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
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
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 & M a v a n t i n f h i a m a t t w i s
R �� " W ' } e C 0 1 0 ( S b ��j w h o i s a n a d i v e m e m b e r i n g o o d s t a n d i a g o f T h e F l o r i d a
( N a m e e n d P l o o d a D a N u m f i e r )
B a r a n d ��b a v o & r s s a t I V U , , W { �� " N G . 1 Q e , A ( R n k t c t / o w s -
N r p f s p a ( , g d ���� m e n d d n ��) ��L S 3 t { t i 2
( C i t y ) 0 6 4 - 6 ' l u - r e a g 5 ( � t a s ) ( Z i p C a d e )
( r d * . W i t h m v m d e )
( I f l o c a l c o u n s e l i s n o t a n a c d v e m e m b w o f T h e P l o d d a B a r i n g o o d s t m d i n g , p l a a s e p r o v i d a
i n f o m m t i o n a s t o l o c a l c o t n u d ' s m e m b a m t d p a t e n m . 1
1 7 . M o v a n t b a s m a d t h e o p p l i s b l e p r o v i s i o n s o f F l o r i d a R u l e o f M c i a l A d m i d v h a l i o n
2 , 5 1 0 a n d R u l e 1 3 . 1 0 o f t h e R u l e s R e g u l a 8 n g i h e P l o r i d a B a r a n d c m t i f i s t h a t . t h i s v e d f i r d
m o t i o n c o m p l i s w i t h t h o s e r u l r s .
1 8 . M o v a n t a & ' s s t o c o m p l y w i t h t h o p m v i s i � s o � t h c F l o d d a R u l e s o f P r o e m i m a l
C o a d u c t a n d c o n a m t s t o t h o j u r i s d i c t i o n o f t h e c o u r t s a n d t h e B a r o f t h e S t a t o o f F l o r i d a
W H E W O R S , M o v a n t r e s p e c t f u l l y r e g o o s t s p t a m i s a i o n t o a p p e a r i s t h l s c o u r t f o r t h i s
c a u s e o n l y .
D A T E D t h i s d a y o f _ [ . , v
M a v a n t
a
0
c
IN'THE FIFTEENTH JUDICIAL CIRCUIT COURT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 2014- CA- 00393BAB k
CERTIFIED
COPY
JASON WEExS, 'CONDENSED
Petitionex,
ve.
TOWN OF PALM BEACH,
Respondent,
TRANSCRIPT OF 'TESTIMONY AND PROCEEDINGS HAD
BEFORE THE HONORABLE THOMAS BARKDULL
DAT9; APRIL 10, 2014
TIME: 9;00 - 10:30 A.M.
PLEASANTON, GREENHILL, MEEK & MARSAA
561/833.7811
I
2
4
1 INDEX
1
PRO DEED ING S- '
2 TESTIMONY AND PROCEEDINGS
2
THE COURT: Jason Weeks va. Town of Palm
3 APRIL 10, 2014
3
Beach, Who Is here on behalf of the plaintiff?
4
6 WITNESSES FOR DEFENDANT
4
MR. MESA: Good morning, Your Honor.
6 DIRECT CROSS REDIRECT
5
Glovanl Mesa on behalf of plafnillf, Jason
7 DANIELLE OLSON
8
Weeks-
8 By Ms. Cooper 13 29
7
THE COURT: And who do you have with you?
By Mc Mass 25
e.
Mr. Weeks?
9
10 SPENCER WILSON
8
MR. O'BOYLE No, sir. My name Is Jon
11 By Ms. Cooper 30
10
O'Boyle. I'm acting as Mr. Mesa's law clerk.
By Mr. Mesa 31
11
I'm a Pennsylvania lawyer.
12
13 KATHRYN DYSON
12
THE COURT: Let me ask you a question, Mr.
14 By Ms. Cooper 33
13
O' Boyle. Anyralalinn to the O'Boyle In the
By Me Mesa 34
14
O'Boyle Lew Finn, P,C.7
15
16
MR. O'SOYLE Yes, Your Honor.
16 EXHIBITS
17 IN EVIDENCE
16
THE COURT: Whats the reiagon7
18
17
MR.OBOYLE: That Is my name an the law
19 Respondent's Exhibit No. 1 37
18
it". It's an lnlordaia law firm.
Letter
19
THE COURT: Haw do you — a's an
70
20
Interstate law fine with a Florida address?
21 Respondent's Exhibit No. 2 37
EEmags
21
MR.O'SOYLE: There's a Florida address
22
22
and a Pennsylvania address.
23 Pedfloner's Exhibit No. 1 30
23
THE COURT: And you're down here
E•mags
24
practicing with a firm without being a member
Z4
25
of the Florida Bar?
26
3
S
1 APPEARING ON BEHALF OF PETITIONER;
1
MR. OBOYLE: No, sir.
2 Glovanl Mesa, Esq.
2
THE COURT: Are you s member or the
THE O'BOYLE LAW FIRM, P.C.
3
Florida Bar?
3 1286 West Newport Center Drive
4
MR. O'BOYLE: No, sir.
