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HomeMy Public PortalAboutPRR 14-1240TOWN 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 mustness rnuty Page 1 of 1 Corporations ONlne Services I Corporations I Forms I Contact Corporations I Business Services sr(ch Business Entity Ring History By Bu^Intvs Name Date: 4125/2014 (Select the link above to View the Business By Business Entity ID Fntlty'c Filing Hlstary) Verify.. ..._.._. .... .. _..__.. ...... ..__..._. Verify Certillmtlon Onlina Orders Business Name History Reglvterlm Or..ina Orders Order Good Standing Nome Name7ype Order Centric! DeCWNllln The O'soyle law Finn, P.C. Current Name Order Business LBt My Images JONATHAN R. O'BOYLE P.C. Pdor Name Search for Images Professional Corporatlon - Domestic- Information Entity Number. 4227661 Status: Actva Entity Creation Date: 1111412013 state of Business.: PA Registered OtilceAddress: 1001 Broad Street Johnstown PA 16906 Cambria Mailing Address: No Address t P [phtagod prnnr)fnN�oryrMnlelsIM. M la" R..d. PnnryPc'kyl srnny Patq httna• //w r.mmnTntinnC atntp bn tpC/r•nrnlanaYh /f'n.,. en.A10AGOC'1 AIncrnn.. rage 1 or 1 Search By Business Name By Business Entity ID Verify Verify Certification Online Orders Register for Online Orders Order Good Standing Order Certified Documents Order Business List My Images Search for Images Bate: 4252014 Corporations Online SeNices I Corporations I Forms I Contact Corporations I Business Services Business Entity Filing History (Select the link above to view the Business EntWs Filing History) Business Name History Name Name Type The O'Boyle Law Amr, P.C. Current Name IONATRAN R. O'BOYLE P.C. Prior Name Professional Corporation - Domestic - Information Entity Number. 4227691 Status: Active Entity Creation Date: 1111412013 State of Business.: PA Registered Office Address: 1001 Broad Street Johnstown PA ts906 Cambria Mailing Address: No Address CaPTaNC Ioci %mrybmia pgMVnr olaNle AO,," 0.rwmd Pdwq Porky I a..* P,il EXHIBIT https: / /www. corporations. state. pa .us /corp /soskb /Corp.asp?3249952 4/25/2014 PA Attorney Information I Pennsylvania Disciplinary Board Page 1 of 1 The Disciplinary Board of the Supreme Court of Pennsylvania PA Attorney Information Jonathan Reilly O'Boyle PA Attorney to: 314500 Current Status: Active Date of Admission: 11/13/2012 Lavfirm: Other Organization: District: 0 County: au7f State Public Access / 23 N HIDDEN HARBOUR DR > Address: t GULFSTREAM, FL 33483 / Tel: 1 758 -1223 Fax: Professional Liability I do not maintain Professional Liability Insurance pursuant to the provisions of Rule of Insurance: Professional Conduct 1.4(C), but I do have private clients and /or a possible exposure to maloractice actions. Comment: Discipline: C2DD7 -2014 The Dhadpllmry aeartl of ae Supreme Cant d Pemrylvanla, l Disclaimer For questiav a wmmertz repardry the w ile, please m a w at r ab auaoort®oacou ,ua EXHIBIT i1�)1 http:// www. padisciplinaryboard .orgllook- 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 Lawnrm: Other Organizatton: District: 0 County: Cambria Public Access Address: 1001 BROAD ST JOHNSTOWN. PA 16906 Tel: 661758-1223 Fax: - Professlonal Liability Insurance: I maintain, either Individually or through my firm, Professional Liability Insurance pursuant to the 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 web.suaport((.Dacourts.us. http:// www. padisciplinaryboard. org/ look- up /pa- attomey- infb.php?id= 314500 &pdcount =0 5/29/2014 ( IN THE CIRCUIT COURT OF THE 15mIUDICIALC curr,INAND fff!(! FOR PALM BPACH, COUNTY, FLORIDA .f ' cUR15fOP8RRP.0'HAR& Case No.2014CA000720 I - PI®Sff 4 Division AT VS. TOWNCEOWSTITAM. wII.LTAMS.TBRASMM Dofendant WRTFIED MOTIONNOR ADMISSION TO AITEAR PRO AAC 7?C)? PMZSUANTTOFLORMARULE OFJUDICfALADMnMTRATION2S10 Comes nowIONATB'AN R. O'BOYLE. Movaut herein, andresp=ffhuyreprasents the following: 1- MuvmtJon -4,x P— O'Boyleisdomiciledmdpem= m0y=ideainLONGFORT, NEW IBR9EY. Moveotis not epemvneotrcsident ofthe State of Florida. Movent Jonathm R O'Boyle Is a tempom yrmidem of am State ofFlerida and has as applicatiompeadingfor admission to TheFloridaBarmd Immotpreviouslybem darted admission to'Tho Florida Bar. 2 Movamismahorrcyandamembwo fthelawfimrof(orprazd = law=4c the name o�2'ye O'Bpvleiaw Fimo PC fFo�e3v lm vnuJpmL nR0'B v1ePCl vrifh offices at 2140 B. Huntingdon 8t Philadelphia Philadelphia PemsvtvWe 91125 551- 758 -1223 (County) (State) (zip Coda) (Teiephuuc) 3. Mpvmthes been mteinedpaesomlly or as amember of the aboveam ed law firm on .Tmwuv 10.2014 by. Christonher O'Rarevia his FL attomeyI,= Roeder pate Reprusentation Commenced) (NamaofPartyorParties) to provide legalxeprembsion is connection with fie above-aryledmattet nowpendmgbolbre the above marred court of the State of Florida. 4. Movantis an active membarin good steodingand ameotly eligible to pcactimlawin � V ./ the followingfiaisdiction( s): Include attomeyorberaambar(s).(Aftwh in additional sheet if necessazy.) f JURf6DICTION ATTOM M MARNUMEER q Sbi) S. These are no discip) imrypraceediags pending agalmt Movant, except as provided below (give jurisdiction of disciplinary action, date ofdisaplinmyaclioq usnue offfwviolation and the saacdou, ifaay, imposed): (Attackma additional sheetifaeassary.) 6. O�ithiB thepast&ve (5f yea®, Movanf Las aotbeensubject to mydisciplivary proceedings, except asprovided below (give jurisdiction ofdisciplinary action, date of disciplinary action, nature ofthe violation and The sanetian, if any, imposed): (Attwh as additional sheetffneces:bW) 7. Movanthes aevcrbcea subject tae�suspeasioapmexdmgs, exrsptaa ptvvIded below jgivcjrmsd3Gioa afddaciplivmy action, dsteofdisciplitiryacdon ,mah=ofthav)ol4on and the smtctlaq ifeny, imposed): (Attach m additional sheetifaecessnryJ g. Movant has ue mbeensubjwtto any disbarmmtpm=xrmge, erceptm provided below (givajnasdiction of disnplimny eoBon, date of disciplinary actin, nature offfievioladon and the sanction, if dny, imposed): (Attach an additional sbeetifnenassary.) 9. Movaat, eitberbyreeigaation, withdrawal, m o0mradsa, neverhas tsnnive[ed or attempted to temdnste Movant's office w as dttomayinorder to avoid administrative, . disciplinary, disbarment, orsuspenaianproccedings. 10. Movan[is ratanimcliva mombaaET'he FlaridaBar. 11. MovautisnetnowamcmbcrofTho FloridaBar. 12 MOVaatia not a suspaoded member of The FtoridaHar. 13. Movantis not a disbmrcd member of Tim FloridaBarnor has Movantmoeiveda. disci*aryxcsigeaticn from The FloridaBae 14. Movaotbaa notpmviouelybeea disciplhred orheld iu matemptby=sanof misconduct commidedwhrTe mgagedia represeaWionputsvmmt to Florida Riga orludiciei Adminbtat an 2510, excapt ae ptwidedbolow (give dme ofdiscipllnmy octlon wwntav4 reasonsthanfor, and coudimposing cvalcmpt): (Attach on additional aheetifnecessary.) FY+ . 15. Movant bas friled=Vm(s) to appear as eounsrl toFlodda atata comb dual past five (5) yeam is the followingmettonc (Attacb an additional sheetifaeceaamy) DateafMotion t:,asa Nance CaseNomher Coud DateMatioa G=tedMmIed 16, local coanael ofmcord wsoci ed wd& Movantin Oils malteris Ry e -W,} eC 010�56�j who fs an acdvemembcrin good slaadingofiheFlodda (Name and Pioeds 8¢ Num6c) Bar and Las ofScm at Mlb(a W• Nt -,35p �l ('Rnkt� '00,,& Oerr� -,a qea�� (srKtaddR,.) FI 33K42 (City) 0.54- 61u -GA65 fin) gipcada) (rdnpEOaawltha=.0&) (If local cuvnoel is oat to acdvemember ofThoFlotida Bain good sanding, pleasopmvido infnmmtion as to local cotvuet's membership atetas. t 17. Movanthas nzd the applicablaproviaioas ofLlodda Rnle of Sudicial Adari,ridmgon 1510 andRgle 1 -3.10 of tho Roles RcguldngTheFlorida Barand wdfim thattbb ved&d motioa complies wRh6wemles. 