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HomeMy Public PortalAboutPRR 14-1222TOWN 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 Detail by Entity Name Detail by Entity Flame THE O'BOYLE LAW FIRM, P.C., INC. Filing Information Document Number F14000000600 FEIJEIN Number NONE Date Filed 02/102014 State PA Status ACTIVE Principal Address 1288 W. NEWPORT CENTER DRIVE DEERFIELD BEACH, FL 33442 Changed: 021142014 Melling Address 2146 E. HUNTINGDON STREET PHILADELPHIA, PA 18125 Reolstered Agent Name & Address WITHER, RYAN L 1288 W. NEWPORT CENTER DRIVE DEERFIELD BEACH, FL 33442 Address Changed: 021142014 Officed0lrector Detail Name & Address Title DP O'BOYLE, JONATHAN R 2146 E. HUNTINGDON STREET PHILADELPHIA, PA 19126 Annual Reports No Annual Reports Filed Document Images Page 1 oft bttp: llseerch. sunbizorg/ InquirylCorpomtion5eamh lSemehResoltnctaillFndtvWnm lfe. f annnnrn PA Attorney Information I Pennsylvania Disciplinary Board Page I of 1 The Disciplinary Board of the Supreme Court of Pennsylvania PA Attorney Information Jonathan Reilly O'Boyle PA Attorney 10: 314500 Current Status: Active Date of Admission: 11/13/2012 Lawfirm: Other Organization: District: 0 County: ut 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 1.4(C), but I do have private clients and/or a possible exposure to malpractice actions. Comment: Discipline: 02007- M14 71w DisdplN ry Soe dtl Shpt eCa dParuy ".I Disclaim Fw qu tiarwwm meds wyenbnD Itre webs . p1mm ended us of web.eu000rtftpwouM.ua EXHIBIT rill http : / /www.padisciplinaryboard.org /look- up /pa- attorney - info.php ?id = 314500 &pdcount =0 4/4/2014 PA Attorney Information I Pennsylvania Disciplinary Board Page 2 of 2 PA Attorney Information Jonathan Reilly O'Boyle PA Attorney ID: 314500 Current Status: Active Date of Admission: 11/13/2012 Lawfirm: Other Organization: District: County: Cambria Public Access Address: 1001 BROAD ST JOHNSTOWN, PA 16906 Tel: 561768-1223 Fax: Professional Liability I maintain, either Individually or through my firm, Professional Liability Insurance pursuant to the Insurance: provisions of Rule of Professional Conduct 1.4(C). Comment: Discipline: ©2007 -2014 The Disciplinary Board of the Supreme Court of Pennsylvania. I Disclaimer For questions or comments regarding the website, please contact us at we b.s u pport(ftacourts. us. http:// www. padisciplinaryboard .org/loolc- up /pa- attomey- info.php ?id= 314500&pdcount =0 5/29/2014 1 •r iN TAR CIRCUIT COURT OF TAE LSm]UDICIAL ciRcti T, WAND FOR PALM BEACH, COUNTY, FLORIDA CBRISTOFSMVO'BARR Plrmmtiff VS. TOWN OF aW SMRAM. WILLUMN.3M ASRhR Dcfendmt Case Mo..2014CA000720 Division Al VLrWMD MOTIONITORADMSSION TO APPEAR P.&OIUCYJC6 PURSUANT TOFLORIDARULE OF JUDICIAL ADMaSMRA'nON 2510 ComesnowIONATHANR. OBOYLP Movant herein, and reVectfully rcpments the following: 1. Movmt7onag= P- O' Boylpisdomiciledmdpap =mtlyresidmiaLONCIPORT, NEW JBSBEY. Moventis not a pemvneatxnsWemtofthe State of Florida. Movent Jonathan R O'Boyle Is a temporaryXmident of the State ofFlmida and has an applicatiompendingfor admission to The FlorldaBwmd basnotprevlonslybeen denied admission t n'The Moudm Bar. 2. Movautis an allomey aadamemberofthe law limrof(orpmcdceslawonderthe mm�e of)TheOBovleLaw F� pC fFa�edv lmowa as JonaL��RO'Bov1ePC) with offices at 2146 E. Hrmtinedon St Pbiladelnlde- Phdadelobia Peonsvlvania 19125 561- 758 -1223 (County) (State) (Zip Code) (Tcicphono) 3. Movamtbs been retained persauaally or as amember of the above named law ffm on Jarmary 10.2014 by Christopher O'Harevia lda FI, attomevLon Roeder (DateRepresentationC mo�e�r (NameofPatyorParUesj to pmvidelegelrepreamtafion irLo= ction withihe abovo styledmatter sawpendingbofmre the abcv named comrt of the State o£Florida. 4.