Loading...
HomeMy Public PortalAboutPRR 14-1183REQUESTEE: RECORDS REQUEST (the "Request ") Date of Request: 7/31114 Requestor's Request ID#: 663 Custodian of Records Town of Gulf Stream REQUESTOR: Airline Highway, LLC REQUESTOR'S CONTACT INFORMATION: E -Mail: records @commerce- group.com Fax: 954- 360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Provide all Public Records which would confirm the statement made by Attorney Sweetap'-pTe—Tin—ifie Introductory Paragraph on Page 1 of the Defendant's Motion To Disqualify The O'Boyle Law Firm, P.C., Inc. And, In The Alternative, For An Evidentiary Hearing which reads as follows: "Jonathan R. O'Boyle has used the Pennsylvania professional corporate to establish an office or other regular presence in the State of Florida without being admitted to practice here generally and is thereby engaged in the unlicensed practice of law." ADDITIONAL INFORMATION REGARDING REQUEST: THIS REQUEST IS MADE PURSUANT TO PUBLIC RECORDS ACT, CHAPTER 119 OF THE FLORIDA STATUTES AND IS ALSO REQUESTED UNDER THE COMMON LAW RIGHT TO KNOW, THE COMMON LAW RIGHT OF ACCESS; AND ANY STATUTORY RIGHT TO KNOW (INCLUDING, WITHOUT LIMITATION, ANY STATUTORY RIGHT OF ACCESS, AS APPLICABLE). THIS REQUEST IS ALSO MADE PURSUANT TO THE RIGHTS OF THE REQUESTOR PROVIDED IN THE FLORIDA CONSTITUTION. IT IS REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED IN ELECTRONIC FORM. IF NOT AVAILABLE IN ELECTRONIC FORM. IT IS REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED ON 11 X 17 PAPER. NOTE: IN ALL CASES (UNLESS IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119.07(4) (a) (2) ALL ELECTRONIC COPIES ARE REQUESTED TO BE SENT BY E -MAIL DELIVERY. PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC RECORDS REQUEST IN ADVANCE. It will be required that the Requestor approve of any costs, asserted by the Agency (as defined in Florida Statute, Chapter 119.01 (Definitions)), in advance of any costs imposed to the Requestor by the Agency. I:P/NPR/FRR 04.22.13 FORM I a -•. ' SNTRECIRCUITCOURTOFTE B ism JUDICIALCBICUIT,INAND 111/ll FOR PALM BBACFI, COUNTY, FLORIDA .� MMEOPMUP. WHARH Case No.2014CA000720 Ptemtiff Division Al VS. TOWN OF Glws1RFAM, WILLYAMH.THRASRHR Defendant VERIFIED MOTIONFORADBMSION TO APPEAR PgOAACYiC& PURSUANT TOFLORMARULE QF JUDICLAL ADMDMTRATION2S10 Compsnow MATiiANR. O' BOYLHHavantberein ,endrespactibllyrcpmenis the fallowing 1. Movant7onathaalL O' Boyleisdomiciledmdpe =,aneatlymsidwiaLONOPORT, NEW JRRMY. Movaotis not apemienentresidentofthe State of Florida. Movant Jonsman R. O'Boylels a terapomryresidma of ale State ofFladda and has an appllmtionpmdingforadmissioata ThoFlodda]3w ndbasaotpreviomlybemdenied admission t o'The Florida Bar. 2. Movantismattomoyandamembwofthelawfirmof (orprardcmlawnnderthe name 0031 O'Bo*Tawt Fm PC.Mognedv knmva m Jonathn R- O'BoylePC) with offices at 2146 B. Huntingdon St Philaddolda_ PhOedelotda Peunswhnnia 19125 Sfi1- 758 -1223 (County) (State) (Tap Code) (Telephmo) 3. Mavnt bas bem mbeinedpemmaliy ores amembm of the abovanemedlaw fin on Jatmary 10.2014 by gaistoaber O'Hareviahis FL WomayLou Roeder (DataRepmsentatioa Commmued) (NameafPartyorpmties) to provide legal aeprumtadm is aoumection with the eb ovo-styled matter aow pending b ofore the above-named comtefthe State of Florida. 4.'Mount is as active membar in good sanding end mxxnatiy eligible to practice law in y} h•.y L, lnN. .� .. t'.� �}' r r the following jurisdiciion(s): Muds attorney orbermm3Is*)_ (Attach an additioml sheaif necessary.) . JUMDLCTMN ATTORNEY"NUNMER S. That are no diseiplhraryprocecdingspending against Movsnt, mcept as provided below (give jnrlsdicdou of disciplinary actloo, data of dtsciplinaryaction, naves, oftheviolatim and tba sanction, if any, imposed): (Attsehan additional shcstif7mussary.) 6. tflriathepastfive(S)yc , Movmtha saotb=mbj=ttomydisciplinary pmcee&Vp, eXceptasprovided below (give jodsdictioa of discipj nary action, data of disciplinary actiou, naaac of the violation and the sauctien, if soy, imposed): (Attach an additional shat ifnecessmy.) Z Mavanthas aeverban sobjectto any suspeasimpmeadmgs , amptas provided below (give jmisdictioa ofdiseiplinary action, data of disciplinsryaction, nahan of the violation and thesmatim;,ifagy, imposed): (Attach an additional sheet if accessary.) H. Movanthw naval bean subjwtm any disbarmeatpmceed'mga, erceptas pmvided Mow (givajmisdicdeaofdiseipBnary action, date of disciplinary action, mtum oftreviolaton and the sanction, ifdny, imposed): (Attacha IM 9. Nfavant tither byresigadon, withdrawal, or otherwise, nev .hss temilartad or attempted to temdnete Mnvant'e ot5cre es sa attmnayiaorda to avoid admio{shalive, disciplinary disbarment orsuspenainnpmceedings. 