18. Movant agues to camplywith thapravisiaae oPthe Fladda Ryles afPtofncsioaet Coaduct and coasenis to theimisdi.etion of the courts and theBar of dwState of Florida WIEREFORE, Mova ntrrspecffeRyrequcslspetmission to appear in this court far Us cause Only. DATED this _dayof [, _ v q 1DJ, ' n R A Mavant 4 /,i�o n nUiviuvuUUty Si Page I of 1� 2146 E HUNTINGDON ST ACCOUNT# 314138000 Assessment Tax LOOP Account Information OWNERS) O'BOYLE KELLY L MAILING ADDRESS 2146 E HUNTINGDON ST Philadelphia PA 191251427 PROPERTY UNIT None PROPERTYZIP 191251427 SALE DATE 811812009 SALE PRICE $193,500 HOMESTEAD $30,000 Property Characteristics LAND AREA 1,260 SgFt IMPROVEMENT AREA 1,548 SgFt IMPROVEMENT DESCRIPTION httn: / /mmnertv.nhilnanv/ ldN<:.z •r4i::Z o cl 1.140 1; riU1N 111VCiUUN N 1 ROW 2 STY MASONRY BEGINNING POINT 200'E OF COLLINS ST EXTERIOR CONDITION New / Rehabbed ZONING RSA5 Residential /Residential Mixed -Use 2012 $27,800 2011 $27,800 2010 $27,800 2009 $27,800 $2,159 ASSESSED Certified Valuation History ASSESSED IMPROVEMENT ASSESSED IMPROVEMENT MARKET LAND YEAR VALUE (TAXABLE) 2015 $138,400 $18,648 2014 $138,400 $18,648 2013 $27,800 $2,159 2012 $27,800 2011 $27,800 2010 $27,800 2009 $27,800 $2,159 ASSESSED ASSESSED. ASSESSED IMPROVEMENT LAND IMPROVEMENT (TAXABLE) (EXEMPT( (EXEMPT) $119,752 $0 $0 $119,752 $0 $0 $6,737 $0 $0 $6,737 $0 $0 $2,159 $6,737 $0 $0 $2;159 $6,737 $0 $0 $2,159 $6,737 $0 $0 Page 2 of 2 TOTAL ASSESSMENT $138,400 $138,400 $8,896 $8,896 $8,896 $8,896 $8,896 Note: The Department of Revenue is responsible for collecting real estate taxes. Please visit the Department of Revenue. Website (http: / /www.phila.gov /tevenue) for information regarding the billing, collecting and accounting of real estate taxes or call 215 - 686 -6442. New Search View Tax Balances (http: / /www.phila.gov/ revenue /RealEstateTaxtDefault.aspx? bctBRTNo= 314138000) Submit an Inquiry (http: / /opa.phila.gov /opa.apps /Help /CitizenMain.aspx? sch= Ctrl2 &s =1 &url= search &id = 4406002146) hffn,//nrnn&j1v nhiln onv/ IN'THE FIFTEENTH JUDICIAL CIRCUIT COURT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2014- CA- 003938AB CER -nmt $ COPT' JASON WEEKS, Petitioner, vs. TOWN OF PALM BEACH, Respondent, CONDENSED TRANSCRIPT OF 'TESTIMONY AND PROCEEDINGS HAD BEFORE THE HONORABLE THOMAS BARKDULL DATN: APRIL 10, 2014 TIME: 9;00 - 10:30 A.M. PLEASANTON, GREENHILL, MEEK & MARSAA i 591/833.7811 I 2 4 1 INDEX 1 PRO CEEOING S- ' 2 TESTIMONY AND PROCEEDINGS 2 THE COURT. Jason Weeks vs. Town of Palm 3 APRIL 10, 2014 4 3 Beach, Who Is here on behalf of the plalntig7 6 WITNESSES FOR DEFENDANT 4 MR. MESA: Good morning, Your Honor. 6 DIRECT CROSS REDIRECT 5 Gl over] Mesa on behalf of plaintiff, Jason 7 DANIELLE OLSON B Weeks. 88y Ma.Cooper 13 29 7 THE COURT: And who do you have with you? By Mr. Mesa 25 e. Mt. Weeks? 9 10 SPENCER WILSON a MR. O'SOYLE: No, sit. My name Is Jan 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. Lei me ask you a question, Mr. 14 By Ms. Cooper 33 13 O' Boyle. Any mlagon to the O'Boyle in the By Mr. Mesa 34 14 O'Boyle Law Finn, P.C.? 15 16 MR. O'BOYLE Yes. Your Honor. 16 EXHIBITS 17 IN EVIDENCE 1B THE COURT: What's the relation? 1B 17 MR.OBDYLE: Thai is my name on the law 19 Respondent's Exhibit No.1 37 18 grin. It's an Interstate law Fum. Letter 19 THE COURT: How do you — it's an 70 20 Interstate law gmf with a Florida address? 21 Respondent's Exhibit No, 2 37 Emags 21 MR. O'BOYLE: There's a Florida eddrasa 22 22 and a Pennsylvania address. 23 Petitioners Exhibit No. 1 34 23 THE COURT; And you're down here E -malls 24 practicing with a grm without being a member 24 25 of the Florida Ball 26 3 s 1 APPEARING ON BEHALF OF PETITIONER: 1 MR. O'BOYLE: No, air. 2 Glavani Mesa, Esq. 2 THE COURT. Are you a member of the THE O'BOYLE LAW FIRM, P.C. 3 Florida Bar? 3 1286 West Newport Center Drive 4 MR. O'BOYLE: No, str. Deerfield Beach, Florlda 33432 5 THE COURT: Why do you think you have any 4 5 APPEARING ON BEHALF OF RESPONDENT: 6 right to stand at thatiabla7 6 Margaret L. Cooper, Esq. 7 MR. O'BOYLE I don't have any fight other JONES, FOSTER, JOHNSTON&STUBBS, P.A. B than to assist Mr. Mesa. 7 505 South Ftegier DIN& 9 THE COURT. Good. You step hack because huge 1100 10 we're abou t to discuss the Illegal practice of 8 West Palm Beach, Mrlda 33401 11 law without 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: ML Mesa, are you a member of 12 BE IT REMEMBERED.that the following testimony 14 the Florida Bar? 13 and proceedings were had In the above- antgied cause 15 MR. MESA: Yes, l am, Your Honor. 14 before the HonorableThomea Barkdull, In the Palm 16 THE COURT: How long have you been 's 15 Beach County Courthouse, city of Weal palm Basch, 17 member of the Florida Ben 18 Slate of Florida. on Thursday, the 10th day of 17 April, 2014, to wit i6 MR. MESA S1nre November of2010. 16 ___ 19 THE COURT; Are you a padnar In the, 19 20 quote,. O'Boyle LawFlrm7 20 21 MR. MESA: I am not, Your Honor. 21 22 THE COURT. Hsu many attorneys am them 22 23 In the O'Boyle law Finn? 23 24 MR.MESA: Four —five atthomomem, 24 25 25 Your. Hanbr. PLEMANTON, MZEE TT'rLL, TIIEEA & NARSAA 561/833.7811 P.LEASANTON, GREENHILL, MEEK & MARSAA 561/8.33.7811 s e ' 1 THE COURT: How many are located In the 1 she admitted m aMng an e; mall from Kathryn. 2 State of Florida? 2 THE COURT. Okay. So there's one e-rnall 3 MR. MESA: Four, Your Honor. 3 at Issue. 4 THE COURT: Okay, Who am the partners In 4 MR. MESA That we're aware of, Your 5 the Florida firm? a Honor. 6 MR. MESA: Brian Wilmer and Jon O'Boyle. 6 THE COURT: And what date 6 the dale of 7 THE COURT: This gentleman Is a padnerin 7 that alleged a -mall? B the Florida Orm7 B MR.MESAt It's May5th. 9 MR. MESA ICs a multHtals On, Your 9 THE COURT: Of what year7 10 Honor. To be quite frank with you, I'm not 10 MR. MESA 2011, Your Honor. ii sure how (i's Incorporated but l know that 11 THECOURTI May5th,2011. 12 Brian Witmer is a parinerin the firm and he u 12 Ms. Cooper, what is your client's position 13 a Florida allarney. 13 on this? 14 THE COURT: Who's here for the defense? 14 MS. COOPER: Your Honor, there is no 15 MS. COOPER: I am, Your Honor, Margaret 16 e- mall. Let me explain. And they were advised iB Cooper. 1e that them is no a -mail. Mr. Weeks is confused 17 THE COURT: Welcome, Ms. Cooper. 17 and I will explain whakhappened. Mr. Weeks Is MS. COOPER Thank you. 16 tried a complaint with the HR department on 19 THE COURT: All right Mr. Mesa, ysu— 19 May S. Mrs. Olson is the HR director. 20 who is Ashlea A. Ric iman7 20 THE COURT: Is Mr. Weeks an employee? 21 MS. COOPER Ashlee Richman Is a lawyer In 21 MS. COOPER: He was at Ilia tine, He's. 22 the low firm of Jonas, Foster, Johnston d 22 been terminated now and were In other 23 Stubbs. 23 litigation with Mr. Weeks. 24 THE COURT: I apologlae. I grabbed Ilia 24 THE COURT: Okay. 25 wrong pleading. Let melee what was Mad by 26 MS. COOPER: Mrs. Olson who is the HR 7 9 1 the plaintiff here who called my office 1 dlmctorwas at an Impasse hearing across the 2 yesterday jumping up and down saying this Is an 2 street In another building. Ms. Dyson 3 emergency. 