Records which elaborate as to what the misconduct emanated from; and what the misconduct was. Dear Airline Highway, LLC. [mail to: records @commerce- group.com], The Town of Gulf Stream has received your public records requests dated July 31, 2014. If your request was received in writing, then the requests can be found at the following links: htty: / /www2.gulf- stream. ore /WebLink8 /0 /doc /I 7189/Pagel .aspx, httv://www2.gulf-stream.org/WebLink8/0/doc/I 7188/Pagel .asnx, http: / /www2. gulf- stream.orgfW ebLink8 /0 /doc /I7322/Pagel .astx, http: / /www2. gulf- stream.orgfWebLink8 /0 /doc /I 7373/Pagel . asg_x http:// www2.gulf- stream.orgfWebLink8 /0 /doc / 173 80/Pagel .aspx, htti):// www2.gulf- stream.orgfWebLink8 /0 /doc /17381/Pagel.aspx, and http:// www2.gulf- streatn.org/WebLink8 /0 /doc /17382/Pagel.asi)x. If your request was verbal, then the description of your public records request is set forth in the italics above. Please refer to the referenced number above with any future correspondence. The Town of Gulf Stream is currently working on a large number of incoming public records requests. The Town will use its very best efforts to respond to you in a reasonable amount of time with the appropriate response or an estimated cost to respond. Sincerely, Town Clerk Custodian of the Records TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail August 26, 2014 Airline Highway, LLC. [mail to: records @commerce - group.com] Re: GS #1179 (665) Provide all Public Records which would confirm that Jonathan R. O'Boyle was a permanent resident of the State of Florida on May 30, 2014, as stated in the Defendant's Motion To Disqualify The O'Boyle Law Firm, P. C., Inc. And, In The Alternative, For An Evidentiary Hearing. Dear Airline Highway, LLC [mail to: records @commerce - group.com], This letter is in response to the public records you have requested in your email received July 31, 2014. This correspondence is reproduced at the following link: ht_pt : / /www2.eulf- stream. ore /WebLink8 /0 /doc /17188/Pagel .asnx. Be advised that no such records exist. We consider this matter closed. Sincerely, Town Clerk Custodian of the Records TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via a -mail August 23, 2014 Airline Highway, LLC [mail to: records @commerce - group.com] Re: GS #1178 (664), #1179 (665), #1183 (663), #1195 (730), #1201 (731), 91202 (732), #1203 (733) Provide all Public Records demonstrating that Jonathan R. O'Boyle was domiciled in Florida on May 30, 2014, as stated in the Defendant's Motion to Disqualify The O'Boyle Law Firm, P. C, Inc. And, In The Alternative, For An Evidentiary Hearing. Provide all Public Records which would confirm that Jonathan R. O'Boyle was a permanent resident of the State of Florida on May 30, 2014, as stated in the Defendant's Motion To Disqualify The O'Boyle Law Firm, P. C., Inc. And, In The Alternative, For An Evidentiary Hearing. Provide all Public Records which would confirm the statement made by Attorney Sweetapple in the Introductory Paragraph on Page 1 of the Defendant's Motion To Disqualify The O'Boyle Law Firm, P.C., Inc. And in The Alternative, For An Evidentiary Hearing which reads as follows: "Jonathan R. O'Boyle has used the Pennsylvania professional corporation to establish an office or other regular presence in the State of Florida without being admitted to practice here generally and is thereby engaged in the unlicensed practice of law. Please provide all Public Records which confirm Attorney Sweetapple's statement in the first sentence of numbered paragraph 14 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. Please provide all Public Records which confirm Attorney Sweetapple's statement in the second sentence of numbered paragraph 14 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. In paragraph 15 of the Defendant's Motion For Sanctions Against Plaintiff' Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, Attorney Sweetapple states (in the last sentence) "It should not be the subject of harassment, intimidation and air raids by opposing counsel and their client." We would ask for any Public Records confirming that both Plaintiffs Counsel and Plaintiff (both) engaged in harassment, intimidation and air raids. In numbered paragraph 16 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, Attorney Sweetapple uses the word "misconduct ". Please provide all Public Records which elaborate as to what the misconduct emanated from; and what the misconduct was. Dear Airline Highway, LLC. [mail to: records @commerce - group.com], The Town of Gulf Stream has received your public records requests dated July 31, 2014. If your request was received in writing, then the requests can be found at the following links: http: / /www2. gulf- stream. ore(WebLink8 /0 /doc /17189/Pagel .aspx, http://www2.gulf-stream.org/WebLink8/0/doc/17188/Pagel.aspx , httv://www2.gulf-stream.org/WebLink8/O/doc/17322/Pagel.asvx , h"://www2.gulf-streain.org/WebLink8/0/doc/17373/Pagel.asl)x http:// www2.gulf- stream.org[WebLink8 /0 /doc /17380/Pagel . aspx, http: / /www2. gulf - stream. ore /WebLink8 /0 /doc /I7381 /Page Laspx, and http:// www2.gulf- stream.orgfWebLink8 /0 /doc /17382/Pagel.asyx. If your request was verbal, then the description of your public records request is set forth in the italics above. Please refer to the referenced number above with any future correspondence. The Town of Gulf Stream is currently working on a large number of incoming public records requests. The Town will use its very best efforts to respond to you in a reasonable amount of time with the appropriate response or an estimated cost to respond. Sincerely, Town Clerk Custodian of the Records