10. Movant is not aninactiva memberofThe FlaridaBar. 11. Movarst ismtnhwamcmheraFlheFloridaBv, 12. Meventis not a suspended member of The FloridaBur. 13. Movamis not a diebaaedmembec o£Thn FloridaBaraor has Moveatteoeiveda disciplinsryresiguation from. The Florida liar. 14. Movanthas notprevlouslybeen disciplined otheld irr mntemptbyaamnof miscandneteomndttedwhrTe cogaged in representatioapunaant to Florida Rule ofJudicial Administation 2510, except as pmvided below (Siva data ofdlsaplhwry action crcontempt rcasoastherefur, and camtimposin8 mulcmpt): (Attachan additional shectifnecessary.) fV+ . 15. Moventhes lRcdmotia(s)to appear es rnunulinFlodda state corals dudng the pastfive (5)years iu 0te followingmettem. (A ffarax as addidoaisheetifnoms my.) Dateof�Mlo /Snaa Casa Name Case Number Court Date Matfoa(imtodMeoied fN�KF 16. I.oca1 conael of mcord assn eiatat wt& Mavvrt is this matlar 3 e Ry>e -1a,} eC 0i0 jS6�j who is ga adivememberin goPd slandingofThe Florida (Nave and Pladds Der Number) .(� Baran((d�bas``offices at muQ 0. Alaa�ac�'i iRx\ktc 90,Qe- O21fi -.4. \d �Pari� (SIreNAdd' (Ctai Rsq- (Sb*) (Zip Cade) (Tdepl�epda,ermwde) (If local eonasel is not as eaivemember ofTbeFlodda Earle good standing, pleasopmvida in erriztion as to local cotmsel•s membaship status. 1 17. Movmdl3a resA capplicablapmvlsioaofp loddaRuleofludicial Adnmristmlioa 2.510 andRi*1 -3.10 of the Rules Rcg JagngTlmFloridaBaread certifies thettbis vedfied mofioa complies WRh.thoserulas. 18. Movant agrees to complywith dw provisions oftba Florida Riles ofPmfossionsl Coaduct and eonsentsto the finiedictioa of the courts eadtheBarof Um State ofFlmids. WFBRBFORB, Movmtrespectfillyregnestspemussion to appear in this court for this cause only. DATED this_ dayof gnuKrw gnu 20J Havant ' 4 rage 1 01 1 Corporations Online Services I Corporations I Forms I Contact Corporations I Business Services Search By Business Name Business Entity Filing History Oaf%: 4252014 By Business Entity ID (Select the link above to view the Business Verity Entity's Filing Hlstory) _.___ ... _....._...... Verify Certification 11/142013 Of Orders Register r for or Online Business Name History Orders 1001 Broad Street Order Good Standing Name Name Type Order Certified Documents Order Business List The O'Boyle law Finn, P.C. Current Name Current My Images ]ONATHAN FL O'BOYLE P.C. Prior Name Search for Images Professional Corporation - Domestic - Information Entity Number. 4227891 Status: Active Entity Creation Date: 11/142013 State of Business.: PA Registered Office Address: 1001 Broad Street Johnstown PA 15908 Cambria Mailing Address: No Address COq h102M Pem,,ana negnmenlolaab N RI,h, Be., Pmacy Policy I sewary Pofry EXHIBIT https: / /www. corporations. state. pa .us /core /soskb /Corp.asp ?3249952 4/25/2014 C IN 'THE FIFTEENTH JUDICIAL CIRCUIT COURT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2014- CA- 003938AB k CiEERi1F10 COPY JASON WEEKS, 'CONDF QSED Petitioner, vs. TOWN OF PALM BEACH, Respondent, TRANSCRIPT OF 'TESTIMONY AND PROCEEDINGS HAD BEFORE THE HONORABLE THOMAS BARKDULL DATF: APRIL 10, 2014 TIME: 9;00 - 10:30 A.M. PLEASANTON, GREMUUML, MEEK & MARSAA 551/833.7811 I 2 4 1 INDEX 1 PROCEEDING S- 2 TESTIMONY AND PROCEEDINGS 2 THE COURT: Jason Weeks vs. Town of Palm 3 APRIL 10, 2014 4 3 Beach, Who Is ham on behalf of the plaintiff? '5 WITNESSES FOR DEFENDANT 4 MR. MESA: Good moming, Your Honor. 5 DIRECT CROSS REDIRECT 5 Giovenl Mesa on behair of plalmlff ,Jason 7 DANIELLE OLSON 6 Weeks. 8 By Ms.Cocper 13 29 7 THECOURT: And who doyouhavawNhyou? By Mr. Mean 25 B, Mr. Weeks? 9 10 SPENCER WILSON 9 MR O'BOYLE: No, sir. My name to Jon 11 By Ms. Cooper 30 10 O' Boyle. I'm acting as Mn Mesa's law cle*. By Mr. Mesa 31 11 I'm a Pennsylvanla lawyer. 12 13 KATHRYN DYSON 12 THE COURT: Let me ask you a question, Mr. 14 By Ms. Cooper 33 13 O'Boyte. Any relation to the O'Boyle in the Sy Mr. Mesa 34 14 O'Boyle Law Finn, P.C.? 15 16 MR. O'BOYLE Yes, Your Honor. 1s EXHIBITS 17 IN EVIDENCE is THE COURT: What's the relation? 18 17 MR.O:BDYLE That is my name on the law 19 Respondent's Exhlblt No.1 37 is firm. It's an Interstate law firm. Lefler 19 THE COURT: How do you — ti's an 20 20 Interstate low fimf with a Florida address? 21 Respondent's Exhibit No, 2 37 EEmelis Zt MR.U'BOYLE Thare'se Florida address 22 22 and a Pennsylvania address. 