3 contacted herto advise her that a complaint 4 Mr. Mesa Bled this. Okay. Mr. Mesa, 4 had been Inlllaled by Mr. Weeks. Later on when , 5 what do you believe your client needs that your 5 Mrs. Olson was being interviewed, It was about 6 client is not receiving other than one falter B maybe six, eight months later, whatever H was, 7 or one "all? 7 she knew that there had been an a -mall 6 MR MESA: IL's the Initial e-mail that 8 communlcafion between she and Mrs. Dyson and e was made between Kathryn and Danielle who are 9 she made a mistake and she misspoke and she 10 both human resources personnel with the Town of 10 said l Initially got the Information by a -mall 11 Palm Beach. Your Honor, spoclfically kwas a 11 from Mrs. Dyson. That was a mistake, it was 12 request that was made by Mr. Weeks forany and 12 either an lnstanl -- 13 all einalis, IMessagas, communications and any 13 THE COURT: Okay. So IV& the town's 14 documents between Danielle Olson and Kathryn 14 position that one. It doesn't exist? 15 Dyson, and as slated, both of whom are human 15 MS. COOPER It doesn't exist And 1 16 resource personnel with the Town of Palm Beach 16 apologize, I thought you Just wanted to hear 17 on May 511b, 2011. 17 from the lawyers today. Mrs. Olson Is an her 16 Your Honor, Mr. Weeks received a potion is way to tesfify, she'll be hero in live minutes, 19 of an e-mail communication, an a-moll chain, 19 It Just simply does nolerlsl and we cost 20 that is. However, it It missing the li lllal 20 produce what'k not. 21 e-mail from Kathryn to Danielle. It is 21 THE COURT: Okay. It doesn't exist so 22 apparent just on a dear New of the documents 22 have you advised Mr. Mesa of this? 23 that were provided that the Initial small is 23 MS..COCPER: Wajustgolthlalawsu4 24 missing. In addition, YcurHomr, there is a 24 filed, Mr. Weeks was advised but l was at the 25 recorded lnlemlewwith Danielle Olson which 26 2nd OCA arguing a case yesterday and this was P.LEASANTON, GREENHILL, MEEK & MARSAA 561/8.33.7811 PLEAHANTON, G&EEMILL, MEEK & MAMA 561/633,7811 to 1z 1 all happening very last I was getting ready • 1 you go to law 50110017 2 to— 2 MR. O'SOYLE Drexel law University In 3 THE COURT: That's why l wanted to do It 3 Philadelphia, Pennsylvania. 4 very quickly because it seems to be a really 4 THE COURT. Are you from Florida 6 simple Issue. One a -mall, if It misb and 6 odillmdr 6 Ira not privileged, It needs to be turned 6' MR. O'BOYLE: Yes, Your Honor. 7 over, If H doesn't exist. R doesn't exist, 7 THE COURT: Whereabouts?' 6 and 11 lake testimony today and we'll 6 MR: O'BOYLE: Gullstream, Florida. 9 determine whether k exists or It doesn't end 9 THE COURT: Okay. Congratulations on 10 this case wig be over. 10 passing the Flodda Bar, Good luck on getting it Mr. O'Boyle, have you moved to bb edmidad 11 admitted. 12 pro has vice In Florida of all? 12 All right. As soon as ourwi nasses 13 MR, O'BOYLIr: Yes, Your Honor, 13 appear, I'll heartestknony. Just advise my 14 THECOURT: Howmanytimes? 14 deputy and well deal with IL Vary good. ib MR. O'BOYLE: Once, YourHooar. 15 (thereupon, a recess was had,) ' k THECOURT: Mysuggestlonlsifyouthink 18 171E COURT; Good morning and welcome, 17 you're going to keep a low firm In Florida and 17 overyone. Waloome back. Okay. We am ham on 16 walk up to counsel table like you're counsel in 18 the case of Weeks va, Town of palm Beach on 19 Florida that you take the Florida Bar. 19 request for an emergency hearing on gro issue 29 MR. O'BOYLE: Yes, Your Honor, 28 of whether pyblic.reroNs am available and 21 THE COURT: How long has your firm been 21 whether they should he produced. Iheard the 72 operating down here? 22 ingid arguments of munsal. The town's 23 MR O'BOYLE: Since January, mid January; 23 position, as I underetand h, Ms. Cooper, Is 24 Your Honor. 24 that they ragdested an "all that does not 25 THE COURT: Have you signed up for the 25 exist Is that correct? 11 13 1 Florida Baryel? 1 MS. 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. Congmlulailoru. When are you 4 MS; COOPER; I'll cell Dantelia Olson. 5 being sworn In? 5 THE COURT: Ma'am, N you'll please take 6 MR. O'BOYLE: That is to be determined, 6 the witness stand. Please watch yourztep, 7 Your Honor. 7 THEREUPON, 6 THE COURT: Having trouble with your a DANIELLE OLSON, 9 batkground check orwhy arent you being sworn 9 caged as a witness by the Defendant, having been 10 In If you passed the Florida Bar? 10 first duly sworn by the Court, In answer to 11 MR. O'SOYLE: Yes, Your Honor, l passed 11 questions propounded, was axonlned and testified as 12 Ins New Jersey ear as well and— 12 follows: 13 THECOURT: Wetl,we're noon New.fersoy. 13 THECOURT: Counsel, you may inquire 14 MR. O'BOYLE- Your Honor, caned, but 14 MS,COOPER: Thank you, Your Honor, 15 Florida is waiting for Now Jersey. their 15 DIRECT EXAMINATION 10 process to be completod until they wig further 16 BY MS. COOPER: 17 procoss my file. 17 O Would you state your name, please? 18 THE COURT: Have you bean admitted In any iii A Danlelle Olson. 19 state7 19 D Mrs. Olson, what is your postion with the 20 MR.O'BOYLE: Yes, Your Honor, 20 Town of palm Basch? 21 Pennsylvania, 21 A Director of human resources, 22 THE COURT: When were you edmlUed In 22 O And have you been involved In tha search 23 Pennsylvania? 23 le response to Mr. Weeka' public document request 24 MR, O'BOY E: November 2012, Your Honor. 24 seeking "mile between you and Mrs. Dyson - 25 THECOURT; November of 2015 Wham did 26 A Yes. ' PLEAHANTON, G&EEMILL, MEEK & MAMA 561/633,7811 A "• f1 i � r f' lob S. igi� s-- Addrem Addtew Lo .PO F 1��! BY4e3 TStato, Ztp Code (;w -I YN 12-2-&_ Telephone Number STAMOF COU=OF A4kt&C- I.�vnrkl�t, Rr ly !t .dohereby mvrm•ar affirm rmdeepemalryo£ perjury that I aati 0&voat is thcabowstyledmatter; that I1tworeed the foregoing Modom and kmawthe contents fhereof, and the contcnte are use of my owalmowlcdgo andbelieE Mav®t Ihercby coasamto be assoclatedae local unsel ofrowd la this cause purauantto Florida Rule o 'Mcial Admiaistmtioa 2.510. DATFDtIda 2-`3�a dayo£ Local Cm`mlsel ofRewrd L1 mf4 W. l�+Pul Address Qat�`.e� • Addris9 Case 9;1 - 60530 -DMM Document 25 Entered on FLSD Docket 06117/2013 Pag Of FILED 6y C9 W o Gw UNITED STATES DISTRICT COURT JUN 17 2013 �i SOUTFIERN DISTRICT OF FLORIDA 9rrvEti � +' 8p�ga16M�E Case No. 13.905,40- CIV- MIDDLEBROOKS w.'ra: MARTIN E.O'BO'YLE /3-50j 30 Plaints$ VS. TOWN OF GULr STREAM Defeddant. MOTION TO APPEAR PROXAC VICE CONSENT TO DESIGNATION .AND REOUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTROMC FILING$ 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 6ac vice of Jonathan R. O'Boyle of 2146 E. Huntingdon St, Philedclphia, PA 19125, 561- 758 -1223, for purposes of appearance as co- counsel on behalf of Martin E. O'Boyle in the above -styled case only, and pursuant to Rule 213 of the CM/ECF Administrative Procedures, and to permit Jonathan R. O'Boyle to receive electronic filings in this case, and in support bereof status 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 CPA Bar#314500). 