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HomeMy Public PortalAboutPRR 14-1190RECORDS REQUEST (the "Request ") Date of Request: 7/31/14 Requestor's Request ID #: 720 REQUESTEE: Custodian of Records Town of Gulf Stream REQUESTOR: Commerce Group, 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: 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. 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:PNPR/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 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 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 Detail by Entity Name Detail by Entity Name 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: 02/14/2014 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 4ddress Changed: 02/14/2014 Xfficer/Dlrector Detail flame & Address title DP YBOYLE, JONATHAN R :146 E. HUNTINGDON STREET ' HILADELPHIA, PA 19125 ,nnual Reports to Annual Reports Filed ocumentlmages EXHIBIT l Page I of 2 http: // search. sunbi7. org/ lnquiry/ CorpomtionSearch/S earchRomItr)efail /P.nfitvNartmr /fi,m_r W111.111nill rage 1 or 1 Search By Business Name By Business Entity ID Venty Verify Certification Online Orders Register for Online Orders Order Good Standing Order Certified Documents Order Business List My Images Search for Images Corporations Online Services I Corporations I Farms 1 Contact Corporations I Business Services Business Entity Filing History Oats: 4/25/2014 (Select the link above to view the Business Entity's Filing History) Business Name History Name Name Type The O'Boyle taw Amt, P.C. Cunent Name IONATHAN R O'BOYLE P.C. Prior Name Professional Corporation - Domestic. Information Entity Number. 4227691 Status: Active Entity Creation Dale: 11/1412013 State of Business.: PA Registered Office Address: 1001 Broad Street Johnstown PA 15906 Cambria Mailing Address: No Address raPrnphtC 20e1 PemwMNa OsryMenle /stela Min" gewm4 PM4 W Pal" I sewft %lacy EXHIBIT I) 1) https: / /www. corporations. state. pa .us /corp /soskb /Corp.asp?3249952 4/25/2014 PA Attorney Information I Pennsylvania Disciplinary Board Page I of I 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: O County: LQ u f State Public Access Address: 23 N HIDDEN HARBOUR DR GULFSTREAM, FL 33483 Tel: 1 758 -1223 Fax: Professional Liability Insurance: I do not maintain Professional Liability Insurance pursuant to the provisions of Rule of Professional Conduct 1 A(C), but I do have private clients and /or a possible exposure to malpractice actions. Comment: Discipline - 0207 -2014 The Dhdplimry Hoe d Pe &4ry 0 Can d Pem"WN . I PAW Fa gmti w moment nper6f0 Vie we ft, pimmw m et web.euovortfte uM.ua EXHIBIT http : / /www.padisciplinaryboard.org /look- up /pa- attomey - info.php ?id = 314500 &pdcount =0 4/4/2014 INTBEMCUITCOURTOFTHB iSmJUDICJALCEtCUIT, imAND f( FOR PALM BEACH, COUNTY, FLORIDA •i ' CMUSTOPRtRF.O•r m Case No. 2014CA000720 PWmgff Division AT VS. T0WN0FOULFS11tFAM. WB.LIAMS.TRRASMUt Defendant VERIFIED MOTIONFOR ADhIISSION TO APPEAR PROlUC VICE PURSUANTTOFLORIDARULE OFRMICIALADMINJSTRATION2.510 Comm mwJONATHANR. OBOYLH. Movant herein, andrespeetfirIlyrep[eae ¢ s tba following 1. Movant7onathanR O' BoyIefadomicilcdmdpa smmmflyresidw iu.LONOFORT, NEW JBRSBY. Movaetis not a pemranentresidentofthe State of Florida. MovantJonaffiaa R O'Boyle Is a terapomryresidem of the State ofFlodda and bas an applimtimpmdingfor admMm to The F1MddaBw=d lm=tprevicuslybew denied admiasim f o'Tba Florida Bar. 2. Movant isan attorney and amembarofthe haw fumof(orpractices lawtmdcrthe name ot)2jlaOBovletaw Fbm.PClFa�edv lmmvn e9 JomfhanR O'H v1ePC) with offices at 2146 R Hontinndm St PMledelohia. Madetohia Penn VJvmdfl . 19125 561- 758 -1273 (County) (State) (zip'Codo) (Telephono) 3. Movanthas born retained peaonallyor es amember of the shovanamed law dmi on Jmmmv 10.2014 by Cbriatoober O'Hanavia Na FLattomevLou Roeder (DataRepmsmtatiOm Commenced) (NauieofPmtyorPadias) to provide Iegalmpr amtEdion in aommtlon v8tb the abovo•styled matter nowpendingbofore the above -umned courtof the State ofFlodda. 