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Home My Public Portal AboutPRR 14-1271RECEIVED 08/08/2014 14:19 5613946102 SBV 08/0812014 14:41 Commerce Group ffOVA3800807 RECORDS REQUEST (the " Requesf� Date of Request: 8/812014 Requestor's Request IDN: 100 REQUESTEE: Custodian of Records - Sweetapple, Brooker, Varkes, P.L. REQUESTOR: STOPDIRTYGOVERNMENT, LLC REQUESTOR'S CONTACT INFORMATION: E- Mail: mcords@commerce- group.com Fax: 954.360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the .) 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'[slc] And William Ring, Esquire, which was filed by Attorney tiweete pp e, copy o paragrap o e r erenca Inch IS o e. 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 R]GHT 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 REQUESTED THAT THIS RECORD R QUEST BE FU FH.L r) IN ELECTRONIC FORM. IF NOT AVAILABLE IN ELECTRONIC FORM IT IS REOUESTED THAT THIS RECORDS REQUEST BE FULFILLED ON 11 X 17 PAPER -NoTEi IN ALL CASES (UNLESS IMPOSSIBLE) THE COPIES SHOULD D BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119.07(4) (a) (2), ALL ELECTRONIC COPIES ARE RE OU .TED TO BE SENT BY .MAIL DEL Y 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 dented In Florida Statute, Chapter 119.01 (Definitions)), in advance of any costa imposed to the Requester by the Agency. I:PNPPJFRR 04.2213 FORM 1271 P.0021005 RECEIVED 08/08/2014 14:19 5613946102 08/0812014 14:41 Commerce Group Filing # 15549445 Electronically Filed 07/034014 01:14:36 FM MARTIN B. O'BOYLE, Plaintiff, v. TOWN OF GULF STREAM, Defendant. SBV ffAXAU30807 P.0031005 IN THE CIRCUIT COURT OF THE I5TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502014CA0044747pt70iMB DIVISION: AG Defendant, Town Of Gulf Stream, moves this Court for the imposition 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 counsel, Sweetapple, Broeker & Varkas, P.L., and Jones, Foster, Johnson & Stubbs, P.A., filed Defondent's Motion to Disqualify the O'Boyle Law Firm, P.C., Inc., Orin the Altemative, for an Evidentiary Hearing (hereinafter the "Motion"). 2. This Motion has been withdrawn without prejudice as Defendant is seeking other remedies with regard to the matters addresscd 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, (hereinafter the "O'Boyle Law Finn', as a Florida foreign profit corporation, the O'Boyle Law Firm LAW OFF=w &WssrApt4.& BaOUsa & VARKAk Py, 20 S.& 30Srneer,BocARATON. Pmwen33432.3911 RECEIVED 08/08/2014 14:19 5613946102 SBV 08108!2014 14:41 Commerce Group M)03600807 P.004 1005 Martin B. O'Boyle V. Town of Gulanam CABS NO. 502014CAOM74XKXX fBAG (PALM BBACH COUNTY) appears to have had no real business presence in Philadelphia, Pennsylvania. Although it was registered as a Pennsylvania Corporation on November 14, 2013, it further appears that a. The O'Boyle Law Firm did not own or lease any commercial space them, b. The O'Boyle Law Firm did not have a business telephone line. c. The O'Boyle Law Firm had no employees and paid no salaries. d. The O'Boyle Law Firm did not pay city, state or federal texas because it had no employees. C. The O'Boyle Law Firm did not obtain an occupational license to conduct business in the City of Philadephia. £ The O'Boyle Law Firm's sole principal, officer and director, Jonathan O'Boyle, used his Florida cell phone number (561- 758 - 1223), as the firm telephone number. g. Jonathan O'Boyle is a manber of the Pennsylvania Bar, but not ofthe Florida Bar. b. Jonathan O'Boyle advised the Pennsylvania Bar that be is an out -of -state attorney with an address in Florida. L Jonathan O'Boyle advised the Pennsylvania Bar that his address is in the Town of Gulf Stream, Florida at 23 N. Hidden Barbour Drive, big parent's home address. j. At the time of the opening of the O'Boyle Law Finn 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, Martin O'Boyle's, office at westNewport Center Drive, Deerfield Beech, Florida. It is still operated out of this building, which is owned or controlled by Martin O'Boyle, 2 LAW 0Mcar onSWMOna, Baorxmt@ VAUM. P.L. 208.8.3" smrar, BOCARA70K FLOawA33432.3911 P.ECEiVED OB/08/2014 14:19 5613946102 SBV 0810812014 14:41 Commerce Group 0X)9543600807 P.0051005 Martin E. O'Boyle V. Town of Oulf6traam CASE NO.502014CA0o4474XXXXMBAG (PALM 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 filings 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 ofJOnes Foster, Mr. Stubbs was not in attendance. 7. O'Boyle indicated the meeting should be confidential in nature as it was called for the purpose of arriving at a settlement, However, Plaintiff then proceeded to issue implicit threats, Mating 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 trade 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 OMCES On S0.EerArrra, BaOBKEa,& VARU%P,L. 203.8.3° sm=, BOCA RATON, FWMA33432.39II TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail November 4, 2014 Stopdirtygovernment, LLC [mail to: records @commerce- group.com] Re: GS #1271 (100) Provide all Public Records pursant to which Attorney Sweetapple relied upon to make the statement that he made in n umbered 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' [sicj And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy ofparagraph 4 of the referenced Motion is attached. Dear Stopdirtygovemment, LLC [mail to: recordsQcommerce- group.coml, This letter provides you with the full production of public records you have requested on August 8, 2014. Your original request can be viewed at the following link htlp://www2.gulf- stream.org/W ebLink8 /0 /doc /20064/Page l .aspx. There were similar requests that we have already responded to that the documents would be responsive to this request that can be found at the following links: http://www2.2ulf- stream.org/WebLink8 /0 /doc /19985/Pagel.aspxx, http://www2.gulf- stream.org/WebLink8 /0 /doc / 17387 /Pagel.aspx _http://www2.gulf- stream.org/WebLink8 /0 /doc /17383/Pagel.asyx, hLy://www2.gulf- stream. org/ WebLink8 /0 /doc/17377/Pagel.asnx, h!W://www2.gulf- stream.org/WebLink8 /0 /doc /17372/Pagel.asyx, httv://www2.gulf- stream.orgfWebLink8 /0 /doc /17379/Pagel.asyx, h!W://www2.gulf- stream.org/WebLink8 /0 /doc /17329/Pagel.aspxx, http://www2.gulf- stream.org/WebLink8 /0 /doc /17385/Pagel.aspx, htti)://www2.gulf- stream.org/WebLink8 /0 /doc /17333/Pa eg 1_aspx, and hgp: / /www2.gulf- stream.org/WebLinkS /0 /doc /17332/Pagel . aspx. We consider this matter closed. Sincerely, Town Clerk Custodian of the Records