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HomeMy Public PortalAboutPRR 14-1191RECORDS REQUEST (the "Request ") Date of Request: 7/31/14 Requestor's Request ID #: 711 REQUESTEE: Custodian of Records Town of Gulf Stream REQUESTOR: Commerce GP, Inc. 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 pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4e. (excluding subparagraphs 4, 4a., 4b., 4c., 4d., 4£, 4g., 4h., 4i., 4j., 4k., 41. and 4m.) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan 0' [sic] And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy of subparagraph 4e. of the referenced Motion is attached. 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 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail August 25, 2014 Commerce GP, Inc. [mail to: records @commerce - group.com] Re: GS #1182 (726), #1184 (722), #1185 (697), #1186 (706), #1187 (719), #1188 (727), #1189 (724), #1190 (720), #1191 (711), #1192 (699), #1200 (715), #1205 (704), #1206 (716), #1208 (713), #1211 (705), #1212 (721), #1219 (709), #1223 (712), #1225 (707), #1231 (698), #1239 (751), #1240 (752), #1241 (723) Please provide all Public Records which confirm the statement made in numbered paragraph 11 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire by Attorney Sweetapple which reads as follows: "After the meeting, O'Boyle commenced to have airborne banners flown on a daily basis over Palm Beach County. Provide all Public Records which confirm all of the statements made by Attorney Sweetapple in numbered paragraph 7 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. Provide copies of all Public Records which confirm the statements by Attorney Sweetapple in Section C17 in the Defendant's Motion To Disqualify The O'Boyle Law Firm, P.C., Inc. And, In The Alternative, For An Evidentiary Hearing, wherein Attorney Sweetapple says: "Jonathan. O'Boyle has failed to move for admission (in a federal court matter) pro hac vice to avoid Rule 4 of the Special Rules Governing the Admission and Practice of Attorneys, Local Rules of the Southern District of Florida. " Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statement that he made in numbered paragraph 4 (excluding subparagraphs a. through c) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy ofparagraph 4 of the referenced Motion is attached. In subparagraph 41., please provide all Public Records which confirm the statement of Attorney Sweetapple in his Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O' (sic) And William Ring, Esquire that Jonathan O'Boyle had a "constant presence" in the State of Florida since the opening of the O'Boyle Law Firm and that during that constant presence, he was handling legal matters for his father and his father's businesses, including at least four (4) pro hoc vice appearances. Please provide all Public Records which confirm the validity of the statement made by Attorney Sweetapple in numbered paragraph 12 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. Provide copies of all Public Records confirming the validity of the statements made by Attorney Sweetapple in numbered paragraph 9 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire. Please provide all Public Records which confirm the statement of Attorney Sweetapple in paragraph 4m. Of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire which was filed by Attorney Sweetapple. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in membered subparagraph 4e. (excluding subparagraphs 4, 4a., 4b., 4c.,4d., 4f., 4g., 4h., 4i., 4j., 4k, 41. And 4m) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'(sic) And William Ring, Esquire, which was filed by Attorney Sweetappple. A copy of subparagraph 4e. of the referenced Motion is attached. Please provide all Public Records which confirm the statements made by Attorney Sweetapple in Paragraph D26 of th e Defendant's Motion To Disqualify The O'Boyle Law Firm, P. C., Inc And In The Alternative, For An Evidentiary Hearing; and further provide all Public Records that show that Jonathan O'Boyle has violated the prohibitions as set forth in D26 in the Defendant's Motion to Disqualify The O'Boyle Law Firm, P.C., Inc. And, In The Alternative, For An Evidentiary Hearing. Please provide all Public Records confirming the statements made by Attorney Sweetapple in Paragraph D28 of the Defendant's Motion To Disqualify The O'Boyle Law Firm, P.C., Inc And, In The Alternative, For An Evidentiary Hearing. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4i. (excluding subparagraphs 4, 4a., 4b., 4c.,4d., 4e., 4f., 4g., 4h., 4j., 4k, 41. And 4m) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O (sic) And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy ofsubparagraph 4i. of the referenced Motion is attached. Please provide all Public Records which confirm the validity of the statement made by Attorney Sweetapple in numbered paragraph 3 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy of paragraph 3 of the referenced Motion is attached. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4j. (excluding subparagraphs 4, 4a., 4b., 4c.,4d., 4e., 4f., 4g., 4h.,4i., 4k., 41. And 4m) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O (sic) And William Ring, Esquire, which was fled by Attorney Sweetapple. A copy ofsubparagraph 4j. of the referenced Motion is attached. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4g. (excluding subparagraphs 4, 4a., 4b., 4c.,4d., 4e., 4f., 4h.,4i.,4j., 4k., 41. And 4m) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O (sic) And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy ofsubparagraph 4g. of the referenced Motion is attached. Please provide all Public Records which confirm that the principal office ofthe O'Boyle Law Firm, P.C. was at 2146 East Huntingdon Street, Philadelphia, PA on July 3, 2014 as stated by Attorney Sweetapple. Please provide all Public Records confirming the statement in numbered paragraph 5 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire wherein Attorney Sweetapple states "Immediately after Defendant fled "the Motion ", Plaintiff, Martin O'Boyle (hereinafter "O'Boyle').... requested a meeting with ..... the Jones Foster law firm. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4c. (excluding subparagraphs 4, 4a., 4b.,,4d., 4e., 4f., 4g., 4h.,4i.,4j., 4k., 41. And 4m) ofthe Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O (sic) And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy of subparagraph 4c. of the referenced Motion is attached. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4f. (excluding subparagraphs 4, 4a., 4b., 4c.,4d., 4e., 4g., 4h.,4i.,4j., 4k., 41. And 4m) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O (sic) And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy of subparagraph 4f. of the referenced Motion is attached. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4a. (excluding subparagraphs 4, 4b., 4c.,4d., 4e., 4f., 4g., 4h.,4,4j., 4k., 41. And4m) ofthe Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel ofRecord, The O'Boyle Law Firm, P.C., Jonathan O (sic)And William Ring, Esquire, which was fled by Attorney Sweetapple. A copy of subparagraph 4a. of the referenced Motion is attached. Provide all Public Records which will affirm the statements made by Attorney Sweetapple in Section D24 in the Defendant's Motion To Disqualify The O'Boyle Law Firm, P.C., Inc. And, Inc The Alternative, For An Evidentiary Hearing. Provide all Public Records which confirm the validity of the statement made by Attorney Sweetapple in subparagraph 41. of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Records, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. Provide all Public Records which confirm the validity of the statement made by Attorney Sweetapple in subparagraph 4m. of the Defendant's Motion For Sanctions Against Plaintiff Martin E. O'Boyle, Counsel of Records, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. Provide all Public Records confirming the statement of Attorney Sweetapple in numbered paragraph 8 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Records, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. Dear Commerce GP, Inc. [mail to: records @commerce - group.com], The Town of Gulf Stream has received your public records requests dated July 31, 2014. If your request was received in writing, then the requests can be found at the following links: http: / /www2. gulf- stream.orWWebLink8 /0 /doc / 17341 /Pagel .aslx http: / /www2. gulf- stream.ore/WebLink8 /0 /doc /17335 /Pagel .aspxx, http://www2.gulf-stream.org/WebLink8/0/doc/17325/Pagel.ast)x , httv://www2.gulf-streain.org/WebLink8/0/doc/I 7327/Page l .aspx, http: / /www2.gulf- stremn.orgfW ebLink8 /0 /doc /I 7333/Pagel .asnx, http:/ /www2.gulf- stream.org/WebLink8 /0 /doc /I 7343/Pagel .aslx http:/ /www2.gulf- stream.orgfWebLink8 /0 /doc /17337/Pa