4. *Movautis an active membernt good staodiagavd cureadyetigibta to practice law in ::fir y�.y,;.; �nia ` the fbllowingjtnisdietion(e): Indudo attorney crbernmcbw@. (Attach so additional sheet if necessary) . t' t RTMICTTON ATTOENEY"NMMER �• Y 657- �Uryll1.4 ' ��1-I .4'�i7 S. Tbere ere no disoiplhaeryproceediags pegdiag against Mavant, mmpt as provided below (give jurisdiction of disciplinary sutim4 date ofdMplinaryadon, ❑soon of (he violation and the samtioa, if any, imposed): (Attachm�additioad eh�odifnecessary.) {WIT ,- 6. Wtibiathepast fivo( S)yeam, Movmtbesnotbdeasubjecttomydisciplinsry pmeeedipp, exceptasprovided below (givo jurisdiction ofdiscipj nary action, dale o£ disdplinary action, nature afthe violation and the sane ion, if any, imposed): (Attach m additional shedifneeesbary.) 7. Moventhes aevesbcea eubjectm saysuspeasIoapmceediags ,incept as pravIded belaw(givc j ma diction ofdisciplinary action, date of disdplinerymetioq nature of the violation mad thesmcdov6 ifsny, imposed): (Attach m additional sheet if necessary.) S. Movaot bas oavarbeeasabjactto any disbarrawtpmceedlogs, eroaptas provided below (givejm isdiction of disciplinary scBon, date of disdplinary action, nature ofthovioladm sad the sanction, ifdny, imposed): (Attach(Attach an sbeetifnecessmy.) . 9. Mwant, either byredgnation, withdrawal, or otherwise, neverbas twninated or attempted to temsinete Mnvast'e office as m adomeyiaordcr to avoid administ®dvq disciplitury, disbarment, orsuspensionproceeding% 10. Movmtis notaninncdv %memberm£TbeFiaridaBar. 11. Movent isnatnbwamembe[ofTbe FloridaBar. 12 Movantis not% suspended member of The MoridaBar. 13. Movantisnotadisb= edmembero MFloridaBaraerbasUm=ttwdveda disci*myrudgnatian fmm The FloridaBau 14. Movantbas notpreWao elybean disciplined orbeld in cantemptbyreasonof misconduct committedwhs7e engaged in repmsmtetioapM=nrttm Florida Ride oflmdieial Administration 2.510, except as provided below (give date of disciplinary action orcontempt, rcasmethemfbr, and Wurtimpusingcumfompt): (Attach amadditional abectifnecessery.) , , .. . 15, Movanthas filedmotiaa(s) to appear as counsel iuMoridastate coals during the past five (5)yeam iu the followingmattetr (Atta& as odditianalsfieetifaecesse y) ' DateofMotiom Casa Neap Case Number Court Date Mattoa Ormmted/Dteded , N14 16, LacalmunaelofmcordassacDiedwi diMova.minthismaharis Ry>.�.�•la',�ri.ec'',�O \OiSG3 who is anaativememberiagogdstandfngofIhaFlodda (N•m. eud Plgoda Sar Number) ` Bazaudbaa offieas at l2�biv lr�. �p.,7pe� iRmitc �ciJL (59reetAddnss) (City) �aa,5 (statc) (Lip Cade) 0.51- 6'7fi- (refepheeewls+ocvmde) (Iflocal mumel is not an aetivemembor of ThoFlotidaBuin good standing; pleasopmvide infonuafion as to local miumel's membership mates. 1 17, Movautbas read tho applicebleprovisfons ofFloudaRole ofludicial Admiaiahelion 2.510 and We 1 -3.10 of the Rules RegulatingThePloridaBorand. certifies thatthis verified motion complies withthose ndea. 18. Mo vantagreestocomplywiththepmvisianso fihe Flodda RulesafPtoi=ional Coaduct end eonsenfsto the jmigdindon of the coeds audlheBarof dmS(ate ofFlorida WFMTMORE, MovanttrspectfuIIyrequesls petmisaion to appear in this court fmthis cause only. DATED this �_ day ofv ivfaVBnt d 1-1 1qu a X1U1V111VL7LLN Si Page 1 of 2146 E HUNTINGDON ST ACCOUNT# 314138000 Assessment Tax LOOP Account Information OWNER(S) O'BOYLE KELLY L MAILING ADDRESS 2146 E HUNTINGDON ST Philadelphia PA 191251427 PROPERTY UNIT None PROPERTYZIP 191251427 SALE DATE 8/18/2009 SALE PRICE $193,500 HOMESTEAD $30,000 Property Characteristics LAND AREA 1,260 SgFt IMPROVEMENT AREA 1,548 SgFt IMPROVEMENT DESCRIPTION httn: / /nrnnertv.nhila onv/ l .. I I.; . t " 1-; :Q &z A 111 11 ,,. . 2.1401;riV1V 111VtiL)VN N 1 ROW 2 STY MASONRY BEGINNING POINT 200'E OF COLLINS ST EXTERIOR CONDITION New / Rehabbed ZONING RSA5 Residential /Residential Mixed -Use Certified Valuation History ASSESSED ASSESSED MARKET LAND IMPROVEMENT YEAR VALUE (TAXABLE) (TAXABLE) Page 2 of 2 ASSESSED. ASSESSED LAND IMPROVEMENT TOTAL (EXEMPT) (EXEMPT) ASSESSMENT 2015 $138,400 $18,648 $119,752 $0 $0 2014 $138,400 $18,648 $119,752 $0 $0 2013 $27,800 $2,159 $6,737 $0 $0 2012 $27,800 $2,159 $6,737 $0 $0 2011 $27,800 $2,159 $5,737 $0 $0 2010 $27,800 $2;159 $6,737 $0 $0 2009 $27,800 $2,159 $6,737 $0 $0 $138,400 $138,400 $8,896 $8,896 $8,896 $8,896 $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 /tevenue) for information regarding the billing, collecting and accounting of real estate taxes or call 215- 686 -6442. New Search View Tax Balances (hftp:/Iwww.phila.gov/revenue/RealEstateTax(Default.aspx? b(tBRTNo= 