HomeMy Public PortalAboutPRR 14-1273RECEIVED 08/0B/2014 13:05 5613946102 SEV
08108/2014 13:27 Commerce Group (FAMS4360W P.002/003
RECORDS REQUEST (the "Request'l 1273
Date of Request: 8/812014
Requestor's Request IDk: 132
REQUESTEE: Custodian of Records - Sweetapple, Brooker, Varkas, P.L.
REQUESTOR: CG Acqulaltion Com any, Inc.
REQUESTOR'S CONTACT INFORMATION: E -Mail: records @commerce- group.com
Fax: 954- 360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442
REQUEST:
With regard to paragraph 17 of the Defendant's Motion For Sancfions Against
onathan O' Isic1 And WWiam Ring sgL ,zLplease proy-d QAL o bile Recnniy
which confirm Attorney Sweetapple's statement that "Attorneys... are prohibited
from disparaging witnesses and attorneys, or otherwise undermining the
administration of Justice."
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 1S REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED ED IN ELECTRONIC
FORM. IF NOT AVAILABLE IN ELECTRONIC FORM UF
IT IS REOUK THAT THI
RECORDS R0, U T BE FULFILLED ON 11 X 17 PAPER NOTE. IN ALL CASES (UNLESS
IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED AND EWULD BE BILLED IN
ACCORDANCE WITH Section 119.07(4) (a) (2)
ALL ELECTRONIC COPIES ARE RE MTFD TO BE SENT BY jYi tIL DELIVERY.
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 (Definitions)), in advance of any costs imposed to the Requestor by
the Agency.
LP/NPR(FRR
0422.13 FORM
PECEIVED 08/08/2014 13:06 5613946102 S13V
0810812014 13:27 Commerce Group ffW54'ib1007
Martin E. O'Boyle Y. Town ofOulfsonam
undertaken to pressure and intimidate defense counsel into not pursuing the issue of whether the
O'Boyle Law Fam is a bona fide interstate Law Firm.
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 miWuduet Is unprofessional, unethical and it constitutes an egregious example of
litigation abuse. These tactics go beyond zealous representation and are designed to interfera with
defense counsels' ethical obligation to their client, Such conduct undermines society,$ commitment
to the resolution of disputes in courts of law, rather than in the streets or in the sky,
17. While citizens enjoy the constitutional right of free speech, that protection is afforded to
truthful 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 of justice.
18. It is well settled that the trial court has inherent jurisdiction to sanction parties and their
counsel for litigation show, In this instance, Plaintiff mod his 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 luw the right to continue to make a spectacle of himself, 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 it novelty for O'Boyle, who has left a historic trail Of abusive litigation.
5
LAW OFF=OFSwsarwT%4 BaoSK$a & VABKAS, P.L.
20 Sir. 3'°ft=T, BOCA ATON,I WPMA33432.3911
P.0031003
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