HomeMy Public PortalAboutPRR 20-2812Renee Basel
From: records <records@commerce-group.com>
Sent: Monday, August 31, 2020 10:32 AM
To: Renee Basel
Cc: Marty O'Boyle; Michelle Melicia
Subject: This is a Records Request pursuant to Chapter 119 of the Florida Statutes (GS# 5003)
Attachments: Gulf Stream RR #5003 8.31.2020.pdf
[NOTICE: This message originated outside of the Town of Gulfstream -- DO NOT CLICK on links or open attachments
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Please see the attached Records Request. We will hand deliver the $250.00 deposit check for the attached.
Thank you,
Records Dept.
954-360-7713
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Public Records Request #5003 — Martin R. O'Bovle - Public Agency — Town of Gulf
Stream
Section I — Instructions
Section II - Request for Public Records Related to Martin O'Boyle Criminal
Case
I. Instructions:
1. This is a request for public records under Art. I, §24, Fla. Const., Chapter 119, and the
common law right to know made by Martin O'Boyle. This request is for records that may
be useful in his criminal trial and is being tendered with $250. The request has multiple
subparts. The expectation is that the Town will fill out each subpart as it is compiled so
that Martin O'Boyle will not have to wait until all records are compiled prior to production.
Martin O'Boyle is a criminal defendant in a case initiated by the Town of Gulf Stream
which currently has a trial date set for December 1, 2020, so time is of the essence. If the
Town feels that it is prudent to issue a separate request number and/or estimate for costs
for each subpart for administrative purposes, there will be no objection except if the Town
insists on a $250 fee for each request. In addition, Martin O'Boyle has attempted to set
forth the below subparts in terms of ease of production to assist the Town.
2. The phrase "pertaining to" or "related to" shall have the same effect as discussed in Grinell
Corp. v. Palms 2100 Ocean Boulevard Ltd., 924 So.2d 887 (Fla. 4'1' DCA 2006).
3. The term "public records" shall have the same definitions contemplated by § 119.011(12)
and Art. I, §24, Fla. Const. Notice: emails, text messages, encrypted messaging service
messages, social media writings, and metadata can be public records. Also, Note: public
records of the Town can be created, sent or received through private channels; for example,
without limitation, a text message or email to or from a government official to or from a
citizen.
4. If you contend that certain records held by your public agency are not "public records", as
referenced above, it is incumbent upon the public agency to have them reviewed by a Court
or be subject to attorneys fees or penalties under §119.10, Fla. Stat. or § 119.12, Fla. Stat.
O'Boyle v. Gulf Stream, 257 So.3d 1036 (Fla. 411' DCA 2018).
5. All electronic public records shall be produced in their original native format and with
attachments if applicable.
6. If a special service charge is to be assessed, please give notice in advance at
nlco ;r (•,)111niLr:L-1210uo.c+on and pmi.L i,i Loin. In addition, we will
insist that you keep contemporaneous time records detailing the actions in furtherance of
production for inspection post -production.
1
7. You are required to make a good faith effort to find responsive public records which
includes prompt acknowledgement of the request, and efforts to determine from others in
the public agency (or those working on the agencies behest or behalf of the public agency
Wisner v. Tampa, 601 So.2d 296 (Fla. 2d DCA 1992)), whether records exist and the
location of those records.
8. The "Town of Gulf Stream" shall mean the municipal corporation itself, its elected or
appointed officials, its employees, its police, its contractors, its representatives, and/or its
agents. This also includes any person acting on behalf of or at the behest of the municipal
corporation itself, its elected or appointed officials, its employees, its police, its contractors,
its representatives, and/or its agents. Note: known agents of the Town of Gulf Stream who
are subject to Chapter 119 are: (1) Jones Foster; (2) Sweetapple Broeker and Varkas; (3)
Johnson Anselmo Law Firm; (4) Weiss Serotta; (5) Richman Greer (6) Shraiberg, Landau
& Page; and any other attorney's or consultants engaged by the Town since January 1,
2013.
9. If you feel the need to seek clarification, please do so promptly and with specificity. Please
identify your proposed understanding and your proposed search methodology with
particularity.
II. Request for Public Records Related to Martin O'Boyle Criminal Case: Please
Produce Copies of the following public records as defined by Chapter 119, Art. 1.
§24, Fla. Const., and/or the Common Law
1. All communications between the Town of Gulf Stream and Calvin, Giordano &
Associates) related to Request #2704.
2. All public records of the Town of Gulf Stream which pertain to Martin O'Boyle's
reputation in the community.
3. All public records of the Town of Gulf Stream which pertain to Martin O'Boyle's being
obstructionist, defiant, or disruptive.
4. All public records created, sent or received by the Town of Gulf Stream which pertain to
signage, speech, pamphlets, advertisements, mailers, or banners (whether displayed in air,
sea, land, or electronically) which the Town attributes to Martin O'Boyle since January 1,
2014.
5. All interagency communication which pertain: (1) to a September 22, 2015 Incident at
Town Hall regarding Martin O'Boyle; (2) to Martin O'Boyle's character; and/or (3) to
State v. O'Boyle, 2015MM012872A now pending in the 15`1' Judicial Circuit.
6. All text messages created, sent or received by Scott Morgan since January 1, 2013.
2
7. All text messages caused or instructed to be sent by Scott Morgan since January 1, 2013
8. All text messages created, sent, or received by every person within the definition of Town
of Gulf Stream, including without limitation, Robert Sweetapple and Joanne O'Connor.
9. All text messages on any phone issued or used by the Town Police dating back to January
1, 2013. The word "phone" as used herein includes without limitation, phones in storage,
phones in current use, phones previously used, and includes without limitation, personal
phones in current use and previous use.
10. All public records that were created by, sent by or received by the Town of Gulf Stream
(especially to or from any State or Federal Attorney General's office, State Attorney's
office, or Federal, State, County, or Local law enforcement agency) which pertains to or
mentions: (1) Martin O'Boyle since January 1, 2014; (2) a September 22, 2015 Incident
at Town Hall regarding Martin O'Boyle; and/or (3) State v. O'Boyle, 2015MM012872A
now pending in the 15►1' Judicial Circuit.
11. All electronic transmissions created by, sent by or received by Scott Morgan which pertain:
(I) to Martin O'Boyle since January 1, 2014; (2) to a September 22, 2015 Incident at Town
Hall regarding Martin O'Boyle; and/or (3) to State v. O'Boyle, 2015MM012872A now
pending in the 15`h Judicial Circuit.
12. All electronic transmissions caused or instructed to be sent at Scott Morgan's behest or
behalf which pertain: (1) to Martin O'Boyle since January 1, 2014; (2) to a September 22,
2015 Incident at Town Hall regarding Martin O'Boyle; and/or (3) to State v. O'Boyle,
2015MM012872A now pending in the 15th Judicial Circuit.
13. All electronic transmissions created by, sent by or received by any member of the Gulf
Stream Police (past or present) which pertain: (1) to Martin O'Boyle since January 1, 2014;
(2) to a September 22, 2015 Incident at Town Hall regarding Martin O'Boyle; and/or (3)
to State v. O'Boyle, 2015MM012872A now pending in the 15`1' Judicial Circuit.
3
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
September 1, 2020
Martin E. O'Boyle [e-mail to: records@commerce-group.com]
Re: GS #2812 (Request for Public Records Related to Martin O'Boyle Criminal Case)
Request for Public Records Related to Martin O'Boyle Criminal Case
Dear Martin E. O'Boyle [e-mail to: meo@commerce-group.com]:
Thank you for your Facilitation Fee of $250.00 by check #52414 on August 31, 2020 for the
public record request described above, received by the Town on August 31, 2020. The Town
will apply this to the production of records in accordance with the 2018 Settlement Agreement.
The original request can be found at the following link:
https://portal.laserfiche.com/Portal/DocView.aspx?id=173216&repo=r-43 0100cc
The Town will use its very best efforts to respond to you in a reasonable amount of time with the
appropriate response.
Sincerely,
ttectl ,-.(24ef
As requested by Rita Taylor
Town Clerk, Custodian of the Records
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
September 17, 2020
Martin E. O’Boyle [e-mail to: records@commerce-group.com]
Re: GS #2812 (Request for Public Records Related to Martin O'Boyle Criminal Case)
Request for Public Records Related to Martin O’Boyle Criminal Case
Dear Martin E. O’Boyle [e-mail to: meo@commerce-group.com]:
The original request can be found at the following link:
https://portal.laserfiche.com/Portal/DocView.aspx?id=173216&repo=r-430100cc
You have asked the Town to identify our proposed understanding of your request and our
proposed search methodology. You have indicated that this is one request for public records,
and that “[t]he request has multiple subparts.” Your request seeks “Public Records Related to
Martin O’Boyle Criminal Case.” Based on this understanding, the Town will not provide you
with records that do not relate to the Martin O’Boyle Criminal Case, and do not relate to the
underlying September 22, 2015 incident at Town Hall to which various below sub-parts of your
request refer. The Town has outlined our search methods, when applicable, below.
You also state that you require advance notice of any special service charges that would be
applied to this request, pursuant to FS 119. Please be advised that this request will incur special
service charges, and until special service charges are approved by you, no charges will be
incurred by the Town in producing records.
1. All communications between the Town of Gulf Stream and Calvin, Giordano &
Associates) related to Request # 2704
a. This subpart of your request identifies the records sought with sufficient
specificity to permit the Town to identify the requested records. Public Records
Request GS 2704 made by Martin O’Boyle on April 16, 2019 sought “all
records . . . which mention or refer to Mar[t]in O’Boyle but limited to the incident
at the Town Hall on September 22, 2015 regarding Martin O’Boyle.” The Town
will include an estimate for their production pursuant to your request in
accordance with FS 119.07(4)(d).
2. All public records of the Town of Gulf Stream which pertain to Martin O’Boyle’s
reputation in the community.
a. This subpart of your request has not identified the records sought with sufficient
specificity to permit the Town to identify the records sought.
b. If you are seeking specific records that you can more clearly identify, please
identify the records with sufficient specificity to permit the Town to identify those
records you are seeking.
c. The Town understands you may believe these records are relevant to your
criminal case. To fulfill this part of your request, the Town of Gulf Stream
proposes a search of our records, from January 1, 2014 to the date of your request,
using the following search terms: O’Boyle and reputation; O’Boyle and
community. If this is not acceptable, please provide different or additional search
terms, or dates.
3. All public records of the Town of Gulf Stream which pertain to Martin O’Boyle’s being
obstructionist, defiant, or disruptive.
a. This subpart of your request has not identified the records sought with sufficient
specificity to permit the Town to identify the records sought.
b. If you are seeking specific records that you can more clearly identify, please
identify the records with sufficient specificity to permit the Town to identify those
records you are seeking.
c. The Town understands you may believe these records are relevant to your
criminal case. To fulfill this part of your request, the Town of Gulf Stream
proposes a search of our records, from January 1, 2014 to the date of your request,
using the following search terms: O’Boyle and obstruct; O’Boyle and defiant;
O’Boyle and disrupt. If this is not acceptable, please provide different or
additional search terms, or dates.