314138000) Submit an Inquiry ( http:// opa. phila. gov/ opq.apps /Help[CitizenMain.aspx? sch= Ctrl2 &s =1 &url= search &id = 4406002146) hifn!11nrnnmrtv nhiln anal I. . ^.. n IN'THE FIFTEENTH JUDICIAL CIRCUIT COURT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2014- CA- 00393BAB CERnFltb COPY JASON WEEKS, Petitioner, vs. TOWN OF PALK BEACH, Respondent, CONDENSED TRANSCRIPT OF TESTIMONY AND PROCEEDINGS HAD BEFORE THE HONORABLE THOMAS BARKDULL DATE: APRIL 10, 2014 TIME: 9 :00 - 10:30 A.M. PLEASANTON, GREENHILL, MEEK & MARSAA i 581/833.7811 2 4 1 INDEX 1 PRO GEED ING S• ' 2 TESTIMONY AND PROCEEDINGS 2 THE COURT. Jason Weeks vs Town of Palm 3 APRIL 10, 2014 4 3 Beach, Vyho Is here on behalf of the phdnliff7 5 WITNESSES FOR DEFENDANT 4 MR, MESA: Goad morning, Your Honor. 5 DIRECT CROSS REDIRECT 5 Glovenl Mesa on behalf of Plaintiff, Jason 7 DANIELLE OLSON 8 Weeks. 8 By Ms.Ccoper 13 29 7 THE COURT: And who do you have with you? BY Mr. Mesa 25 S. Mr. Weeks? y 10 SPENCER WILSON 0 MR O'BOYLE: No, sir. My name Is Jan 11 By Ms. Cooper 30 10 O'Boyle. I'm acting as Mr. Mesa's law clerk, 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'Boyle. Anymlallon to the O'Boyle In the By Mr. Mesa 34 14 O'Boyle Law Firm, P,C.7 15 16 MR. O'BOYLE: Yes, Your Honor. 16 EXHIBITS 17 IN EVIDENCE 18 THE COURT: What's the rotation? Ig 17 MR. OBOYLE: That is my name on the low 19 Respondent's ExhlbR No. 1 37 18 On. II's an lnlantale law firm. Lollar 19 THE COURT: How do you — it's an 2A 20 Interstate law firm with a Florida address? 21 Respondent's Exhlblt No. 2 37 Emans; 21 MR.O'BOYLE: There's a Florida address 22 22 and a Ponnsylvania address, 23 Petitionees Exhibit No.1 38 23 THE COURT: And you're down here E•malls 24 practicing with a On without being a member 24 25 of the Florida Bar? 25 3 6 1 APPEARING ON BEHALF OF PETITIONER; 1 MR. O'BOYLE: No, air. 2 Glovanl Mess, Esq, 2 THE COURT: Are you a member of the THE O'BOYLE LAW FIRM, P.C. 3 Florida Bar? 3 1286 West Newport Center Drive 4 MR, O'BOYLE: No, sir. Dgerfleld Beach, Florida 33432 5 THE COURT: Why doycu think you have any 4 6 APPEARING ON BEHALF OF RESPONDENT: 8 right to stand at [bailable? 8 Mamaret L. Cooper, Esq. 7 MR. O'SOYLE I don't have any light other JONES, FOSTER, JOHNSTON & STUBBS, P.A. 8 than to assist Mr. Mesa. 7 505 South Flagler Drive 9 THE COURT: Good. You step back because Suite 1100 10 we're about to discuss the Illegal practice of B West Palm Beach, Florida 33401 11 law without being a member of the Florida Bar. a 10 ALSO PRESENT: Jonathan O'Boyle, Esq, 12 MR. O'SOYLE: Yes, Your Harm: 11 ___ 13 THE COURT: Mr. Mesa, are you a member of 12 BE IT REMEMSERE01hat the following tesilmony 14 the Florida Bar? 13 and proceedings were, had In the above•antiled muse 15 MR. MESA: Yes, l am, Your Honor. , 14 before the Honorable Thomas Barkdull, In the Palm 1B THE COURT: Howlong haveyou been e 15 Beach County Courthouse, City of West Palm Beach, 17 member of the Florida Bar? 18 Slate of Florida, on Thursday, the 10th day of 17 April, 2014, to wit 18 MR.MESA: S1nre Nwemher ot2010. 18 ___ 19 THE COURT; Are you a partner In the, 19 20 quote,. O'Boyle LowFInn? 20 21 MR. MESA: I am not, Your Honor. 21 22 THE COURT, How many attorneys etc them 22 23 In the O'Boyle LawFhm7 23 24 MR.MESA: Four —five at the moment, 24 25 Your Honor. 25 PLEASANTON, GREENHILL, MEEK & WARSAA 561/833.7811 PLEA13ERTON, GREENI32LL, h= & MARSAA 561/8.33.7811 6 8 I THE COURT: How many are totaled In the 1 she admitted receiving an a -nrsll from Kathryn: 2 State of Florida? 2 THE COURT, Okay. So there's one a -mall 3 MR. MESA: Four, Your. f ionon 3 at Issue, 4 THE COURT: Okay. Who are the partners In 4 MR. MESA: That were aware of, Your 5 the Florida fimt? 6 Honor. B MR, MESA: Brian Winter and Jon O'Boyle, 5 THE COURT: And Whet data is the dale of 7 THE COURT: This gentleman is a pannerin 7 that alleged e-mal? e the Flodda firm? B MR. MESA: IN MayStiL 9 MR. MESA: Ira a multi -state firm, Your a THECOURT: Ofwhatywr7 10 Honor. To be quite frank with you, I'm not to MR. MEBA: 2011, Your Honor, 11 sure how its incorporated butt know that 11 THEOOUITP. Meyelh,2o11. 12 Orion Wilmer Is a partner in the firm and he U 12 Ms. Cooper, what Is your client's position 13 aFlorida attorney, 13 onthls? 14 THE COURT: Who's hamforlhadefanes? 