23 Petilloner's Exhibit No. 1 38 23 THE COURT. And you're down here Em295 24 practicing with a firm without being a member 24 25 of the Florida Bar? 26 3 6 1 APPEARING ON BEHALF OF PETITIONER; 1 MR. O'BOYLE: No, sir. 2 Glovant Mesa, Esq. 2 THE COURT. Are you a member or the THE O'BOYLE LAW FIRM. P.C. 3 Florida Bar? 3 1206 West Newpod Center Drive 4 MR. O'BOYLE: No, sir. Deerfield Beach, Florida 33432 5 THE COURT: Why do you think you have any 4 5 APPEARING ON BEHALFOF RESPONDENT: 8 right to stand at lhatfabie? 0 Margaret L. Cooper, Esq, 7 MR. O'BOYLE: I don't have any light other JONES, FOSTER, JOHNSTON & =699, PA. 8 than to assist Mc Mesa. 7 505 South Flagler Drive 9 THE COURT. Goad. You step back because Suite 1100 10 were about to discuss the Illegal practice of 8 West Palm Beach, Florida 33401 11 law without being a member of the Florida ear. 9 10 ALSO PRESENT: Jonathan O'Boyle, Esq, 12 MR. USOYLE: Yea, Your Honor. 11 ___ 13 THE COURT: Mr. Mesa, are you a member of 12 BE IT REMEM13EREDlhat the following testimony 14 the Florida Bar? 13 and proceedings ware, had In the above- entkled muse 15 MR, MESA: Yes, l am, Your Honor. 14 before the HonorableThomes Barkdull, In the Palm 18 THE COURT: How, long have you beer's is Beach County Courthouse, Cltyof Weal Palm Beach, 17 member of the Florida Bar? 18 Stela of Florida, on Thursday, the fifth day of 17 April, 2014, to wit 18 MR. MESA Since November of 2010. 18 - -- . 19 THE COURT., Are you a partner In the, 19 20 quote,, O'Boyle LawFlmt7 20 21 MR. MESA: I am not, Your Honor. 21 22 THECOURTt How many attorneys am them 22 23 In the O'Boyle LRwFimr7 23 24 MR. MESA Four —five at the moment, 24 25 25 Your Honor. PLEASANTON, GREENHILL, MEEK & MARSAA 561/833.7811 PLEASIMd011, GREENHILL, MEEK & MARSAA 561/8.33.7811 a e ' 1 THE COURT: How marry are located in the 1 she admitted receiving an e-mail from Kathryn 2 Slate of Florida? 2 THE COURT: Okay. So there's one a -mall 3 MR. MESA: Four, Your Honor. 3 at issue, 4 THE COURT: Okay. Who are the partners In 4 MR. MESA: That we're aware of, Your 5 the Florida Arm? 5 Honor. 6 MR. MESA: Brian Witmer and Jon O'Boyle, a THE COURT: And what date Is the dale of 7 THE COURT: This gentleman Ia a paMerin 7 that alleged a -mall? B the Florida ft? B MR. MESA: It's May5th. 9 MR. MESA: Ira a multi stale firm, Your 9 THE COURT: Of whatyear? 10 Honor. To he quite frank with you, I'm not 10 MR. MESA: 2011,Ywr, Honor. 11 sure how IN Incorporated but l know that 11 THECOURT: May6th,2011. 12 Sdan Nirner Is a partnerin the fem ondhe is 12 Ms. Cooper, what is your cilenfs position 13 a Florida aflame -, 13 on this? 14 THE COURT: Who's herefor the defense? 14 MS. COOPER: Your Honor, there k no 15 MS. COOPER: I am,Your Honor,Margemt 16 a map, Let me explain. And thaywere advised 1S Cooper. 1a that [hare is no e-mail. Mr. Weeks is confused 17 THE COURT: Welcome, Ms, Cooper. 17 and 1 will explain whalhappened. Mr. Weeks iB MS. COOPER Thank you. 16 Bled a complaint with the HR department on 19 THE COURT: All right. Mr. Mass, you— 19 MaY5. Mrs, Olson is the HR director. 20 who is Ashles A. Ricliman? 20 THE COURT: Is Mr. Weeks an employee? 21 MS, COOPER Ashlee Richman Is a lawyer in 21 M9. COOPER: He was at the lime. He s. 22 the law firm of Jonas, Foster, Johnston A 22 been terminated now and we're in other 23 Stubbs. 23 [ligation with Mr. Weeks. 24 THE COURT: Iapalogize, [grabbed the 24 THE COURT: Okay. 25 wrong pleading. Let mete whet was filed by 26 MS. COOPER: Mrs. Olson who is the HR 7 B 1 the plaintiff here who called my office 1 director was at an impasse hearing across the 2 yesterday Jumping up and down saying this Is an 2 street In another bulking• Ms. Dyson 3 emergency. 3 contadad harlot advise her that a complaint 4 Mr. Mesa filed this. Okay. Mr. Mean, 4 had been Initiated by Mr. Weeks, Later on when , 5 What do you believe your client needs tha(yoyr 5 Mrs. Olson Was being Interviewed, It was about 6 client Is not receiving other than one letter a maybe six, eight months later, whatever It was, 7 oronae -mall? 7 she lmewthat them. had been an e•mall B MR MESA: Ira the initial a -mall that B communication between she and Mrs. Dyson and G was made between Kathryn end Danielle who are 9 she made amistake and she mlsspoka and she 10 both human resources personnel with the Town of 10 said l Initially got the information by a -mall i t Palm Beach. Your Honor, specifically kwas a 11 from Mrs. Dyson. That Was a mistake, It was 12 request that was made by Mr. Weeks forany and 12 either an Instant- 13 alt a- malls, iMessages, communlcafforls and any 13 THE COURT.' Okay. So ire the low's 14 documents between Danielle Olson and Kathryn 14 position that one. It douret sxlst7 16 Dyson, and as stated, both ofwhom are human 15 M5. COOPER It doesn't exist. And I 16 resource personnel with the Town of Palm Beach 16 apologize, I thought youlust wanted to hear 17 on May 5m, 2011. 