Deerfield Beach, Florida 33432
5
THE COURT: Why doyau think you have erry
4
5 APPEARING ON BEHALF OF RESPONDENT:
8
right to stand at that iable7
6 Margaret L. Cooper, Esq.
7
MR. O'BOYLE: I don't have any light other
JONES, FOSTER, JOHNSTON & STUBBS, P.A.
B
than to assist Mr. Mesa.
7 5Q5 South FfaglerDrlve
9
THE COURT: Good. You step back because
Sbfle 1100
10
we're about to discus the Illegal practice of
8 Weal Palm Beach, Florida 33401
11
lowwIthoul being a member of the Florida Bar.
9
10 ALSO PRESENT: Jonathan O'Boyle, Esq,
12
MR. O'BOYLE: Yes, Your Honor.
11 ___
13
THE COURT: Mr. Mesa, ate you a member of
12 BE IT REMEM13ERED1hal the following testimony
14
the Florida Bar?
13 and proceedings were. had In the above•antillad cause
15
MR. MESA: Yes, l am, Your Honor.
14 before the Honorable Thomas Barkdult, In the Palm
18
THE COURT: How long have you been'¢
15 Beach County Courthouse, city of Wed Palm Beach,
17
member of the Florida Bar?
18 state of Ffodd% on Thursday, the 10th day of
17 April, 2014, to wlu
18
MR. MESA: Since November of 2010.
18 ___
19
THE COURT: Are you a partner in the,
19
20
quote,. O'Boyle LawFkm?
20
21
MR. MESA: I am not, Your Honor.
21
22
THECOURTI How many 900MOYS ate them
22
23
In the O'Boyle LgWFlmli
23
24
MR. MESA: Four —five at the moment,
24
zs
25
Your Honor.
PLEMANTON, GREENHILL, MEEK & MAREAA
561/833.7811
I THE COURT: How many are located In the
2 State of Florida?
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
MR. MESA: Four, Your Honor
THE COURT: Okay, Who are the panners In
the Florida firm?
MR. MESA: Brian Witmer and Jon O'Boyle,
THE COURT: This genfleman is a padnorin
the Florida fhm7
MR. MESA: It's a mufil tmte firm, Your
Honor. To be quite frank with you, I'm not
sure how It's Incorporated but I know that
Brian Witmer Is a partner In the firm and he Is
a Florida attorney.
THE COURT: Who's here far the defense?
MS. COOPER: I am, Your Honor, Margaret
Cooper.
THE COURT: Welcome, Ms. Cooper.
MS.COOPER: Thankyou.
THE COURT: All right Mr. Mass, you —
who Is Ashtae A. Rlcpm2n7
MS. COOPER: Ashles Richman Is a lawyer In
the low firm of Jones, Faster, Johnston 6
Stubbs,
THE COURT: I apologize, I grabbed the
wrong pleading. lot mete what was filed by
1 the plaintiff here who called my office
2 yeaterdaylumptng up and dawn saying this is an
3 emergency.
4 Mr. Mesa filed this. Okay. Mr. Mesa,
5 what do you believe your client needs thalyogr
6 client Is not receiving other than one letter
1D
11
12
13
14
16
16
17
18
19
20
21
22
23
24
or one a -ma117
MR MESA: IN the Initial e-mail that
was made between Kathryn and Danielle who are
bath human resources personnel with the Town of
Palm Beach. Your Honor, specifinlly kwaa a
request that was made by Mr. Weeks forany and
off emalls, IMassagas, communlcaticns and any
documents between Danielle Olson and Kathryn
Dyson, and as stated, both ofwhcm are human
resource personnel with the Town of Pah Beach
on May 6th, 2011.
Your Honor, Mr. Weeks moah ed a portion
of an a,mall communication, an smell chain,
that Is. However, it is missing the Initial
e-mail from Kathryn to Danielle, ]its
apparent 101 on a clear view of the documents
that were provided that the Initial email Is
mining. In oddlgan, YourHonor then is a
recorded Inten,law with Danielle Olson which
1 she admitted receiving an e-mall from Kathrym.
2 THE COURT: Okay. So there's one a -mall
3 at Issue,
4 MR. MESA: That we're aware of, Your
6 Honor.
e THE COURT: And whet date Is the dale of
7 that alleged a -mall?
e MR.MESAt It's MaySth.
a THECOURT: Ofwhatyear?
10 MR.MESA: 2011,Your Honor.
11 THECOURT. May601,2011.
12 Ms. Cooper, what is your client's posidon
13 on thls7
14 MS. COOPER: Your Honor, there is no
15 e-mail. Let me explain. And they were advised
16 the} there is no email. Mr. Weeks is confused
17 and l will explain what happened. Mr. Weeks
16 filed a complaint with the HR department on
19 May S. Mrs. Olson is the HR director.
26 THE COURT: Is Mr. Weeks an employee?
21 MS. COOPER: He was at the lime. He's.
22 been laminated now and we're In other
23 litigation with Mr. Weeks.