2. Movant Robert S. Gershman, Esquire, of the law firm of OER$HMAN & 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 Southern 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 Case 9:13 -cv- 80530 -DMM Document 25 Entered on FLSD Docket 06/1712013 Page 2 of 5 Mqvant 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 electronioally file all documents and things that maybe Sled electronioally, and who shall be responsible for filing documents in compliance with the CM/ECF AdministrativeProcedmes, Sea 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 Court's $75 admission fee. A certification in accordance with Rule 4(b) is attached hereto. •4. Jonathan R, O'Boyle, by and through designated counsel andpursuant to Secdon 2B CM(ECF Administrative Procedures, hereby requests the Court to provide Notice of Electronic Filings to Jonathan R, O'Boyle at email address ;Jonathmmboyle ®gmail.com. WHEREFORE, Robert S. Gershman, moves Us Court to enter an Order Jonathan R. O'Boyle, to appear before this Court onbebalf of Martin E. O'Boyle, for all purposes relating to the proceedings in the above -styled matter and d'uectiag the Clerk to provide notice of electronic filings to Jonathan R. O'Boyle. Date: June 17, 2013 Respectfully submitted, R art S. Qershman Flo [ids. Bar No, 91,7397 Robca@rglawfum.us GERSHMAN & GERSHMAN, P.A, 2160 W. Atlantic Avenue, 2d Floor Delray Bomb, FL 33445 (561) 684 -8898 (telephone) (561) 998 -5868 (faosirtdle) Attorney for Martin E, O'Boyle Case 9:13 -cv- 60530 -DMM Document 25 Entered on FLSD Docket06 /17/2013 Page 3 of S UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Cate No. 13. 80530- CIv- MIDDLFBROOKS MARIVR O'BOYLE Plaintiff,. vs. TOWN OF GULP STREAM Defendant CERTIFICATION OF JONATHAN R. O'BOYLE Jonathan R O'Boyle, Esqufre, pursuant to Rule 4(b) of the Special Rules Ooveming the Admission and Practice of Attorneys, hereby certifies that (I)1 have studied the Local Rules of the United States District Court for the Southern District of Florida; and (2) I amamembcr in good standing of the Pennsylvarde Supreme Court. P 9ti iCl O'Boyle 0314500 Case 9:13- - 80530 -DMM Document 25 Entered on FLSD Docket 06/1712013 Page 4 of 5 CERTIFICATE OF SERVICE . IHEREBY CERTIFY that atme and correct copy of the foregoing Motion to Appear Pro Hoc Nice, Consent to DesiguaUon and Request to Electronically Receive Notices of Electronic Filings was served by uploading same to the'CM/ECF. SERVICE LIST JOanoe M. O'Connor joconnor(a anccfosteccom JONES FOSTER JOHNSTON & STUBBS,.P.A. 505 South mega Drive Suito 1100 West Palm Beech, FL 33401 561-659 -3000 (telephone) 561 -650 -5300 (facsimile) Attorneys for Defendant Town of Gulf Stara 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- 80530- CN- MIDDLEBROOKS MARTINE. O'BOYLE Plaintiff, VS. TOWN OF GULF STREAM Defendant ORDER GRANTINO MOTION TO APPEAR PRO HAC VICE, CONSENT TO DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING THIS CAUSE having comebeforethe Court on the Motion-to AppearPro Hac Vice for Jonathan R. O'Boyle, CongmttoDesignatiott, BMRequesttDFlwftWc ffyReceive 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 of the CM/BCF 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 lonaflmroboyle@gmaii.com. DONE AND ORDERD in Chambers, West Palm Beach, Palm Beach County, Scuthem District of Florida, on June , 2013. DONALD MBDDLEBROOKS United States District Judge Copies famished to: All Counsel of Record 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- 1l7IDDLEBROOKS MARTIN E, O'BOYLE, Plaintiff, V5. TOWN OF GULF STREAM, Defendant. i!°''ym —mow 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 premises. 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 ionathanroboylvApinail. com. DONE AND ORDERED in Chambers at West Palm' Beach lorida, this 109 day of June, 2013, t UNITED STATES DISTRICT JUDGE Copies to: Counsel of Record I , UN'ITE15 S'CATES DISTRICT COURT FOR,THE S,OUMERN DISTRICT OF FLORIDA WEST PALMBRACHT1rPISION CASD NQ: 9r13- cYAW3 -49 :r Plaintiff, Va. TOWN OF GULF STRUM at, al, Defanclants. T� •Y Tr i iii' MANG . In accordance with Local Rules 4(b) of the Special Rules Governing the Admiksion and Practice ofAttnmeysofthe:Uaited Stains District Court far the Southern District of Florida, the undersigned respectfidly moves for the admission pro 1140 vice of Jonathan R. O'Boyle of2146 U. Huntingdon St, Pldlndelplhia PA 19125, 561-758-1223, For purposes of appearance as ao- ommsol on behalf of chris O'Hare In the above - styled vase only, and plasaaat to Rule 2B of the CM/ECF Admiulstrative Procedures, to permit Jonathan R. Q'Bayloto recalmelcettonle filings In this.onse, and is support thereof strifes as follows: 1. Jonathan R. O'Boyle is notadmitted to practice in the Southern Districtof Florida and is a member in good standing of the Pennsylvania Supreme Court (PA 13w* 314500). The undersigned is a member in goad dtanding of the Th0lorida Bar and theUtdtcd States District Court for the Southern District of floridn, maintains on office In dils State for the practice of law, and is authorized to file through the Court's electronic filing system. Movant consents to be designated as .a. member of the Bar of this Corot whb.wbom the Court and Opposing counsel may readily communicate regarding the conduct of the case; upon wlhorh filings shell be served, who sball be required to electronically file ail documents and things that may be filed oleolronically, dad who shall bo responsible lot tiling documents in compliance with the CWECF Administrative procedures. Sea Section 213 of the CM /13CFAdministradva Procedure, JAN 1 3 2014 R( {N ^;� -,.:i?;,�` -> BYE 3. In accordance with lhp local . rules of this Court, Jonathan It O'Boyle has made paymanLoftlda Court's $75 admission.fee. Acertifioation in accordance with Rnle 4(b) is being filed contemporaneously with this Motion, A copy is attached heratc, 4. Jonathan R O'Boyle, by and through designatbd copnsol end pursuant to Section 213 CM/ECF Administrative Procedures, hereby rativasts the Court to provide Notice ofEleotronio Filing to Jonathan R. O'Boyle at emafl address: jonatiuuvnboyle@gmnt.com. WHMREFORL, Mark J. Hanna moves this Court to enter an Order permitting Jonudtau IL O'Boyle to hppcar before this Court on behalf of Chris O'Hare fpr all purposes relating to the pr&eadings In the above - styled matter and directing the Clark to proWde notice of eleatroblo filings to Jonathan R. O'Boyle. I HBREBy CERTIFY that on Joinimy 10, 2014,1 filed the firogoing document with the Clerk of Court via conventional method due to the natutc of the motion. I fbriher eertifythat mailed tho rnregaing document via picpaid first class U.S_ rlail to the following: Michael R Pillar JOHNSON, ANSELMQ, MLWOCH, $URIC$, PIPBR & HOCHMAN, P.A. 2455 East Sunrise Boulevard, Suite 1000 Fort Laudordslo, F10rida 33304 Tolophone.: (954) 463.0100 pipet @jambg.com steams@jambg.com Dated: Jabuary 7, 2014 GMI UADISON P.A. 4.01 South,C?upfy Ruai Palm Bpadh 3�4 80 Tblt S6 -7h,�, 999 text) UNITED STATES DISTRICT COURT FORM3E SOUTHERN DISTRICT OF FLORIDA NEST PAW B$ACii DIVLSiON WE NO: 9113 -ar- 91953 -RIA CUM O`EARE rral4Yrlr, vs. TOWN OP GULF SMAM e4 aL Doleaduah. M. t U Jonodam R. O'Bayl% Esgpbe, purswntta Rglo 4(b of the Special Was Omemiugtire Admfssiryr and IRecdco o£Attameys, hereby ceegfiw tbat( ),Iheva studied the Locxl Rulas ditbctTnbd Smtes District Court for the Southern District ofFlpdds, and (2) f aun a membee h good standing of ilia Pemisylvmda Supreme Court lanafhyh C oyie, Big. It. 390. O'Boyle, P.C. 2146 B. Ifundngdan SL PhiladdlpldR, PA 19175 AI; 561- M-1223 Pgx;215 -997 -3641 Pennsylvania BarNoA14500 I HEREBY CERTIFY gtatpn January 10, 2014,1 filed the foregaing domuocnt with Wa Cleric of Corot vlawnweddonal mothod due la the nature of the motion. I Outher certify dmt mailed the (ongoing document via prepaid first claw U.S. man to the Pollawfng Mlchdel JLPiper ChrlsmpbgrI Stearns 1OENSUN, ANSEGMO, MURDOCK EURKE, PEIER& HOGFDYAN, PA. 2455 East Sunrise Boulevard, Saito 1000 FortI=derdole, Florida 33304 Tclepbonv(954) 463 -0100 pipengambecom slenrmaambg.com Obtad: Yen" y, 2014 OMMMAD150N M 401 Souk County Road #3272 Pe¢n Boncb FL334804991 Tot: 561+221.9990 Ra*1.Hera Florida proNo. 