- Movautis an active membwia good standiagand ctm estly eligibletopraedw lawin Em the followingiurisdicdon(s): Made attorney orbermmbsr(s). (Attach an additional sheet if necessary.) . JUAf6DICTION ATTORNEYIBAJLNUNSER '3f4 S8n S. That am no disaiplbtatyp oceediags pending against Movmt, except as provided below (giveindsdiction of disdptinary action, date ofdiseiplinazyaction, nature of (ho vlolatim and the suction, ifany, imposed): (Atb&m additional sheet ifnecessaty.) 6. 'Yithinthepastfivo (5) ymm Movmthas notbemmbjeat to my disciplinary pmeeedipgs, except asprovidedbelaw Wva jnrisdiction of discipjinary action, date of discipiinary action, name oftba violation andihe senetion, ifany, imposed): (Attach an additional sheet ifneeesmry.) 7. Movmthasneverbocaaubjeetto a aysuspmsimpmcecd 'cgs. mmptaspmvided ttelnw (give j®sdicdoa of diseiplinmy actioa, dam of discipihvayaetion, what of the violation and the smctioq ifsgy, imposed): (Attach m additional ahxtifnecessary.) . 2 9. Movmt has never beensobjectto my disb,armmtpmceediap, ezceptm provided below (give jucisdictioaof diseiplinmy action, data of disciplinary mom, nature ofthevielatim and the sanction, if dny, imposed): (Attachaa sbeetifneawary.) 9. Movant, either byresigoatioq withdrawal, or otherwise, nmerbas terminated or attempted to temrinate Movmt's affice as an attomeyin onkt to avoid administra0ve, dlsciplinary, disbarment, orsuspewionproceedings. 10. Mavmtis mteainectivo member of The FloridaBm. 11. Mov =isnotnowammtberofneFloridaHa. 12. Mavemis note suspendedmeunberofMe FloridaBar. 13. Movmtis not a disbarred member of Me Florida Bar= has Movantteceiveda disci*myresigoatica from The ploridaBan 14. Movantbas notprevionslybem disciplined orbeld in mntemptbymmaof misconductcummiftedwhite engaged in rnpreseotetion.putsuantto Florida Role ormcial Administration 2.510, except as providedbelow (give date of disciplinary action or contempt, reamsthamfor, and courtimposing contempt): (Attach madditmal sheetifnecessary.) ���� . 15. Movanfbat filed unction(a) to sppear as counsel la Florida state courts during the past five (5) years in the followingmattata: (Attach an additional sheetifnecessay.) DateofMotion Casa Nana CaseNmiber Court Date Motloa OrantediDmfed 16. T.nealcoanael oframzd essaciated wfOrMavmtiathismattais � �- •la'.�...ee�{ -0 075b3 who is an adtvomemteria gopd standing of The Florida (Name sari Florida Bss Number) {� Bazmdhaa offiees at l2Q(, 1ri. �iea�at't( iRn� \ /CiNE. �l�, (BlmetAdd=) ,tt ,,a (Seams\. - Ft_ `53b1y'A (city) tgam) Op Coda) a5u -su- t,�tss (Tdeph®e with ens cads) (If local mumW is not in active membetoflheFlorida Bar in good sta diog, plemapmvide information as to local mmael's membership status, 17. MovmtbmreadtheappEmblopmviaiomofFlodElknleofluMcialAd minis ion 2.510 and Rgle 13.10 of dw Ames RegulafingiheFlorida Barand wtifies that.this verified motion complies withthosamles. 18. Movant agrms to complywith tbeprmvisi'cm of the Florida Rates afPro 6mimal Conduct and mosaats to tho jmisdiedon of the courts and theBmof&eState of Florida. WHEREFORE, Mova ntrespectfutlysquea1spend3sion to appear in this court lion M rerun only. DATED this 7 _ day of_[ vo Movant a Case 9;1 - 80530 -DMM Document 25 Entered on FLSD Docket 06/17/2013 Pag of FILED by UNITED STATES DISTRICT COURT JUN 17 2013 pt SOUTHERN DISTRICT OF FLORIDA 8TEVEryp{ -U a� Fu.a, OISIIr0E '"JON Case No, 13.805A0- CIV- MIDDLEBROOKS `r^ P.. a' �° MARTIN E.O'BOYLE 13 --50 ;3o Plainti$ VS. TOWN OF GULF STREAM Defendant. MOTION TO APPEAR PRO HAC VICE CONSENT TO DESIGNATION .AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC MINOS In accordance with Local Rules 4(b) of the Special Rules Governing the Admission and Practice of Attorneys of the United States District Court for the Southern District of Florida, the undersigned respectfully moves for the admission pro hac vice of Jonathan R O'Boyle of 2146 E. Huntingdon St, Philadelphia, PA 19125,561-758-1223, for purposes of appearance as co- counsel on behalf of Martin E. O'Boyle in the abgve -styled case only, and pursuant to Rule 213 of the CMIECF Administrative Procedures, and to permit Jonathan R. O'Boyle to receive electronic filings in this case, and in support bereof states as follows; 1. Jonathan R. O'Boyle is not admitted to practice in the Southern District of Florida and is a member in good standing of the Pennsylvania Supreme Court (PA Bar#314500). 