HomeMy Public PortalAboutPRR 14-12741274
RECEIVED 08/08/2014 13:05 5613946102 S13V
0810812014 13:25 Commerce Group 6N)9543800807
RECORDS REQUEST (the "Requcst'�
Date of Request; 8/8/2014
Requestor's Request ID #: 130
REQUESTEE: Custodian of Records- Swsetapple, Broeker, Varkas, P.L.
REQUESTOR CQ Acquisition Company, Inc.
REQUESTOR'S CONTACT INFORMATION; E -Mail: recolds@commerce•group.com
Fax: 954- 360 -0807; Address: 1280 West Newport Center Drive, Deaffiald Beach, FL 33442
REQUEST:
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.,
durrathal. 0, [S de all Public Records
which confirm jile rggIvIngnt by Attg=y Sweetatiole in the second sentence
of that paragraph.
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 REQUESTED THAT THIS RECORDS REOUEST BE FULFILLED IN ELECTRONIC
FORM. IF NOT AVAH,ABLE IN F RONIC FORM IT IS RFO IFSTED THAT THIS
RECORDS REQUEST BE FULFILLED ON 1 t X 17 PAPER NOTE IN ALL CASFS (UNL SS
IMPOSSIBLE) THE COPIES SHOO r_.n nE TWO SIDED AND SHOULD BE BILLED IN
ACCORDANCE Section 119.07(4) a 2
ALL ELECTRONIC COPIES ARE REQUESTED TO BE SENT BYE MAIL DELIVERY
PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC
RECORDS REQUEST IN ADVANCE.
It will be required that the Requester approve of any costs, asserted by the Agency (a$ defined In
Florida Statute, Chapter 119.01 (Definitions)), in advance of any costs imposed to the Requestor by
the Agency.
I;PINPMRR
04.22.13 FORM
P.0021003
RECEIVED 08/0B/2014 13:05 5613946102 SBV
08/0812014 13:26 Commerce Group ffi*5431S00A07
Mectin E. O'Boyle v. Town of Gu]Stream
undertaken to pressure and intimidate defense counsel into not pursuing the issue of whether the
O'Boyle Law Firm is a bona fide Interstate Law Film.
15. The issue of wbethor 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 apposing counsel and their client
16. The misconduct is unprofessional, unethical and it constitutes an egregious example of
litigation abuse. 'These tactics go beyond zealous =presentation and are designed to interfere with
defense counsels' ethical obligation to their client. Such conduct undermine society,$ commitment
to the resolution of disputes in courts of law, rather than in the streets or in the sky.
17. While citizeus 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 $ore disparaging witnesses and attorneys, or otherwise
undermining the administration of justice.
I8. 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 his counsel have sought to cease any
litigation or determination of the bona fides of the O'Boyle Law Firm by threatening and iostitutiog
reprisals against counsel, their client and families.
19. While O'Boyle has the rightto 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 for O' Boyle, who has left a historic trail of abusive litigation.
5
LAwOFF= oFSwa6rAFK2 BPJNbM &VAxr.A3.P.L.
20SY -3 STaesr, SocAiAr FU=A33432-3911
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