0045251 561 -713 -8284 (call & trout) mhatrrm&3mlmv,00m UNTrED STATES DISTRICT COURTFOR THE SOVMRN DIST=CT OF FLORIDA WEST PALM BLACIT DIVISION CASE NO.9as- ev- sios # -nR C 141S O!HARF Plaintiff, VS. TOWN OF GULF ST1EANet al. Defendants; r h F n THIS CAUSE having come before 11: Court on.the Motion to Appear Pro &w Vice for Jonathan R. O'Boyle; Consent to Designation, and Request to Glentrohically Receive Notices of Electronic Filing (die "Motion" ), pursuant to the Special Rules Governing die Admission and Pmctico:ofAttorneys in die United States District Couttfor the Southern District of Florida and Section 2 B ofthe CWECF Administrative Procedures. Tills Court having considered the motion and all otber ibloyant actors, it is hereby ofFlorlda ORDERED OR ADJUDGED that The Motion is GRANTED. Jonalhao R O'Boylo, may appoar and participate In tilts action oa behalf of Chris O' Hare. The Ciork shall providoolectrocin notification of all olectromichlingqto Jonathan R. O'Boyle at jonadianroboyle@gmall,com. DONB AND ORDERED In Chambers, West Palm Beach, Palm Beach County, Soulh'ern District ofForida,anJamtery 2014. Copies furnished to: All Counsol of Record KiNNETH L. RYSILpMI' United States Dlstrlot Judge Find Lawyer, Attorney, Law Firms, Attorneys, Legal Information. LegalDirectories.com Page 1 of 1 http : / /Www.legaldirectories.com/ Search•e spx? SearchOpt= B&SearchFor- 0 &BioLr O &State... 4/21 /2014 x d I aYerr,., .d dal nd. aryr x. m- .mamnrrM rloarLr r • nV. Al Said 4'U,i .1 1d0011PiA6ed.t16 Low Wedaba Puba6lYng Calgarry. i c„ Ian bealPldysM1mg alga kqN 6mgonva s,ra IMS ontl lus m b b Amiukae. Lie PuUalav U Stale Oirdous N'a' BaA I+ryu Arc.Y•nuaYY rdr.r, :d.,w ar Find a Lawyer Search.Re5Uft5 By Location Areas as Practice Slabol Uceaaa: FL Experts & Services Maul Code: am" Products Counly1706h: Palm BeaClt co my Ahomeyls.t Noma: Movie OnNno Stare AhomaY FlretNOmu Jonathan Bar Llnles Reahsaodedby: Attomiya Lau Nam. About Us No rueluf mu. Plan try. dlffennt.umh Cdrvh. Contest Us Glsclnlmer alum to Sadmh Privacy Policy Advance Search 0aWe.+GeareAHyaw Fv.Iel ^M I- Ytr,urlEµ vlC. n' oIMnWar '•.dllYlnbrJ£dubogHwr•IL ^1•mr .•xxTFl6 xma t!rOY ;`n sinyityL1P?^JI�Y.1L• "GIr ISCH!t.I9R'r. AIIY,Jfib mmrved V/j; czs Weof ltu J.•ele Udde. mm web a0e arrtl Ne Ntamatlon root eimdM1amTl. 6ableq to Ne rubletom rob YMletlonednoihetlbQ4atJJ !l49and e:,ncl pn:g, Bya�ving or nalaNnn Nbrrrle6on hen LepelCimxanumm, We WnadnoMeddaa and aeraea b.be bouts Ly Cr h rrrb!1',{{;n attl �a+(,Pr_y. Lagarnbegaka PubWag Com(,my 4M -9111 padend RWd, WAS Tava4 7MI11 • (001447ZITS1214) 321.3;7. http : / /Www.legaldirectories.com/ Search•e spx? SearchOpt= B&SearchFor- 0 &BioLr O &State... 4/21 /2014 ,onathan Reilly O'Boyle - Lawyer in Gulf Stream, Florida (FL).Palm Beach County - lega .. Page 1 of 1 ••• •• •V fly,1mr OWeNrarantlwnl true no unra inlwmwan an Aexpatlrx • Yow rden boa. pba6aal a Baas 6Deaest at 14001174a76 an 110 !.P'r1I 3mr iur•• h<acJ +n4CPyur i.63 ., at.lYwtpds3n+�u.dn.yP daafilm•+ tn.v 15.1M1arn1 M4 {•ah`.n:IW 4vM1'- v.:dt'R \'141bWQl I \1R9 Lr6i1 "h1edCLH. MMiy- rlpVlnY 14Arnfi l:ltWm fJr Find a LaYryet rypipt >arM1x44m /u4 >AA CEM1 at PIarWP> GVI(SIst'. PlorO. U.,n ey Location Jonathan Reilly O'Boyle y Area, of Practice y Updele Wa Pr,ele t Experts S Services Product, J.narlenii-P101loylo Bataayerin Fladda,Gult6tnam Online Store Bar LmRa (Penmyhren/e Baird But$ LJ$tJnpf About De Jonathan Reilly O'Boyle Contact Be 23 N Hidden Harbour Pr Disclaimer Gulf SVealo, rL 33463.7244 Privacy Policy Paint Beach County Advance Search Contact Jonathan Reilly O'BaTla (561) 768 -1223 the np,Jaeaalunerne r;nJ JUoIc.ipY LC11-a I CI. 441A 60r.W I AMI V pnracel ManMM p Cn'rAMm I Hlmn I DadJ.me' iTa.'. L1MaaNL t:6W ht;"C yr �r�g Aypry,:; ;..g_ei:.lre- TI�Stgul f_er Ff�y >, A6 e4lrarca.rvna :Cff UAn of Ila>kAML'r nm m rc•d UI> rawk6ona ofndg,r4, Ir aunM ellC". 114raln dIha orr.1•dy]q! 10 a bland o a #uIbed - 93001V: Podc,DOlkv. By •uYeaay or rr.�:nn�6 •:Ihir.•aLrl lram LepA4Nro:JU¢a ae^L llx� asarddtntrr4eduv! mW tylmea to be bwnd bJ slxb 7rJ0f>i!gp and 'Le' Po6cv L:.)+: D•'r.;•: •!a FUL4Y.eq CrTI Jt Y, U•; -9117 G aI n!d Road; OaBu Tene 7876 - X60.11417 5376 (1111321.3]]. RULE 4.5.5 UNLICENSED PRACTICE OF LAW; MULTIJURISDIC ZONAL PRACTICE OF LAW Page I of 7 The Florida Bar www.floridabar.org RULE 4 -5.5 UNLICENSED PRACTICE OF LAW; MULTIJURISDICTIONAL PRACTICE OF LAW 4 RULES OF PROFESSIONAL CONDUCT 4 -5 LAW FIRMS AND ASSOCIATIONS RULE 4 -5.5 UNLICENSED PRACTICE OF LAW; MULTIJURISDICTIONAL PRACTICE OF LAW (a) Practice of Law. A lawyer shall not practice law in a jurisdiction other than the lawyer's home state, in violation of the regulation of the legal profession in that jurisdiction, or in violation of the regulation of the legal profession in the lawyer's home state or assist another in doing so. (b) Prohibited Conduct. A lawyer who is not admitted to practice in Florida shall not: (1) except as authorized by other law, establish an office or other regular presence in Florida for the practice of law; (2) hold out to the public or otherwise represent that the lawyer is admitted to practice law in Florida; or (3) appear in court, before an administrative agency, or before any other tribunal unless authorized to do so by the court, administrative agency, or tribunal pursuant to the applicable rules of the court, administrative agency, or tribunal. (c) Authorized Temporary Practice by Lawyer Admitted in Another United States Jurisdiction. A lawyer admitted and authorized to practice law in another United States jurisdiction who has been neither disbarred or suspended from practice in any jurisdiction, nor disciplined or held in contempt in Florida by reason of misconduct committed while engaged in the practice of law permitted pursuant to this rule, may provide legal services on a temporary basis in Florida that: (1) are undertaken in association with a lawyer who is admitted to practice in Florida and who actively participates in the matter; or bttp:/ /www.floridabacorp/divcxc/rrtfb.n JVFVI AE4F324F9P246E2085257A2Cg0628278 5/29/2014 RULE 4-5.5 UNLICENSED PRACTICE OF LAW; MULTDUAISDICfIONAL PRACTICE OF LAW Page 2 of 7 (2) are in or reasonably related to a pending or potential proceeding before a tribunal in this or another jurisdiction, if the lawyer is authorized by law or order to appear in such proceeding or reasonably expects to be so authorized; or (3) are in or reasonably related to a pending or potential arbitration, mediation, or other alternative dispute resolution proceeding in this or another jurisdiction, and the services are not services for which the forum requires pro hac vice admission: (A) if the services are performed for a client who resides in or has an office in the lawyer's home state, or (B) where the services arise out of or are reasonably related to the lawyer's practice in a jurisdiction in which the lawyer is admitted to practice; or (4) are not within subdivisions (c)(2) or (c)(3), and (A) are performed