2. Movsnt, Robert S. Garshman, Esquire, of the law fvm of GERSHMAN & GERSHMAN, P.A., 2160 W. Atlantic Avenue, 2d Floor, 561- 684 -8898, is a member in good standing of the The Florida Bar and the United States District Court for the Sogthem District of Florida, maintains an office in this State for the practice of law, and is authorized to file through the Comes electronic filing system. 0. ±2 in I c;,1 Case 9:13 -cv- 80530 -DMM Document 25 Entered on FLSD Docket 06/1712013 Page 2 of 5 Movant 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 may be filed clectronioaly, andwho shall be responsible for filing documents in compliance with the C VECP AdministradycProcedures. See 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 adrrrission fee. A certification in accordance with Rule 4(b) is attached hereto. •4. Jonathan R. O'Boyle, by and through designated counsel andpursuant to Section 2B CMIECF Administrative Procedures, hereby requests the Court to provide Notice of Electronic Filings to Jonathan R, O'Boyle at email address; Jonatha=boyle(rdgmail.com. WIffiREFORE, Robert S. Gershman, moves this Court to enter an Order Jonathan R.. O'Boyle, to appear before this Court onbebalfof Martin E .O'Boyle, for an purposes. relating to tile 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 sgbmitted, R err S. Gershman Flo 'da Bar No, 917397 Robert@rglawfimr.us OERSIWAN & GERSHMAN, P.A. 2160 W. Atlantic Avenue, 2d Floor Delray Beach, FL 33445 (561) 684 -8898 (telephone) (561) 998 -5868 (facsimile) Attomey for Martin E, O'Boyle Case 9:13 -cv- 80530 -DMM Document 25 Entered on FLSD Docket D6117/2013 Page 3 at 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 13.80530- aWMDLFBROOAS MARTINS. O'BOYLE Plafntfff,, Va. TOWN OF GULF STREAM Defendant CERTIFICATION OF JONATHAN R_ O'BOYLE Jonathan R. O'Boyle, Esquire, pursuant to Rule 4(b) of the Special Rules Govcndng the Admission and Practice of Attorneys, hereby certifies that (1) 1 have studied the Local Rates of the United States District Court for the Southern District of Florida; and (2)1 are amamber in good shading of the Pennsylvania Supremo Court. P ga"l OBoyle rH374500 Case 9:13ty- 80530 -DMM Document 25 Entered on FLSD Docket 06/1712013 Page 4 of 5 CERTIFICATE OF SERVICE . IHEREBY CERTIFY that strue and waect copy of the foregoing Motion to Appou Pro Hoc l ice, Consent to Desigoadon and Request to Electroaically Receive Notices of Electronic Filings was served by uploading same to the'CM/ECF. SERVICE LIST Joanne M. O'Connor jomnnor@jonesfoster eom JONES FOSTER JOHNSTON & STUBBS,. F.A. 505 South Flagler Drivo Suite 1100 West Palm Beech, FL 33401 561 -659 -3000 (telephone) 561 - 650 -5300 (famfinile) Attorneys for Defendant Towa of Gulf Stm= 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 OF FLORIDA Case No, 13- 80530- CIV- MDDLEBROOKS MARTINE. O'BOYLE Plaintiff, VS. TOWN OF GULF STREAM Defendant ORDER GRANITNGMOTION TO APPEAR PRO HAC VICE, CONSENT TO DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING THIS CAUSE having comebeforethe Court on the Motionto AppearPro Hac Vice for Jonathan R. O'Boyle, ConxattDDesig-ai aMRequesttoE lwfti3McallyReceive Notices of 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 2B 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, may appear and participate in this action on behalf of Martin E. O'Boyle, The Clerk shall provide electronic notification