eg l.Wx, http:/ /www2.gulf- stream.orgfWebLink8 /0 /doc /I7332/Pa eg 1_aslx http:/ /www2.gulf- stremn.orgfWebLink8 /0 /doc /I7329/Page l . aspx, http://www2.gulf-stream.org/WebLink8/0/doc/l 73 70/1'age l . asnx, http: / /www2. gulf- stream.org[WebLink8 /0 /doc /17379/Pagel . asnx http: / /www2. gulf- stream.orgfW ebLink8 /0 /doc /173 84/Pagel .aspxx http:/ /www2.gulf- stream.org/WebLink8 /0 /doc /I7385/Pa eg 1_aspxx htty: / /www2.pulf- stream. ore /WebLink8 /0 /doc /173 87/Pa¢el .asnx, httv://www2.gulf-stream.org/WebLink8/0/doc/I 7390/Page l .asnx, http://www2.gulf-stream.org/WebLink8/0/doc/I 739 I /Pagel .asnx, http: / /www2. gulf- stream.orgfWebLink8 /0 /doc /I7418/Page l .asnx, http:// www2.gulf- stream.orgfWebLink8 /0 /doc /I7426/Pagel .asnx, http://www2.gulf-stream.org/WebLink8/0/doc/I743O/Pajzel.asi)x , htti)://www2.gulf-stream.org/WebLink8/0/doc/I 7442/Page l .asnx, http:// www2.gulf- stream.org/WebLink8 /0 /doc /l7459/Pagel .asnx . http:// www2.gulf- stream.orgfWebLink8 /0 /doc /17461/Pagel.aspx and http:// www2.gulf- stream.orgfWebLink8 /0 /doc /17463/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. The Town of Gulf Stream is currently working on a large number of incoming public records requests. The Town will use its very best efforts to respond to you in a reasonable amount of time with the appropriate response or an estimated cost to respond. Sincerely, Town Clerk Custodian of the Records w a CORRECTED — REMOVED 1185 & ADDED 1198 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via a -mail August 25, 2014 Commerce GP, Inc. [mail to: records @commerce- group.com] Re: GS #1182 (726), #1184 (722), #1186 (706), #1187 (719), #1188 (727), #1189 (724), #1190 (720), #1191 (711), #1192 (699), #1198 (714), #1200 (715), #1205 (704), #1206 (716), #1208 (713), #1211 (705), #1212 (721), #1219 (709), #1223 (712), #1225 (707), #1231 (698),! 12359 4wL Q. #1240 75 #1241 (723) Please provide all Public Records which confirm the statement made in numbered paragraph 11 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire by Attorney Sweetapple which reads as follows: "After the meeting, O'Boyle commenced to have airborne banners flown on a daily basis over Palm Beach County. Provide all Public Records which confirm all of the statements made by Attorney Sweetapple in numbered paragraph 7 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statement that he made in numbered paragraph 4 (excluding subparagraphs a. through c.) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy ofparagraph 4 of the referenced Motion is attached. In subparagraph 41., please provide all Public Records which confirm the statement of Attorney Sweetapple in his Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O' (sic) And William Ring, Esquire that Jonathan O'Boyle had a "constant presence" in the State of Florida since the opening of the O'Boyle Law Firm and that during that constant presence, he was handling legal matters for his father and his father's businesses, including at least four (4) pro hoc vice appearances. Please provide all Public Records which confirm the validity of the statement made by Attorney Sweetapple in numbered paragraph 12 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. CORRECTED— REMOVED 1185 & ADDED 1198 FA0ide copies of all Public Records confirming the validity of the statements made by Attorney Sweetapple in numbered paragraph 9 of the Defendant's Motion For Sanctions Against Plaintiff Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire. Please provide all Public Records which confirm the statement of Attorney Sweetapple in paragraph 4m. Of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire which was filed by Attorney Sweetapple. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4e. (excluding subparagraphs 4, 4a., 4b., 4c., 4d., 4f., 49., 4h., 4i., 4j., 4k, 41. And 4m) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The 0 Boyle Law Firm, P.C., Jonathan O'(sic) And William Ring, Esquire, which was filed by Attorney Sweetappple. A copy of subparagraph 4e. of the referenced Motion is attached. Please provide all Public Records which confirm the statements made by Attorney Sweetapple in Paragraph D26 of the Defendant's Motion To Disqualify The O'Boyle Law Firm, P.C., Inc And In The Alternative, For An Evidentiary Hearing; and further provide all Public Records that show that Jonathan O'Boyle has violated the prohibitions as set forth in D26 in the Defendant's Motion to Disqualify The O'Boyle Law Firm, P.C., Inc. And, In The Alternative, For An Evidentiary Hearing. Please provide all Public Records confirming the statements made by Attorney Sweetapple in Paragraph D26 of the Defendant's Motion To Disqualify The O'Boyle Law Firm, P.C., Inc And, In The Alternative, For An Evidentiary Hearing. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4h. (excluding subparagraphs 4, 4a., 4b., 4c.,4d., 4e., 4f., 4g., 4i., 4j., 4k, 41. And 4m) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O (sic) And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy ofsubparagraph 4h. of the referenced Motion is attached. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4i. (excluding subparagraphs 4, 4a., 4b., 4c., 4d., 4e., 4f., 4g., 4h., 4j., 4k., 41. And 4m) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O (sic) And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy of subparagraph 4i. of the referenced Motion is attached. Please provide all Public Records which confirm the validity of the statement made by Attorney Sweetapple in numbered paragraph 3 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And CORRECTED — REMOVED 1185 & ADDED 1198 iiPilh'am Ring, Esquire, which was fled by Attorney Sweetapple. A copy of paragraph 3 of the referenced Motion is attached. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4j. (excluding subparagraphs 4, 4a., 4b., 4c.,4d., 4e., 4f., 4g., 4h.,4i., 4k., 41. And 4m) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O (sic) And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy of subparagraph 4j. of the referenced Motion is attached. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4g. (excluding subparagraphs 4, 4a., 4b., 4c.,4d., 4e., 4f., 4h.,44,4j., 4k, 41 And 4m.) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O (sic) And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy ofsubparagraph 4g. of the referenced Motion is attached. Please provide all Public Records which confirm that the principal office of the O'Boyle Law Firm, P.C. was at 2146 East Huntingdon Street, Philadelphia, PA on July 3, 2014 as stated by Attorney Sweetapple. Please provide all Public Records confirming the statement in numbered paragraph 5 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire wherein Attorney Sweetapple states "Immediately after Defendant filed "the Motion" Plaintiff, Martin O'Boyle (hereinafter "O'Boyle') .... requested a meeting with ..... the Jones Foster law firm. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4c. (excluding subparagraphs 4, 4a., 4b.,, 4d., 4e., 4f., 4g., 4h.,4i.,4j., 4k, 41. And 4m) ofthe Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C., Jonathan O (sic) And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy of subparagraph 4c. of the referenced Motion is attached. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4f. (excluding subparagraphs 4, 4a., 4b., 4c.,4d., 4e., 4g., 4h.,4i.,4j., 4k, 41. And 4m) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O (sic) And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy of subparagraph 4f of the referenced Motion is attached. CORRECTED — REMOVED 1185 & ADDED 1198 Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4a. (excluding subparagraphs 4, 4b., 4c.,4d., 4e., 4f., 4g., 4h.,4,4j., 4k., 41. And 4m) ofthe Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O (sic) And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy of subparagraph 4a. of the referenced Motion is attached. Provide all Public Records which will ajfIrm the statements made by Attorney Sweetapple in Section D24 in the Defendant's Motion To Disqualify The O'Boyle Law Firm, P.C., Inc. And, Inc The Alternative, For An Evidentiary Hearing. Provide all Public Records which confirm the validity of the statement made by Attorney Sweetapple in subparagraph 41. of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Records, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. Provide all Public Records which confirm the validity of the statement made by Attorney Sweetapple in subparagraph 4m. of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Records, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. Provide all Public Records confirming the statement of Attorney Sweetapple in numbered paragraph 8 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Records, The O'Boyle Law