for a client who resides in or has an office in the jurisdiction in which the lawyer is authorized to practice, or (B) arise out of or are reasonably related to the lawyer's practice in a jurisdiction in which the lawyer is admitted to practice. (d) Authorized Temporary Practice by Lawyer Admitted in a Non - United States Jurisdiction. A lawyer who is admitted only in a non - United States jurisdiction who is a member in good standing of a recognized legal profession in a foreign jurisdiction whose members are admitted to practice as lawyers or counselors at law or the equivalent and are subject to effective regulation and discipline by a duly constituted professional body or a public authority, and who has been neither disbarred or suspended from practice in any jurisdiction nor disciplined or held in contempt in Florida by reason of misconduct committed while engaged in the practice of law permitted pursuant to this rule does not engage in the unlicensed practice of law in Florida when on a temporary basis the lawyer performs services in Florida that: (1) are undertaken in association with a lawyer who is admitted to practice in Florida and who actively participates in the matter; or (2) are in or reasonably related to a pending or potential proceeding before a tribunal held or to be held in a jurisdiction outside the United States if the lawyer, or a person the lawyer is assisting, is authorized by law or by order of the tribunal to appear in such proceeding or reasonably expects to be so authorized, or http:// www. foridabar. org/ divexe/ nTfb, ncf/ FV/ AE4F324F9F246A2085257A2C00628278 5292014 RULE 4 -5.5 UNLICENSED PRACTICE OF LAW; MULTDURISDICnONAL PRACTICE OF LAW Page 3 of (3) are in or reasonably related to a pending or potential arbitration, mediation, or other alternative dispute resolution proceeding held or to be held in Florida or another jurisdiction and the services are not services for which the forum requires pro hac vice admission (A) if the services are performed for a client who resides in or has an office in the jurisdiction in which the lawyer is admitted to practice, or (B) where the services arise out of or are reasonably related to the lawyer's practice in a jurisdiction in which the lawyer is admitted to practice; or (4) are not within subdivisions (d)(2) or (d)(3), and (A) are performed for a client who resides or has an office in a jurisdiction in which the lawyer is authorized to practice to the extent of that authorization, or (B) arise out of or are reasonably related to a matter that has a substantial connection to a jurisdiction in which the lawyer is authorized to practice to the extent of that authorization; or (5) are governed primarily by international law or the law of a non - United States jurisdiction in which the lawyer is a member. Comment Subdivision (a) applies to unlicensed practice of law by a lawyer, whether through the lawyer's direct action or by the lawyer assisting another person. A lawyer may practice law only in a jurisdiction in which the lawyer is authorized to practice. A lawyer may be admitted to practice law in a jurisdiction on a regular basis or may be authorized by court rule or order or by law to practice for a limited purpose or on a restricted basis. Regardless of whether the lawyer is admitted to practice law on a regular basis or is practicing as the result of an authorization granted by court rule or order or by the law, the lawyer must comply with the standards of ethical and professional conduct set forth in these Rules Regulating the Florida Bar. The definition of the practice of law is established by law and varies from one jurisdiction to another. Whatever the definition, limiting the practice of law to members of the bar protects the public against rendition of legal services by unqualified persons. This rule does not prohibit a lawyer from employing the services of paraprofessionals and delegating functions to them, so long as the lawyer supervises the delegated work and retains responsibility for their work See http: / /www.floridabu.org/divc e/ rrt lb. nsgFV/A E4F324F9F246B2085257A2C00628278 5/292014 RULE 4-5.5 UNLICENSED PRACTICE OF LAW, MULTIURISDICnONAL PRACTICE OF LAW Page 4 of 7 rule 4 -5.3. Likewise, it does not prohibit lawyers from providing professional advice and instruction to nonlawyers whose employment requires knowledge of law; for example, claims adjusters, employees of financial or commercial institutions, social workers, accountants, and persons employed in government agencies. In addition, a lawyer may counsel nonlawyers who wish to proceed pro se. Other than as authorized by law, a lawyer who is not admitted to practice in Florida violates subdivision (b) if the lawyer establishes an office or other regular presence in Florida for the practice of law. Presence may be regular even if the lawyer is not physically present here. Such a lawyer must not hold out to the public or otherwise represent that the lawyer is admitted to practice law in Florida Subdivision (b) also prohibits a lawyer who is not admitted to practice in Florida from appearing in a Florida court, before an administrative agency, or before any other tribunal in Florida unless the lawyer has been granted permission to do so. In order to be granted the permission, the lawyer must follow the applicable rules of the court, agency, or tribunal including, without limitation, the Florida Rules of Judicial Administration governing appearance by foreign attorneys. There are occasions in which a lawyer admitted and authorized to practice in another United States jurisdiction or in a non - United States jurisdiction may provide legal services on a temporary basis in Florida under circumstances that do not create an unreasonable risk to the interests of his or her clients, the public, or the courts. Subdivisions (c) and (d) identify such circumstances. This rule does not authorize a lawyer to establish an office or other regular presence in Florida without being admitted to practice generally here. Furthermore, no lawyer is authorized to provide legal services pursuant to this rule if the lawyer is disbarred or suspended from practice in any jurisdiction or has been disciplined or held in contempt in Florida by reason of misconduct committed while engaged in the practice of law permitted pursuant to this rule. The contempt must be final and not reversed or abated. There is no single test to determine whether a lawyer's services are provided on a "temporary basis" in Florida and may therefore be permissible under subdivision (c). Services may be "temporary" even though the lawyer provides services in Florida on a recurring basis or for an extended period of time, as when the lawyer is representing a client in a single lengthy negotiation or litigation. Subdivision (c) applies to lawyers who are admitted to practice law in any United States jurisdiction, which includes the District of Columbia and any state, territory, or commonwealth of the United States. The word "admitted" in subdivision (c) contemplates that the lawyer is bapJ/ www. floridabarorgUvexdrrtfb. mVFwAE4F324F9F246B2085257A2C00628278 529/2014 RULE 45.5 UNLICENSED PRACTICE OF LAW; MULTUURISDICITONAL PRACTICE OF LAW Page 5 of 7 authorized to practice in the jurisdiction in which the lawyer is admitted and excludes a lawyer who while technically admitted is not authorized to practice because, for