HomeMy Public PortalAboutPRR 14-1239TOWN 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
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http://www2.gulf-stream.org/WebLink8/0/doc/l
73 70/1'age
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http:
/ /www2.
gulf- stream.org[WebLink8
/0 /doc /17379/Pagel
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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
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http://www2.gulf-stream.org/WebLink8/0/doc/I
739 I /Pagel
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http:
/ /www2. gulf-
stream.orgfWebLink8
/0 /doc /I7418/Page
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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
I �r
/ IN THH CItCUfl' COURT OF THE I5M MDICIAL CIRCUIT, INAND
111/ll FOR PALM BEACH, COUNTY, FLORIDA
cHRISIOPHRAF. O'tiARS CeseNo.2014CA000720
Plainfiff
Division Al
VS.
TOWNOFrT usTREW,
Wn1LWZr.2HRASffiR
Dofmdmt
VERIFIED MOTIONP'OR ADMISSION TO A.PPPAR PROAAC YTCW
PURSUANT TOFLORMARDLE OF MDICIALADMBQISTRATION 2510
Comm mwIONATHAN R. O'HOYL& Havant herein, andrespne futlyrepments
the following:
1. Mavmtl( ffianR. O' BoylpfsdomidlcdmdpermanmdyresidmiaLON aPORT,
NEW JERSEY. Movmtis not a ptruanmt resideatofthe State ofFhrrlda,
Movmt Jonatbaa. R. O'Boyle Ise, t"ormyresident of the State ofFlar(da and has an
applicetiaapendingfar admission to The FlorldaBar•and hasvotpreviouslybem denied
admissiaa to'Tho Flouda Har.
2. Movantismtattmneyandamemberoftho haw firm of(orprartiem lawimilm the
name ol) The O'BovloTAw Finn P.C. (Fome3v lmmvn as lovaLn R. O'Bo*?C) wi0t
offices at 21445 H. Hmtinedon St PMladeltild
Fbyiadelobia Peonsvlvania 19125 561- 758 -1223
(county) (Smte) (Zg'Code) (Tcicphoac)
3. Movantbasbemmtainedl) c= uaAyorasamembmo ftbeabovenamedlawfianen
lamrary 10.2014 by Chrietanher O'Harovia hie FL ettomevLan Roeder
(DateRepresmtation Cmnmenc.m (NemeofhdywPartic )
to provide Iogal3epreamtatioa in connection with the abovo-styled. matternewpeadingbofare,
the above-named conrtofthe State ofFlorida.
4.'Moveat ism aedve memberia good smndingead maxeotly eligible topraatle, lawin
Im
the following jmisdicdon(s): Tneludo attomay orbarmnnboc(s). (Attach mt addi&nuidwct if
necessary.) .
SUMDICTION ATtORM- ARNmmER
pt;A4� 111r.,tf,
5. There are no disuipifimypruceedings pending agelnst Maysnt, except as provided
below(givejudsdiction of disciplinary action, date ofd 41inetyaction, mom,sofamviolatian
and the sanction, ifany, imposed):
(Attacha�n additional sbeetifnecessary.)
6. Winn thepastfn a (5) yea®, Movsnthas notbemmbj=t to any disciplinary
proceedings, except asprovided below (give jndadiclion offteiponary action, date of
disciplinary aWoo, nature of the violation and the sanction, if =y, imposed):
(Attach an additional shodifneeessmy.) '
7. Movant has never been aubject to any suspensionproceedbags, except ea provided
below (glut jurisdiction of disciplinary action, date of disciplicaWactioq nine of the violation
and the smcdon;.ifany, imposed):
(Attach an additional sheet if necessary.)
E
R. Movant has never beansubjectin any disbarmestpmceed'mga, exceptas provided
below (givejndsdictioaofdiscipHnary acfian, date of discipHuaty action, natam aftheviolatlon
and the motion, if tiny, imposed):
(Atmehan V�1additional sheet if necessary.) .
iQ� .
9. Mavant, either byreaignation, withdraws), or otherwise, naverbas temdnatod or
attempted to tenninste Movant'a office es sa alfomayia ante to avoid administrative,
disciplinary, disbarment, orsuspeasinnproceedings.
10. Movantis aoteninaclive mombaofThe FladdaBar.
11. Movam:isnotnhwa,c m acafThoploridaTtar.
12. Mavamis notasuspeadedmranber of The RaridaBar.
13. Movantis ant a disbaaed member ofTbe Florida BwzW has Movaatteceiveda
disciplinmyxesigvetion from The FloridaBan
I4. Movanthssnotprevlouslybe disciplined orheldinwntemptbyreasoaof
miswadnct ammhtadwhr7e cngagcdia represeofatiaapmsruat to Florida &ale of Judicial
Adminlstralion 2.510, except as provided below Wve date ofdisciplioary action m• contempt,
reasaas them for, and wmtimposing contempt):
(Attach an additional &act ifnecessary.) , h , . .
���� 1 5 . M o v a n t h a s 5 l e d m o t i o n ( s ) t o a p p e a z e s e o u o a e l i a F t o r i d a y t a m e a m t s d u r i a g t h e
` p a s t l i v e ( 5 ) y a m i n t h e f o l l o w i n g m a t t e n n ( A t t a c h a n a d d i t i o n a i s h e e t i f n e c e s s . " o y . )
D a t e o f ��M l o t r i o o n , C a s a N a m e C e s e N u m b e r C o u r t D a t e M o t l o a Q n m t a m c a f e d
I N a /
1 6 . l a c a l e m n s e l o f m o o r d a s s a c i a t e d w i &