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HomeMy Public PortalAboutPRR 14-1181RECORDS REQUEST (the "Request") Date of Request: 7/31/14 Requestor's Request ID#: 725 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 a copy of any communications sent by William Ring to John Randolph in response to the statement made by Attorney Sweetapple in numbered paragraph 10 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 Rine, Esquire that John Randoluh wrote William Ring. 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 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), #1239 (751), #1240 (752), #1241 (723) Please provide all Public Records which confirm the statement made in numbered paragraph]] 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 hac 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 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 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 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 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.,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 wasfiled 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.) of the Defendant's Motion For Sanctions Against Plaint 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 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.,44,4j., 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 ajjirm 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: httv://www2.pulf-stream.org/WebLink8/0/doc/I 7341 /Pagel . asox, htti)://www2.eulf-stream.org/WebLink8/0/doc/I 7335/Pagel .asnx http: / /www2.gulf- stream.org/W ebLink8 /0 /doc /I 7327/1age l .asyx http:/ /www2.gulf- stream.org[WebLink8 /0 /doc /I7333/Page l .asox, http: / /www2. gulf- stream.orgf WebLink8 /0 /doc /l7343/Pagel .asnx, httv://www2.gulf-stream.org/WebLink8/0/doc/l 7337/1agel .asm hU: / /www2. gulf- stream.org[WebLink8 /0 /doc / 17332/Pagel .aspx . h!W://www2.gulf-strearn.org/WebLink8/0/doc/I 7329/Pa2el .aspxx http: / /www2. gulf- stream.org[WebLink8 /0 /doc /I 7370/Page l .asnx, http: / /www2. gulf- stream.orgfWebLink8 /0 /doc /I7377/Page l .asnx, http: / /www2.gulf- stream. org /WebLink8 /0 /doc/I 7379/Pagel .aspxx h!W://www2.gulf-stream.org/WebLink8/0/doc/l 73 84/Pagel .aspxx hU: / /www2. gulf- stream.orgfWebLink8 /0 /doc /l 73 85/Pagel . aspxx CORRECTED - REMOVED 1185 & ADDED 1198 http: / /www2.gulf- stream.orw WebLink8 /0 /doc /17387/PageI .asnx, http:/ /www2.gulf- stream.org[WebLink8 /0 /doc /I 7390/Page l . asnx, http:/ /www2.gulf- stream.orgfWebLink8 /0 /doc / 17391 /Pagel . asnx, http:/ /www2.gulf- stream.orgfWebLink8 /0 /doc /I 7418/Pagel .aspx http: / /www2. gulf- stream.orgfWebLink8 /0 /doc /I 7426/Pagel .asnx, http://www2.gulf-streain.org/WebLink8/0/doc/I 7430/Pagel .asnx, http: / /www2. gulf- stream.org(WebLink8 /0 /doc /l7442/Page l . aspx, http: / /www2. gulf- stream.org(WebLink8 /0 /doc /I 7459/Page l .asnx. http:/ /www2.gulf- stream.orgfWebLink8 /0 /doc /17461/Pagel.asnx, and http:/ /www2.gulf- stream.orgfWebLink8 /0 /doc /17463/Pagel.asl2x. 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 Matias, Sall From: Randolph, John C. Sent: Thursday, June 05, 2014 425 PM To: 'William Ring' Subject: RE: Town of Gulf Stream Follow Up Flag: Follow up Flag Status: Flagged No such view or opinion regarding persons with disabilities was either stated or implied and is absolutely untrue. How anyone can come to that conclusion as a result of yesterday's meeting is beyond me. Neither you nor your client were ejected from the meeting. Your client was asked if he had anything else to present and he advised he had nothing further so the meeting was concluded. We stand by our position in our letter of yesterday that there were no discussions regarding settlement of pending litigation. JONESFOSTER John C. Randolph Attorney Direct Dial: 561.650.0458 1 Fax: 561.650.5300 1 imridolphRjonesfoster.com Jones, Foster, Johnston R Stubbs, P.A. Flaglet Center I ower, 505 South Flaglcr Drive, Suite 1 100. Nest Palm Beach, Florida 33401 561 -659 -3000 1 www jonesfoster.com O.S 1 rtataurt• 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 dint may be imposed by die Internal Revenue Service. Incoming cmails are filtered which may delay receipt. 'Phis email is personal to the named meipient(s) and may be Privileged and confidential. If you arc not die intended recipient, you received dtis in error If so, any review, dissemination, or copying of this email is prolubitcd. Please immediately notify us by email and delete the original message. From: William Ring rmailto:wrinq(@commerce-ciroup.com Sent: Thursday, June 05, 2014 12:05 PM To: Randolph, John C. Cc: William Ring Subject: FW: Town of Gulf Stream Dear Skip: This will acknowledge receipt of the attached email /letter. Your second and third paragraphs, in addition to being self- serving, are just plain incorrect. On a side note, my client was absolutely appalled that you and your associate made your disdain for the handicapped (ADA) people (the "ADA Folks ") clear. I say this because when my client raised implementing additional business in Gulf Stream which business may have Included properties occupied by ADA Folks, we were at that point ejected from the meaning This email is a continuation of our agreement regarding settlement discussions as discussed and agreed to yesterday. Sincerely Bill William F Ring 1280 West Newport Center Drive Deerfield Beach, FL 33442 954 -570 -3510 (ph) 954 - 360- 0807(fax) 954 - 3284383 (cell) From: Matias, Sally [ mailto :SMatias()jonesfoster.com] Sent: Wednesday, June 04, 2014 4:51 PM To: William Ring Subject: Town of Gulf Stream Please see attached correspondence from John C Randolph. JONES FOS i ER - - - ^� -- p 111`.+111 \:: +I t Intl, I•d. Sally Matias Secretary to John C.. Randolph and I-I Michael Easley Direct Dial: 561.650.0458 1 Fax: 56L650.5300 1 smatins0oncsfostcr.co Jones, Foster, Johnston & Stubbs, P.A. Hagler Center Tower, 505 Sauth Flagler Drive, Suite 11011, West Palm Beach, Florida 33401 561 -659 -31100 1 www.ioncsfoster.com I :S Treasure Regulation Circular 330 requires us to advise you that written communications issued by us are not intended to brand cannot be relied upon to avoid penalties that may be imposed by the Internal Revenue Senice. Incurring avails are filtered which may delay receipt 'llus email is personal to the named recipient(s) and may be privBcged and confidential Tf 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