24 THE COURT: Okay,
26 MS. COOPER Mrs. Olson who Is the HR
1 director was al an impasse hearing across the
2 street In another building. Ms. Dyson
3 contacted herto advise her that a complaint
4 had been Initialed by Mr. Weeks. Later on when
5 Mrs. Olson was being bdenlewed, It was about
6 maybe six, eight months later, whatever Il was,
7 she knew that them had been an e-mall
6 communication between she and Mrs. Dyson and
9 she made a mistake and she misspoke and she
10 said I initially got the Information bya -mall
11 from Mrs. Dyson. That was a mistake, It was
12 either an Instant —
13 THE COURT: Okay. 6o Its the town's
14 position the% one, It doesn't axist7
15 MS. COOPER Itdoesn'I exist, And 1
16 apologize, I thought you Just wanted to hear
17 from the lawyers today. Mrs. Olson Is an her
16, way to testify, she'll be here in five minutes.
19 It lust simply does not exist and we cant
20 produce what'b not.
21 THE COURT: Okay. It doesn't exist so
Z2 have you advised Mr. Mesa of this?
23 MS.,COOPER: Walustgolthlalawsull
24 flied. Mr. Weeks was advised but l was atthe
25 2nd OCA arguing a case yesterday and this was
PLEASMON, GREEMLL, MEEK & MARSAA
561/8.33.7811
e
PLEASAMODT, GREENHLLL, MEEK & MARSAA
551/e33,7811
10
12
1
all happening very fest, I was getting ready
• 1
you go to law school?
2
to—
2
MR O'BOYLE Drexel Law Universltyln
3
THE COURT: That's why I wanted to do It,
3
Philadelphia, Penn rybanla,
4
very quickly because 6 seems to be a really
4
THE COURT: Are you from Florida
5
simple Issue. One a -mall, If It MIMI and
6
originally?
6
IVs not privileged, It needs to be fumed
B
MR. O'BOYLE: Yes, Your Honor.
7
over, If 6 doennl exlet, It doesn't axial,
7
THE COURT: Whereabouts?
a
and l'6 take lasilmorry today and well
6
MR: O'BOYLE: Gulfstmom, Florida.
9
determine whether k exists or it doesn't and
9
THE COURT: Okay. Congratulations on
10
this case wig be over.
10
passing the Florida Bar, Good luck on getting
11
Mr, O'BoYlet have you moved to be admitted
11
admitted
12
pre hac vice In Florida at all?
12
All right. As soon as ourwlinesses
13
MR, O'90YLE: Yes, Your Honor.
13
appear, I'll hear testimony. Just advise my
14
THE COURT: How many times?
14
deputy and wail deal with IL Verygood.
15
MR. O'BOYLE: Dma, Your Honor.
15
(Thereupon, a recess was had,)
THECOURT: Mysuggesllunislfyoulhink
16
THE COURT; Good morning and welcome,
17
you're going to keep a law firm in Florida and
17
everyone. Welcome back. Okay. We am hem on
16
walk up to counsel table Ilke you're caumef In
IS
the case of Weeks vo. Town of Palm Beach on a
19
Florida that you take the Florida Bar.
19
mquesl for an emergenry, hearing on the Issue
20
MR. O'BOYLE: Yes, Your Honor,
20
of whetherptibllcrecords are available and
21
THE COURT: Haw long has your firm bean
21
whether they shouldbe produced. I heard the
22
opemUng down here?
22
Inllal arguments of counsel. The town's
23
MR. O'BOYLE: Since January, mid January;
23
position, as I Understand h, Me, Cooper, h
24
Your Honor.
24
that they requested an e•mall that does not
25
THE COURT: Have you signed up for the
25
exist, Is that correct?
11
13
1
Florida Baryef?
1
MB, COOPER: That is correct, Your Honor.
2
MR, O'BOYLE: Yes, Your Honor, and 1
2
THE COURT: Okay. You may call your first
3
passed it actually,
3
witness.
4
THE COURT: Congmlulallons. When are you
4
MS: COOPER; I'll call Denlello Olson.
5
being swam In?
5
THE COURT: Ma'am, if you'll please take
6
MR. O'BOYLE: That is to be determined,
6
the witness stand. Please watch yaurstep,
7
Your Honor.
7 THEREUPON,
e
THE COURT: Having trouble with your
a
DANIELLE OLSON,
9
background check or why aren't you being sworn
9 called as a witness by the Defendant, having been
40
In If you passed the Florida Bar?
10 fast
duly swam by the Court, In answer to
11
MR. O'BOYLE Yes, Your Honor. I passed
11 questions
propounded, was examined and testiled as
12
the New Jersey ear as well and—
12 follows:
13
THECOURT: Well, we're not In New Jersey
13
THE COURT: Counsel, you may Inquire.
14
MR. O'BOYLEC Your Honor, coned, but
14
MS,COOPER Thank you, Your Honor.
15
Florida is walling for Now Janney. their
15
DIRECTEXAMINATION
Is
process to be completed until they wig further
16 BY MS. COOPER'
17
process my Me.
17
Q Would you stale yourname, please?
15
THE COURT How you been admitted In any
16
A Oanlelle Olson,
19
stale?
19
0 Mrs. Olson, what is your posItlon with the
20
MR, O'BOYLE: Yes, Your Honor,
20 Town of Palm Beach7
21
Pennsywgla,
21
A Olredorofhamarresources,
22
THE COURT: When were you admitted in
22
0 And have you been involved In the search
23
Pennsylvania?
23 In
response to Mr. Weeks' public document requeal
24
MR,O'BOYLE: Novembet2012, Your Honor.