17 feria the lawyers today. Mrs. Olson Is an her 1B Your Honor, Mr. Weeks revolved a portion 14 way to testify, she'll be here In five minutes. 19 of an amali communication, an o-mall chain, 19 It just simply does not exist and we can'l 20 coatis. However, it is missing the lnlflel 20 pmducewhaVI; not. 21 e-mail from Kathryn to Danielle. It is 21 THE COURT: Okay. It doesn't exist so 22 appare nt lust on a dear view of the documents 22 have you advised Mr. Mesa of this? 23 that were provided that the lnifial e-mall is 23 MS,CDOPER: Walust got this lawsuit 24 missing. In addition, Your Honor. there is a 24 filed. Mr. Waaks was advised bul l Was atthe 25 recorded intsivlswwith Denials Olson which 26 2nd DCA arguing a case yesterday and this was PLEASIMd011, GREENHILL, MEEK & MARSAA 561/8.33.7811 PLEASANTON, GRIMMILL, MEEK & MAIZSAA 561/b33,7811 10 12 I all happening very fesL I" a getting reedy 1 you go to law school? 2 lo— 2 MR. O'BOYLE: Drexel Law University In 3 THE COURT: That's why l wanted to do It 3 Philadelphia, Pennsylvania, 4 wry qukkly bemuse it seems to be a really 4 THE COURT., Are you from Florida 5 simple Issue. One o-mall, If It u1sh, and 6 cdginelly7 5 Its not privileged, It needs to be tuned B MR. O'BOYLE: Yes, Your Honor. 7 over, If 9 doesn't exist, R doesn't exist, 7 THE COURT: Whereabouts? a and I'll take lesfimany today and we'll a MR: O'BOYLE Gullstresm, Florida 9 determine whether It exists or It doesn 't end 9 THE COURT: Okay. Congratulations on 10 this mss wig be over. 10 passing the Florida Bar, Goad luck an gelling it Mr. O'Bayler have you moved to bb admMed 11 admitted. 12 pro hac vita in Florida al ell? 12 All dght. As soon as ourwiinesses 13 MR, O'BOYLE: Yes, YourHonon 13 appear, I'll heartmilmony. Just advise my 14 THE COURT. How manytimes? 14 deputy and we'll deal with IL Y.ery good. 15 MR O'BOYLE Once, Your Honor. 16 (Thereupon, a lamas was had,) THECOURT; Mysuggestlon isifyou think is THE COURT: Good morning and welcome, 17 you're going to keep a low firm In Florida and 17 everyone. Welcome back. Okay. We am hem on 16 walk up to counsel table like you're munsof In 10 the case of Weeks vs. Town of palm Beach on a 19 Florida that you lake the Florida Bar. 19 request for an emergency. hearing on the issue 29 MR, O'BOYLE: Yes, Your Honor. 20 of whetherpgbllc.ramrds are available and 21 THECOURT: How long hasyourfum been 21 whether they should be produced. Iheard the 22 operating down here? 22 Iniltai arguments of counsel. The town's 23 MR O'BOYLE: Slncs January, mid January; 23 posiflon, as I understand h, Ms. Cooper, is 24 Your Honor. 24 that they requested an e•mall that does not 25 THECOURT: Have you signed up for the 25 exist, Is that cormc17 11 13 1 Flodda Baryal7 1 MS, COOPER: That is correct. Your Honor. 2 MR. O'BOYLE: Yes, Your Honor, and l 2 THE COURT: Okay. You may call your first 3 passed It actually. 3 witness. 4 THECOURT. Congratulations, Whenomyou 4 MS: COOPER; I'll call Deniello Olson. 5 being swum In? 5 THECOURT. Ma'am,•dyou'll please take 6 MR. O'BOYLE: That is to be delemnlned, 6 the witness stand. Please watch yourstep, 7 Your. HOnar. 7 THEREUPON, 5 THE COURT: Having trouble with your a DANIELLE OLSON, 9 background check erwhy aren't you being sworn 9 called as a witness by the Defendant, having boon 10 in If you passed the Florida Bar? 10 first duly awom by the Court, In answer to 11 MR. O'BOYLE: Yes, Your Honor. I passed 11 questions propounded, was examined and lestllled so 12 the New Jersey Bar as well and— 12 follovm; 13 THE COURT: Well,we'tenotln New farsay, 13 THECOURT: Counsel, you may lnquhe. 14 MR, O'BOYLE: Your Honor, correct, but 14 MS,COOPER: Thank you, Your Honor. 15 Florida is waiting for New Jersey ,their 15 DIRECT EXAMINATION is process to be completed until they will further 16 BY MS. COOPER 17 process my Me. 17 Q Would you state your name, please? 15 THE COURT. Have you been admitted In any 16 A Oaniello Olson. 19 stale? 19 O Mrs. Olson, what is your position with the 20 MR OSOYLE: Yes, Your Honor, 20 Town of Felm Boach7 21 Pennsylvania, 21 A Dlrectorofhumanmemmaes, 22 THE COURT: When wore you admitted In 22 O And have you been involved In the search 23 Pennsylvania? 23 In response to Mr. Weeks' public document request 24 MR, O'BOYLE: Novembar=2, Your Honor. 