14 MS. COOPER: Your Honor, there is no 15 MS. COOPER: I am, Your Honor, Margaret 16 e-mall, Let me axplatm And theywers advised 16 Cooper. 19 thol them is no "all. Mr. Weeks is confused 17 THE COURT: Welcome, Ms. Cooper, 17 and I will explatnwhathappened. Mr. Weekp Is MS,COOPFR: Thankyou. 16 pled a complaint with the HR department on 19 THE COURT. All dghl. Mr. Mass, yqu— 19 May 5. Mrs, Olson is the HR dlreclor. 20 who is Ashton A. Richman? 20 THE COURT: Is Mr. Weeks an employee? 21 M6, COOPER Ashlee Richman Is a lawyer' In 21 Me. COOPER: Ho was at the Ikne. He's. 22 the law firm of Jones, Foster, Johnston R 22 been terminated now and we're in other 23 Stubbs. 23 litigation with Mr. Weeks. 24 THE COURT: Iapologim, Igrabbed the 24 THE COURT: Okay. 25 wrengpieading. Letme'fe-ewhatwasilledby 25 MS. COOPER: Mrs. Olson who is the HR 7 8 1 the plaintiff here who called my office 1 director was at an Impasse heating across the 2 yesterdayJumping up and down saying this Is an 2 street In another building. Me. Dyson 3 emergency. 3 contacted herto advise her that b complaint 4 Mr. Mesa filed this. Okay. Mr. Mesa, 4 hadbeanlnlflatedby Mr. Weeks. Lateronwhen , 5 What do you balleve your client needs that your 5 Mrs. Olson was being interviewed, It was about 6 client Is not receiving other than one letter B maybe six, eight months later, whatever it was, 7 oronee -mall? 7 she knew that there , had been an e-mai 6 MR MESA: IN the Inklal a -mail that 8 communkation between she and Mm. Dyson and 9 was made between Kathryn and Danielle who are 9 she made a mistake and she misspoke and she 10 both human resources personnel with the Town of 10 said l Initially out the Information by small 11 Palm Basch. Your Honor, specifically hwas a II from Mrs. Dyson. That was a mistake, It was 12 request that was made by Mr. Weeks for any end 12 either an Instant — 13 all a -maps, (Messages, communications and any 13 THE COURT: Okay. So Its the town's 14 documents between Danielle Olson and Kathryn 14 position that one, It doesn't exist? 15 Dyson, and as stated, both ofwhom are human 16 MS. COOPER: It doesn't exist. And 1 15 resource personnel With the Tam of Palm Beach 16 apologize, I drought you Just wanted to hear 17 on May 5th, 2011. 17 from the lawyers today. Mrs. Olson is on her 16 Your Honor, Mr. Weeks received a portion 1B, way to leefily, she'll be here in live minutes. 19 of an e-mail communication, an" all chain, tit It just simply does no exist and we cant 20 thane. However, It is missing the Initial 20, pnoduee wheys not. 21 a -mall from Kathryn to Danielle. It Is 21 THE COURT: Okay. It donsn't exist so 22 apparent lost on a dear View of the documents 22 have you advised Mr. Mesa of this? 23 that were provided that the Initial e-mail is 23 MS.,COOPER: Welustgolthlslawsua 24 missing. In addition, YourHono, there is a 24 filed. Mr. Weeks was advised bull was atthe 25 recorded intarvlew with Danielle Olson which 26 2nd OCA arguing a case yesterday and this was PLEA13ERTON, GREENI32LL, h= & MARSAA 561/8.33.7811 PLEASANTON, GRE=1111L, MEEK & MARSAA 561/833,7811 10 12 1 all happening veryfes4 I was getting reedy • 1 you go to law schoo17 2 to— 2 MR, O'BOYLE Drexel Law Unlverelly In 3 THE COURT. That's why I wanted to do It, 3 Philadelphia, Pennsylvania. 4 very quickly because it seems to be a really 4 THE COURT. Are you from Florida ' 6 simple Issue, One e-meg, If It exists and 6 originalw 6 It's not privilegad, It needs to be turned B MR. O'BOYLE: Yes, Your Honor. 7 over, It A doesn't exist, R doasn'f exist, 7 THE COURT: Whereabouts? 8 and 17 lake tesllmcrry today aadwe'll 8 MR: O'BOYLE GUIfstream, Florida. 9 determine whether R exists or It doesn't and 9 THE COURT: Okay. Congratulations on 10 [his case wig be over 10 passing the Florida Bar, Good luck on gelling 11 Mr, O'Boyle, haveyou moved to bb admitted 11 admitted 12 pro hac vlce in Florida at all? 12 All right. As soon as ourwIpmases 13 MR, O'SOYLE: Yes, YourHonor, 13 appear, I'll hear testgnony. Just advise my 14 THECOURT: Howmanytimes? 14 deputy and wdfl deal with IL Verygood. 15 MR O'BOYLE: Once, Your Honor. 15 (Thereupon, a recess was had,) THECOURT: My suggesllon is If you think to THE COURT; Goon moming and welcome, 17 you're going to keep a law fine in Florida and 17 everyone, Welcome beck. Okay. We are hem on 1a walk up to counsel table like yours counsel In 18 the case of Weeks vs, Town of palm Beach on 19 Florida that you take the Florida Bar, 19 request for an emergency. hearing on the issue 29 MR. O'SOYLE: Yes, Your Honor. 