24 seeking a-malls between you and Mrs. Dyson —
25
THE COURT: November of 2012. Where did
26
A Yes. '
PLEASAMODT, GREENHLLL, MEEK & MARSAA
551/e33,7811
{
r` r "• f1
l 0b S. 191 5+
Address
Address hh
Loe.y hate zip 03
� , srat� ztp cone
S61 7K� ��z
TgepbooeNumber
STATE OF
COUNTYOF, A+lk,1:c.
7 �a4.C�!�.ylr .do hereby sovem•or affirm imderpraalfyof
pmjsry that I em IlaMavent iu the ebowstyled matter thatl'haveread the foXcgoing Motion
Rad kaowthe confeats thereof, and the contents we true ofmy ovmlmowledgo andbelief.
Mov®t
Ihereby consent to be asseclatedm local ousel of record•ui this eausepun;amtta
Florida Rule ofludicial Administration 2 .510..
DATED tIda ij "A day o£ .I gm Vll'
4 "
-"' Local Counsel ofR=rd
Address
p«: �P�a.t F), 3awm
Address
Case 9:1 - 80530 -DMM Document 25 Entered on FLSD Docket 06117/2013 Pag of
FRED by
w tp G UNITED STATES DISTRICT COURT JUN 17 22113
t SOUTHERN DISTRICT OF FLORIDA 9e
F su. , e
O a OIBIMO
'y0��. Case No.I3.805/30- CIV- MIDDLEBROOKS "'"WPaI
MARTINE. 0 'BOYLE 13-50J,30
Plaintiff,
vs.
TOWN OF GULF STREAM
Defendant.
MOTION TO APPEAR PRO HAC HCE CONSENT TO DESIGNATION
AND REOLWT TO ELECTRONICALLY RECEIVE NOTICES OF
ELECTRONIC FILINGS
In accordance with Local Rules 4(b) of the Special Rules Governing the Admission and
Practice of Attorneys of the United States District Court for the Southern District of Florida, the
undersigned respectfully moves for the - admission pro hoc 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 abgva -styled case only, and pursuant to Rule 2B of
the CM/ECF Administrative Procedures, and to permit Jonathan R. O'Boyle to receive electronic
filings in this case, and in support heaof states as follows:
1. Tonathan 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. Movant, Robert S. Gershman, Esquire, of the law Cum of OEUHMAN &
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 Soqthem District of
Florida, maintains an office in this State for the practice of law, and is authorized to file through
the Court's electronic filing system. ,"4 , .�1;yl;
Case 9:13 -cv- 80530 -DMM Document 25 Entered on FLSD Docket 06/1712013 Page 2 of 5
Movaut 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 oftho case; upon whom filings
shall be served, who shall be required to electronically filo all documents and things that maybe
filed electronically, andwho shall be responsible for filing documents in compliance with
the CM/ECF AdadnistrativeProcedures. See Section 2B of the CM/ECF Administrative
Procedures.
3. In accordance with the local rules of this Court, Jonathan & O'Boyle has made
payment of this Court's $75 adrrrission lea. A certification in accordanco with Rule 4(b) is attached
hereto.
•4. Jonathan R. O'Boyle, by and through designated counsel andpursuant to Section 2B
CM/ECF Administrative Procedures, hereby requests the Court to provide Notice of EIectronic
Filings to Jonathan R. O'Boyle at email address; Jonathanmboyle@gnail.com.
WHEREFORE, Robert S. Gershman, moves this Court to enter an Order Jonathan R.
O'Boyle, to appear before this Court onbebalf of Martin E. O'Boyle, for all purposes. relating tothe
proceedings in the above -styled matter and directing the Clerk to provide notice of electronic
filings to Jonathan R. O'Boyle.
Date: June 17, 20I3
Respectfully sgbmitted,
R edatart Gean
F 9)7397
Robert@rglaw6rmus
GERSWAN & GERSHMAN, RA.
2160 W. Atlantic Avenue, 2d Floor
Delray Beach, FL 33445
(561) 684 -8898 (telephone)
(561) 999 -5868 (facsimile)
Attorney for Martin E. O'Boyle
Case 9:13 -cv- 60530 -DMM Document 25 Entered an FLSD Docket. 0611712013 Page 3 of 5
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CW No. 13- 8 0 5 3 0- Civ- MIDDLEBROOIGS
1VMTINB. O'BOYLB
Plaintiff,.
VS.
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
Governing the Admission and Pmotice of Attorneys, hereby certifies that (I) J have studied
the Local Rules of the United States District Court for the Southern District of Florida; and
(2) I am amomber in good standing of the Pennsylvania Supreme Court.
93141
onathan O'Boyle
PA BerN374500
Case 9:13-cw60SSO -OMM Document 25 Entered on FLSD Docket 06/1712013 Page,t of S
CERTIFICATE OF SERVICE
. IHEREEY CERTIFY that atrue and correct copy of the foregoing Motion to
Appear Pro Hoe Mce, Consent to Dmiguation and Request to Electronically Receive
Notices ofElectronic Filings wss served by uploading same to the CM/ECF.
SERVICE LIST
loamo M. O'Comor
jammor(ajonesfostenmm
JONES FOSTER JOHNSTON &STUBBS,.P.A.
