HomeMy Public PortalAboutPRR 14-12721272
RECEIVED 08/08/2014 13:06 5513946102 SBV
0810812014 13:27 Commerce Group TAX)9543600807
RECORDS REQUEST (the "Request ")
Date of Request; 8/8/2014
Requestor's Request ID#: 131
REQUESTEE: Custodian of Records - Sweetapple, Brooker, Varkas, P.L.
REQUESTOR: CG Acquisition Company Inc.
REQUESTOR'S CONTACT INFORMATION: E -Mail: record9Qeommerce- group.com
Fax: 954- 360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442
REQUEST:
With regard to paragraph 18 of the Defendant's Motion For Sanctions Against
Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law FirtTr, P.C.,
which confirm the statement bV Attorney Rweetapple in the third sentence of
that paragraph.
ADDITIONAL INFORMA71ONREGARDING 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 RECI 1ECTED THAT THIS RECORDS REQUEST BE FULFILLED IN ELECTRONIC
FORM. IF NOT A VAILABLE IN ELECTRONIC FORM IT IS REOUESTED TART THIS
RECORDS REO itrcT nF. Frn Ftt * ED ON 11 X 17 PAPER NOTE IN ALL C E 1 (UNLESS
IMPOSSIBLE) THE COMM SHOULD BE TWO SIDED AND SHOULD BE BILLED IN
ACCORDANCE WITH Section 119.07(4) (a) (2)
ALL ELECTRONIC GOP ARF REOUESTED TO BE SENT BY E-MAH, DEI IV Rv
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 coats, asserted by the Agency (as defined in
Florida Statute, Chapter 119.01 (Definitions)), In advance of any costa imposed to the Requestor by
the Agency.
I:PMPa/FRR
04.22.13 FORM
P.002/003
RECEIVED 08/08/2014 13:06 5613946102 SBV
0910812014 13:27 Commerce Group 0:AX)9543600807 P.0031003
btutln E. O'Boyle v. Town of Guli9veam
undertaken to pressure and intimidate defense counsel into not pursuing the issue of whether the
O'Boyle Law Firm is a bons fide Interstate Law Finn.
15. The issue of whether the O'Boyle Law Firm is a bona fide Interstate Law Firm is one that
should be resolved according to law. It should not be the subject of harassment, intimidation and air
raids by opposing counsel and their client.
16. The misconduct is unprofessional, unethical and it constitutes an egregious example of
litigation abuse. These tactics go beyond zealous representation and are designed to interfere with
defense counsels' ethical obligation to their client Such conduct undermines society's commitment
to the resolution of disputes in courts of law, rather than in the streets or in the sky.
17. %ile citizens enjoy the constitutional right of free speech, that protection is afforded to
ttufl firl speech, and while attorneys must zealously represent their client's interests, they are also
Officers of the court, and are prohibited from disparaging witnesses and attorneys, or otherwise
undermining the administration'af justice.
18. It is well settled that the trial court has inherent jurisdiction to sanction parties and their
counsel for litigation abuse. In this instance, Plaintiff and Ids counsel have sought to cease any
litigation or determination of the bona fides of the O'Boyle Law Firm by threatening and instituting
reprisals against counsel, their client and families.
19, While O'Boyle has the right to continue to make a spectacle ofhimself, he, with the assistance
of counsel, cannot impugn, malign and attempt to extort opposing parties or their counsel as part of
the litigation process.
20. Abusive conduct is not a novelty fur O'Boyle, who has left a historic trail of abusive litigation.
5
LAW OFFlea9 orSWrarAFrre, Baossaa &V, XAx ,P.L.
205.E.3"° SMSr, Boca BATON, FLORMo 33431.3911
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e -mail
September 11, 2014
CG Acquisition Company, Inc.. [mail to: records @commerce- group.com]
Re: GS #1272 (131), #1273 (132), #1274 (130)
With regard to paragraph 16 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, please provide all Public Records which confirm the statement by Attorney
Sweetapple in the third sentence of that paragraph.
With regard to paragraph 17 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, please provide all Public Records which confirm Attorney Sweetapple's statement
that "Attorneys... are prohibited from disparaging witnesses and attorneys, or otherwise
undermining the administration offustice."
With regard to paragraph 16 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' [sicf And William
Ring, Esquire, please provide all Public Records which confirm the statement by Attorney
Sweetapple in the second sentence of that paragraph.
Dear CG Acquisition Company, Inc. [mail to: records(a)commerce- erouo.coml,
This letter is in response to the public records you have requested in your fax received August 8,
2014. This correspondence is reproduced at the following links: http: / /WWW2. ug_lf-
stream. ore /WebLink8 /0 /doc/ 20065 /Paeel.asnx, htt : / /WWW2.eulf-
stream.ore/WebLink8 /0 /doc /20066/Paeel.asRx, and httv://www2.gulf-
stream.ora/WebLink8 /0 /doc /20067/Pagel.ast)x.
Be advised that no such records exist.
We consider this matter closed.
Sincerely,
Town Clerk
Custodian of the Records