HomeMy Public PortalAboutPRR 14-1184RECORDS REQUEST (the "Request ")
Date of Request: 7/31/14
Requestor's Request ID#:
722
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: 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.
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:
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and
http://
www2.gulf-
stream.orgfWebLink8
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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:/
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stream.orgfWebLink8
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7333/Pagel
.asp
http:
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CORRECTED - REMOVED 1185 & ADDED 1198
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stream .org /WebLink8
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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
From: Matias, Sally [ mailto:SMatias @jonesfoster.com]
Sent: Wednesday, June 04, 2014 4:51 PM
To: wring @commerce- group.com
Subject: Town of Gulf Stream
Please see attached correspondence from John C. Randolph.
JONESFOSTER
passMursnUeas.ra.
Sally Matias Secretary to john C. Randolph and 1 1. i\Iichael Easley
Direct Dial: 561.650.0458 1 Pax: 561.650.5300 1 smatiaseionesfoster.com
Jones, Foster, Johnston & Stubbs, P.A.
F7agler Center Tower, 505 South Flagler Drive, Suite 1100, \X est Palm Beach, Florida 33401
561 - 659 -3000 1 www.jonesfoster.com
U.S. Treasury Regulation Circular 230 requires us to advise you that written communications issued by us are
not intended to be and cannot be relied upon to avoid penalties that may be imposed by the Internal Revenue
Service.
Incoming emails are filtered which may delay receipt. This email is personal to the named recipient(s) and may
be privileged and confidential. If you are not the intended recipient, you received this in error. If so, any
review, dissemination, or copying of this email is prohibited. Please immediately notify us by email and delete
the original message.
JODIMSFOS TE ..
-- JOIi NSIUN �Sl Ultlis.l'.: \..
June 4, 2014
VIA EMAIL (wring(&commerce- aroup.com)
AND REGULAR U.S. MAIL
William F. Ring, Jr., Esquire
1280 West Newport Center Drive
Deerfield Beach, FL 33442
RE: Meeting of June 4, 2014
Dear Mr. Ring:
John C. Randolph
Attorney
561 -650 -0458
Fax: 561 - 650 -5300
jrandolphQonesfoster com
Yesterday you requested a meeting between you and your client, Martin E. O'Boyle,
and me and my partner, Joanne O'Connor. We represent the Town of Gulf Stream. I
inquired as to the subject matter of the meeting, but you would not disclose it in
advance.
At the outset of this afternoon's meeting, your client requested that our communications
be treated as privileged settlement communications regarding pending litigation We
agreed that our communications would be treated as such only to the extent that they
were, in fact, communications regarding the settlement of pending litigation. We
specifically advised you that the privilege would not apply to any discussions relating to
future litigation or threats of future action.
Please be advised that because none of today's discussions concerned the potential
settlement of any pending litigation between our clients, we do not consider them to be
privileged settlement discussions under Florida law.
Sincerely,
JONES, FOSTER, JOHNSTON & STUBBS, P.A.
JCR:mtm
pAdocs \1 3 1 4710 0 0 51 \Itr\1J17198 docx
Since 1924 1 \CIezt Palm t1L'ALII I.lupitcr I I,r_la l c1111r loucr
i0i lnwh Il.n�lcr I hia tiuim I VIII
Wot Palm Ibarh. Ilolkh ii 101
sysysr.jnnesl'n.stcncom
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
September 10, 2014
Commerce GP, Inc. [Mail to: records @commerce- group.com]
Re: GS #1184 (722)
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.
Dear Commerce GP, Inc. [Mail to: records @commerce - group.com],
This letter provides you with the full production of public records you have requested in your
email dated July 31, 2014 that can be viewed at the following link: httn://www2.gulf-
stream.ore/WebLink8 /0 /doc/ 17335/Paeel .aspxx.
The attached correspondence is being produced to you solely in an abundance of caution and
without waiving the Town's position that it is not a public record as it was not copied or
forwarded to the Town. The Town further responds that the only other responsive public record
is a June 6, 2014 memorandum by counsel for the Town reflecting the reflecting counsel's
mental impressions and conclusions, which memorandum is exempt pursuant to Fla. Stat. §
119.071(1)(d). The exempt document relates to pending and reasonably anticipated imminent
litigation involving the Town, on the one hand, and Martin O'Boyle and entities controlled by or
affiliated with him including, but not limited to, Commerce GP, Inc., the Commerce Group, Inc.,
Asset Enhancement, Inc., CG Acquisition Company, Inc., Citizens Awareness Foundation, Inc.,
Airline Highway, LLC, N984AC Caravan LLC, STOPDIRTYGOVERNMENT, LLC., Jonathan
O'Boyle and The O'Boyle Law Firm, on the other hand.
We consider this matter closed.
Sincerely,
Town Clerk
Custodian of the Records