4. All public records created, sent or received by the Town of Gulf Stream which pertain to
signage, speech, pamphlets, advertisements, mailers, or banners (whether displayed in
air, sea, land, or electronically) which the Town attributes to Martin O’Boyle since
January 1, 2014.
a. This subpart of your request has not identified the records sought with sufficient
specificity to permit the Town to identify the records sought.
b. If you are seeking specific records that you can more clearly identify, please
identify the records with sufficient specificity to permit the Town to identify those
records you are seeking.
c. The Town understands you may believe these records are relevant to your
criminal case. To the extent there are records that the Town attributes to Martin
O’Boyle’s speech, Mr. O’Boyle has spoken at many Gulf Stream Town
Commission Meetings, which is reflected in videos (located at the Town of Gulf
Stream’s YouTube Channel,
https://www.youtube.com/channel/UCyJTjen2HMOSbss-CYOpzdQ) and
Meeting Minutes of the Gulf Stream Town Commission (available at the Town’s
Public Records repository,
https://portal.laserfiche.com/Portal/Browse.aspx?repo=r-430100cc and clicking
on the following items in succession: Town Clerk, Minutes, Commission, then the
year, followed by the month). If you would like the Town to review these publicly
available records to identify in which ones you are identified or identify yourself
as a speaker, let us know. There will be a service charge pursuant to FS
119.07(4)(d) for this review.
d. In addition to the records referenced in the preceding paragraph, to fulfill this part
of your request, the Town of Gulf Stream proposes a search of our records, from
January 1, 2014 to the date of your request, using the following search terms:
O’Boyle and sign; O’Boyle and speech; O’Boyle and pamphlet; O’Boyle and
advertisement; O’Boyle and mailer; O’Boyle and banner. If this is not acceptable,
please provide different or additional search terms.
5. All interagency communication which pertain: (1) to a September 22, 2015 Incident at
Town Hall regarding Martin O’Boyle; (2) to Martin O’Boyle’s character; and/or (3) to
State v. O’Boyle, 2015MM012872A now pending in the 15th Judicial Circuit.
a. Part of this subpart of your request, parts (1) and (3), were previously answered in
response to GS 2704 made by Martin O’Boyle on April 16, 2019 (“all records . . .
which mention or refer to Mar[t]in O’Boyle, but limited to the incident at the
Town Hall on September 22, 2015 regarding Martin O’Boyle”). The Town will
supplement those records to include responsive records from April 16, 2019 to the
date of this request.
b. The Town understands you may believe records responsive to part (2) of this
request are relevant to your criminal case. To fulfill part (2) of this subpart of your
request, the Town of Gulf Stream proposes a search of our records, from January
1, 2014 to the date of your request, using the following search terms: O’Boyle and
character. If this is not acceptable, please provide different or additional search
terms, or dates.
6. All text messages created, sent, or received by Scott Morgan since January 1, 2013.
a. This subpart of your request identifies the records sought with sufficient
specificity to permit the Town to identify the requested records.
b. Records responsive to this request were previously provided to you in response to
GS 2704 made by Martin O’Boyle on April 16, 2019 (“all records . . . which
mention or refer to Mar[t]in O’Boyle, but limited to the incident at the Town Hall
on September 22, 2015 regarding Martin O’Boyle”).
c. Based on our understanding, records responsive to subpart 6 of your request will
also be responsive to subpart 8 and included in that estimate.
7. All text messages caused or instructed to be sent by Scott Morgan since January 1, 2013.
a. This subpart of your request has not identified the records sought with sufficient
specificity to permit the Town to identify the records sought.
b. Specifically, there is no way to determine upon the review of a record if that
record was “caused or instructed to be sent by” a specific person.
c. If you are seeking specific records that you can more clearly identify, please
identify the records with sufficient specificity to permit the Town to identify those
records you are seeking.
d. Based on our understanding, although there is no way to determine upon the
review of a record whether a record was “caused or instructed to be sent by”
Mayor Scott Morgan, records responsive to subpart 7 of your request will also be
responsive to subpart 8 and included in that estimate.
8. All text messages created, sent, or received by every person within the definition of Town
of Gulf Stream, including without limitation, Robert Sweetapple and Joanne O’Connor.
a. This part of your request identifies the records sought with sufficient specificity to
permit the Town to identify the requested records.
b. Records responsive to this request were previously provided to you in response to
GS 2704 made by Martin O’Boyle on April 16, 2019 (“all records . . . which
mention or refer to Mar[t]in O’Boyle, but limited to the incident at the Town Hall
on September 22, 2015 regarding Martin O’Boyle”).
c. Based on our understanding, the Town will provide an estimate to supplement
those records with additional text messages from April 16, 2019 to the date of
your request.
9. All text messages on any phone issued or used by the Town Police dating back to January
1, 2013. The word “phone” as used herein includes without limitation, phones in
storage, phones in current use, phones previously used, and includes without limitation,
personal phones in current use and previous use.
a. This part of your request identifies the records sought with sufficient specificity to
permit the Town to identify the requested records.
b. Records responsive to this request were previously provided to you in response to
GS 2704 made by Martin O’Boyle on April 16, 2019 (“all records . . . which
mention or refer to Mar[t]in O’Boyle, but limited to the incident at the Town Hall
on September 22, 2015 regarding Martin O’Boyle”).
c. Based on our understanding, records responsive to subpart 9 of your request will
also be responsive to subpart 8 and included in that estimate.
10. All public records that were created by, sent by or received by the Town of Gulf Stream
(especially to or from any State or Federal Attorney General’s office, State Attorney’s
office, or Federal, State, County, or Local law enforcement agency) which pertains to or
mentions: (1) Martin O’Boyle since January 1, 2014; (2) a September 22, 2015 Incident
at Town Hall regarding Martin O’Boyle; and/or (3) State v, O’Boyle, 2015MM012872A
now pending in the 15th Judicial Circuit.
a. Part of this subpart of your request, parts (2) and (3), were previously answered in
response to GS 2704 made by Martin O’Boyle on April 16, 2019 (“all records . . .
which mention or refer to Mar[t]in O’Boyle, but limited to the incident at the
Town Hall on September 22, 2015 regarding Martin O’Boyle”). The Town will
provide an estimate to supplement those records to include responsive records
from April 16, 2019 to the date of this request.
b. Based on our understanding, records responsive to part (1) of this subpart will
also be responsive to parts (2) and (3) as indicated above.
11. All electronic transmissions created by, sent by or received by Scott Morgan which
pertain: (1) to Martin O’Boyle since January 1, 2014; (2) to a September 22, 2015
Incident at Town Hall regarding Martin O’Boyle; and/or (3) to State v O’Boyle,
2015MM012872A now pending in the 15th Judicial Circuit.
a. Part of this subpart of your request, parts (2) and (3), were previously answered in
response to GS 2704 made by Martin O’Boyle on April 16, 2019 (“all records . . .
which mention or refer to Mar[t]in O’Boyle, but limited to the incident at the
Town Hall on September 22, 2015 regarding Martin O’Boyle”).
b. Based on our understanding, records responsive to part (1) of this subpart will
also be responsive to parts (2) and (3); and records responsive to subpart 11 of
your request will also be responsive to subpart 10 and included in that estimate.
12. All electronic transmissions caused or instructed to be sent at Scott Morgan’s behest or
behalf which pertain: (1) to Martin O’Boyle since January 1, 2014; (2) to a September
22, 2015 Incident at Town Hall regarding Martin O’Boyle; and/or (3) to State v O’Boyle,
2015MM012872A now pending in the 15th Judicial Circuit.
a. This subpart of your request has not identified the records sought with sufficient
specificity to permit the Town to identify the records sought.
b. Specifically, there is no way to determine upon the review of a record if that
record was “caused or instructed to be sent at” the direction of a specific person.
c. If you are seeking specific records that you can more clearly identify, please
identify the records with sufficient specificity to permit the Town to identify those
records you are seeking.
d. Based on our understanding, although there is no way to determine upon the
review of a record whether a record was “caused or instructed to be sent at”
Mayor Scott Morgan’s behest or behalf, records responsive to subpart 12 of this
request will also be responsive to subpart 10 and included in that estimate.
13. All electronic transmissions created by, sent by or received by any member of the Gulf
Stream Police (past or present) which pertain: (1) to Martin O’Boyle since January 1,
2014; (2) to a September 22, 2015 Incident at Town Hall regarding Martin O’Boyle;
and/or (3) to State v O’Boyle, 2015MM012872A now pending in the 15th Judicial
Circuit.
a. Part of this subpart of your request, parts (2) and (3), were previously answered in
response to GS 2704 made by Martin O’Boyle on April 16, 2019 (“all records . . .
which mention or refer to Mar[t]in O’Boyle, but limited to the incident at the
Town Hall on September 22, 2015 regarding Martin O’Boyle”).
b. Based on our understanding, records responsive to part (1) of this subpart will
also be responsive to parts (2) and (3); and records responsive to subpart 13 of
your request will also be responsive to subpart 10 and included in that estimate.
All references to records provided in response to GS 2704 includes any supplemental production
provided to you by the Town. If we do not hear back from you within 30 days of this letter, we
will consider this request closed.
Sincerely,
Reneé Rowan Basel
As requested by Rita Taylor
Town Clerk, Custodian of the Records
Renee Basel
From:Jonathan O'Boyle <joboyle@oboylelawfirm.com>
Sent:Friday, October 16, 2020 2:27 PM
To:Renee Basel; Trey Nazzaro; Hudson Gill; OConnor, Joanne M.
Cc:Suze Courtney; Marty O'Boyle; Jonathan O'Boyle; Kristen Blackwell
Subject:Follow Up to Request 2812
\[NOTICE: This message originated outside of the Town of Gulfstream -- DO NOT CLICK on links or open attachments
unless you are sure the content is safe.\]
To all, Suze has asked me to transmit this letter on behalf of Martin O’Boyle which is in response to the Town’s
September 17, 2020 response. I am copying Town Counsel since I am not sure who will be the point of contact if there
needs to be any further discussion on this request. I was hoping that the request(s) for production in the Federal Judge
Bloom matter would have produced some if not all responsive documents but my understanding is that all documents
have not been provided and will likely not be produced in time. Thus, Mr. O’Boyle must proceed in this matter.
As such, I will be handling this request for Martin O’Boyle and I would ask the custodian or (counsel) copy
myself, Suze Courtney, and Martin O’Boyle on any responses going forward. I would remind the Town that December 1,
2020 is Mr. O’Boyle’s trial date and thus, this request must forward with the utmost expedience. Mr. O’Boyle has
already submitted $250 advance fee and I am not aware of any other outstanding public records requests that are active
by Mr. O’Boyle but to the extent there are, we graciously ask that you put them on hold to deal with this public records
request first as it is extremely time sensitive. This request was broken into subparts so that records could be produced
as efficiently as possible as soon as a subpart is ready so that Mr. O’Boyle would not have to wait until all records for all
subparts have been completed. Please let me know ASAP where we stand with the clarifications contained in this letter
and to the extent you are able to start producing some of the records regardless of further need for clarification, please
do so without delay. If litigation is necessary, Martin Reeder and I will likely be counsel of record and will likely be
seeking an immediate hearing.
Thank you kindly.
Jonathan O’Boyle, Esq., LLM.
Licensed In Pennsylvania*
Licensed In New Jersey*
Licensed in Florida*
The O’Boyle Law Firm, P.C.
www.oboylelawfirm.com
Pennsylvania Office
1001 Broad St.
Johnstown, PA 15906
Tel: 754-212-4201
Fax: 215-893-3641
joboyle@oboylelawfirm.com
New Jersey Office
1
525 Route 73 North, Suite 104
Marlton, NJ 08053
Tel: 856-619-8558
Fax: 856-619-8559
joboyle@oboylelawfirm.com
Florida Office
1286 West Newport Center Drive
Deerfield Beach, FL 33442
Office: 754-212-4201
Direct: 954-570-3533
Fax: 754-212-2444
joboyle@oboylelawfirm.com
IRS Circular 230 disclosure: To ensure compliance with requirements
imposed by the IRS, we inform you that any tax advice contained in this
communication, unless expressly stated otherwise, was not intended or
written to be used, and cannot be used, for the purpose of (i) avoiding
tax-related penalties under the Internal Revenue Code or (ii) promoting,
marketing or recommending to another party any tax-related matter(s)
addressed herein.