example, the lawyer is on inactive status. Subdivision (d) applies to lawyers who are admitted to practice law in a non - United States jurisdiction if the lawyer is a member in good standing of a recognized legal profession in a foreign jurisdiction, the members of which are admitted to practice as lawyers or counselors at law or the equivalent and subject to effective regulation and discipline by a duly constituted professional body or a public authority. Due to the similarities between the subsections, they will be discussed together. Differences will be noted. Subdivisions (c)(1)and (d)(1) recognize that the interests of clients and the public are protected if a lawyer admitted only in another jurisdiction associates with a lawyer licensed to practice in Florida. For these subdivisions to apply, the lawyer admitted to practice in Florida could not serve merely as a conduit for the out -of -state lawyer, but would have to share actual responsibility for the representation and actively participate in the representation. To the extent that a court rule or other law of Florida requires a lawyer who is not admitted to practice in Florida to obtain admission pro hac vice prior to appearing in court or before a tribunal or to obtain admission pursuant to applicable rule(s) prior to appearing before an administrative agency, this rule requires the lawyer to obtain that authority. Lawyers not admitted to practice generally in Florida may be authorized by law or order of a tribunal or an administrative agency to appear before the tribunal or agency. This authority may be granted pursuant to formal rules governing admission pro hac vice or pursuant to formal rules of the agency. Under subdivision (c)(2), a lawyer does not violate this rule when the lawyer appears before a tribunal or agency pursuant to such authority. As with subdivisions (c)(1) and (d)(1), to the extent that a court rule or other law of Florida requires a lawyer who is not admitted to practice in Florida to obtain admission pro hac vice prior to appearing in court or before a tribunal or to obtain admission pursuant to applicable rule(s) prior to appearing before an administrative agency, this rule requires the lawyer to obtain that authority. Subdivision (c)(2) also provides that a lawyer rendering services in Florida on a temporary basis does not violate this role when the lawyer engages in conduct in anticipation of a proceeding or hearing in a jurisdiction in which the lawyer is authorized to practice law or in which the lawyer reasonably expects to be admitted pro hac vice. Examples of such conduct include meetings with the client, interviews of potential witnesses, and the review of documents. Similarly, a lawyer admitted only in another jurisdiction may engage in conduct temporarily in Florida in connection with pending litigation in another jurisdiction in which the lawyer is or reasonably expects to be authorized to appear, including taking depositions in Florida. bttp: / /www.floridabe. orb/ divexe/ rrtfb. mf7FV/ AE4F324F9F246B2085257A2CO0629278 5292014 RULE 4-5.5 UNLICENSED PRACTICE OF LAW; MULTUURISDICnONAL PRACTICE OF LAW Page 6 of 7 Subdivision (d)(2) is similar to subdivision (c)(2), however, the authorization in (d)(2) only applies to pending or potential proceedings before a tribunal to be held outside of the United States. Subdivisions (c)(3) and (d)(3) permit a lawyer admitted to practice law in another jurisdiction to perform services on a temporary basis in Florida if those services are in or reasonably related to a pending or potential arbitration, mediation, or other alternative dispute resolution proceeding in this or another jurisdiction, if the services are performed for a client who resides in or has an office in the lawyer's home state, or if the services arise out of or are reasonably related to the lawyer's practice in a jurisdiction in which the lawyer is admitted to practice. The lawyer, however, must obtain admission pro hac vice in the case of a court- annexed arbitration or mediation if court rules or law so require. The lawyer must file a verified statement with The Florida Bar in arbitration proceedings as required by rule 1 -3.11 unless the lawyer is appearing in an international arbitration as defined in the comment to that rule. A verified statement is not required if the lawyer first obtained the court's permission to appear pro hac vice and the court has retained jurisdiction over the matter. For the purposes of this rule, a lawyer who is not admitted to practice law in Florida who files more than 3 demands for arbitration or responses to arbitration in separate arbitration proceedings in a 365 -day period shall be presumed to be providing legal services on a regular, not temporary, basis; however, this presumption shall not apply to a lawyer appearing in international arbitrations as defined in the comment to rule 1 -3.11. Subdivision (c)(4) permits a lawyer admitted in another jurisdiction to provide certain legal services on a temporary basis in Florida that are performed for a client who resides or has an office in the jurisdiction in which the lawyer is authorized to practice or arise out of or are reasonably related to the lawyer's practice in a jurisdiction in which the lawyer is admitted but are not within subdivisions (c)(2) or (6)(3). These services include both legal services and services that nonlawyers may perform but that are considered the practice of law when performed by lawyers. When performing services which may be performed by nonlawyers, the lawyer remains subject to the Rules of Professional Conduct. Subdivisions (c)(3), (d)(3), and (c)(4) require that the services arise out of or be reasonably related to the lawyer's practice in a jurisdiction in which the lawyer is admitted. A variety of factors evidence such a relationship. The lawyer's client may have been previously represented by the lawyer, or may be resident in or have substantial contacts with the jurisdiction in which the lawyer is admitted. The matter, although involving other jurisdictions, may have a significant connection with that jurisdiction. In other cases, significant aspects of the lawyer's work might be conducted in that jurisdiction or a significant aspect of the matter may involve the law of that hllp://wv v .11uridabu.org/divcxe/rrtfb.nsL V/ AE4F324F9F246B2085257A2CO0628278 5292014 RULE 4-5.5 UNLICENSED PRACTICE OF LAW: MULTTJURISDICnONAL PRACTICE OF LAW Page 7 of 7 jurisdiction. The necessary relationship might arise when the client's activities or the legal issues involve multiple jurisdictions, such as when the officers of a multinational corporation survey potential business sites and seek the services of their lawyer in assessing the relative merits of each. In addition, the services may draw on the lawyer's recognized expertise developed through regular practice of law in a body of law that is applicable to the client's particular matter. Subdivision (d)(4) permits a lawyer admitted in a non - United States jurisdiction to provide certain services on a temporary basis in Florida that are performed for a client who resides in or has an office in the jurisdiction where the lawyer is authorized to practice or arise out of or are reasonably related to a matter that has a substantial connection to a jurisdiction in which the lawyer is authorized to practice to the extent of that authorization but are not