505 South MMIa Dtivo Suite 1100
West Palm Beach, FL 33401
561-659 -3000 (Wcphone)
561 -650 -5300 (Facsimile)
Anomoys for Defmdaat
Town ofOulfStm m
Case 9 :13 -cv- 80530 -DMM Document 25 Entered on FLSD Docket 06117/2013 Page 5 of 5
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No, 13- 50530- CTJ- MIDDLE13ROOKS
MARTINE. O'BOYLE
Plaintiff,
vs.
TOWN OF GULF STREAM
Defendant
ORDER GRANTINGMOTION TO
APPEAR PRO HA VICE, CONSENT TO DESIGNATION AND
REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF
ELECTRONIC FILING
THIS CAUSE having comebefore the Court on the Motionto AppearPro Hae Vice
for Jonathan R. O'Boyle, ConserA toDesigaiar, and RequesttoFledtonicallyReceiveNotices 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.
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 Jonathmroboyle @gmail.com.
DONE AND ORDERD in Chambers, West Palm Beach, Pahn Beach County,
Southern District of Florida, on June , 2013.
DONALD MIDDL13BROOKS
United States District Judge
Copies famished 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- CTV- 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 X 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
a
ionathanroboyle (mail.com.
DONE AND ORDERED in Chambers at West Palm Beach loride, this day of June,
2013.
UNITED STATES DISTRICT JUDGE
Copies to: Counsel of Record
l
t:
i
l
Y
1
1
t
UNfMb S'CATES DISTRICT COURT FOILTRE S,OUTmw DISTRICT OF FLo=A
WDsTPALMBDAca)Dr i:oN
CASD N4:9:13 -cv,- 811153 -Rt)Z
Cix M O'B:ARE
Plaintiff,
vs,
TOWN OF GOLF STRMM et, al.
Defendants_
IYiOTTtTN TO APB T1207iA r'. VTt'.It SL'rNi'TO E,'Sj�i3'ATYON- AIDRROTIPUTQ
FT T'CTRONTf`ATTVRn;(''PTVTi!NOTT ORh'YR 1"-MM(''
In accordance with Local Rules 4(b) of the Special Rulos Governing the AdmUsion and PmctlGe
ofAttomeysiftheUnited States DistriotCouxt for the Southern District of Florida, the undersigned
respectfully moves for the admission pro Ilse vice of Tonathan R. O'Boyle of2146P.,Tluntingdon St.,
Pldindelphia PA 19125, s61 -m -1223, For purposes of oppearnneo as co- emmsel on behalf of Chris
O'Ilare In the above -stylad oast only, and plrrsuant to Rule 2)3 of the CM/ECF AdminlAtmtivo
Procedures, to permikdonalhan R. Q'Deyleta recotveelcoltonlc fi(irigs In this.sase, and insupport dtoreof
states as follows:
Ioaalhan 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).
The undersigned is a member in good dtanding of the ThdFlorida Bar and theUnitcd States
District Coutt for the Southern District of Clorlda, maintains an ofd"ice, In tills State for the practice
of law, and is authorized to file through the Court's electmnie filing system. Tvlovant poasents to
be designated as .a member of the Bar of this Court with. whom the Court sad Opposing cannel
may readily communicate regarding the conduct of the case; upon whmh filings shall be served,
who shall be required to electronically file all documents and things that may be filed
electronically, dnd who shall be responsible fit filing documents in odmpliance with the CM/ECF
Administrative procedures. See Section 213 of the CM /ECF Administrative Procedure,
ECICa VE
JAN 13 2014
i-
3. In accordance with 11M local, rates of this Cour4 Jonathan R- O'Boyle has made paymentof Oils
Courts $75 admission.fee. A certification, in accordance with Rule 4(b) is being filed
contompmaneouslywiOt this Motion, A copy is attached hereto,
4- Jonathan IL O'Boyle, by and through designotbd copnsel aqd puma and. to Section 28 CMIECF
Administrative Procedures, hereby requests the Court to pnoVlde Notice ofEleotronic Filing to
Jonathan R. O'Boyle at email addmsg:jonztha=boyfc@gTnaii.com.
WHEREFORE, Mark J. Hanna moves this Court to enter an Order permitting lamdaa R.
O'Boyle to appear before this Court on behalf of Chris O'Rue for all purposes rdleting to thtl ptUoeadingg
In the above4yled matter and directing the Clerk to proPido notice of eleotmblo filings to Jonathan R.
O'Boyle.
I RGREBy CERTIFY that on January 10, 2014,1 filed the foregoing document with the Clerk of
Court via conventional method due to the nature of thn rnotion. I forihercortifylhat mailed the foregaing
document via pidpaid first class U.S. alail to the following:
l4chael R. Piper
Cluistopher.1, Steams
JOHNSON, A149BLM(1, MURDOC(4, BURKL, PIPER & HOC[iIv1AN, P.A.
2455 East Sunrise Boulevard, Sulto 1000
Fort.Laudardalo, Florida 33304
Toloplione.: (954) 463.0100
pipet@jamhg.com
ateams()a jambi;xom
Dated., Tommy 7, 2014 GM149ADISON P.A.