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2
Dear Custodian of Records
Re: Request GS#2812 Response Letter of September 17, 2020 (the “Response”).
- The capitalized term Town will have the same meaning as it did in the Original Request.
I. History of Events
a. August 30, 2020 Request 2812 Submitted to Town.
b. September 1, 2020, Town acknowledges request and receipt of $250 fee.
c. September 14, 2020, Marty O’Boyle, having heard nothing further, follows
up and sends 5-day letter under 119.12.
d. September 17, 2020, Town transmits clarification letter.
e. October 16, 2020, Marty O’Boyle transmits response.
II. Scope of Request Generally
In the Response, the Town Stated, “You have indicated that this is one request for public
records, and that ‘the request has multiple subparts.’ Your request seeks ‘Public Records
Related to Martin O’Boyle Criminal Case.’ Based upon this understanding, the Town will
not provide you with records that do not relate to the Martin O’Boyle Criminal Case, and
do not relate to the underlying September 22, 2015 incident at Town Hall to which various
below sub-parts of your requests refer.”
As a clarification, Mr. O’Boyle is seeking the records responsive to the subparts of the
request “as stated” and is not limiting his request solely to documents w hich the Town
believes is relevant to the Incident or the Criminal Case. As you are aware, §119.12, Fla.
Stat. has been amended and Mr. O’Boyle’s above statement reflects his intentions and
purposes behind seeking these records and the importance of the timeliness of the Town’s
response. As you know, Mr. O’Boyle is required under Brady v. Maryland to make diligent
efforts to search for all evidence that may be helpful to his criminal case in terms of
exculpatory, impeachment, or otherwise.
To further assist the Town, Mr. O’Boyle is not looking for duplicates of materials already
transmitted to him through a response to a previous public records request including but
not limited to Request 2704. However, if any materials responsive to this request should
have been produced pursuant to a former public records request made by him, but were not
produced (for any reason), Mr. O’Boyle requests that those materials be produced now. To
avoid confusion, if certain records are responsive to more than one request, please be sure
to note that so that Mr. O’Boyle will be aware of the Town’s efficiency measures and will
not confuse it with nonproduction of records.
In addition, Mr. O’Boyle’s (5) day notice under §119.12, Fla. Stat. which was transmitted
on September 14, 2020 remains in effect and is renewed to the extent there is any confusion.
Below Mr. O’Boyle will reply to the Town’s Response in turn as follows:
***
1. Mr. O’Boyle is thankful that you are able to respond to the following subpart, “All
communications between the Town of Gulf Stream and Calvin, Giordano & Associates
related to Request #2704.” However, you have promised to provide a special service charge
related to this subpart and Mr. O’Boyle has not received it yet. Please forward immediately
as the delay in producing this estimate is beyond reasonable. Please note that for the future,
Mr. O’Boyle objects to the Town using a clarification letter to avoid production of public
records or estimates for subparts or portions of a request for which the Town does not seek
clarification.
2. As for the second sub-part, “All public records of the Town of Gulf Stream which pertain
to Martin O’Boyle’s reputation in the community.” Mr. O’Boyle knows that the Town has
the advice of numerous lawyers and that two of the Town’s Commissioners are attorneys.
The Town is adequately able to identify records as they are the same records that would be
responsive to a request for production under Fla. R. Civ. P. 1.350 to establish Mr.
O’Boyle’s reputation in the community if he were to sue the Town for defamation. These
may include, but are not limited to, records where Mr. O’Boyle’s character traits are being
ascribed or described or records reflecting what members of the Town (as defined in the
original request) or members of the community think of Mr. O’Boyle. For example, a
responsive document would be a communication which identifies Martin O’Boyle (or any
variation of his name or any codewords used to describe him) as a noun. There may be
other responsive records based upon the context of the content of the record – the previous
example is not exhaustive but is meant to assist the Town in identifying records.
In addition, the State has sought to elicit the testimony of Mayor Morgan, William
Thrasher, and Serge DeLaville as to Martin O’Boyle’s reputation in the community in Case
No. 50-2015-MM-012872, State v. O’Boyle (the “Criminal Matter”). The public records
which are used to support or reflect that proffered testimony would be responsive to this
request. Also, records memorializing or discussing that proposed testimony would also be
responsive.
In addition, the Town has sent letters and emails to the community at large or media outlets
which has reported on Martin O’Boyle’s conduct or motives. Those communications
would, by definition, pertain to Martin O’Boyle’s reputation in the community.
While the search terms proposed by the Town are helpful, mechanical search terms will
not obviate the need to confer with individuals in the Town (as defined in the original
request) which is required under §119.07(1)(C), Fla. Stat. as they may have knowledge of
responsive record. In addition, the records responsive are context and content sensitive so
mechanical search terms are of limited value.
Lastly, the request did not contain a temporal limitation. However, we will accept January
1, 2013 to the date of the request in order to limit the Town’s search.
3. As for the third sub-part, “All public records of the Town of Gulf Stream which pertain to
Martin O’Boyle being obstructionist, defiant, or disruptive.” In the Criminal Matter,
Mayor Morgan and former Town Manager William Thrasher have offered to testify that
Martin O’Boyle’s reputation in the community is obstructionist, defiant, or disruptive.
O’Boyle would like the records which formulate the basis for that opinion and any other
records of the Town which support Mayor Morgan and former Town Manager Thrashers’
opinion. O’Boyle would also like communications reflecting O’Boyle’s reputation in the
community as being defiant, obstructionist, or disruptive as well as public records
reflecting or describing specific instances of defiance, obstructionism, and disruptiveness.
In addition, the Town has sent letters and emails to the community at large, media outlets,
lobbyists, or other governmental entities which describe Martin O’Boyle’s conduct or
motives which may pertains to O’Boyle being defiant, obstructionist, or disruptive Those
communications would be responsive.
While the search terms proposed by the Town are helpful, mechanical search terms will
not obviate the need to confer with individuals in the Town (as defined in the original
request) which is required under §119.07(1)(C), Fla. Stat. as they may have knowledge of
responsive records. In addition, the records responsive are context and content sensitive
so mechanical search terms are of limited value.
Lastly, the request did not contain a temporal limitation. However, we will accept January
1, 2013 to the date of the request in order to limit the Town’s search.
4. As to the Fourth sub-part, “All public records created, sent or received by the Town of Gulf
Stream which pertain to signage, speech, pamphlets, advertisements, mailers, or banners
(whether displayed in air, sea, land, or electronically) which the Town attributes to Martin
O’Boyle since January 1, 2014.” Mr. O’Boyle thanks you for directing him towards
meeting minutes and the YouTube channel where his comments to the commission can be
viewed. However, in order to assist the Town in specifying the request, Mr. O’Boyle would
like communications or reports created, sent, or received by the Town of Gulf Stream
where speech, signage, pamphlets, advertisements, mailers, or banners (which the sender
or recipient attributes to Mr. O’Boyle) are a subject of discussion or comment from January
1, 2014 to the date of the request.
While search terms such as “banner planes”, “pamphlets”, “Gulf Stream Patriot”,
“painting(s)”, “mural(s)”, “Campaign Sign(s)”, “truck”, “boat”, “election day” may be
helpful to the Town, mechanical search terms will not obviate the need to confer with
individuals in the Town (as defined in the original request) which is required under
§119.07(1)(C), Fla. Stat. as they may have knowledge of responsive records. In addition,
the records responsive are context and content sensitive so mechanical search terms are of
limited value. For example, this could include emails which, in whole or in part, concern
banners, paintings, or pamphlets, ect… which the sender believes are attributable to Mr.
O’Boyle
5. As to the Fifth sub-part, “All interagency communication which pertain: (1) to a September
22, 2015 Incident at Town Hall regarding Martin O’Boyle; (2) to Martin O’Boyle’s
character; and/or (3) to State v. O’Boyle, 2015MM012872A now pending in the 15th
Judicial Circuit.” Mr. O’Boyle will accept a date of January 1, 2014 to the date of the
request.”
Mr. O’Boyle appreciates your ability to provide responsive records as to subcategories (1)
and (3) and does not require the Town to produce documents that have already been
produced in response to Request #2704 or the Town’s production of additional records
pursuant to Court Order in July 2019 or the Request for Production responses in that
litigation. However, Mr. O’Boyle would emphasize that any other public records
responsive to Request #2704 which were not produced for whatever reason, must be now
be produced. Also please note, the date of this request is more than a year after Request
#2704 and a good faith response to this request will require conferring with individuals of
the Town to ascertain omitted or new public records which are responsive. This request
does not seek a mere running of search terms in emails.
With regard to character, Mr. O’Boyle is looking for public records that would fall under
Federal Rules of Evidence 404 and 406 regardless of admissibility. Although the Town
has legal resources, Mr. O’Boyle asserts that communications which reflect, comment, or
describe (in whole or in part) opinions of Mr. O’Boyle, his habits, his reputation, or specific
instances of conduct are responsive records.
While the search terms proposed by the Town are helpful, mechanical search terms will
not obviate the need to confer with individuals in the Town (as defined in the original
request) which is required under §119.07(1)(C), Fla. Stat. as they may have knowledge of
responsive records. In addition, the records responsive are context and content sensitive
so mechanical search terms are of limited value.
6. As to the Sixth sub-part, “All text messages created, sent, or received by Scott Morgan
since January 1, 2013” – this request is not limited to any category of information. This
asks for all text messages and will require conferring with individuals of the Town as they
may have messages that Mayor Morgan may have deleted.
7. As to the Seventh sub-part, “All text messages caused or instructed to be sent by Scott
Morgan since January 1, 2013” – this request is not limited to any category of information.
This asks for all text messages that Mayor Morgan directed to be sent and will require
conferring with individuals of the Town to ascertain which messages are responsive.
8. As to the Eighth sub-part, “All text messages created, sent or received by every person
within definition of Town of Gulf Stream, including without limitation, Robert Sweetapple
and Joanne O’Connor” – this request is not limited to any category of information. This
asks for all text messages and will require conferring with individuals of the Town to
ascertain which messages are responsive and if individuals of the Town possess text
messages that were deleted by others. Mr. O’Boyle will limit this request temporally to
January 1, 2013 to the date of the request.
9. As to the Ninth sub-part, “All text message on any phone issued or used by the Town Police
dating back to January 1, 2013. The word “phone” as used herein includes without
limitation, phones in storage, phones in current use, phones previously used, and includes
without limitation, personal phones in current use and previous use ” – this request is not
limited to any category of information. In addition, Mr. O’Boyle was not provided all text
messages in the possession of the Town as evinced by Sgt. Passegiatta’s deposition in the
litigation over Request #2704. Specifically, there are phones being stored in Lt. Hasley’s
desk which were never searched. Mr. O’Boyle would like those messages.