24 seeking a -mails between you and Mrs. Dyson - 25 THE COURT. November of 2012. Whom did 25 A Yes. ' PLEASANTON, GRIMMILL, MEEK & MAIZSAA 561/b33,7811 lob S. i3tti s� Address Addmss .eo,.1 -���] OSt�fe3 Sfst%Zip Code ' Tc(epbouaNumbet STATEOF LiJ t^St COUNTY OF AflkA - c- Ix -li} .460 R. IC .dehemby�oralii==dmpewltyof pmjury that am thoM&mt is the abav tyled matter; that Ihavomad the fotcgoLtg Motien and knowthe contents fhcrwt and the contmte are tme ofmyawnlmowledgo mdbelleE Mavens Ifimeby wusantte bo aamdetedas local twsel ofrocozd ul this cauaepursumtte FloridaRulc eJ'udicWAdmiaistmtion 2 .510. DATEDtLie 2. 3fd dayof ;�-AvjkZ4 I,oesl Counsel afR=rd mc. 1.1 Nee, a ('�avrixl' �lti`tC Address �at t 0raca.t FI. - �Sw - Address >JEM -1 71by lint ti Name Detail by Entity flame Foreign Profit Corporation THE O'BOYLE LAW FIRM, P.C., INC. Filing Information Document Number FEI /EIN Number Date Filed State Status F14000000600 NONE 02/10/2014 PA ACTIVE Principal Address 1286 W. NEWPORT CENTER DRIVE DEERFIELD BEACH, FL 33442 Changed: 02114/2014 Mailing Address 2146 E. HUNTINGDON STREET PHILADELPHIA, PA 19125 Registered Agent Name & Address WITMER, RYAN L 1286 W. NEWPORT CENTER DRIVE DEERFIELD BEACH, FL 33442 Address Changed: 02114/2014 Officer /Director Detail Name & Address Tftle DP O'BOYLE, JONATHAN R 2146 E. HUNTINGDON STREET PHILADELPHIA, PA 19125 Annual Reports No Annual Reports Filed EXHIBIT Document Images Page I of 2 http: // search. sunbi7. orgllnquiry/ CorporationSearch, �SearchResultnetail /FniirvX',gn,r /Pnm_r a11.1nnl.i Case 9:1 - 80530 -DMM Document 25 Entered on FLSD Docket 06/17/2013 P �agijl of E.S,rEVCN UNITED STA TES DISTRICT COURT 17 1013 SOUTHERN DISTRICT OF FLORIDA M o'sjMo , g, RE Case No, 13.805/30- CIV- MIDDLEBROOKS xRa �0 MARTIN E.0'BOYLE 1 �C�S30 Plaintiff, VS. TOWN OF GULF STREAM Defendant. MOTION TO APPEAR PRO HAC VICE CONSENT TO DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILINGS In accordance with Local Rules 4(b) of the Special Rules Governing the Admission and Practice of Attorneys of the United States District Court for the Southern District of Florida, the undersigned respectfully moves for the admission pro hac vice of Jonathan R, O'Boyle of 2146 E. Huntingdon St, Philadelphia, PA 19125,561-758-1223, for purposes of appearance as co- counsel on behalf of Martin E. O'Boyle in the abpve -styled case only, and pursuant to Rule 2B of the CM/ECF Administrative Procedures, and to permit Jonathan R. O'Boyle to receive electronic filings in this case, and in support hereof states as follows; 1. Jonathan R O'Boyle is not admitted to practice in the Southern District of Florida and is a member in good standing of the Pennsylvania Supreme Court (PA BaT#314500). 2. Movant Robert S. Gersbman, Esquire, of the taw 6rm of GER$HMAN & GERSHMAN, P.A, 2160 W. Atlantic Avenue, 2d Floor, 561.684 -8898, is a member in good standing of the The Florida Bar and the United States District Court for the Southern District of Florida, maintains an office in this State for the practice of law, and i4 authorized to file through the Cone electronic filing system X,..s? ;;y,; Case 9:13 -cv- 80530 -DMM Document 25 Entered on PLSD Docket 06/17/2013 Page 2 of 5 Mgvaat consents to be designated as a member of the Bar of this Court with whom the Court and opposing counsel may readily communicate regarding the conduct ofthc case; upon whom filings shelf be served, who shall be required to electronically file all documents and things that maybe Sled electronically, andwho shell be responsible for filing documents in compliance with the CM/ECF AdministrafiveProcedures, Sea Section 2B of the CM/ECF Administrative procedures. 3. In accordance with the local rules of this Court, Jonathan R. O'Boyle has made payment of this Court's $75 admission fee. A certification in accordance with Rule 4(b) is attached hereto. •4. Jonathan R. O'Boyle, by and through designated counsel andpursuantto Section 2B CMIECF Administrative Procedures, hereby requests the Court to provide Notice of Electronic Filings to Jonathan R, O'Boyle at email address; Jonathmmboyle@gmail.com. WHEREFORE, Robert S. Oershman, moves this Court to enter an Order Jonathan R O'Boyle, to appear before this Court onbehalf of Mat* H. O'Boyle, forall purposes. relating to the proceedings in the above -styled matter and directing the Clerk to provide notice of electronic filings to Jonathan R. O'Boyle. Date: June 17, 2013 Respectfully submitted, 41datar=947397 Ian Robert®rglawfum.us QERSWAN & OERSHMAN, P,A, 2160 W. Atlantic Avenue, 2d Floor Delray Beach, FL 33445 (561) 684 -8898 (telephone) (561) 998 -5868 (facsimile) Attorney for Martin E. O'Boyle Case 9:13 -cv- 60530 -DMM Document 25 Entered on FLSD Dacke( 06/17/2013 Page 3 ot5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Casa No. 13. 