28 of whether pgbllc,records ate available and 21 THE COURT: Haw long has your firm been 21 whether theyshouldbe produced. I heard the 22 operating dawn here? 22 Iniflel arguments of counsel. The lown's 23 MR O'SOYLE: Since January, mid January; 23 posluon, as 1 understand h, Ms. Cooper, Is 24 Your Honor. 24 that they requested an o -mall that does not 26 THE COURT: Have you signed up for the 25 exist, Is that correct? 11 13 1 Florida Baryel7 1 MS, COOPER: That Is correct, Your Honor. 2 MR. O'BDYIE: Yes, Your Honor, and l 2 THE COURT: Okay. You may call your first 3 passed It actuagy, 3 witness, 4 THECOURT. Congratulgtlons. Whenemyou 4 MS; COOPER; I'll call Deniella Olson. 5 being swam ln7 5 THE COURT: Ma'am, it you'll please take 6 MR. O'BOYLE: That is to be determined, 6 the wibtess stand. Please watch yourstep, 7 Your Honor. 7 THEREUPON, B THE COURT: Having trouble with your B DANIELLE OLSON, 9 background check orwhy aren't you being sworn 9 called as a witness by the Defendant, having been 10 N If you passed the Florida Bar? t0 first duly swam by the Count, In answer to 11 MR. OBOYLE` Yes, Your Honor, I passed 11 questions propounded, was examined and testified as 12 the New Jersey Bar es well and— 12 follows: 13 THE COURT: Well, we're not In New Jersey, 13 THECOURT: Counsal,youmaylnqutm. 14 MR. O'BOYLE; Your Honor, correct, but 14 M91 COOPER: Thank you, Your Honor, 15 Florida is waiting for Now Jersey. their 15 DIRECT EXAMINATION 18 process to be completed until they wig further 16 BY M6. COOPER 17 process my Me. 17 0 Would you state your name, please? 1B THE COURT: Heys you been admitted In any ie A Donlelle Olson, 19 state? 19 O Mm. Olson, what is your pos{cn with the 20 MR, O'BOYLE: Yes, Your Honor, 20 Town of Palm Beach7 21 Pennsylvania. 21 A Director of human resources, 22 THE COURT: When Mrs 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: Novembr2012, Your Honor. 24 seeking a -motto between you and Mrs. Dyson - 25 THE COURT: November of 2012. Whore did 26 A Yes. ' PLEASANTON, GRE=1111L, MEEK & MARSAA 561/833,7811 Addroa Addtcss Lo,..ea s 1 n�T D 0-310 � ,State, Zip Coda S61 -1.4N ' Te(ephoAa Number STATE OF COUN!'YOF /4'1•Iunl:C. 1 2�?,.468 R. © If .doh4ebY sweet or affirm uvdrrpmaltyof perjury that am the Movantia the abov styledmatter; that Ihavereed the fbScgofog Motion and knewthe contents thereof, and the contents are true ofmy owalmawledge aadbelieE Mover[ I hereby consent to be wmcfatedm local camel ofmwrd hi this camopumoantto Florida Rule afdudicW Administration. 2 .510. OATEDthis Qf4 dayof --'L,,O Ccr,�scl afR 1UG W. NP.m �p 1 ev kl QIti�C Address 3'�ti1�t2- Address Case 9 :1 - 80530 -DMM Document 25 Entered on FLSD Docket 06/17/2013 Pag of FILED by �ry'0 c6 a UNITED STATES DISTRICT COURT JUN 17 2013 , t SOUTHERN DISTRICT OF FLORIDA arEVEry M Vr ale V,gAO s� �E Case No.13.805,30- CIV- MIDDLEBROOKS WPa' �a MARTIN E. O'BOYLE r �-5o '3L9 Plaintif, VS. TOWN OF GULF STREAM Defeddant. MOTION TO APPEAR PRO HAC HCE, 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 respectfiilly 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 213 of the CM/ECF Administrative Procedures, and to perrhit Jonathan R. O'Boyle to receive electronic filings in this case, and in support hereof states as follows: 1. Sonathan 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 Bart{314500). 2. Movant Robert S. Gershman, Esquire, of the law firm of GER$HMAN & GERSHMAN, P.A, 2160 W. Atlantic Avenue, 2d Floor, 561- 684 -8598, is a member in good standing of the The Florida Ear and the United States District Court for the Southern District of Florida, maintains an office in this State for the practice of law, and is authorized to file through the Court's electronic filing system 0,7 ,T Case 9:13 -cv- 80530 -DMM Document 25 Entered on FLSD Docket 06/1712013 Page 2 of 5 Mqvant 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 ofthe case; upon whom filings shall be served, who shall be required to electronically file all documents and things that maybe filed electronically, andwho shall be responsible for filing documents in compliance with the CM/ECF AdministradyeProcedures. 