10. As to the Tenth sub-part, “All public records that were created by, sent by or received by
the Town of Gulf Stream (especially to or from any State or Federal Attorney General’s
office, State Attorney’s office, or Federal, State, County, or Local law enforcement agency)
which pertains to or mentions: (1) Martin O’Boyle since January 1, 2014; (2) a September
22, 2015 Incident at Town Hall regarding Martin O’Boyle; and or (3) State v. O’Boyle,
2015MM012872A” – this request is not limited to any category of information but Mr.
O’Boyle believes he can narrow the request.
As for “Subpart (1)”, Mr. O’Boyle will limit the request solely to communications (and
any attachments) to or from any State or Federal Attorney General’s office, State
Attorney’s office, or Federal, State, County, or Local law enforcement agency or agencies
which pertain or mention Martin O’Boyle. Note, this refers to the individual Martin
O’Boyle and any names, pronouns, or codewords that have been used to identify him.
As for “Subparts (2)&(3)” Mr. O’Boyle still seeks all public records which pertain to his
September 22, 2015 Incident and his subsequent prosecution.
11. As to the Eleventh sub-part, “All electronic transmissions created by, sent by or received
by Scott Morgan which pertain: (1) to Martin O’Boyle since January 1, 2014; (2) to a
September 22, 2015 Incident at Town Hall regarding Martin O’Boyle; and/or (3) to State
v. O’Boyle 2015MM012872A now pending in the 15th Judicial Circuit” – this request is
not limited in any way and must be responded to as-is. Mr. O’Boyle acknowledges that
some of the records responsive to this subpart will be responsive to other subparts but
would like an estimate, nonetheless in the event he may wish to go forward with this
production while modifying other subparts.
12. As to the Twelfth sub-part, “All electronic transmissions caused or instructed to be sent at
Scott Morgan’s behest or behalf which pertain: (1) to Martin O’Boyle since January 1,
2014; (2) to a September 22, 2015 Incident at Town Hall regarding Martin O’Boyle; and/or
(3) to State v. O’Boyle 2015MM012872A now pending in the 15th Judicial Circuit” – The
Town has contended that there is no way to determine if a record was “caused or instructed
to be sent at the direction of a specific person.” The Town’s response misunderstands its
obligations under the Florida Constitution and Chapter 119 as §119.07(1)(C), Fla. Stat.
specifically requires the Town to make inquiry. Here, the Town would start by asking
Mayor Morgan whether he directed transmissions to be sent on his behalf and then make
reasonable efforts to locate them. In addition, the Town must also make inquiry to other
individuals which fall under the definition of the “Town” to ascertain if they have
information about said transmissions and the location of those records. Mr. O’Boyle
contends that Chapter 119 and the Florida Constitution do not bound him to seek records
which will only be responsive to mechanical search terms. Since the Town has
continuously protested that it is a very small Town with very few people, this task should
not be momentous.
13. As for the Thirteenth sub-part, “All electronic transmissions created by, sent by or received
by any member of the Gulf Stream police (past or present) which pertain to: (1) to Martin
O’Boyle since January 1, 2014; (2) to a September 22, 2015 Incident at Town Hall
regarding Martin O’Boyle; and/or (3) to State v. O’Boyle 2015MM012872A now pending
in the 15th Judicial Circuit” – Although this subpart does overlap in part with other subparts,
Mr. O’Boyle would still like an estimate in the event he wanted to proceed with this subpart
while narrowing or assisting in clarification on other subparts.
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
October 23, 2020
Martin E. O'Boyle [e-mail to: recordsgcommerce-group.com]
Re: GS #2812 (Request for Public Records Related to Martin O'Boyle Criminal Case)
Request for Public Records Related to Martin O'Boyle Criminal Case
1. All communications between the Town of Gulf Stream and Calvin, Giordano
& Associates) related to Request # 2704
Dear Martin E. O'Boyle [e-mail to: meo(a commerce-group.com]:
Thank you for your most recent response dated October 16, 2020. The original request and
partial response can be found at the following link:
httys://portal.laserfiche.com/Portal/DocView.aspx?id=I 73216&rel2o=r-4301 00cc
The Town has spent at least 15 minutes on subpart one of your request and now estimates that to
fully respond to subpart one of your request will require an additional 49 minutes of
administrative support at $48.38 per hour, the labor cost of the personnel providing the service,
per Fla. Stat. § 119.07(4)(d). If the costs of producing these documents will exceed your deposit,
the Town will provide you with an initial production of responsive records and an estimate for
the production of any additional responsive records. If the costs of production are less than the
deposit, the Town will provide you with the responsive records and a refund.
(.82 hour @ 48.38 = 39.67 - .25 hour @ 48.38 = 12.10 = 27.57) = Deposit Due: $27.57 in cash
or check.
Upon receipt of your acknowledgement that you will pay for these records, the Town will use its
very best efforts to further respond to your public records request in a reasonable amount of time.
If we do not hear back from you within 30 days of this letter, we will consider this closed.
Sincerely,
As Requested by Rita Taylor
Town Clerk, Custodian of the Records
Renee Basel
From:Jonathan O'Boyle <joboyle@oboylelawfirm.com>
Sent:Tuesday, October 27, 2020 12:52 PM
To:Renee Basel; Trey Nazzaro
Cc:Suze Courtney; records@commerce-group.com; William Ring
Subject:RE: GS #2812 (Request for Public Records Related to Martin O'Boyle Criminal Case)
\[NOTICE: This message originated outside of the Town of Gulfstream -- DO NOT CLICK on links or open attachments
unless you are sure the content is safe.\]
Thank you for your response, just to be clear the $27.57 will be deducted from the $250.00 deposit? Will we receive
and itemization of the time spent on this subpart? How are 15 minutes already expended on producing responsive
records? To the extent there is any payment for the cost of estimating an advance deposit, we agree to the deduction
(or payment) under protest to the extent any time expended is for creating estimates or for seeking clarification. If the
Town intends on charging Martin O’Boyle for those services with respect to Request 2812 or any future requests, please
let us know so that we may seek a declaratory action for the benefit of the parties and the public at-large. Mr. O’Boyle
notes that he has not waived his (5)-day notice and renews it out of an abundance of caution with regard to the issued
contained in this missive as it relates to Request 2812 or the issues of not providing detailed time entries accounting for
charges or charging for estimates or clarifications more broadly.
Bill Ring can come by tomorrow and pick the documents up or they can be emailed.
Also, where are we on the other subparts?
Thank you kindly, if you require additional payment above the $250 already on deposit, please let us know and we will
get it paid under protest ASAP and, if that is the case, we inquire what has the $250 deposit been used for since Martin
O’Boyle is not in possession of any responsive records. Thank you.
From: Renee Basel <rbasel@gulf-stream.org>
Sent: Friday, October 23, 2020 12:32 PM
To: Jonathan O'Boyle <joboyle@oboylelawfirm.com>
Cc: Suze Courtney <scourtney@commerce-group.com>; records@commerce-group.com
Subject: GS #2812 (Request for Public Records Related to Martin O'Boyle Criminal Case)
Good afternoon:
See attached correspondence.
Kindest regards,
Reneé Basel
1
Renee Basel
From:Jonathan O'Boyle <joboyle@oboylelawfirm.com>
Sent:Tuesday, October 27, 2020 5:00 PM
To:Renee Basel
Cc:Suze Courtney; records@commerce-group.com
Subject:RE: GS #2812 (Request for Public Records Related to Martin O'Boyle Criminal Case)
\[NOTICE: This message originated outside of the Town of Gulfstream -- DO NOT CLICK on links or open attachments
unless you are sure the content is safe.\]
Thanks Renee, I will be sending this off to Marty for his inspection and let you know if the Laserfiche is sufficient or if he
has any other questions for me.
From: Renee Basel <rbasel@gulf-stream.org>
Sent: Tuesday, October 27, 2020 4:53 PM
To: Jonathan O'Boyle <joboyle@oboylelawfirm.com>
Cc: Suze Courtney <scourtney@commerce-group.com>; records@commerce-group.com
Subject: GS #2812 (Request for Public Records Related to Martin O'Boyle Criminal Case)
Good afternoon, Jonathan:
See attached correspondence.
Kindest regards,
Reneé Basel
The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.
The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
1
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
2
The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.
The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
2
Renee Basel
From:
Renee Basel
Sent:
Tuesday, April 23, 2019 11:40 AM
To:
Carlos Valdes
Subject:
Public Records Request for Gulf Stream
Per our conversation, please do a search on all the Town and PD's servers from January 1, 2017
through April 18, 2017 with any e-mails that have the address @commerce-group.com.
Also keep track of the time it takes you to do this. O
Lemme know what you come up with.
Thanks and have a GRAND day!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.ol88-fax
www.gulf-stream.or
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Renee Basel
From:
Carlos Valdes
Sent:
Tuesday, April 23, 2019 3:45 PM
To:
Renee Basel
Subject:
RE: Public Records Request for Gulf Stream
On your desktop you will find a folder called "Commerce". Inside the folder is the PST with all the
Emails sent @commerce-group.com between 1/1/2017 - 4/ 18/ 2019
Inside the PST there will be a breakdown of folders showing who the recipients was for each email.
Project time:
11:30-12:00
1:00-3:40
However I had a call that took me away for this project for 40 minutes.
Total time: 2.5 Hours
Please let me know if you need anything else.
Carlos Valdes
Jr. Systems Administrator I Data Technologies (Broward)
Calvin, Giordano & Associates, Inc. 1 1800 Eller Drive I Suite 600 Fort Lauderdale, FL 33316
`•; t Office: 954.921.77811 Direct: 954.766.2762 1 Fax: 954.921.8807
Fort Lauderdale / Miami -Dade / West Palm Beach / Clearwater/Tampa / Estero Port St. Lucie
L
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Tuesday, April 23, 2019 11:40 AM
To: Carlos Valdes <CValdes@cgasolutions.com>
Subject: Public Records Request for Gulf Stream
Per our conversation, please do a search on all the Town and PD's servers from January 1, 2017
through April 18, 2017 with any e-mails that have the address @commerce-group.com.
Also keep track of the time it takes you to do this. O
Lemme know what you come up with.
Thanks and have a GRAND day!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.o188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Renee Basel
From:
Renee Basel
Sent:
Tuesday, April 23, 2019 3:47 PM
To:
Carlos Valdes
Subject:
RE: Public Records Request for Gulf Stream
Thanks, Carlos. Will you be available in the morning to walk me through how to open that file up? O
Lemme know! Thanks!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5ii6
561.737.0188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: Carlos Valdes[mailto:CValdes@cgasolutions.comj
Sent: Tuesday, April 23, 2019 3:45 PM
To: Renee Basel <RBasel@gulf-stream.org>
Subject: RE: Public Records Request for Gulf Stream
On your desktop you will find a folder called "Commerce". Inside the folder is the PST with all the
Emails sent @commerce-group.com between 1/1/2017 - 4/18/2019
Inside the PST there will be a breakdown of folders showing who the recipients was for each email.
Project time:
11:30-12:00
1:00-3:40
However I had a call that took me away for this project for 40 minutes.
Total time: 2.5 Hours
Please let me know if you need anything else.
Carlos Valdes
Jr. Systems Administrator I Data Technologies (Broward)
Calvin, Giordano & Associates, Inc. 1 1800 Eller Drive I Suite 600 1 Fort Lauderdale, FL 33316
. Office: 954.921.7781 1 Direct: 954.766.2762 1 Fax: 954.921.8807
Fort Lauderdale / Miami -Dade / West Palm Beach / Clearwater/Tampa I Estero / Port St. Lucie
0 0
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Tuesday, April 23, 2019 11:40 AM
To: Carlos Valdes <CValdes@cgasolutions.com>
Subject: Public Records Request for Gulf Stream
Per our conversation, please do a search on all the Town and PD's servers from January 1, 2017
through April 18, 2017 with any e-mails that have the address @commerce-group.com.