80530- Civ- MIDDLFBROOAS MARTWR O'BOYLE Plaintiff,. VS. TOWN OF OULF STREAM Defendant CERTIFICATION OF JONATHAN R. O'BOYLE Jonathan R. O'Boyle, Esquire, pursuant to Rule 4(b) of the Special Rules Onveming the Admission and Practice of Attorneys, hereby certifies that (]) I have studied the Luca] Rules of the United States District Court for the Southern District of Florida; and (2) I am amember in good standing of the,Pennsylvenia Supremo Court, yx✓9arel onathan O'Boyle PA BerH314500 Case 9:13 -cv- 80530 -DMM Document 25 Entered on FLSD Docket 06/17/2013 Page 4 of 5 CERTIFICATE OF SERVICE . IHPREEY CERTIFY that atrue and correct copy of the foregoing Motion to Appear Fro Hoc Nice, Content to Designation and Request to Electronically Receive Notices of Electronic Filings was served by uploading same to the CMJECF. SERVICE LIST Joanne M. O'Connor jocoanor©jonmfacmncom JONES FOSTER JOHNSTON & STUBBS,P.A. 505 South Flagler Drive Suits 1100 West Palm Beech, FL 33401 561-659.3 0 00 (telephone) 561-650- 5300(famirnile) Attorneys for Defendant Town of Oulf Stream Case 9:13 -cv- 80530 -DMNI Document 25 Entered on FLSD Docket 0611712013 Page 5 of S UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No, 13- 50530- CIV- MIDDLEBROOKS MARTIN E. O'BOYLE Plaintiff, VS. TOWN OF GULF STREAM Defendant. ORDER GRANTINGMOTION TO APPEAR PRO HAC VICE, CONSENT TO DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING TFRS CAUSE having comebefore the Court on the Motionto AppearPro Hac Vice forlonathaaR .O'Boyle,CormuttoDesigrisi aMRequesttoElecft icanyReceiveNoticesof Electronic Filing (the "Motion"), pursuant to the Special Rules Governing the Admission and Practice of Attorneys in the United States District Court for the South District of Florida and Section 213 ofthe CM(ECF Administrative Procedures. This Court having considered the motion and all other ralevant factors, it is hereby of Florida. ORDERED ORADJUDGED that: The Motion is GRANTED. Jonathan R. O'Boyle, may appear and participate in this action on behalf of Martin E. O'Boyle. The Clerk shall provide electronic notification of all electronic filings to Jonathan R. O'Boylo at lonathanroboyle@gmail.com. DONE AND ORDERD in Chambers, West Palm Beach, Pahn Beach County, Southern District of Florida, on June , 2013. DONALD MIDDLEBROOICS United States District Judge Copies fiunished to: All Counsel of Record Case 9:13 -cv- 80530 -DMM Document 27 Entered on FLSD Docket 06/19/2013 Page 1 of 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.13- 80530- CIV- MIDDLEBROOKS MARTIN E, O'BOYLE, Plaintiff, VS. TOWN OF GULF STREAM, Defendant. THIS CAUSE comes before the Court upon a Motion to Appear Pro Hoc Vice, Consent to Designation, and Request to Electronically Receive Notice of Electronic Filings (DE 25) ( "Motion "), filed June 17, 2013, The Court has reviewed the record and is fully advised in the promises. Pursuant to Local Rule 4(b) of the Special Rules Governing the Admission and Practice of Attorneys in the United States District Court for the Southern District of Florida, the Motion requests permission for the limited appearance of Jonathan R. O'Boyle, of 2146 E. Huntington St., Philadelphia, PA 19125, as co- counsel on behalf of Plaintiff in this matter. The Motion has been property filed with the required documentation, and the attorney appears to be in good standing. Accordingly, it is hereby ORDERED AND ADJUDGED that the Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notice of Electronic Filings (DE 25) is GRANTED, Jonathan R. O'Boyle may appear and participate as co- counsel in this action on behalf of Plaintiff. The Clerk shall provide electronic notification of all electronic filings to Jonathan R O'Boyle at ionathamobo le(aa gmail.com. DONE AND ORDERED in Chambers at West Palm Beach lorida, this / day of June, 2013. UNITED STATES DISTRICT JUDGE Copies to: Counsel of Record t t 1 f Z11r0 a rIUiv 11IN VLUN 31 Page I of 2 0 2146 E HUNTINGDON ST ACCOUNT# 314138000 Assessment Tax LOOP Account Information OWNER(S) O'BOYLE KELLY L MAIUNO ADDRESS 2146 E HUNTINGDON ST Philadelphia PA 191251427 PROPERTY UNIT None PROPERTYZIP 191251427 SALE DATE 8/1812009 SALE PRICE $193,500 HOMESTEAD $30,000 Property Characteristics LAND AREA 1,260 SgFt IMPROVEMENT AREA 1,548 SgFt IMPROVEMENT DESCRIPTION httn: / /nrnnertv.nhi1s anv/ hur1' e11, L140 L' MUN 11114131JUN d1 ROW 2 STY MASONRY BEGINNING POINT 200'E OF COLLINS ST EXTERIOR CONDITION New / Rehabbed ZONING RSA5 Residential /Residential Mixed -Use Page 2 of 2 Note: The Department of Revenue is responsible for collecting real estate taxes. Please visit the Department of Revenue, Website (http: / /www.phila.gov /ievenue) for information regarding the billing, collecting and accounting of real estate taxes or call 