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 Ceurfs $75 admission fee. A certification in accordanco with Rule 4(b) is attached hereto. -4. Jonathan R. O'Boyle, by and through designated counsel andpursoant to Section 2B CM/ECF Administrative Procedures, hereby requests the Court to provide Notice of Electronic Filings to Jonathan R. O'Boyle at email address; Jonathumboyle@gmail.com. WHEREFORE, Robert S. Oershman, moves this Court to enter an Order Jonathan X. O'Boyle, to appear before this Court onbehalf of Martin E. 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, R art S. Oershmen Flo 'da Bet No, 91,7397 Robert@rglawfi mus OERSHMAN & OERSHMM, P.A, 2160 W. Atlantic Avenue, 2d Floor Delray Beach, PL 33445 (561) 684 -8898 (telephone) (561) 998 -5868 (facsimile) Attorney for Martin E. O'Boyle Case 9:13-cv- 80530 -DMM Document 25 Entered on FLSD Dacket06 /17/2013 Page 3 of 5 UNMM STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Casa No. 13.80530- Civ- MDDLEBROOKS MARTINB.O'BOYLE Plaintiff,. vs. TOWN OF GULP STREAM Defendant CERTIFICATION OF TONATHAN R. O'BOYLE Ionatban R O'Boyle, Esquire, pursuant to Rule 4(b) of the Special Rules Govcming the Admission and Practice of Attorneys, hereby certifies that (1) I have studied the Local Rules of the United States District Court for the Southern District of Florida; and (2)l am amember in good standing of the Pennsylvania Supreme Court. 9a"1 onathan O'Boyle PA Berg374500 case 9:13- cv- B0530-DMM Document 25 Entered on FLSD Docket 0611712013 Page 4 of 5 CERTIFICATE OF SERVICE . IHEMY CERTIFY that atrue and comet copy of the foregoing Motion to Appear Pro Hac Me, Consent to Designation and Request to Electronically Receive Notices of Electronic Filings was served by uploading same to the'CMIECF. SERVICE LIST Joanne M. O'Connor jacomor@jonwfaster.mm JONES FOSTER JOHNSTON & STUBBS, P.A. 505 South Flagier Drive Suite 1100 Wes[Palm Beech, FL 33401 561 -639 -3000 (mlephom) 561- 650 -5300 (fambile) Attomoys for Defecdant Town ofOulfStmam Case 9:13 -CV- 80530 -DMM Document 25 Entered on FLSD Docket 06/17/2013 Page 5 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OE FLORIDA Case No, 13- 80530- CIV- MIDDLEBROOKS MARTIN E. O'BOYLE Plaintiff, VS. TOWN OF GULF STREAM Defendant. ORDER GRANTING MOTION TO APPEAR PRO HAC VICE,, CONSENT TO DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING THIS CAUSE having comebcfore the Court on the Motionto AppearPro Hac Vice forJonathanR.O'Boyle, Cons nd oDeai6aiorr, andReT= ttoElechonicallyReceiveNoticesof 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 relevant factors, it is hereby of Florida. ORDERED OR ADJUDGED that: The Motion is GRANTED. Jonathan R. O'Boyle, ntay 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'Boyle at Jonathanrcboyle@gmail.com. DONE AND ORDERD in Chambers, West Palm Beach, Palm Beach County, Southern District of Florida, on June , 2013. DONALD MMDMBR05KS United States District Judge Copies furnished to: All Counsel ofRecord 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 OFFLORIDA CASE NO.13- 80530- CIV- MMDLEBROOKS y MARTIN E. O'BOYLE, Plaintiff, .- I TOWN OF GULF STREAM, i m Defendant. ORDER GRANTING MOTION TO APPEAR i PRO HA VICE, CONSENT TO DESIGNATION, AND REQUEST TO ELECTRONICALLY i RECEIVE NOTICE OF ELECTRONIC FILINGS G THIS CAUSE comes before the Court upon a Motion to Appear Pro Hac Vice, Consent to f' A 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 properly 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. 7 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 ionathanrobwle0 arnall.com. DONE AND ORDERED in Chambers at West amoli day of June, 2013, j i j UNITED STATES DISTRICT JUDGE Copies to: Counsel of Record t 1 I I , UNI' b STATiS DISTRICT COURT FOB,T1M S,OUTM, RN DISTRICT OF FLORIDA WDS`'PALMBEACHbMMON CASE Not 9:13- cv,810M -)pLR CHATS O'HARi . Pla{ntiff, vs, TOWN OF GULT STRRAM et. al, Derenr?ants. MOTIONTO A O f'kY1'k4r'9'TAItT(lIITOTN rr AT'NrT D i iPviM• ttT PTO TPLITCTON(AI7 N In accordance with Local Rules 4(b) of the Speoial Rules Governing the Admimion and Pmetico ofAttomaysefthe:United States DistrietCourt for the Southern District ofFlorlda, the utidersign6d respectfidly moVca'for the admission Pro Into vice ofJonatbanR , O'Boyle ef2146Lr.TlunlingdonSt, Philadelphia