Also keep track of the time it takes you to do this. O
Lemme know what you come up with.
Thanks and have a GRAND day!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.o188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Renee Basel
From:
Renee Basel
Sent:
Wednesday, April 24, 2019 3:58 PM
To:
Carlos Valdes
Subject:
RE: Public Records Request for Gulf Stream
Hey Carlos ... I was able to figure out how to open the pst file .... yay me! O
We need another IT search, please. On all servers again, including PD.
We are searching for: sao17.state.fl.us
SAO standing for State Attorney's Office. O
Thanks! Call me in the morning with your findings.
Have a GRAND evening!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
too Sea Road
Gulf Stream FL 33483
561.276.51i6
561.737.o188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: Carlos Valdes [mailto:CValdes@cgasolutions.com]
Sent: Tuesday, April 23, 2019 3:48 PM
To: Renee Basel <RBasel @gulf-stream.org>
Subject: RE: Public Records Request for Gulf Stream
Yeah, tomorrow morning is perfect.
Carlos Valdes
Jr. Systems Administrator I Data Technologies (Broward)
Calvin, Giordano & Associates, Inc. 1 1800 Eller Drive I Suite 600 Fort Lauderdale, FL 33316
Office: 954.921.7781 1 Direct: 954.766.2762 1 Fax: 954.921.8807
Fort Lauderdale / Miami -Dade / West Palm Beach / Clearwater/Tampa I Estero Port St. Lucie
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Tuesday, April 23, 2019 3:47 PM
To: Carlos Valdes <CValdes@cgasolutions.com>
Subject: RE: Public Records Request for Gulf Stream
Thanks, Carlos. Will you be available in the morning to walk me through how to open that file up? O
Lemme know! Thanks!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.o188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: Carlos Valdes [mailto:CValdes@cgasolutions.com]
Sent: Tuesday, April 23, 2019 3:45 PM
To: Renee Basel <RBasel@gulf-stream.org>
Subject: RE: Public Records Request for Gulf Stream
On your desktop you will find a folder called "Commerce". Inside the folder is the PST with all the
Emails sent @commerce-group.com between 1/1/2017 - 4/18/2019
Inside the PST there will be a breakdown of folders showing who the recipients was for each email.
Project time:
11:30-12:00
1:00-3:40
However I had a call that took me away for this project for 40 minutes.
Total time: 2.5 Hours
Please let me know if you need anything else.
Carlos Valdes
Jr. Systems Administrator I Data Technologies (Broward)
Calvin, Giordano & Associates, Inc. 1 1800 Eller Drive I Suite 600 Fort Lauderdale, FL 33316
Office: 954.921.7781 1 Direct: 954.766.2762 1 Fax:954.921.8807
Fort Lauderdale / Miami -Dade / West Palm Beach / Clearwater/Tampa / Estero Port St. Lucie
000
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Tuesday, April 23, 2019 11:40 AM
To: Carlos Valdes <CVaIdes@cgasolutions.com>
Subject: Public Records Request for Gulf Stream
Per our conversation, please do a search on all the Town and PD's servers from January 1, 2017
through April 18, 2017 with any e-mails that have the address @commerce-group.com.
Also keep track of the time it takes you to do this. O
Lemme know what you come up with.
Thanks and have a GRAND day!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5ii6
561.737.o188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Renee Basel
From:Jonathan O'Boyle <joboyle@oboylelawfirm.com>
Sent:Tuesday, October 27, 2020 12:52 PM
To:Renee Basel; Trey Nazzaro
Cc:Suze Courtney; records@commerce-group.com; William Ring
Subject:RE: GS #2812 (Request for Public Records Related to Martin O'Boyle Criminal Case)
\[NOTICE: This message originated outside of the Town of Gulfstream -- DO NOT CLICK on links or open attachments
unless you are sure the content is safe.\]
Thank you for your response, just to be clear the $27.57 will be deducted from the $250.00 deposit? Will we receive
and itemization of the time spent on this subpart? How are 15 minutes already expended on producing responsive
records? To the extent there is any payment for the cost of estimating an advance deposit, we agree to the deduction
(or payment) under protest to the extent any time expended is for creating estimates or for seeking clarification. If the
Town intends on charging Martin O’Boyle for those services with respect to Request 2812 or any future requests, please
let us know so that we may seek a declaratory action for the benefit of the parties and the public at-large. Mr. O’Boyle
notes that he has not waived his (5)-day notice and renews it out of an abundance of caution with regard to the issued
contained in this missive as it relates to Request 2812 or the issues of not providing detailed time entries accounting for
charges or charging for estimates or clarifications more broadly.
Bill Ring can come by tomorrow and pick the documents up or they can be emailed.
Also, where are we on the other subparts?
Thank you kindly, if you require additional payment above the $250 already on deposit, please let us know and we will
get it paid under protest ASAP and, if that is the case, we inquire what has the $250 deposit been used for since Martin
O’Boyle is not in possession of any responsive records. Thank you.
From: Renee Basel <rbasel@gulf-stream.org>
Sent: Friday, October 23, 2020 12:32 PM
To: Jonathan O'Boyle <joboyle@oboylelawfirm.com>
Cc: Suze Courtney <scourtney@commerce-group.com>; records@commerce-group.com
Subject: GS #2812 (Request for Public Records Related to Martin O'Boyle Criminal Case)
Good afternoon:
See attached correspondence.
Kindest regards,
Reneé Basel
1
The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.
The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
2
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
October 27, 2020
Martin E. O’Boyle [e-mail to: records@commerce-group.com]
Re: GS #2812 (Request for Public Records Related to Martin O'Boyle Criminal Case)
Request for Public Records Related to Martin O’Boyle Criminal Case
1. All communications between the Town of Gulf Stream and Calvin, Giordano
& Associates) related to Request # 2704
Dear Martin E. O’Boyle [e-mail to: meo@commerce-group.com]:
The original request and response can be found at the following link:
https://portal.laserfiche.com/Portal/DocView.aspx?id=173216&repo=r-430100cc
Thank you for your most recent response dated October 27, 2020. Please see your response and
our answers to your questions below:
Just to be clear the $27.57 will be deducted from the $250.00 deposit?
Since you have agreed to pay for the records, the $27.57 will be deducted from your $250
deposit.
Will we receive and itemization of the time spent on this subpart?
Attached are rough notes created regarding this request.
How are 15 minutes already expended on producing responsive records?
A partial response was provided with the Town’s October 23, 2020 letter via Laserfiche. You
have asked that the Town produce records in their original native format. Please confirm that the
Town’s production of records via Laserfiche is sufficient for your needs.
To the extent there is any payment for the cost of estimating an advance deposit, we agree to the
deduction (or payment) under protest to the extent any time expended is for creating estimates or
for seeking clarification. If the Town intends on charging Martin O’Boyle for those services with
respect to Request 2812 or any future requests, please let us know so that we may seek a
declaratory action for the benefit of the parties and the public at-large.
Time spent creating an estimate or seeking calcification is not included as part of an estimate.
The remainder of the records for subpart one of your request can be found at the above link.
Sincerely,
Reneé Basel
As Requested by Rita Taylor
Town Clerk, Custodian of the Records
r C Ara-4F-cCAI VOA
ocPEE /Vg City of 'Greenacres
�- Department of Leisure Services Like us on
(jlCityofGreenacres
tf1
501 Swain Blvd., Greenacres, FL 33463
(561) 642-2090 I w-vw.greenacresil.gov
Renee Basel
From:
Carlos Valdes
Sent:
Wednesday, April 24, 2019 4:09 PM
To:
Renee Basel
Cc:
Eric Wells
Subject:
RE: Public Records Request for Gulf Stream
Hello Renee,
Glad you got the PST opened.
Igo on vacation after today and will not be back till May 131n
I have included Eric Wells in this email as he will be able to help with this requests and any other in my absence.
Also, is there a date range for this request? Or just all Emails past and present?
Carlos Valdes
Jr. Systems Administrator I Data Technologies (Broward)
-_- Calvin, Giordano & Associates, Inc. 1 1800 Eller Drive I Suite 600 1 Fort Lauderdale, FL 33316
Office: 954.921.7781 1 Direct: 954.766.2762 1 Fax: 954.921.8807
Fort Lauderdale / Miami -Dade / West Palm Beach J Clearwater/Tampa / Estero / Port St. Lucie
0 � - '14 0
From: Renee Basel <RBasel @gulf-stream.org>
Sent: Wednesday, April 24, 2019 3:58 PM
To: Carlos Valdes <CVaIdes@cgasoIutions.com>
Subject: RE: Public Records Request for Gulf Stream
Hey Carlos ... I was able to figure out how to open the pst file .... yay me! O
We need another IT search, please. On all servers again, including PD.
We are searching for: sao i state.fl. us
SAO standing for State Attorney's Office. O
Thanks! Call me in the morning with your findings.
Have a GRAND evening!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5ii6
561.737.o188-fax
i
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: Carlos Valdes [mailto:CValdes@cgasolutions.comj
Sent: Tuesday, April 23, 2019 3:48 PM
To: Renee Basel <RBasel@gulf-stream.org>
Subject: RE: Public Records Request for Gulf Stream
Yeah, tomorrow morning is perfect.
Carlos Valdes
Jr. Systems Administrator I Data Technologies (Broward)
Calvin, Giordano & Associates, Inc. 1 1800 Eller Drive I Suite 600 1 Fort Lauderdale, FL 33316
Office: 954.921.7781 1 Direct: 954.766.2762 1 Fax: 954.921.8807
Fort Lauderdale / Miami -Dade / West Palm Beach / Clearwater/Tampa / Estero / Port St. Lucie
0
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Tuesday, April 23, 2019 3:47 PM
To: Carlos Valdes <CValdes@cgasolutions.com>
Subject: RE: Public Records Request for Gulf Stream
Thanks, Carlos. Will you be available in the morning to walk me through how to open that file up? O
Lemme know! Thanks!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.oi88-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: Carlos Valdes [mailto:CValdes@cgasolutions.com]
Sent: Tuesday, April 23, 2019 3:45 PM
To: Renee Basel <RBasel@gulf-stream.org>
Subject: RE: Public Records Request for Gulf Stream
On your desktop you will find a folder called "Commerce". Inside the folder is the PST with all the
Emails sent @commerce-group.com between 1/1/2017 - 4/18/2019
Inside the PST there will be a breakdown of folders showing who the recipients was for each email.
Project time:
11:30-12:00
1:00-3:40
However I had a call that took me away for this project for 40 minutes.
Total time: 2.5 Hours
Please let me know if you need anything else.
Carlos Valdes
Jr. Systems Administrator I Data Technologies (Broward)
_ Calvin, Giordano & Associates, Inc. 11800 Eller Drive I Suite 600 1 Fort Lauderdale, FL 33316
Office:954.921.7781 1 Direct:954.766.2762 1 Fax: 954.921.8807
w: Fort Lauderdale / Miami -Dade / West Palm Beach / Clearwater/Tampa / Estero / Port St. Lucie
0
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Tuesday, April 23, 2019 11:40 AM
To: Carlos Valdes <CValdes@cgasolutions.com>
Subject: Public Records Request for Gulf Stream
Per our conversation, please do a search on all the Town and PD's servers from January 1, 2017
through April 18, 2017 with any e-mails that have the address @commerce-group.com.