215£86 -6442. New Search View Tax Balances (http://Www.phila.gov/revenue/RealEstateTaxIDefault.aspx? bctBRTNo= 314138000) Submit an Inquiry (http: / /opa.phila.gov /opi.apps /Help /CitizenMain. sch= Ctrl2 &s =1 &url= search &id = 4406002146) hffnt / /nrnnrxty nhiln anv/ Certified Valuation History ASSESSED ASSESSED ASSESSED. ASSESSED MARKET LAND IMPROVEMENT LAND IMPROVEMENT TOTAL YEAR VALUE (TAXABLE) (TAXABLE) (EXEMPT) (EXEMPT) ASSESSMENT 2015 $138,400 $18,648 $119,752 $0 $0 $138,400 2014 $136,400 $18,648 $119,752 $0 $0 $136,400 2013 $27,800 $2,159 $6,737 $0 $0 $8,896 2012 $27,800 $2,159 $6,737 $0 $0 $8,896 2011 $27,800 $2,159 $6,737 $0 $0 $8,896 2010 $27,800 $2;159 $6,737 0 $0 $8,896 2009 $27,800 $2,159 $6,737 $0 $0 $8,896 Note: The Department of Revenue is responsible for collecting real estate taxes. Please visit the Department of Revenue, Website (http: / /www.phila.gov /ievenue) for information regarding the billing, collecting and accounting of real estate taxes or call 215£86 -6442. New Search View Tax Balances (http://Www.phila.gov/revenue/RealEstateTaxIDefault.aspx? bctBRTNo= 314138000) Submit an Inquiry (http: / /opa.phila.gov /opi.apps /Help /CitizenMain. sch= Ctrl2 &s =1 &url= search &id = 4406002146) hffnt / /nrnnrxty nhiln anv/ I UN=15 S'T'ATES DISTRICT COTMT FO$TE3 SOUTEEW DISTRICT OF FLORIDA WEST PALM BEACH bM610N CASE NQ. Pr13-cv,483 -49 Valatitti; vs. TOWN OF GULF STR];AN et, at, Defentlauts. MOTTON TO AP RRO A'AC VEC`R,S;()13$L'+fYP TO ," j`y, fG#<7ATYON.AN7 RL�',QTTT_.iF'TCl P:ilT,t`.TRO1dTCAi,TA'R'RCRTVI2 NOTE . OhRY,RCT1 —T T' Crat In accordsnee with Local Rules 4(b) of the Special Rules Oovoming the Admission and Pmatlee ofAttomeysofthe:United States District Court for the Southern District of Florida, the midorsign4d respectfrdly moves for the admission pro ime vice of To ratban R. O'Boyle, of2146 V.Tluntingdon St., Pidindelphla PA 1912.5, 561 -758 -1223, Porpurposes afappearaoco as co- ootmsel on bebalfofChris O'llaw In the above -styled vase only, and pinsuont to Rule 2a of the CM/ECF Adminlsaativo Procadures, to permit ronathan R. O'Boyle to tecolvaelcoltonle filings In this.oase, and in support thereof states as follows: 1. Jonathan R. O'Boyle is not'admitted to practice in the Southern Mtrlctof Florida and is a meoiber in good standing of the Pennsylvania Supreme Court (PA Bar# 314500). 2. The undersigned is a muMber io good dtending of the ThdTlorida Bar and theUmtcd States District Court for the Southern District of Clorida, maintains an ofGee, in this State for the practice of law, and is authorized to file through the Court's electronic filing system. Movant ponsents to be designated man member of the Bar of this Court withwbom the Court ad Opposing counsel may readily oommunloate regarding the conduct of the case; upon whodt filings shall be served, who shall be inquired to oleationically file all documents and things that may be filed electronically, dad who shall be responsible fat filing documents In compliance with the CMIECF Administrative procedures. Sae Section 2B of the CM /I3CF Administrative Procedure. '.'i.:. ICay IGa a4 JAN 1 S 2014 , 3. In accordance with the local. rules of this Court, Jonathan R. O'Boyle has made paymentoftds Court's $75 admission, fee. Acertification. in adcordanes with Role 4(b) is being bled contemporaneously Suitt this Motion. A bogy is attached hereto, 4. Jonathan IL O'Boyle, by and througb designated counsel aqd pursuant to Section 213 CMIECF Admintstrative Procedures, hetaby rtquests the Court to prot%de Notce ofEleotchnfc Filing to Jonathan R. O'Boyle at email addmsrjonathauaboylc@gmag.com. WHEREFORE, Mark J. Hanna moves this Court to an ter an Order permitting Jonathan R- 0 93 oyle to appour before this Court on behalf of Chris OTare fpr all purposes rdlgting to th8 py6ocodings In tiro above- glyled matter and directing the Clerk to provido notice of eleotrohia filings to Jonathan R. O'Boyle. to) VIA vm fIFIV 9 UW • a c t I IMRE13Y CERTIFY that on January 10, 2014,1 tiled the foregoing document with the Clerk of Court via conventional me0rod due to the nature of thcuration. I furthercertifythat mailed Cho foregoing document via prepaid first claid U.S.:Mail tothe following: lvl:ichaol R. Piper Christopher J. Stearns JOHNSON, ANSEI.MQ, MIJRDOCH, B.URICt, PIPER & HOCIINJAN, PA. 2155 East Sunrise Boulevard, Salto 1000 Fort Laudordalo, Florida 33304 Tolopliono.: (954) 463 -0100 pipti@jambg.com stcamsQajambg.aom Dated., January, 7, 2014 GIVITAMADISON RA- 4.01 Southgi.nly Rdad #3272 Palm II�adh; ,1 80 -9.191 Ta1:56rdb 999 FlocAa Bar No• 0045251 561 - 721-8294 (cell & text) Tphaara@g3;m1%w.com UNITJ6D