Firm, P. C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. Dear Commerce GP, Inc. [mail to: records @commerce - group.com], The Town of Gulf Stream has received your public records requests dated July 31, 2014. If your request was received in writing, then the requests can be found at the following links: http://www2.gulf-stream.org/WebLink8/0/doc/I 7341 /Pagel .aspx _http:/ /www2.gulf- stream.orgfWebLink8 /0 /doc /I7335/Pa eg 1_aslx http: / /www2. gulf- stream.orgfWebLink8 /0 /doc /I7327/Pagel .aspx httR://www2.gulf-streain.org/WebLink8/0/doc/I 7333/Pagel .asp http: / /www2. gulf- stream.orgfW ebLink8 /0 /doc /I 7343/Page l . aspx http: / /www2.gulf- stream.orgfW ebLink8 /0 /doc /17337 /Pagel . aspx http: / /www2. gulf- stream.orgfWebLink8 /0 /doc /I7332/Pagel .aspx, h!W://www2.gulf-strearn.org/WebLink8/0/doc/I 7329/Pagel .asyxx, http: / /www2. gulf- stream.orgfWebLink8 /0 /doc /173 70/Page l .aspx http: / /www2. gulf- stream.orgfWebLink8 /0 /doc /I 7377/Page l . aslx http: / /www2. gulf - stream. org/ WebLink8 /0 /doc / 173 79/P aee l .aspx, http:/ /www2.gulf- stream.org/WebLink8 /0 /doc /I7384/Pagel .asox, httv://www2.gulf-stream.org/WebLink8/0/doc/I 7385/Pagel .aspx, CORRECTED - REMOVED 1185 & ADDED 1198 http: / /www2.gulf- stream .org /WebLink8 /0 /doc /17387/Pa eg 1_aspxx, http: / /www2. gulf- stream.orgfWebLink8 /0 /doc /I 7390/Page l .aspx, http: / /www2. gulf- stream.org[WebLink8 /0 /doc /17391 /Page I .aspx, http:/ /www2.gulf- stream.orgfWebLink8 /0 /doc /I 7418/Page l .aspx, htti)://www2.gulf-streatn.org/WebLink8/0/doc/I 7426/Page l .asyx. http:/ /www2.gulf- streatn.orgfWebLink8 /0 /doc /l 7430/Page l . aspx http: / /www2. gulf- stream.orgMebLink8 /0 /doc /I 7442/Pagel .aspx, httR://www2.gulf-stream.org/WebLink8/0/doc/I7459/Pagel.asvx , h_ptt :/ /www2.gulf- stream.org[WebLink8 /0 /doc /I7461/Pagel.aspx, and http:/ /www2.gulf- stream.orgfWebLink8 /0 /doc /17463/Pagel.asox. If your request was verbal, then the description of your public records request is set forth in the italics above. Please refer to the referenced number above with any future correspondence. The Town of Gulf Stream is currently working on a large number of incoming public records requests. The Town will use its very best efforts to respond to you in a reasonable amount of time with the appropriate response or an estimated cost to respond. Sincerely, Town Clerk Custodian of the Records V 1 4 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail August 25, 2014 Commerce GP, Inc. [mail to: records @commerce - group.com] Re: GS #1182 (726), #1184 (722), #1185 (697), #1186 (706), #1187 (719), #1188 (727), #1189 (724), #1190 (720), #1191 (711), #1192 (699), #1200 (715), #1205 (704), #1206 (716), #1208 (713), #1211 (705), #1212 (721), #1219 (709), #1223 (712), #1225 (707), #1231 (698), #1239 (751), #1240 (752), #1241 (723) Please provide all Public Records which confirm the statement made in numbered paragraph 11 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire by Attorney Sweetapple which reads as follows: "After the meeting, OBoyle commenced to have airborne banners flown on a daily basis over Palm Beach County. Provide all Public Records which confirm all of the statements made by Attorney Sweetapple in numbered paragraph 7 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which wasfled by Attorney Sweetapple. Provide copies of all Public Records which confirm the statements by Attorney Sweetapple in Section C17 in the Defendant's Motion To Disqualify The O'Boyle Law Firm, P.C., Inc. And, In The Alternative, For An Evidentiary Hearing, wherein Attorney Sweetapple says: "Jonathan. O'Boyle has failed to move for admission (in a federal court matter) pro hoc vice to avoid Rule 4 of the Special Rules Governing the Admission and Practice of Attorneys, Local Rules of the Southern District of Florida." Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statement that he made in numbered paragraph 4 (excluding subparagraphs a. through c.) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy of paragraph 4 of the referenced Motion is attached. In subparagraph 41., please provide all Public Records which confirm the statement of Attorney Sweetapple in his Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O' (sic) And William Ring, Esquire that Jonathan O'Boyle had a "constant presence" in the State of Florida since the opening of the O'Boyle Law Firm and that during that constant presence, he was handling legal matters for his father and his father's businesses, including at least four (4) pro hoc vice appearances. Please provide all Public Records which confirm the validity of the statement made by Attorney Sweetapple in numbered paragraph 12 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. Provide copies of all Public Records confirming the validity of the statements made by Attorney Sweetapple in numbered paragraph 9 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire. Please provide all Public Records which confirm the statement of Attorney Sweetapple in paragraph 4m. Of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C, Jonathan O'Boyle And William Ring, Esquire which was filed by Attorney Sweetapple. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4e. (excluding subparagraphs 4, 4a., 4b., 4c.,4d., 4f., 4g., 4h., 4i., 4j., 4k., 41. And 4m) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C, Jonathan O'(sic) And William Ring, Esquire, which was filed by Attorney Sweetappple. A copy of subparagraph 4e. of the referenced Motion is attached. Please provide all Public Records which confirm the statements made by Attorney Sweetapple in Paragraph D26 of the Defendant's Motion To Disqualify The O'Boyle Law Firm, P. C., Inc And In The Alternative, For An Evidentiary Hearing; and further provide all Public Records that show that Jonathan O'Boyle has violated the prohibitions as set forth in D26 in the Defendant's Motion to Disqualify The O'Boyle Law Firm, P.C., Inc. And, In The Alternative, For An Evidentiary Hearing. Please provide all Public Records confirming the statements made by Attorney Sweetapple in Paragraph D28 of the Defendant's Motion To Disqualify The O'Boyle Law Firm, P.C., Inc And, In The Alternative, For An Evidentiary Hearing. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4i. (excluding subparagraphs 4, 4a., 4b., 4c.,4d., 4e., 4f., 4g., 4h., 4j., 4k., 41. And 4m) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C, Jonathan O (sic) And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy of subparagraph 4i. of the referenced Motion is attached. Please provide all Public Records which confirm the validity of the statement made by Attorney Sweetapple in numbered paragraph 3 of the Defendant's Motion For Sanctions Against Plaint Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy of paragraph 3 of the referenced Motion is attached. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4j. (excluding subparagraphs 4, 4a., 4b., 4c.,4d., 4e., 4f., 4g., 4h.,4i., 4k., 41. And 4m) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C, Jonathan O (sic) And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy ofsubparagraph 4j. of the referenced Motion is attached. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4g. (excluding subparagraphs 4, 4a., 4b., 4c.,4d., 4e., 4f., 4h.,4i.,4j., 4k., 41. And 4m) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C., Jonathan O (sic) And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy ofsubparagraph 4g. of the referenced Motion is attached. Please provide all Public Records which confirm that the principal office of the O'Boyle Law Firm, P. C. was at 2146 East Huntingdon Street, Philadelphia, PA on July 3, 2014 as stated by Attorney Sweetapple. Please provide all Public Records confirming the statement in numbered paragraph 5 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire wherein Attorney Sweetapple states "Immediately after Defendant filed "the Motion ", Plaintiff, Martin O'Boyle (hereinafter "O'Boyle').... requested a meeting with ..... the Jones Foster law firm. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4c. (excluding subparagraphs 4, 4a., 4b.,,4d., 4e., 4f., 4g., 4h.,4i.,4j., 4k., 41. And 4m) ofthe Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C, Jonathan O (sic) And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy of subparagraph 4c. of the referenced Motion is attached. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4f. (excluding subparagraphs 4, 4a., 4b., 4c.,4d., 4e., 4g., 4h.,4i.,4j., 4k., 41. And 4m.) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C., Jonathan O (sic) And William Ring, Esquire, which was fled by Attorney Sweetapple. A copy ofsubparagraph 4f of the referenced Motion is attached. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4a. (excluding subparagraphs 4, 4b., 4c., 4d., 4e., 4f., 4g., 4h.,4,4j., 4k., 41. And 4m.) ofthe Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle LawFirm, P.C., Jonathan O (sic) And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy of subparagraph 4a, of the referenced Motion is attached. Provide all Public Records which will affirm the statements made by Attorney Sweetapple in Section D24 in the Defendant's Motion To Disqualify The O'Boyle Law Firm, P. C., Inc. And, Inc The Alternative, For An Evidentiary Hearing. Provide all Public Records which confirm the validity of the statement made by Attorney Sweetapple in subparagraph 41. of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Records, The O'Boyle Law Firm, P. C., Jonathan O'Boyle And William Ring, Esquire, which wasfeled by Attorney Sweetapple. Provide all Public Records which confirm the validity of the statement made by Attorney Sweetapple in subparagraph 4m. of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Records, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. Provide all Public Records confirming the statement of Attorney Sweetapple in numbered paragraph 8 of the Defendant's Motion For Sanctions Against Plaintiff Martin E. O'Boyle, Counsel of Records, The O'Boyle Law Firm, P. C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. Dear Commerce GP, Inc. [mail to: records @commerce - group.com], The Town of Gulf Stream has received your public records requests dated July 31, 2014. If your request was received in writing, then the requests can be found at the following links: http:/ /www2.gulf- stream.org(WebLink8 /0 /doc /17341 /PageI.aspxx http: / /www2. gulf- stream. ore /WebLink8 /0 /doc /17335/Pagel .aspx htty: / /www2.gulf- stream.orgfW ebLink8 /0 /doc / 17325/Pagel .asox, http: / /www2. gulf-strearn.org/WebLink8/0/doc/I 7327/Page l .aspx http: / /www2. gulf- stream.orel W ebLink8 /0 /doc / 17333/P age 1. asp h!W://www2.gulf-stream.org/WebLink8/0/doc/I 7343/Pagel .aspx htty: / /www2. gulf- stream.org/WebLink8 /0 /doc /I 7337/Pagel .aspx, htty://www2. gulf- stream.org/WebLink8 /0 /doc /l 7332/Pagel .aspx, httv:/ /www2.gulf- stream.org/WebLink8 /0 /doc /I 7329/Page 1. aspx, http:/ /www2.gulf- stream.org/WebLink8 /0 /doc /17370 /Page 1. aspx, http://www2.gulf-stream.org/WebLink8/0/doc/I7379/Pagel.aspx http://www2.gulf-stream.org/WebLink8/0/doc/I7384/Pa2el.asRx , http://www2. gulf- stream.org/WebLink8 /0 /doc /I 7385/Pagel .aspx .hftp://www2.gulf-strearn.org/WebLink8/0/doc/I 73 87/Pagel .aspx h6: / /www2. gulf- stream.org[WebLink8 /0 /doc /17390/Page l . aspx hn:/ /www2.gulf- stream.orgfWebLink8 /0 /doc /I7391/Pagel aspx http: / /www2. gulf- stream.orgfWebLink8 /0 /doc /I 7418/Pagel .aspx, htti)://www2.gulf-stream.org/WebLink8/0/doc/I7426/PageI.asvx . http: / /www2. gulf- stream.orgfWebLink8 /0 /doc /l743O/Page l .aspx http: / /www2. gulf- streatn.orgfW ebLink8 /0 /doc /l 7442/Pagel .aspx http: / /www2. gulf- stream.orgfWebLink8 /0 /doc /I7459/Pagel .aspx, http:/ /www2.gulf- stream.orgfWebLink8 /0 /doc /l7461/Pagel.asi)x, and http:/ /www2.gulf- stream.orgfWebLink8 /0 /doc /17463/Pagel.asyx. If your request was verbal, then the description of your public records request is set forth in the italics above. Please refer to the referenced number above with any future correspondence. The Town of Gulf Stream is currently working on a large number of incoming public records requests. The Town will use its very best efforts to respond to you in a reasonable amount of time with the appropriate response or an estimated cost to respond. Sincerely, Town Clerk Custodian of the Records A TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via a -mail August 26, 2014 Commerce GP, Inc [mail to: records @commerce - group.com] Re: GS #1191 (711) Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4e. (excluding subparagraphs 4, 4a., 4b., 4c.,4d., 4f., 4g., 4h., 4i., 4j., 4k., 41. And 4m.) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The OBoyle Law Firm, P. C, Jonathan O'(sic) And William Ring, Esquire, which was filed by Attorney Sweetappple. A copy ofsubparagraph 4e. of the referenced Motion is attached. Dear Commerce GP, Inc [mail to: records @commerce - group.com], This letter is in response to the public records you have requested in your email received July 31, 2014. This correspondence is reproduced at the following link: httv://www2.eulf- stream.orR/ WebLink8 /0 /doc/ 17329/Paee l . asnx. Be advised that no such records exist. We consider this matter closed. Sincerely, Town Clerk Custodian of the Records