Also keep track of the time it takes you to do this. O
Lemme know what you come up with.
Thanks and have a GRAND day!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.oi88-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
4
Renee Basel
From: Renee Basel
Sent: Thursday, April 25, 2019 9:53 AM
To: Eric Wells
Subject: Re: Search for Gulf Stream
Good morning, Eric:
I believe Carlos sent you the search we need done. He asked if there was a date range and it is
9/ 22/ 15 through today.
Please let me know what you find and time it takes.
Thank you and have a GRAND day!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.o188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Renee Basel
From:
Renee Basel
Sent:
Friday, April 26, 2019 10:04 AM
To:
Eric Wells
Subject:
We need your help....
Good morning, Eric. I e-mailed and left you a voice message yesterday. Our staff attorney, Trey
Nazzaro, and I need to speak with you regarding these IT searches for public records requests and
we are under a time limit. Please call asap .... thank you!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.0188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Renee Basel
From:
Eric Wells
Sent:
Friday, April 26, 2019 10:17 AM
To:
Renee Basel
Subject:
RE: We need your help....
Renee,
I will give you a call shortly.
Can you send me the details of your search request again?
From: Renee Basel <RBasel @gulf-stream.org>
Sent: Friday, April 26, 2019 10:04 AM
To: Eric Wells <EWells@cgasolutions.com>
Subject: We need your help....
Good morning, Eric. I e-mailed and left you a voice message yesterday. Our staff attorney, Trey
Nazzaro, and I need to speak with you regarding these IT searches for public records requests and
we are under a time limit. Please call asap .... thank you!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.oi88-fax
v,, w.gulf-stream.or
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Renee Basel
From:
Renee Basel
Sent:
Friday, April 26, 2019 10:35 AM
To:
Eric Wells
Subject:
RE: We need your help....
Yes.
1. Carlos did a search for me earlier this week but he only sent me a -mails that were FROM any address
with the ending @commerce-group.com. I also needed any e-mails on our servers sent TO that address,
that includes Forwards.
2. The second IT search on all servers again, including PD.
We are searching for anything to/from: saol7.state.fl.us
SAO standing for State Attorney's Office. O
The date range for the second search is 9/22/15 through today.
3. The third is a search of e-mails to/from ipasseggiata(&gulf-stream.org
The date range is 9/22/15 through today.
4. The fourth search is any e-mails to/from
a. hsargeantLglobaloilmgmt.com
b. HSargeantl\TPglobaloilmgmt.com
The date range for those is 12/26/13 through today.
Please keep tabs on time for each search you do as these are all separate requests so we need to bill them each
separately.
Thanks!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.o188-fax
ww w. gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: Eric Wells[mailto:EWells@cgasolutions.com]
Sent: Friday, April 26, 2019 10:17 AM
To: Renee Basel <RBasel@gulf-stream.org>
Subject: RE: We need your help....
Renee,
I will give you a call shortly.
Can you send me the details of your search request again?
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Friday, April 26, 2019 10:04 AM
To: Eric Wells <EWells@cgasolutions.com>
Subject: We need your help....
Good morning, Eric. I e-mailed and left you a voice message yesterday. Our staff attorney, Trey
Nazzaro, and I need to speak with you regarding these IT searches for public records requests and
we are under a time limit. Please call asap .... thank you!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.o188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
2
Renee Basel
From:
Renee Basel
Sent:
Friday, April 26, 2019 10:45 AM
To:
Eric Wells
Subject:
a quick change
Hey ... Trey just told me to not do a specific search on the sargeant e-mails, but to do a search on
anything to/from globaloilmgmt.com
Thanks!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.o188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Renee Basel
From:
Eric Wells
Sent:
Friday, April 26, 2019 11:21 AM
To:
Renee Basel
Subject:
RE: We need your help....
Renee,
Where do you want these requests copied to on the network?
I have re -run the first one already, just need to know where to save it for you.
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Friday, April 26, 2019 10:35 AM
To: Eric Wells <EWells@cgasolutions.com>
Subject: RE: We need your help....
Yes.
Carlos did a search for me earlier this week but he only sent me e-mails that were FROM any address
with the ending @commerce-group.com. I also needed any e-mails on our servers sent TO that
address, that includes Forwards.
2. The second IT search on all servers again, including PD.
We are searching for anything to/from: saoi7.state.fl.us
SAO standing for State Attorney's Office. O
The date range for the second search is 9/22/15 through today.
3. The third is a search of e-mails to/from jpasseggiata(&gulf-stream.org
The date range is 9/22/15 through today.
4. The fourth search is any e-mails to/from
a. hsargeant(&globaloilmgmt.com
b. HSargeantIVPglobaloilmgmt.com
The date range for those is 12/26/13 through today.
Please keep tabs on time for each search you do as these are all separate requests so we need to bill them each
separately.
Thanks!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.o188-fax
www.gulf-stream.or
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: Eric Wells[mailto:EWells@cgasolutions.com]
Sent: Friday, April 26, 2019 10:17 AM
To: Renee Basel <RBasel@gulf-stream.org>
Subject: RE: We need your help....
Renee,
I will give you a call shortly.
Can you send me the details of your search request again?
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Friday, April 26, 2019 10:04 AM
To: Eric Wells <EWells@cgasolutions.com>
Subject: We need your help....
Good morning, Eric. I e-mailed and left you a voice message yesterday. Our staff attorney, Trey
Nazzaro, and I need to speak with you regarding these IT searches for public records requests and
we are under a time limit. Please call asap .... thank you!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
10o Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.o188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
2
Renee Basel
From:
Eric Wells
Sent:
Friday, April 26, 2019 11:36 AM
To:
Renee Basel
Subject:
RE: We need your help....
I have completed these requests for you, about 15 minutes for each one.
Just need to know where you want the PST files transferred to.
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Friday, April 26, 2019 10:35 AM
To: Eric Wells <EWells@cgasolutions.com>
Subject: RE: We need your help....
Yes.
1. Carlos did a search for me earlier this week but he only sent me e-mails that were FROM any address
with the ending @commerce-group.com. I also needed any e-mails on our servers sent TO that
address, that includes Forwards.
2. The second IT search on all servers again, including PD.
We are searching for anything to/from: saol7.state.fl.us
SAO standing for State Attorney's Office. O
The date range for the second search is 9/22/15 through today.
3. The third is a search of e-mails to/from jpasseggiatapgulf-stream.org
The date range is 9/22/15 through today.
4. The fourth search is any e-mails to/from
a. hsargeantjrCuglobaloilmgmt.com
b. HSargeantIV(&globaloilmgmt.com
The date range for those is 12/26/13 through today.
Please keep tabs on time for each search you do as these are all separate requests so we need to bill them each
separately.
Thanks!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.0i88-fax
Nyw w. gu if-stre a m. o rg
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: Eric Wells[mailto:EWells@cgasolutions.com)
Sent: Friday, April 26, 2019 10:17 AM
To: Renee Basel <RBasel@gulf-stream.org>
Subject: RE: We need your help....
Renee,
I will give you a call shortly.
Can you send me the details of your search request again?
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Friday, April 26, 2019 10:04 AM
To: Eric Wells <EWells@cgasolutions.com>
Subject: We need your help....
Good morning, Eric. I e-mailed and left you a voice message yesterday. Our staff attorney, Trey
Nazzaro, and I need to speak with you regarding these IT searches for public records requests and
we are under a time limit. Please call asap .... thank you!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.oi88-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
2
Renee Basel
From:
Renee Basel
Sent:
Friday, April 26, 2019 11:37 AM
To:
Eric Wells
Subject:
RE: We need your help....
Hey ... you can put them on my desktop. O
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.oi88-fax
www.gulf-stream.or
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: Eric Wells[mailto:EWells@cgasolutions.com]
Sent: Friday, April 26, 2019 11:36 AM
To: Renee Basel <RBasel@gulf-stream.org>
Subject: RE: We need your help....
I have completed these requests for you, about 15 minutes for each one.
Just need to know where you want the PST files transferred to.
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Friday, April 26, 2019 10:35 AM
To: Eric Wells <EWells cgasolutions.com>
Subject: RE: We need your help....
Yes.
1. Carlos did a search for me earlier this week but he only sent me e-mails that were FROM any address
with the ending @commerce-group.com. I also needed any e-mails on our servers sent TO that address,
that includes Forwards.
2. The second IT search on all servers again, including PD.
We are searching for anything to/from: saoi7.state.fl.us
SAO standing for State Attorney's Office. O
The date range for the second search is 9/22/15 through today.
3. The third is a search of e-mails to/from Ipasseggiata(&gulf-stream.org
The date range is 9/22/15 through today.
4. The fourth search is any e-mails to/from
a. hsargeantjr(abglobaloilmgmt.com
b. HSargeantIV(&globaloilmgmt.com
The date range for those is 12/26/13 through today.
Please keep tabs on time for each search you do as these are all separate requests so we need to bill them each
separately.
Thanks!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
too Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.o188-fax
www.gulf-stream.or
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: Eric Wells[mailto:EWells@cgasolutions.com]
Sent: Friday, April 26, 2019 10:17 AM
To: Renee Basel <RBasel@gulf-stream.org>
Subject: RE: We need your help....
Renee,
I will give you a call shortly.
Can you send me the details of your search request again?
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Friday, April 26, 2019 10:04 AM
To: Eric Wells <EWells@cgasolutions.com>
Subject: We need your help....
Good morning, Eric. I e-mailed and left you a voice message yesterday. Our staff attorney, Trey
Nazzaro, and I need to speak with you regarding these IT searches for public records requests and
we are under a time limit. Please call asap .... thank you!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
too Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.o188-fax
wu iv.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Renee Basel
From:
Eric Wells
Sent:
Friday, April 26, 2019 11:41 AM
To:
Renee Basel
Subject:
RE: We need your help....
Ok, you should see individual folders for each request.
I added the new PST to your existing Commerce folder.
From: Renee Basel <RBasel @gulf-stream.org>
Sent: Friday, April 26, 2019 11:37 AM
To: Eric Wells <EWells@cgasolutions.com>
Subject: RE: We need your help....
Hey ... you can put them on my desktop. O
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.oi88-fax
www. gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: Eric Wells[ma iIto: EWells@cgasolutions.com]
Sent: Friday, April 26, 2019 11:36 AM
To: Renee Basel <RBasel@gulf-stream.org>
Subject: RE: We need your help....
I have completed these requests for you, about 15 minutes for each one.
Just need to know where you want the PST files transferred to.
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Friday, April 26, 2019 10:35 AM
To: Eric Wells <EWells@cgasolutions.com>
Subject: RE: We need your help....
Yes
Carlos did a search for me earlier this week but he only sent me a -mails that were FROM any address
with the ending @commerce-group.com. I also needed any a -mails on our servers sent TO that
address, that includes Forwards.
2. The second IT search on all servers again, including PD.
We are searching for anything to/from: saol7.state.fl.us
SAO standing for State Attorney's Office. O
The date range for the second search is 9/22/15 through today.
3. The third is a search of a -mails to/from jpasseggiatapgulf-stream.org
The date range is 9/22/15 through today.
4. The fourth search is any e-mails to/from
a. hsargeantjr(&globaloilmgmt.com
b. HSargeantIV(&globaloilmgmt.com
The date range for those is 12/26/13 through today.
Please keep tabs on time for each search you do as these are all separate requests so we need to bill them each
separately.