4.01 South .Gr m1V Rdad #3272
Tot:
Flotida Bor Np- 0045251
561 - 7234294 (cell & text)
mhanna@g3mI%w.com
UNITED STATES 3➢DJ118ICI COURT IfQRTj3X SOVIMNDISTETTCr op FLORIDA
W=PALME$ACDDIVL4ION
CABS Not 9A3,V- 81063 -RLS
CBM O'HARE
Ihat91714
VG
TOWN OP GOLF SIM?4eL al.
Do hodaah.
N�: 1' Ya�P' as; Y ➢:fit Ilea
Jonodtan R OIBWA16 Esgphe, purnumtto Rgln4(b1 of the Special Rulns Owmaiugdta
Admisslap and Modes afAttomays, hetaby cethiSw chat( )t hoe studied the Local Rules dith,U Lkd
SM109 DWct Court for the Southern Dtahict ofPlpddq mid (2) T 4 a mamba' in good standing oftbo
Pemsy lvmtia Supreaf a Court
JmWhm 0 oyTc 1Bsq.
lowthpn R. O'Boyle. P.C.
;146 H. Hmtiagdan 8L
AT; 55lp7d1- 12 39125
ibl; 561 -75 &1223
ITM 215.893.3641
Pohnaylvanla Bar Nc, 314500
I HEREBY CERIB+Y thatpn Jawmy 10. 2014, ISlpd the foregoing domuomtwith We Clerk of
Croat viownryaritionul mothcd due (0 the nature of the modoe. I flusher =ti y diet molld tha fomgcing
documantvis pmpstd fast else U.S. man to the fnllowing
Miollml IL Piper
Christophp IStearm
JOHNSON, AN6E4MD, M[AiDOC$ EDRItE, PIP$R &HOfal:IIi?pN, PA.
2455 EmtBunsiaaB'avlcvud, Solm ] 000
FwtLwdadnl0. Florlda333g4
Talapbona.:(954)461 -0100
pipeQlambgoom
elenrm0,4Jambe.eom
Du1ed: Jammu %2014 OMMMADISON M
401 Soulb Comfy Road 63272
Fahn Brach, pL33480.9991
TcI: 561-223-9990
Malt J. Hmoa
Florida BwWo. 004 ;261
S61 -IM -8284 (call di text)
rnumu@ag3mIM,mm
UNITED STATES DISTRICT COURTFOR TIM SOUTBIBRN DISTRICT OF FLORIDA
WEST PALM BEACII DMMON
CASK NO: 9:13 -ev- 81051 -KLB
,Mmtt • :.: n
Plaintiff,
Vs.
tOWN OF GULF STREAM et. al,
Defendant4.
R n .1 . .TLON O �
A C
THIS CAUSE having coma before tht Court on.the MoUan to Appear ?to Hao Vice for Joanihmn
R, O'Boyle; Consent to Designation, and Request to Electronically iteceive Notioes of Elcolionlc Filing
(the "Motion"), pursuant to the Special Rulas Cpv.kmaing the Admission and Pmcilcc; ofAttomeys in d»
United States District Cobtt for lire Southern Dishlct ofFl9ridaand Scotlon 2 B oftha CMlECF
AdministrativePmcedums. This Courthaving consldmd the motion and oil otber iblvant firturs, it is
horeby ofPlcrldn
ORDERED OR ADJUDGED that
The Motion is GRANTED. Jonathan R. O'Boylo, may appear and participate In this action on
behalf of Chris O'llme. The Clork shall provido electronic nodScaHon of all olectronie filings to
Jonathan R. O'Boyle atjonafliulfoboyle@gmall.com.
DONE AND ORDEREl7 in Cbambers, WestP9lm Beach, palm Beach County, Soullpsm District
of Florida, on Jannary 2014,
KENNETH L. RYSI(ANA'
United StatesDlstrletJudge
Copies furnished to;
All Counsel ofReoord
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 #1239 (751)
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.
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: h"://www2.gulf-
stream.org/WebLink8/0/doc/I 7459/Papel.asr)x.
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
w
a
CORRECTED — REMOVED 1185 & ADDED 1198
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via a -mail
August 25, 2014
Commerce GP, Inc. [mail to: records @commerce- group.com]
Re: GS #1182 (726), #1184 (722), #1186 (706), #1187 (719), #1188 (727), #1189 (724), #1190
(720), #1191 (711), #1192 (699), #1198 (714), #1200 (715), #1205 (704), #1206 (716), #1208
(713), #1211 (705), #1212 (721), #1219 (709), #1223 (712), #1225 (707), #1231 (698),! 12359 4wL Q.
#1240 75 #1241 (723)
Please provide all Public Records which confirm the statement made in numbered paragraph 11
of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record,
The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire by Attorney
Sweetapple which reads as follows: "After the meeting, O'Boyle commenced to have airborne
banners flown on a daily basis over Palm Beach County.
Provide all Public Records which confirm all of the statements made by Attorney Sweetapple in
numbered paragraph 7 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E.
O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring,
Esquire, which was filed by Attorney Sweetapple.
Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the
statement that he made in numbered paragraph 4 (excluding subparagraphs a. through c.) of the
Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The
O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire, which was filed by
Attorney Sweetapple. A copy ofparagraph 4 of the referenced Motion is attached.