within subdivisions (d)(2) and (d)(3). The scope of the work the lawyer could perform under this provision would be limited to the services the lawyer may perform in the authorizing jurisdiction. For example, if a German lawyer came to the United States to negotiate on behalf of a client in Germany, the lawyer would be authorized to provide only those services that the lawyer is authorized to provide for that client in Germany. Subdivision (d)(5) permits a lawyer admitted in a non - United States jurisdiction to provide services in Florida that are governed primarily by international law or the law of a non - United States jurisdiction in which the lawyer is a member. A lawyer who practices law in Florida pursuant to subdivisions (c), (d), or otherwise is subject to the disciplinary authority of Florida. A lawyer who practices law in Florida pursuant to subdivision (c) must inform the client that the lawyer is not licensed to practice law in Florida. The Supreme Court of Florida has determined that it constitutes the unlicensed practice of law for a lawyer admitted to practice law in a jurisdiction other than Florida to advertise to provide legal services in Florida which the lawyer is not authorized to provide. The rule was adopted in 820 So. 2d 210 (Fla. 2002). The court first stated the proposition in 762 So. 2d 392, 394 (Fla 1999). Subdivisions (c) and (d) do not authorize advertising legal services to prospective clients in Florida by lawyers who are admitted to practice in jurisdictions other than Florida. Whether and how lawyers may communicate the availability of their services to prospective clients in Florida is governed by rules 4 -7.1 through 4 -7.10. A lawyer who practices law in Florida is subject to the disciplinary authority of Florida fRevBed: 07101/20121 0 2014 The Florida Bar I Disclaimer I Top of page I Get Adobe Acrobat http:// www. floridabu. org/ divexch rttb. nsUF V/ AE4F324F9F246B2085257A2CO0628279 512912014 Philadelphia City Wage Taxes Overview The City Wage Tax is a tax on salaries, wages, commissions and other compensation paid to an employee who Is employed by or renders services to an employer. Generally, Individuals whowork for a company In Pennsylvania will find that the company deducts the Wage Tax from their pay since this Is required by law. All Philadelphia residents owe the City Wage Tax regardless of where they work. Non - residents who work In Phlladelphla must also pay the Wage Tax. Who Must File All employers located In Pennsylvania are required to register with the City of Philadelphia within 30 days of becoming an employer of a resident of Philadelphia or of a non - resident of Philadelphia doing business In Phlladelphla. Employers are required to withhold and remit the Wage Tax at the prescribed rate from all residents of Philadelphia or non - residents doing business in Philadelphia in its employ. Employers and payroll service companies must also remit W -2s to Philadelphia, W -2 submission Instructions are in the Common Forms box to the right. If you are a resident of Philadelphia or a non - resident who works In Philadelphia, and your employer is not required to withhold the tax, you must register for an Earnings Tax Account. You can register for an Earnings account on our website using your Social security Number. PROFESSIONAL ETHICS OF TILE FLORIDA BAR OPINION 74 -48 December 26, 1974 It is permissible for an interstate partnership with an office in Florida to use its firm name in this state even though none of the lawyers listed in the firm name are admitted in Florida, but the letterhead should indicate which members of the firm are admitted in Florida. [Note: See, The Florida Bar v. Savitt, 363 So.2d 559 (Fla. 1978), which discusses the requirements of a bona fide interstate partnership.] CPR: DR 2- 102(D) Opinion: 65 -15 Vice Chairman Daniels stated the opinion of the committee: A member of The Florida Bar contemplates formation of an interstate partnership with aNew York law firm and requests guidance regarding operations of the Interstate partnership in Florida. The formation of interstate partnerships is sanctioned by DR 2- 102(D); which provides: A partnership shall not be formed or continued between or among lawyers licensed in different jurisdictions unless all enumerations of the members and associates of the firm on its letterhead and in other permissible listings make clear the jurisdictional limitations on those members and associates of the firm not licensed to practice in all listed jurisdictions; however, the same firm name may be used In each jurisdletlon. In view of the underscored language above, the New York firm name may be used in Florida although none of the lawyers in such firm name are admitted in Florida. Former opinions to the contrary; such as 65 -15 [since withdrawn], have been overruled by the subsequent amendment to the Code of Professional Responsibility underscored above. However, the Committee reaffirms the following language from former Opinion 65 -15: ... it is not improper for a Florida lawyer to be a member of an interstate law firm which: maintains offices both in Florida and elsewhere.. The; partnership, however, must be a full, bona fide partrershi i. n which the profits and losses, of the several offices are actually shared according to the terms of the partnership agreement. It is improper to engage in such an arrangement if its true effect is merely to create an association whereby legal matters are referred from one office to another and fees are shared only with reference to the particular matters so referred. x ** ... all attorneys who are members or associates of such firm must be "amenable to professional discipline" at the place where the partner or associate is actually engaged in practice and the partner or associate must be a member ofthe bar authorized to practice law at that place; and that the public arid other lawyers must not in any way be misinformed or misled concerning the authority of any member of an interstate firm tq practice in a particular jurisdiction. In the latter connection, if the name of a lawyer is listed on the letterhead of a Florida firm when that lawyer Is not admitted to practice in Florida, then an affirmative statement must appear on the letterhead indicating that the lawyer is not authorized to practice in this state. Further, it is not proper to list the name of any attorney in a telephone directory, published and used in Florida, unless the attorney is admitted to practice in this state. Under the contemplated interstate partnership, the partnership letterhead used in Florida will use the New York firm name at the top. On the left margin the letterhead will have a heading "Partners' Admitted in Florida" and will thereafter list onlythe'parmers admitted in Florida. The Committee deems this an appropriate method to avoid misleading the public as it will indicate to the public that the lawyers in the firm name are not admitted'in Florida. However, care should be exercised in the conduct of the firm's Florida prattice to avoid any false impression that other partners are Florida lawyers. 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 #1240 (752) 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. 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: http://WWW2.gulf- stream.org/WebLinkg/O/doc/17461/Pagel.asvx. 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