Thanks!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
10o Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.o188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: Eric Wells[mailto:EWells@cgasolutions.com]
Sent: Friday, April 26, 2019 10:17 AM
To: Renee Basel <RBasel@gulf-stream.org>
Subject: RE: We need your help....
Renee,
I will give you a call shortly.
Can you send me the details of your search request again?
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Friday, April 26, 2019 10:04 AM
To: Eric Wells <EWells@cgasolutions.com>
Subject: We need your help....
Good morning, Eric. I e-mailed and left you a voice message yesterday. Our staff attorney, Trey
Nazzaro, and I need to speak with you regarding these IT searches for public records requests and
we are under a time limit. Please call asap .... thank you!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.oi88-fax
www.gulf-stream.or
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
3
Renee Basel
From:
Renee Basel
Sent:
Friday, April 26, 2019 3:50 PM
To:
Eric Wells
Subject:
RE: We need your help....
Thank you, Eric!
Have a GRAND weekend!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5i16
561.737.oi88-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: Eric Wells[mailto:EWells@cgasolutions.com]
Sent: Friday, April 26, 2019 11:41 AM
To: Renee Basel <RBasel@gulf-stream.org>
Subject: RE: We need your help....
Ok, you should see individual folders for each request.
I added the new PST to your existing Commerce folder.
From: Renee Basel <RBase I@gulf-stream.org>
Sent: Friday, April 26, 2019 11:37 AM
To: Eric Wells <EWells@cgasolutions.com>
Subject: RE: We need your help....
Hey ... you can put them on my desktop. O
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5ii6
561.737.o188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). if
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: Eric Wells[mailto:EWells@cgasolutions.com]
Sent: Friday, April 26, 2019 11:36 AM
To: Renee Basel <RBasel@gulf-stream.org>
Subject: RE: We need your help....
I have completed these requests for you, about 15 minutes for each one.
Just need to know where you want the PST files transferred to.
From: Renee Basel <RBasel@gulf-stream.or>
Sent: Friday, April 26, 2019 10:35 AM
To: Eric Wells <EWells@cgasolutions.com>
Subject: RE: We need your help....
Yes
Carlos did a search for me earlier this week but he only sent me e-mails that were FROM any address
with the ending @commerce-group.com. I also needed any e-mails on our servers sent TO that address,
that includes Forwards.
2. The second IT search on all servers again, including PD.
We are searching for anything to/from: sao17.state.fl.us
SAO standing for State Attorney's Office. O
The date range for the second search is 9/22/15 through today.
3. The third is a search of e-mails to/from j_passeg iag taikgulf-stream.org
The date range is 9/22/15 through today.
4. The fourth search is any e-mails to/from
a. hsargeantjr0globaloilmgmt.com
b. HSargeantIV(&globaloilmgmt.com
The date range for those is 12/26/13 through today.
Please keep tabs on time for each search you do as these are all separate requests so we need to bill them each
separately.
Thanks!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
10o Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.o188-fax
y,ww. gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: Eric Wells[mailto:EWells@cgasolutions.comj
Sent: Friday, April 26, 2019 10:17 AM
To: Renee Basel <RBasel@gulf-stream.org>
Subject: RE: We need your help....
Renee,
I will give you a call shortly.
Can you send me the details of your search request again?
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Friday, April 26, 2019 10:04 AM
To: Eric Wells <EWells@cgasolutions.com>
Subject: We need your help....
Good morning, Eric. I e-mailed and left you a voice message yesterday. Our staff attorney, Trey
Nazzaro, and I need to speak with you regarding these IT searches for public records requests and
we are under a time limit. Please call asap .... thank you!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
too Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.0188-fax
"ivw.gulf-stream.or
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Renee Basel
From:
Renee Basel
Sent:
Friday, May 3, 2019 8:56 AM
To:
Eric Wells
Subject:
Another couple of searches, please
Good morning, Eric:
We need a few more searches done THIS MORNING, if at all possible. O
Search terms "O'Boyle" AND "September 22" OR "lobby" OR "incident"
The date range for the above is September 22, 2015 through April 16, 2019
Search terms "O'Boyle" OR "Hidden Harbor" OR "Hidden Harbour" AND "dock" OR "promenade"
The date range for this one is January 1, 2017 through April 16, 2019
Please give me a call if you need any further explanation.
Thanks,
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.51i6
561.737.o188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Renee Basel
From:
Eric Wells
Sent:
Friday, May 3, 2019 11:49 AM
To:
Renee Basel
Subject:
RE: Another couple of searches, please
Renee,
To clarify, do you want the searches as follows:
O'Boyle AND September 22
O'Boyle AND Lobby
O'Boyle AND Incident
Then
O'Boyle AND Dock
O'Boyle AND Promenade
Hidden Harbor AND Dock
Hidden Harbor AND Promenade
Hidden Harbour AND Dock
Hidden Harbour AND Promenade
Just making sure that I understand this correctly.
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Friday, May 3, 2019 8:56 AM
To: Eric Wells <EWells@cgasolutions.com>
Subject: Another couple of searches, please
Good morning, Eric:
We need a few more searches done THIS MORNING, if at all possible. O
Search terms "O'Boyle" AND "September 22" OR "lobby" OR "incident"
The date range for the above is September 22, 2015 through April 16, 2019
Search terms "O'Boyle" OR "Hidden Harbor" OR "Hidden Harbour" AND "dock" OR "promenade"
The date range for this one is January 1, 2017 through April 16, 2019
Please give me a call if you need any further explanation.
Thanks,
Renee Rowan Basel
Executive Administrative Assistant
i
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.o188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
2
Renee Basel
From:
Renee Basel
Sent:
Friday, May 3, 2019 11:53 AM
To:
Eric Wells
Subject:
RE: Another couple of searches, please
Yes, Eric, you are correct. Please let me know how much time it takes as well. O
Thanks again!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.o188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: Eric Wells [mailto:EWells@cgasolutions.com]
Sent: Friday, May 3, 2019 11:49 AM
To: Renee Basel <RBasel@gulf-stream.org>
Subject: RE: Another couple of searches, please
Renee,
To clarify, do you want the searches as follows:
O'Boyle AND September 22
O'Boyle AND Lobby
O'Boyle AND Incident
Then
O'Boyle AND Dock
O'Boyle AND Promenade
Hidden Harbor AND Dock
Hidden Harbor AND Promenade
Hidden Harbour AND Dock
Hidden Harbour AND Promenade
Just making sure that I understand this correctly.
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Friday, May 3, 2019 8:56 AM
To: Eric Wells <EWells@cgasolutions.com>
Subject: Another couple of searches, please
Good morning, Eric:
We need a few more searches done THIS MORNING, if at all possible. O
Search terms "O'Boyle" AND "September 22" OR "lobby" OR "incident"
The date range for the above is September 22, 2015 through April 16, 2019
Search terms "O'Boyle" OR "Hidden Harbor" OR "Hidden Harbour" AND "dock" OR "promenade"
The date range for this one is January 1, 2017 through April 16, 2019
Please give me a call if you need any further explanation.
Thanks,
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
too Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.0188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Renee Basel
From:
Eric Wells
Sent:
Friday, May 3, 2019 1:58 PM
To:
Renee Basel
Subject:
RE: Another couple of searches, please
Renee,
You should have a folder on your desktop with today's date and a bunch of PSTs.
Time was 0.5 hours.
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Friday, May 3, 2019 11:53 AM
To: Eric Wells <EWells@cgasolutions.com>
Subject: RE: Another couple of searches, please
Yes, Eric, you are correct. Please let me know how much time it takes as well. O
Thanks again!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.o188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: Eric Wells [mailto:EWells@cgasolutions.com]
Sent: Friday, May 3, 2019 11:49 AM
To: Renee Basel <RBasel @gulf-stream.org>
Subject: RE: Another couple of searches, please
Renee,
To clarify, do you want the searches as follows:
O'Boyle AND September 22
O'Boyle AND Lobby
O'Boyle AND Incident
Then
O'Boyle AND Dock
O'Boyle AND Promenade
Hidden Harbor AND Dock
Hidden Harbor AND Promenade
Hidden Harbour AND Dock
Hidden Harbour AND Promenade
Just making sure that I understand this correctly.
From: Renee Basel <RBasel@gulf-stream.orB>
Sent: Friday, May 3, 2019 8:56 AM
To: Eric Wells <EWells@cgasolutions.com>
Subject: Another couple of searches, please
Good morning, Eric:
We need a few more searches done THIS MORNING, if at all possible. @
Search terms "O'Boyle" AND "September 22" OR "lobby" OR "incident"
The date range for the above is September 22, 2015 through April 16, 2019
Search terms "O'Boyle" OR "Hidden Harbor" OR "Hidden Harbour" AND "dock" OR "promenade"
The date range for this one is January 1, 2017 through April 16, 2019
Please give me a call if you need any further explanation.
Thanks,
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.oi88-fax
w-ww.gulf-stream.or
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Renee Basel
From:
Renee Basel
Sent:
Tuesday, July 2, 2019 11:19 AM
To:
Carlos Valdes
Subject:
IT search for a public records request
Good morning, Carlos:
Could you please do an IT search for the following:
"O'Boyle" AND "criminal" OR "2015mm012872" from 9/22/2015 to 4/16/19
Is there any way you can get this to me by close of business on Friday of this week?
Thanks and have a GRAND day!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5li6
561.737.0188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Renee Basel
From:
Carlos Valdes
Sent:
Wednesday, July 3, 2019 1:15 PM
To:
Renee Basel
Subject:
RE: IT search for a public records request
Hello Rene,
We placed a folder on your desks with the Emails we located, however, I wanted to note that we found zero emails with
the "2015mm012872" term. And where only able to find emails with "O'Boyle" AND "criminal"
Carlos Valdes
Jr. Systems Administrator I Data Technologies (Broward)
Calvin, Giordano & Associates, Inc. 1 1800 Eller Drive I Suite 600 1 Fort Lauderdale, FL 33316
Office:954.921.7781 1 Direct: 954.766.2762 1 Fax:954.921.8807
Fort Lauderdale / Miami -Dade / West Palm Beach / Clearwater/Tampa / Estero / Port St. Lucie
0 0
From: Renee Basel <RBasel@gulf-stream.org>
Sent: Tuesday, July 2, 2019 11:19 AM
To: Carlos Valdes <CValdes@cgasolutions.com>
Subject: IT search for a public records request
Good morning, Carlos:
Could you please do an IT search for the following:
"O'Boyle" AND "criminal" OR "2015mm012872" from 9/22/2015 to 4/16/19
Is there any way you can get this to me by close of business on Friday of this week?
Thanks and have a GRAND day!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
loo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.o188-fax
www.gulf-stream.or
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Renee Basel
From:
Renee Basel
Sent:
Wednesday, July 10, 2019 11:59 AM
To:
Carlos Valdes
Subject:
RE: IT search for a public records request
Hey, Carlos. How long did that take you?
