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Home My Public Portal AboutPRR 14-1269RECEIVED 08/08/2014 14:19 5613946102 SBV 1 2 6 9 0810812014 14:40 Commerce Grog ffA1f)6543600807 P.0021005 RECORDS REQUEST (the "Request ") Date of Request: 8/8/2014 Requestor's Request ID#: 108 REQUESTEE: Custodian of Records - Sweetapple, Brooker, Varkas, P.L. REQUESTOR: StoliDirtyGOVernment, LLC REQUESTOR'S CONTACT INFORMATrON; E- Mail: records@commerce- group.eom Fax: 954- 360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beacb, FL 33442 REQUEST: Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the en a e me e n num re su paragrep . ex u no su para0rap a , ., 4b., 4c, 4d., 4e. , 4f. 4g., 41. 4., 4k. 41. and 4m. of the Defendants Motion For Sanctions Against Plalntitf, Martin E. O'Boyle, Counsel of Record, The O'Boyle Lew Finn, P.C., Jonathan 0' [sic) And William Ring, quire, which was filed ey Attomey wsmepple. A copy of su paragraph -4h, of the reforanized Motion ADDITIONAL INFORMATION REGARDING REQUEST: THIS REQUEST IS MADE PURSUANT TO PUBLIC RECORDS ACT, CHAPTER 119 OF THE FLORIDA STATUTES AND IS ALSO REQUESTED UNDER THE COMMON LAW RIGHT TO KNOW, THE COMMON LAW RIGHT OF ACCESS; AND ANY STATUTORY RIGHT TO KNOW (INCLUDING, WITHOUT LIMITATION, ANY STATUTORY RIGHT OF ACCESS, AS APPLICABLE). THIS REQUEST IS ALSO MADE PURSUANT TO THE RIGHTS OF THE REQUESTOR PROVIDED IN THE FLORIDA CONSTITUTION. IT IS RE VESTED THAT THIS RECORD RE VEST BE FULFILLED IN ELECTRONIC FORM IF NOT AVAILABLE IN ELECTRONIC FORM, rc rc REOUES D THAT THIS RECORDS REOIJEST BE FULFILLED ON 11 X 17 PAPER NOTE IN Ai i CASES (UNLESS INI OSSI LE ) THE FtOPIES SHOULD BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119,07(4) (a 2 ALL ELEGTROrVIC COPIES ARE BE OIMSTED TO BE c YE- MAtt DE I VERY PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC RECORDS REQUEST IN ADVANCE. It Will be required that the Requestor approve of any costs, asserted by the Agency (as defined In Florida Statute, Chapter 119.01 (Deflnitlons)), in advance of any casts Imposed to the Requestor by the Agency. ITWRMRR 04.22,13 FORM RECEIVED 08/08/2814 14:19 5613946182 0810812014 14:40 Commerce Group Filing # 15549445 Electronically Fled 07/032014 01:14:36 PM MARTIN B. O'BOYLE, Plaintiff; V. TOWN OF GULF STREAM, Defendant. SBV P*5436=7 P.0031005 IN THE CIRCUIT COURT OF THE 15TIt JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502014CA004474XXKXMB DIVISION: AG Defendant, Town OE Gulf Stream, moves this Court for the impoaition of sanctions against Plaintiff, Martin E. O'Boyle, Counsel of Record, the O'Boyle Law Firm, P.C., Inc, its President, Jonathan O'Boyle, and William Ring, Esquire, for unprofessional, unethical and abusive litigation tactics, and as grounds therefore would show the Court that: 1. On May 30, 2014, Defendant, through its tourist!, Swaetapple, Broeker & Varkas, P.L., and Jones, Foster, Johnson & Stubbs, P.A., filed Defendant's Motion to Disqualify the O'Boyle Law Firm, P.C., Inc., or in the Alternative, for an Evidentiary Hearing (hercinafter the "Motion'). 2. This Motion has been withdrawn without prejudice as Defendant is seeking other remedies with regard to the matters addressed in the Motion. 3. Significantly, the O'Boyle Law Firm, P.C, Inc., registered as a Florida foreign profit corporation on February 10, 2014, claiming its principal office as 2146 B, Huntingdon Street, Philadelphia, Pennsylvania. 4. Upon information and belief, at the time of registering the O'Boyle Law Firm, P.C., Inc. (liminaf er the "O'Boyle Law Firm'), as a Florida foreign profit corporation, the O'Boyle Law Firm LAW Orrrws or SP'a6rAM BR== VAaxAS, P.L. 208.E.3'6reaar,80CARAT09 FwwDA33432.3911 RECEIVED 08/0B/2014 14:19 5613945102 g8V 08108/2014 14:40 Commerce Group ffA*5436 M P.0041005 Mmdn 8.O'Boyle v. Town of oulrstrum appears to have had no real business presence in Philadelphia, pennsyivenia. Ahhough it was regiatered as a Pennsylvania Corporation on November 14, 2013, it furtber appears that; IL The O'Boyle Law Firm did not own or lease any commercial space there. b. The O'Boyle Law Firm did not have a business telephone line. c. The O'Boyle Law Firm had no employees and paid ao salaries, d. The O'Boyle Law Firm did not pay city, state or federal taxes because it bad no employees, e. The O'Boyle Law Finn did not obtain an occupational license to conduct business in the City of Philadephia. f The O'Boyle Law Firm's Bole principal, officer and director, Jonathan O'Boyle, used his Florida cell phone number ( 561 - 