of all electronic filings to Jonathan R. O'Boyle at Jonaffmmboyle@gmail.com. DONE AND ORDERD ur Chambers, West Palm Beach, Palm Beach County, Southern District of Florida, on June , 2013. DONALD MIDDLEBROOKS United States District Judge Copies Analshed 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 OF FLORIDA CASE NO.13- 80530- CIV- MIDDLEBROOKS MARTIN E. O'BOYLE, Plaintiff, VS. TOWN OF GULF STREAM, Defendant. THIS CAUSE comes before the Court upon a Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notice of Electronic Filings (DE 25) ( "Motion "), filed June 17, 2013. The Court has reviewed the record and is fully advised in the promises. Pursuant to Local Rule 4(b) of the Special Rules Governing the Admission and Practice of Attorneys in the United States District Court for the Southern District of Florida, the Motion requests permission for the limited appearance of Jonathan R. O'Boyle, of 2146 E. Huntington St., Philadelphia, PA 19125, as co- counsel on behalf of Plaintiff in this matter. The Motion has been 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, 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 ionathanrobovle(a1¢mail, com. DONE AND ORDERED in Chambers at West Palm'Beach lorida, this day of June, 2013, UNITED STATES DISTRICT JUDGE Copies to: Counsel of Record t r. t t I i UNI'1715 S'CATES DTSTRrCT COURT FOB,TBE 80UTM1 RN DISTRICT OF FLORIDA WESTPALMBTv1CHDIS kON CASE N4: 9:13- cv41053 -19$ Plajntiff, vs. TOWN OF GULF STREAM et, al, Detenilauts. 1 MQTT0NTOAPP]iAT(.- OffAt: VTCIt OTT1 T0] aSjC,'iS'ATYON.ANRRPOTTCir'T0 Fr'rCTRONTCAT.TYRTt( RNT/ r;() +c�()I TiCTROMC Frr MV In wcordanco with Local Rules 4(b) of the Sppoial Rules Governing the Admission and PmeSce ofAttomeys of the: United States District Caurt for the Southern District of Florida, the undersigned respeclfrdly m008 for tho admission Pro lrae vice of 7onathan R. O'Boyle of214611luntingdon St., Philadelphia PA 1912.1,561-758-1223, For purposes ofoppeamieo as on- ommsel an behalf of Chrls O'Hare In the above - styled owe only, and plrrsaant to Rule 2D of the CM/ECF Administrative Procedures, to permit 7onuthan R. Q'Beyle to receive electronic filings In this.ouse, and In support thereof states as falloves: 1. Jonathan R. O'Boyle is not admitted to practice in the Sautham District of Florida and is a member in good standing of the Pennsylvania Supremo CD wt (PA Bar# 314500). The undersigned is a member in good dmnding of the Thd Florida Bar and the United States District Court for the Southern District of Clorida, maintains m office in this State for the practice of law, and is authorized to file through the Court's electronic filing system. Movant poaseuts to be designated as .a member of tbo Bar of tldd Court with. whom the Court and Opposing counsel may readily communicate regarding the conduct of the case; upon whartr filings shall be served, who shall be required to electronically file all documents and things that may be filed electronically, dad who shell be rospensible for filing documents In compliance with the CI&ECF Administrative procedures. See Section 213 oft ha CM /BCF Administrative Procedure, JAN 13 Zow SY 3. In accordanca with Ste local, rules ofthis CouM Jonathan R. O'Boyle has made paymentof this Court's $75 admission.feo. A certification in adcordance with Role 4(b) is being filed contemporaneously Willi this Motion, A bopy is attached hereto, 4- Jonathan R. O'Boyle, by and through designatbd copnsol and pursuant to Section 2B CM/BCF Administrative Procedures,hetoby rdquesis the Court to profldeNotice ofl?deotronic Filing to Jonathan R. O'Boyle at small address: fonatharmboylc@gmaB.eom. WHEREFORE, Mark J. Henan moves this Court to enter an Older permitting 7oa'athaa R O 'Boyle to appear bofom this Court on behalf of Zhris OTare fpr all pprposes rdldting to thb peGueedings in the above - styled matter and directing the Clerk to proyido notice ofcieetrohlo filings to Jonathan R. OBoyle. I IM-REBy CERTIFY that on January 10, 2014;1 filed the foregoing 40cument with the Clerk of Court via convendoualme0tod due to the natutc of the motion. I further eertifylhat mailed the foregoing docurnant via pidpald first class U.S- fail to the following: N Vchaol R Piper CpristopherJ, Sterns JOHNSON, AN8BLM9, MUMCCH, BURKE, PIPER & HOCii NW, P.A. 2455 East sunrise Boulevard Suite 1000 Fort Lnudcrdaio, Florida 33304 Tolophono.: (954) 463.0100 piptr(rr�jambg.com steamsQajambg.com Dated: January 7, 2014 GNAMAMSON P.A. 4fi1 South my Rdat Palm BrM1791" 3 so- Ta1:551 -7 Flocida BarNp. 0045251 561- 7234264 (cell & text) mhannaQa g3mlpwcom UNITED STATES DISTRICT COU&TF T88SODTMMDI8'PAIC!'OFFLORIDA VMTPALMNACII I)IMON LASS NO: 9:13- dr•61053•XI.H C US O'HARE PIa14Y1R, vt. TOWN OPGOLFSMAMeL ML Dclhndaets. Ntl is ;Y SS'as; 11Mt1:e�_ Tonsillar; R. O'BOy14, Esgpir% pursuant to Rglo 4(6 ofdle Spaolel $elm Owetniugd:e Admisslap and PraoOm ofANOmeys, hesbtry cett(Gw lbat( )Ihava studied the LOml Rules dithoUalied Swim DlstNct Court for the Southern Dfcbiat ofFlprlda, end (2) Ian a membee kgood standing of the PemuylvadaSuprants CourL loaf me O oyle, Esq. Jwalhpn B. O'Boyle, P.C. 2146 dlHwBugdon SL Phlodl . 19125 161;581 -71-758 -1212 23 ITW215 -09:1 -3641 Pon nsylvanla Bar No: 314500 1 HERESY CERTIFY that.ou January 10, 2014, INird the foregoing domtmeatwhh the Clark of Cmntviemnventionul method due]n %o net= of themotiw. 1 Nether certify dint mailed the foregoing doouusantvia prepaid first at= US. sued to thefollnest; bualidal IL Pip.T Chriamphfrl. Steerds JOHNSON, ANSELMO, MQRDOCA BARKS, Fn%k&H0MWAN, P.A. 2455 EsmtBunr'veB'aalNan(8oite 1000 FmtL msdardals, Floride33304 lhlspbonv (954) 463 -0100 pipergambg.win 6tenms@Jambg.wM baled: January 7, 2014 (IMM vJAI)rSON pA 401 Saudi Cowry Road 03272 FeGn Bough, 171,334119-9991 Tot: 561.2234990 ldnrkJ. Hamm Florida BarNo. 0045251 561.723 -6264 (colt & tanc* mhamaQoglmiaw,com w UNr= STAIRS DISTRICT COURT FOR TIM SOUTDISRbi DISTRICT OF FLORIDA WEST PALM BLACII DIVISI'ON CASPs Nt5:9;23 cv 8105 # -KI 13 CMUS OMARB Plaintiff, vs. TOWN OF GUIY STRLTAM et. al. DerendAMM R A Yyr D FOUFST'1'0 TT PCTQ h ' N R S' t)MV hti1TYNi` THIS CAUSE having cone before the Court on.the Motion to Appear Pro Him Vice for Joonthan R, O'Boyle; Consent to Designation, and Request to Electrobiealiy Raeeive Notices of Electronic Filing (the "Motion "), pursuant to the Special Rules Governing the Admission and Practice ofAttomays in via United States District Cohlifor the Southern District ofFlgrida and Section 2 B oftha CM/ECF Administrative Procedures. This Court having considered the motion and aU other rolovant actors, itis hereby ofPlorlda ORDERED OR ADJUDGED that The Motion is GRANTED. Jonathan IL O'Boyle, may appear and participate in tills action on behalf of Chris O'H'are. The Clark snail provide electronic notification ofall Eectronie filings to Jonathan R. O'Boyle nt jonathanrnboyleC3e gmail•com. DONE AND ORDEREp in Cbambvs, WestPidm Beach, Palm Beach County, Soulh'ern Dishlct of Florida, on January 2014, Copies furnished to: All Counssl ol'Record KENNM'H L. RYSKAW United States District Judge r' TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail August 26, 2014 Commerce GP, Inc. [Mail to: records @commerce - group.com] Re: GS #1223 (712) Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4f. (exchiding subparagraphs 4, 4a., 4b., 4c.,4d., 4e., 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 4f of the referenced Motion is attached. 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 .orQ/WebLink8 /0 /doc /17426/Paee l .asox. Please note that you will find all responsive documents at the same link. We consider this matter closed. Sincerely, Town Clerk Custodian of the Records