In subparagraph 41., please provide all Public Records which confirm the statement of Attorney
Sweetapple in his Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel
of Record, The O'Boyle Law Firm, P.C., Jonathan O' (sic) And William Ring, Esquire that
Jonathan O'Boyle had a "constant presence" in the State of Florida since the opening of the
O'Boyle Law Firm and that during that constant presence, he was handling legal matters for his
father and his father's businesses, including at least four (4) pro hoc vice appearances.
Please provide all Public Records which confirm the validity of the statement made by Attorney
Sweetapple in numbered paragraph 12 of the Defendant's Motion For Sanctions Against Plaintiff,
Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And
William Ring, Esquire, which was filed by Attorney Sweetapple.
CORRECTED— REMOVED 1185 & ADDED 1198
FA0ide copies of all Public Records confirming the validity of the statements made by Attorney
Sweetapple in numbered paragraph 9 of the Defendant's Motion For Sanctions Against Plaintiff
Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And
William Ring, Esquire.
Please provide all Public Records which confirm the statement of Attorney Sweetapple in
paragraph 4m. Of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle,
Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire
which was filed by Attorney Sweetapple.
Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the
statements that he made in numbered subparagraph 4e. (excluding subparagraphs 4, 4a., 4b.,
4c., 4d., 4f., 49., 4h., 4i., 4j., 4k, 41. And 4m) of the Defendant's Motion For Sanctions Against
Plaintiff, Martin E. O'Boyle, Counsel of Record, The 0 Boyle Law Firm, P.C., Jonathan O'(sic)
And William Ring, Esquire, which was filed by Attorney Sweetappple. A copy of subparagraph
4e. of the referenced Motion is attached.
Please provide all Public Records which confirm the statements made by Attorney Sweetapple in
Paragraph D26 of the Defendant's Motion To Disqualify The O'Boyle Law Firm, P.C., Inc And In
The Alternative, For An Evidentiary Hearing; and further provide all Public Records that show
that Jonathan O'Boyle has violated the prohibitions as set forth in D26 in the Defendant's Motion
to Disqualify The O'Boyle Law Firm, P.C., Inc. And, In The Alternative, For An Evidentiary
Hearing. Please provide all Public Records confirming the statements made by Attorney
Sweetapple in Paragraph D26 of the Defendant's Motion To Disqualify The O'Boyle Law Firm,
P.C., Inc And, In The Alternative, For An Evidentiary Hearing.
Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the
statements that he made in numbered subparagraph 4h. (excluding subparagraphs 4, 4a., 4b.,
4c.,4d., 4e., 4f., 4g., 4i., 4j., 4k, 41. And 4m) of the Defendant's Motion For Sanctions Against
Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O (sic)
And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy ofsubparagraph 4h.
of the referenced Motion is attached.
Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the
statements that he made in numbered subparagraph 4i. (excluding subparagraphs 4, 4a., 4b.,
4c., 4d., 4e., 4f., 4g., 4h., 4j., 4k., 41. And 4m) of the Defendant's Motion For Sanctions Against
Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O (sic)
And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy of subparagraph 4i.
of the referenced Motion is attached.
Please provide all Public Records which confirm the validity of the statement made by Attorney
Sweetapple in numbered paragraph 3 of the Defendant's Motion For Sanctions Against Plaintiff,
Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And
CORRECTED — REMOVED 1185 & ADDED 1198
iiPilh'am Ring, Esquire, which was fled by Attorney Sweetapple. A copy of paragraph 3 of the
referenced Motion is attached.
Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the
statements that he made in numbered subparagraph 4j. (excluding subparagraphs 4, 4a., 4b.,
4c.,4d., 4e., 4f., 4g., 4h.,4i., 4k., 41. And 4m) of the Defendant's Motion For Sanctions Against
Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O (sic)
And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy of subparagraph 4j.
of the referenced Motion is attached.
Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the
statements that he made in numbered subparagraph 4g. (excluding subparagraphs 4, 4a., 4b.,
4c.,4d., 4e., 4f., 4h.,44,4j., 4k, 41 And 4m.) of the Defendant's Motion For Sanctions Against
Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O (sic)
And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy ofsubparagraph 4g.
of the referenced Motion is attached.
Please provide all Public Records which confirm that the principal office of the O'Boyle Law Firm,
P.C. was at 2146 East Huntingdon Street, Philadelphia, PA on July 3, 2014 as stated by Attorney
Sweetapple.
Please provide all Public Records confirming the statement in numbered paragraph 5 of the
Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The
O'Boyle Law Firm, P.C., Jonathan O'Boyle And William Ring, Esquire wherein Attorney
Sweetapple states "Immediately after Defendant filed "the Motion" Plaintiff, Martin O'Boyle
(hereinafter "O'Boyle') .... requested a meeting with ..... the Jones Foster law firm.
Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the
statements that he made in numbered subparagraph 4c. (excluding subparagraphs 4, 4a., 4b.,, 4d.,
4e., 4f., 4g., 4h.,4i.,4j., 4k, 41. And 4m) ofthe Defendant's Motion For Sanctions Against Plaintiff,
Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C., Jonathan O (sic) And William
Ring, Esquire, which was filed by Attorney Sweetapple. A copy of subparagraph 4c. of the
referenced Motion is attached.
Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the
statements that he made in numbered subparagraph 4f. (excluding subparagraphs 4, 4a., 4b.,
4c.,4d., 4e., 4g., 4h.,4i.,4j., 4k, 41. And 4m) of the Defendant's Motion For Sanctions Against
Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O (sic)
And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy of subparagraph 4f
of the referenced Motion is attached.
CORRECTED — REMOVED 1185 & ADDED 1198
Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the
statements that he made in numbered subparagraph 4a. (excluding subparagraphs 4, 4b., 4c.,4d.,
4e., 4f., 4g., 4h.,4,4j., 4k., 41. And 4m) ofthe Defendant's Motion For Sanctions Against Plaintiff,
Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O (sic) And William
Ring, Esquire, which was filed by Attorney Sweetapple. A copy of subparagraph 4a. of the
referenced Motion is attached.
Provide all Public Records which will ajfIrm the statements made by Attorney Sweetapple in
Section D24 in the Defendant's Motion To Disqualify The O'Boyle Law Firm, P.C., Inc. And, Inc
The Alternative, For An Evidentiary Hearing.
Provide all Public Records which confirm the validity of the statement made by Attorney
Sweetapple in subparagraph 41. of the Defendant's Motion For Sanctions Against Plaintiff, Martin
E. O'Boyle, Counsel of Records, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And William
Ring, Esquire, which was filed by Attorney Sweetapple.
Provide all Public Records which confirm the validity of the statement made by Attorney
Sweetapple in subparagraph 4m. of the Defendant's Motion For Sanctions Against Plaintiff,
Martin E. O'Boyle, Counsel of Records, The O'Boyle Law Firm, P.C., Jonathan O'Boyle And
William Ring, Esquire, which was filed by Attorney Sweetapple.
Provide all Public Records confirming the statement of Attorney Sweetapple in numbered
paragraph 8 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle,
Counsel of Records, The O'Boyle Law Firm, P. C., Jonathan O'Boyle And William Ring, Esquire,
which was filed by Attorney Sweetapple.
Dear Commerce GP, Inc. [mail to: records @commerce - group.com],
The Town of Gulf Stream has received your public records requests dated July 31, 2014. If your
request was
received in writing, then the requests
can be found at the following links:
http://www2.gulf-stream.org/WebLink8/0/doc/I
7341 /Pagel
.aspx
_http:/
/www2.gulf-
stream.orgfWebLink8
/0 /doc /I7335/Pa
eg 1_aslx
http:
/ /www2.
gulf- stream.orgfWebLink8
/0 /doc /I7327/Pagel
.aspx
httR://www2.gulf-streain.org/WebLink8/0/doc/I
7333/Pagel
.asp
http:
/ /www2.
gulf- stream.orgfW
ebLink8 /0 /doc /I 7343/Page
l . aspx
http:
/ /www2.gulf-
stream.orgfW
ebLink8 /0 /doc /17337 /Pagel
. aspx
http:
/ /www2.
gulf- stream.orgfWebLink8
/0 /doc /I7332/Pagel
.aspx,
h!W://www2.gulf-strearn.org/WebLink8/0/doc/I
7329/Pagel
.asyxx,
http:
/ /www2.
gulf- stream.orgfWebLink8
/0 /doc /173 70/Page
l .aspx
http:
/ /www2.
gulf- stream.orgfWebLink8
/0 /doc /I 7377/Page
l . aslx
http:
/ /www2.
gulf - stream. org/
WebLink8 /0 /doc / 173 79/P aee
l .aspx,
http:/
/www2.gulf-
stream.org/WebLink8
/0 /doc /I7384/Pagel
.asox,
httv://www2.gulf-stream.org/WebLink8/0/doc/I
7385/Pagel
.aspx,
CORRECTED - REMOVED 1185 & ADDED 1198
http: / /www2.gulf-
stream .org /WebLink8
/0 /doc /17387/Pa
eg 1_aspxx,
http: / /www2. gulf-
stream.orgfWebLink8
/0 /doc /I 7390/Page
l .aspx,
http: / /www2. gulf-
stream.org[WebLink8
/0 /doc /17391 /Page
I .aspx,
http:/ /www2.gulf-
stream.orgfWebLink8
/0 /doc /I 7418/Page
l .aspx,
htti)://www2.gulf-streatn.org/WebLink8/0/doc/I
7426/Page
l .asyx.
http:/ /www2.gulf-
streatn.orgfWebLink8
/0 /doc /l 7430/Page
l . aspx
http: / /www2. gulf-
stream.orgMebLink8
/0 /doc /I 7442/Pagel
.aspx,
httR://www2.gulf-stream.org/WebLink8/0/doc/I7459/Pagel.asvx
,
h_ptt :/ /www2.gulf-
stream.org[WebLink8
/0 /doc /I7461/Pagel.aspx,
and
http:/ /www2.gulf-
stream.orgfWebLink8
/0 /doc /17463/Pagel.asox.
If your request was verbal,
then the description
of your public records request is set forth in the italics above. Please refer to
the referenced number above with any future correspondence.
The Town of Gulf Stream is currently working on a large number of incoming public records
requests. The Town will use its very best efforts to respond to you in a reasonable amount of time
with the appropriate response or an estimated cost to respond.
Sincerely,
Town Clerk
Custodian of the Records
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