STATRSDPd=CT COURT FORTERSOU17UMNDISTRSCPOFFLORMA V;=PAIMBuCRDX=ON dmW NO; 9r73lvBL053.ftL,R rmutYrtr; TOWN OF GULF SIRRAMal. A Dchadaoh. Jonmltm RO'Boy1q,Esgphe,purs ntto Rglo4(b ofthe Spocial Rulos Oavmoiugthe Admkalojr and Praodm ofAttamays, heroby eeffffim tbat( )Ihava dialled die LoadRulet ditto UoOed Smtnr District Court far the Sootham District ofFlpddq und (2)14m a mcmbae hgaml smnding of the pemnylvm)k Supreme Court Jm 01 O'Boyle, Beg. Jomdli n R. O'Boyle, P.C. 7,146 H. Huntingdon St. PhOaddlplda, PA 79125 161:561-75 &1223 ITW215 - -89J -3641 Pmnsy7vmfa BarNa:314500 1 HEREBY CEM-ArY diatpn January 10, 2014, 1filod %a foregoing doonmantwith he Clerk of Comavkamrveddonul mothod due to the natum of the motion. I further citify dint mailed the fomgofng documontvi /prepaid first class U.S. mail to thafallcwkg Wehdal F.Plpor Cbrlempbgl. Stearea JOHNSON, ANSE('.MD, M[RtDOCB, BURKE. PM &130MZMN, PA, 2455 EmtSunrisaB'ealeva d, Saito 1000 FodLodanlule, Floridn33304 Ihlephone; (954) 463.0100 pipera mbg.com steotnsgambg.com Dated: Jonomy Y, 2414 OMMMADISON PA. 40l South County Road 03272 FftQn BnaoE, 8.33489 -9991 161:SSi.22 -9994 Madt J.Hennn Florida i)mNo. 0045251 561.723 -8284 (call & ter) mbmmaQg3mlaw,com UN= STATUS DISTRICT COURT FOR THE SOUTM" DISTRICT OF FLOMA W.CSTPALMBL cnDIVISION CASPh NO. 9ti3 cv- gSlSj -KL8 ,N:1[ tr t o F1nlntiII; vs. T OWN OIz GULF STIt);AM et al. PerendatIO, OWE r r .� ON A(RFi ,S`f'T'n i'I TCTRONYCA �y +�(` S THIS CAUSE having cone before thi: Court on.the Motion to Appear Flu Him Vino for Jonathan R, O'Boyle; Consent to Designation, and Requestto Ettatr bleally Receivallotices of Electronic Fling (the "Motione), pursuant to the Special Rules Govurning the Admission andpmctlgc ofAttomeys in de United States District Cobltfor the Southern Dlstrlet ofFlcridnand Section 2 B of the CWECF Administrativertpcedures. This Court having considered the motion and oil other relovant actors, itis hereby, ofVlorlda ORDERED OR ADJUDGED that: The Motion is GRANTED. Jonathan R. O'Boylo, may appoar and participate is tills aadon on behalf ofChrlsO Hare. TheCIorltshall provideeleclroninnotiHeationofallo lectrouioflingsto Jonathan M O'Boyle atjonaflimaboyie@gmall.com. DONE- AND ORDBREp in Cbambem, WestNim Boach, Palm Beach County, Soulhem District of plorido, on January 2014, Copies furnished to: All Counsel ofRenord KBT1Nh"1H L. RYSIt AMP United Was DIWlot Judge PA Attorney Information I Pennsylvania Disciplinary Board Page I of 1 The Disciplinary Board of the Supreme Court of Pennsylvania PA Attorney Information Jonathan Reilly O'Boyle PA Attorney ID: 314500 Current Status: Active Date of Admission: 11/13/2012 Lawfirm: Other Organization: District: 0 County: f State Public Access 23 N HIDDEN HARBOUR DR Address: GULFSTREAM, FL 31 Tel: %1758 -1223 Fax: {� Professional Liability I do not maintain Professional Liability Insurance pursuant to the provisions of Rule of Insurance: Professional Conduct 1.4(C), but I do have private clients and/or a possible exposure to malpractice actions. Comment: Discipline: 02007 -2014 The Dhdpllmry Board d ax supmne Cwt d PMUYWanie. I 01n1alme r Por queadiora m=meda regsr rg Cie we &. please w d web.eaeeort®oaceurta.u& EXHIBIT http : / /www.padisciplinaryboard.org /look- up /pa- attomey - info.php ?id = 314500 &pdcount=O 4/4/2014 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail February 11, 2015 Airline Highway, LLC [mail to: records @commerce- group.com] Re: GS #1183 (663) Provide all Public Records which would confirm the statement made by Attorney Sweetapple in the Introductory Paragraph on Page 1 of the Defendant's Motion To Disqualify The O'Boyle Law Firm, P.C., Inc. And in The Alternative, For An Evidentiary Hearing which reads as follows: "Jonathan R. O'Boyle has used the Pennsylvania professional corporation to establish an office or other regular presence in the State of Florida without being admitted to practice here generally and is thereby engaged in the unlicensed practice of law. Dear Airline Highway, LLC [mail to: records(a)commerce- eroup.comlI The Town of Gulf Stream has received your public records requests dated July 31, 2014. If your request was received in writing, then the requests can be found at the following link htto: / /www2 .gulf- stream.orgfWebLink8 /0 /doc /17322 /Pagel.aspx. If your request was verbal, then the description of your public records request is set forth in the italics above. Please refer to the referenced number above with any future correspondence. You will find the responsive documents at the same link. We consider this matter closed. Sincerely, Town Clerk, Custodian of the Records