PA 19125, 561 -758 -1223, for purposes ofoppeamnco as oo- counsel on babolfofChris O,Hara In the above -styled case only, and plas4oat to Rule 2B of the CWECF Adnini;trative Procedures, to permit Jonathan R. Q'Boyle to mcaivo c1cottonle fi(idgs In this.aase, and in support thereof states as follows: 1. Jonathan R. O'Boyle is not admitted to practice In the Southam District of Florida and is a metuber in good standing of the Pennsylvania Supreme Court (PA Bar# 314500). The undor'signed is a member in good standing of the IhdPorida Bar and the United States District Cowt for the Southern District of Florlda, maintains no office 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 as.a member of the Bar of this Court with. whom the Court and Opposing counsel may readily eommurdoate regarding the conduct of the case; upon whoth filings shall be served, who shall be required to ole*oaically file all documents and things that maybe filed electronically, dad who shall bo responsible fot filing documents iu compliance with the CMIECF Administradveproceddures. See Seotioo2Bof the CM JFCF Administrative Procedure, JAN i 3 2014 3. In acoordaaca with the local. rules of this Court, Jonathan R. O'Boyle has made paymantof Oils Court's $75 admission.fec. A certification. in accordance with Rule 4(b) is being Mad contemporaneously wi0t this Motion. A bopy is attachad hereto, 4. Jonathan R. O'Boyle, by and through designathd copnsel and pursuanito Section 2B CM/BCF Administrative Procedures, hereby rAquests the Court to pro%gdo Notice ofEleotranic Filing to Jonathan R. O'Boyle at email address: Jonathanroboylc@gmail.eom. WHMREFOU, Mark J. Hanna moves this Court to enter an Order permitting Jonathan R. O 'Boyle to Appear before es Court on bohalf of Orris O'Hara fir all purposes relating to the ptUacadbtgs In time above- illyled matter and directing the Cictkto provido notice of eleotrohio filings to Jonathan R. O 'Boyle. I HEREBY CERTIFY flint on January 10, 2014,1 filed the foregoing 4ocumont with the Cledc of Court via conventional method due to the ni fate ofthe motion. I furthercertifylbat mulled tbo foregoing document via ptcpaid first cheul U.S. mail in the following: iv)ichaol R. Piper CluistopherJ, Stearns JOHNSON, ANSBI.MQ, MURDOCH, B.URK$, PIPER & HOCBMAN, P.A. 7455 East sunrise Boulevard, Suite 1000 Fort,Laudcrdalo, Florida 33304 Tolopliono.: (954) 463 -0100 pipetgambg.com atcoms( jambg.com Dated: January 7, 2014 OMMMAD(SON P.A. 441 South f `tnly Roar Palm B dh, 3 80 Tal:5B 1� 9191 Floods Bar'NP. 0045251 561 -723 -8284 (cell & text) ipliauna@g3rDlqw.com UNTIIID STATICS DISTRICT COURT FORTJ34 SOUTHDEN DTSTRICP OF FLORIDA W3bT PALFJ'. B&ACR DIvMON CASE NO: 9t13<vg1053 -ur.ea Plaltiliff ve. TO WN OP GOLFSTREAK eL a4 Dchadanh. N D1.4 0 12 Ign Y I pig Kai wum m "Fag a a Kau . a, Jonathan R.O'Boylo, Esgphe, pursuant to Rgle 4(h)) of tha Spccial Rules Owetniogdsc Admisedap end Pacdea oMomeys, hemhy eerfi6es tbat(1)Ihave studied the Lncal Rules dfGu Uabd Statue District Court for the Southern District oEFlprida, and (2) Tom a membe' h goodl standing ofthe Pennsylvarda Supreme Court Scan dhga O'Boyle, Esq. JonnthaaR,O'Boyle,P.C. 2146 B.Iiuntingdon gt. PhSadalplilk PA 19115 AT: 561 -75 11-1223 Fpx:215 -0 -3641 Pehnsylvanla BarNu, 374500 1 HBREBY CERTIFY that on January 10, 2014, I Mad the foregoing domimantwith the Clerk of Cosutviauonventional method due to the namm of the motion. 1 further ccrtity tint madled the foregoing dooumentvia prepaid first elms U.S. mail to the following MiohBcl R. PI1x.T ChrLtoph4rJ. Steams JOHNSON, ANESGMO, MUIMOCA BM P. PIPER& HOCFIIVIAN, P.A. 2455 EastSunrueBoulevard, Solt, 1000 FastLa tderdala, Florids33304 Toleplsone.: (954) 463.0100 pipe1ownbg.eom stcmns@damhg.wrn Dated; Joaucry Y, 2014 OM AKQrSON PA 401 South Ccunty Road 63272 Fafm Beach FL33480 -9991 Tel: 5&1 22i -999Q Mmk J,Hamn FloridaI)wWo. 0045.251 561.723 -8264 (call & text) mhemc(a?g3micw,cnm UNITED STATES DISTRICT COURTFOR TIM SOUTJDI" DTSTRYCT OF FLORIDA W EST PALMBEACII DTVL9ION CASK Nfl:9rI3 -ev BI053 -ICLR Plaintiff, VS. TOWN OF GULP STREAM et. al. Defendaa(4, THIS CAUSE havibg cone before the Court on.the Motion In Appear Pro Him Vice for Soudhan R, O'Boyle; Consent to Designation, and Request to Bleetrohically Receive Notices of Electronic Filing (Ore "Motion!), pursuant to that Special Rules Governing dte Admission and Proctlee: ofAttomeys in dre United States District CoUt for (lie Southern District ofFlgrida and Section 2 B onthe CMIECF AdministralivePmoedums. T131S Court having considered the motion and all otber iblevulit fictors, it is hereby of'Florlda ORDERED OR ADJUDGED that The Motion is GRANTED. fonnthan 1L O'Boyle, may appoar and participate in tills colon on behalf of Chris O'Hare. The Clorl: shall provide electmnie notification of all electronic filings to Jonathan R. O'Boyle atjbnathzTiroboyle@gmaII.com. DONE AND ORDEREP in Cbmnbers, WestPs(m Beach, Palm Beach County, Soulh'em District ofPloridn, on January 2014, KENNETH L. RVSKAMP Copies famished to: United StntesDistrletJudge All Counsal of Record Find Lawyer, Attomey, Law Firms, Attorneys, Legal Information. LegalDirectories.com Page 1 of 1 @p .fyFuYealuyaen.+ dmmrt nd -mlr m a .masnmM rmcrt:v y 'tleHEcia. YUny. a Se.0 4 •aa:lal ).tppMPi3)3 ed.+16 Legd 0"uecfalee Pubsslhlg Goe4ca'ry. �„ Ma Wn)sdi.eM1Cg dJe legal dre7am urea tlO6 and 63s b be Amencu. UU pea",,, Side Must." �m Besl uWd y: e. '&..y 6M,v, .d.;m CST Ford a Lawyer Search Results By Loeatien Areas of I'McUce ShWWU..... FL Exports 4 Services Metal Code: 3M63 Products C..my.Padsh: PAM Both County Aaemey Last Name: OBOyie Orions Stare Ars ay Fllat Name: JomMm Bar palm Ramd1s,enedbr. AOurnap Lest Name About Us No refulle band. Pleea by a dlNerem search cdnde. Contest Us Olsclnimar atomb6eemit Prtyany Polley Advance Search Na Wp'eltomN erynw Fa.gal•xr IByL eraolEUb ;,n- nlAr•wplq•, •611YItdiPJ£NuexelNam'IL • tl: mr W3n1pOiNL1 •FOts tny: nn r:r 3oyi<< iL. Lf ?nyry :Y.1L'= �rlil ^fi$YNrhjpy.r. AlIY,JM1b rnelved tyCSS Neof Ike J,^eelObedodea oxn wcbdieand Ne Wlomwtlon ccnlelnetl M1emio to ehbJed to the whi c. end Amhetlonetlmmbod6QEBC11LL :mid �d61 pn :y, pyamselnp or reWednp WIOrIPe Man tram le6elLlmaaneemm, be me+adnoWledper eN opreee b be bwnd Lysl h i6ObtPr,U!F A "d pliypy,Pyny. LegafBbndelCa 1'uh6ehinp Comfxry, W -stit Fadond aWd. Oal'.n TUM. 73ID4• 13pp1'tO33)5{pIq 321333 r http: / /www.legaldirectories.com/ Search. aspx ?SearchOpt= B &SearchFor- 0 &Bio" &State... 40-1/2014 rnnathan Reilly O'Boyle - Lawyer in Gulf Stream Florida (FL).Palm Beach County - lega... Page 1 of 1 • - - � +y II Y4YTelaayarWm WMIIMR 6Wnalba an On AepI y erce' IMurldev • Yoww i l pIOtd all a 6e4a Speadut n: spec art 1400147t an lie l!•O.K la, r i..vv F.4W.i1h44 /�al:.). ht .r nL. thWllylafh�•N.dn w,.311 Q9ryAlnr... ;bti i5J4:41n Nd � bN4:r: IlY •LNM1'.lr. ;dl'g. \' L'I✓bAWtl l\ alA% LPIaI JYIA41r1. Mn I41M 4,4 'it gtI or Find a LaMar noaa> errnra Lnry -Arta AA Co. [r NOW. O GOe Snean 1101!. Uwyen By Location P Aroea of Practice i! u Jonathan Reilly O'Boyle dale NB Profile a Experts 8 Services Products J.TOta,,R e7 O1oykleoLa"arin FImWz, GUll Stnan Online Store Bar LInIW (Pennsy/ran/a Our of State LJ ;tfng) About Ue Jonathan Reilly O'Boyle Contact Ile 23 N Hidden Harbour Or Oleclalmer GUIS Steep PL 33463 -7244 Privacy Policy Palm Beach County Advance Search contact Jonathan Reilly O'Boyle (S61)766 -1723 the NOW .80180 mama r;11 J Uycr 15y LC 1I'n l Dr1m a So' -•real MaA L• PndU l M.*ellOO Snkaro l HtmO l DO ,tat' yAnRIL k 014!. qlJ.. +r.su:4.lar5 ^:ryBd.::.Irc. Tl•S5Aul l.rl F�l'11 ^.M tylRa lnn.rvp4 +Cff vW of INN, A19LP44'FA1ot1S' n;A.v.dbnFJonnt5MC•Il:N1cd ficriilIs subject 'o the aaltk8ans"lt:dlellrna lhymbtd In Lmn orth4 er4?MPPY POea. 6y MIM.F`a tt IN!., -. •p1 ^tf.`J1.Y.1 voT LePafJ a$40fA cbt IN! user edlnWadr]eaavel NJTea IO be bnUnd by 512h TT,,M2AA]t and Pj,aN Pony Lu.N:O°r,;`v ^!s foi'4Y k.3 CwT.I d + W, I:•: - at 11 Goltuid RNd: caeea Toaa 75218 - 15001447.5375 (1141= 2L]]]: TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail November 1, 2014 Commerce Group, Inc. [mail to: records @commerce - group.com] Re: GS #1190 (720) 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. Dear Commerce Group, Inc. (mail to: records(7a,commerce- eroun.com], This letter provides you with the full production of public records you have requested on July 31, 2014. Your original request can be viewed at the following link: http://WWW2.gulf- stream.org/WebLink8/0/doc/17332/Pagel.asi)x You can find the responsive documents at the same link. We consider this matter closed. Sincerely, Town Clerk Custodian of the Records