Thanks!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561-737.o188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: Carlos Valdes[mailto:CValdes@cgasolutions.comj
Sent: Wednesday, July 3, 2019 1:15 PM
To: Renee Basel <RBasel@gulf-stream.org>
Subject: RE: IT search for a public records request
Hello Rene,
We placed a folder on your desks with the Emails we located, however, I wanted to note that we found zero emails with
the "2015mm012872" term. And where only able to find emails with "O'Boyle" AND "criminal"
Carlos Valdes
Jr. Systems Administrator I Data Technologies (Broward)
X alvin, Giordano & Associates, Inc. 1 1800 Eller Drive I Suite 600 1 Fort Lauderdale, FL 33316
Office: 954.921.7781 1 Direct: 954.766.2762 1 Fax: 954.921.8807
Fort Lauderdale J Miami -Dade / West Palm Beach / Clearwater/Tampa / Estero / Port St. Lucie
a
From: Renee Basel <RBase I@gulf-stream.or6>
Sent: Tuesday, July 2, 2019 11:19 AM
To: Carlos Valdes <CValdes@cgasolutions.com>
Subject: IT search for a public records request
Good morning, Carlos:
Could you please do an IT search for the following:
"O'Boyle" AND "criminal" OR "2015mmoi2872" from 9/22/2015 to 4/16/19
Is there any way you can get this to me by close of business on Friday of this week?
Thanks and have a GRAND day!
Renee Rowan Basel
Executive Administrative Assistant
Town of Gulf Stream
ioo Sea Road
Gulf Stream FL 33483
561.276.5116
561.737.o188-fax
www.gulf-stream.org
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Renee Basel
From: Carlos Valdes
Sent: Wednesday, July 10, 2019 1:35 PM
To: Renee Basel
Subject: Re: Voice Message Attached from 5612761942 - TOWN OF GULF ST
Hi Renee,
That search was 15 minutes.
Get Outlook for Android
From: voicemessage@vm.isncom.net <voicemessage@vm.isncom.net>
Sent: Wednesday, July 10, 2019 1:21:46 PM
To: Carlos Valdes
Subject: Voice Message Attached from 5612761942 - TOWN OF GULF ST
Time: Jul 10, 2019 1:21:46 PM
Click attachment to listen to Voice Message
Renee Basel
From:
Renee Basel
Sent:
Monday, January 6, 2020 11:43 AM
To:
Carlos Valdes
Subject:
RE: Record Request Search
To/From John Passeggiata containing the word "O'Boyle"
Date parameters: 9/22/15 through today's date.
Thankyou!
From: Carlos Valdes <CValdes@cgasolutions.com>
Sent: Monday, January 6, 2020 11:28 AM
To: Renee Basel <rbasel@gulf-stream.org>
Cc: Trey Nazzaro <tnazzaro@gulf-stream.org>
Subject: Record Request Search
[NOTICE: This message originated outside of the Town of Gulfstream -- DO NOT CLICK on links or open attachments
unless you are sure the content is safe.]
Hello,
Can you please provide me the details for the search you need done via Email here?
Carlos Valdes
Jr. Systems Administrator I Data Technologies (Broward)
XCalvin, Giordano & Associates, Inc. 1 1800 Eller Drive I Suite 600 Fort Lauderdale, FL 33316
Office: 954.921.7781 1 Direct: 954.766.2762 1 Fax: 954.921.8807
Fort Lauderdale / Miami -Dade / West Palm Beach / Clearwater/Tampa / Estero Port St. Lucie
0
Renee Basel
From:Jonathan O'Boyle <joboyle@oboylelawfirm.com>
Sent:Tuesday, October 27, 2020 5:00 PM
To:Renee Basel
Cc:Suze Courtney; records@commerce-group.com
Subject:RE: GS #2812 (Request for Public Records Related to Martin O'Boyle Criminal Case)
\[NOTICE: This message originated outside of the Town of Gulfstream -- DO NOT CLICK on links or open attachments
unless you are sure the content is safe.\]
Thanks Renee, I will be sending this off to Marty for his inspection and let you know if the Laserfiche is sufficient or if he
has any other questions for me.
From: Renee Basel <rbasel@gulf-stream.org>
Sent: Tuesday, October 27, 2020 4:53 PM
To: Jonathan O'Boyle <joboyle@oboylelawfirm.com>
Cc: Suze Courtney <scourtney@commerce-group.com>; records@commerce-group.com
Subject: GS #2812 (Request for Public Records Related to Martin O'Boyle Criminal Case)
Good afternoon, Jonathan:
See attached correspondence.
Kindest regards,
Reneé Basel
The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.
The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
1
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
2
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
November 13, 2020
Martin E. O’Boyle [e-mail to: meo@commerce-group.com]
Re: GS #2812 (Request for Public Records Related to Martin O'Boyle Criminal Case)
Dear Martin E. O’Boyle [e-mail to: meo@commerce-group.com]:
Thank you for your Facilitation Fee of $250.00 by check #52414 on August 31, 2020 for the
public record request described above, received by the Town on August 31, 2020. The Town
will apply this to the production of records in accordance with the 2018 Settlement Agreement.
The original request can be found at the following link:
https://portal.laserfiche.com/Portal/DocView.aspx?id=173216&repo=r-430100cc
Through your attorney, you agreed to have $27.57 deducted from the $250.00 Facilitation Fee
for GS #2812-1 of the request above. That leaves you with a balance of $222.43. On November
10, 2020, your attorney responded to GS #2812-9 and stated “Let’s go ahead and produce. What
additional funds do you need from us?” GS #2812-9 required a deposit of $241.90 which would
deplete the $222.43 balance of your Facilitation Fee leaving a balance owed of $19.47.
Sincerely,
Reneé Rowan Basel
As requested by Rita Taylor
Town Clerk, Custodian of the Records
1
Dear Custodian of Records For the Town of Gulf Stream
Re: Follow-up to Various Subparts
- The capitalized term Town will have the same meaning as it did in the Original Request.
1. Subpart 1 - All communications between the Town of Gulf Stream and Calvin, Giordano
& Associates related to Request #2704.
a. We understand that all records have been paid for and produced by the Town. I
thank you kindly and ask to correct my statement if I am wrong.
2. Subpart 2 - “All public records of the Town of Gulf Stream which pertain to Martin
O’Boyle’s reputation in the community.”
a. On November 5, 2020, we received an estimate for $35,646.16 which consists of
133 hours @220.00/hour and 132 hours @48.38/hour.
b. We ask that you please clarify who will be performing the tasks and what is the
basis for their hourly rate.
c. We also ask that you let us know how you came to this estimate. What tasks was
each person planning to do and how long was each task estimated to take to arrive
at the estimates time to completion.
3. Subpart 3 - “All public records of the Town of Gulf Stream which pertain to Martin
O’Boyle being obstructionist, defiant, or disruptive.”
a. On November 5, 2020, we received an estimate for $1,034.00 which consists of 4.7
hours @220.00/hour and 4 hours 27 minutes @48.38/hour.
b. We ask that you please clarify who will be performing the tasks and what is the
basis for their hourly rate.
c. We also ask that you let us know how you came to this estimate. What tasks was
each person planning to do and how long was each task estimated to take to arrive
at the estimates time to completion.
4. Subpart 4 - “All public records created, sent or received by the Town of Gulf Stream which
pertain to signage, speech, pamphlets, advertisements, mailers, or banners (whether
displayed in air, sea, land, or electronically) which the Town attributes to Martin O’Boyle
since January 1, 2014.”
a. On November 13, 2020, we received an estimate for $16,946.00 which consists of
68 hours @220.00/hour and 24 hours 26 minutes @48.38/hour.
b. We ask that you please clarify who will be performing the tasks and what is the
basis for their hourly rate.
2
c. We also ask that you let us know how you came to this estimate. What tasks was
each person planning to do and how long was each task estimated to take to arrive
at the estimates time to completion.
5. As to the Fifth sub-part, “All interagency communication which pertain: (1) to a September
22, 2015 Incident at Town Hall regarding Martin O’Boyle; (2) to Martin O’Boyle’s
character; and/or (3) to State v. O’Boyle, 2015MM012872A now pending in the 15th
Judicial Circuit.”
a. We do not believe we received an estimate for this. Were these records already
produced in response to Request 2704?
6. As to the Sixth sub-part, “All text messages created, sent, or received by Scott Morgan
since January 1, 2013”
a. We authorize you to produce these records if we have not already made such
authorization.
7. As to the Seventh sub-part, “All text messages caused or instructed to be sent by Scott
Morgan since January 1, 2013”
a. We understand that on November 13, 2020 you have represented that the Town has
performed a diligent inquiry as required under Chapter 119 but have found no
responsive records other than the Code Red Text. Please alert us if our
understanding is incorrect.
8. As to the Eighth sub-part, “All text messages created, sent or received by every person
within definition of Town of Gulf Stream, including without limitation, Robert Sweetapple
and Joanne O’Connor”
a. We do not believe we have seen an estimate for this. Please resend if it was not
produced.
9. As to the Ninth sub-part, “All text message on any phone issued or used by the Town Police
dating back to January 1, 2013. The word “phone” as used herein includes without
limitation, phones in storage, phones in current use, phones previously used, and includes
without limitation, personal phones in current use and previous use”
a. I believe we have already ordered this and the Town is awaiting funds.
10. As to the Tenth sub-part, “All public records that were created by, sent by or received by
the Town of Gulf Stream (especially to or from any State or Federal Attorney General’s
office, State Attorney’s office, or Federal, State, County, or Local law enforcement agency)
which pertains to or mentions: (1) Martin O’Boyle since January 1, 2014; (2) a September
22, 2015 Incident at Town Hall regarding Martin O’Boyle; and or (3) State v. O’Boyle,
2015MM012872A”
a. We do not believe we have seen an estimate for this. Please resend if it was not
produced.
3
11. As to the Eleventh sub-part, “All electronic transmissions created by, sent by or received
by Scott Morgan which pertain: (1) to Martin O’Boyle since January 1, 2014; (2) to a
September 22, 2015 Incident at Town Hall regarding Martin O’Boyle; and/or (3) to State
v. O’Boyle 2015MM012872A now pending in the 15th Judicial Circuit”
a. We would like these records produced.
b. We ask that you provide us with a detailed accounting of time spent and actions
taken upon reconciliation of the final bill.
12. As to the Twelfth sub-part, “All electronic transmissions caused or instructed to be sent at
Scott Morgan’s behest or behalf which pertain: (1) to Martin O’Boyle since January 1,
2014; (2) to a September 22, 2015 Incident at Town Hall regarding Martin O’Boyle; and/or
(3) to State v. O’Boyle 2015MM012872A now pending in the 15th Judicial Circuit”
a. We do not believe we have seen an estimate for this. Please resend if it was not
produced.
13. As for the Thirteenth sub-part, “All electronic transmissions created by, sent by or received
by any member of the Gulf Stream police (past or present) which pertain to: (1) to Martin
O’Boyle since January 1, 2014; (2) to a September 22, 2015 Incident at Town Hall
regarding Martin O’Boyle; and/or (3) to State v. O’Boyle 2015MM012872A now pending
in the 15th Judicial Circuit”
a. On November 13, 2020, we received an estimate for $935.42 which consists of 19
hours and 20 minutes @48.38/hour.
b. We ask that you please clarify who will be performing the tasks and what is the
basis for their hourly rate.
c. We also ask that you let us know how you came to this estimate. What tasks was
each person planning to do and how long was each task estimated to take to arrive
at the estimates time to completion.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing document was furnished via email to
Rbasel@gulf-stream.org and tnazzaro@gulf-stream.org, on December 4, 2020.
Respectfully Submitted,
THE O’BOYLE LAW FIRM
Attorneys for Requestor
1286 West Newport Center Drive
Deerfield Beach, FL 33442
Telephone: (754) 212-4201
4
Facsimile: (754)-212-2444
For Service of Court Documents:
oboylecourtdocs@oboylelawfirm.com
By: /s/ Jonathan R. O’Boyle
Jonathan R. O’Boyle, Esq.
Florida Bar #117547
joboyle@oboylelawfirm.com