758- I223), as the firm telephone number. g. Jonathan O' Boylelsa member of the Pennsylvania Bar, but riot of the Florida Bat. h. Jonathan O'BoyIe advised the Pennsylvania gar that he is an out -of -state attorney with an address in Florida i. Jonathan O'Boyle advised the Pennsylvania Bar that his address is in the down of Gulf Stream, Florida at 23 N. Bidden harbour Drive, his parent's home address, I. At the time of the opening of the O'Boyle law Finns in Florida, Jonathan O'Boyle resided and was domiciled in Florida. k. when the O'Boyle Law Firm opened in Florida, it was operated out of his father, Malin O'Boyle's, office at west Newport Center Drive, Deerfield Beach, Florida. It is still operated Out of this building, which Is owned or controlled by Martin O'Boyle, 2 LAw thncator5weanun.a.Baoeas t & VAaxAS, P,L, 206.5.3 $To=, BOCARA17a, FLOSwA33432d81I RECEIVED 08/08/2014 14:19 5613946102 SBV 0810812014 14:40 Commerce Group ITAX)9543600807 P.0051005 matin E. O'Boyle v. Town of Gulfancem CASE NO.502014CA004474XXXXMBAO (PA1.a41 BEACH COUNTY) 1. Since opening the O'Boyle Law Firm, Jonathan O'Boyle has had a constant presence in the State of Florida handling legal matters for his father and his father's businesses, including at least four (4) pro hac vice appearances. m. Jonathan O'Boyle has misrepresented his residence as part of his Slings with the Court and/or the Bar. 5. Immediately after Defendant filed "the Motion ", Plaintiff; Martin O'Boyle (hereinafter "O'Boyle ") and his counsel, William Ring, requested a meeting with Joanne M. O'Connor, John C. Randolph and Sidney Stubbs of the Jones Foster law firm. 6. On June 4, 2014, O'Boyle, William Ring, Joanne O'Connor, and John Randolph met in the Offices of Jones Foster, Mr. Stubbs was not in attendance. 7. O'Boyle indicated the meeting should be confidential in nature as it was called for thepurpose of arriving at a settlement However, Plaintiff then proceeded to issue implicit threats, stating that as a result of the Motion, which was directed at O'Boyle's son's law firm, O'Boyle intended to take steps against opposing counsel and their children. O'Boyle also made an implicit threat of physical violence stating, "You know I've never been a violent person. These hands have never touched anyone." O'Boyle inquired regarding opposing counsel, Joanne O'Connor's, marital status and threatened to hire investigators to 'watch counsel's daughter to see if she slips up." 8. O'Boyle further stated that he was going to open sober houses throughout the Town of Gulf Stream. 9. These statements were made for the purpose of intimidating counsel, including undersigned counsel. The above conduct has caused undersigned counsel's co- counsel to become witnesses with regard to these events and this motion. 3 LAW Omcm oPsw=ACry9, BROeasx & VAffA . P.L. 203.n.3"StarEr, BOCA RATON, FLORIDA 33432.3911 PA Attorney Information I Pennsylvania Disciplinary Board Page I of 1 The Disciplinary Board of the Supreme Court of Pennsylvania PA Attorney Information Jonathan Reilly O'Boyle PA Attorney ID: 314500 Current Status: Active Date of Admission: 11/13/2012 Lavfirm: Other Organization: District: 0 County: u f State Public Access Address: 23 N HIDDEN HARBOUR DR GULFSTREAM, FL 33483 Tel: 561 758 -1223 Fax: Professional Liability Insurance: I do not maintain Professional Liability Insurance pursuant to the provisions of Rule of Professional Conduct 1 A(C), but I do have private clients end /or a possible exposure to malpractice actions. Comment: Discipline 02007 -2014 The MdpOmry 8.m of ew 6upmme Cart d Pe.ny N . I IYmar Fa qu tiorw w me rW"M the webeib, plmm wN w M web.eutwwrgpB ur .ua. EXHIBIT il�)1 http:// www. padisciplinaryboard .orgAook- up /pa- attorney- info.php?id= 314500 &pdcount =0 4/4/2014 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail September 11, 2014 Stopdirtygovernment, LLC [mail to: recordsgcommerce- group.com] Re: GS #1269 (108) 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., 4/c, 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 4h, of the referenced Motion is attached. Dear Stopdirtygovemment, LLC [mail to: records @commerce - group.com], This letter provides you with the full production of public records you have requested in your fax dated August 8, 2014 that can be viewed at the following link: htti)://www2.eulf- stream .org /WebLink8 /0 /doc /20062/Pagel .asox. Be advised that the responsive records are available at the same link. We consider this matter closed. Sincerely, Town Clerk Custodian of the Records