HomeMy Public PortalAboutPRR 14-1276RECEIVED 08/08/2014 13:08 5613946102 SBV
0810812014 13:29 Commerce Group TAM543%0807
RECORDS REQUEST (the "Request ")
Date of Request: B/812014
Requestor's Request ID#: 125
REQUESTEE; Custodian of Records - Sweetapple, Brooker, Varkas, P.L.
REQUESTOR: CG Acquisition Company, Inc.
REQUESTOR'S CONTACT INFORMATION: E -Mail: records@commerce- group.00m
Fax: 954- 360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442
REQUEST:
In paragraph 15 of the Defendant's Motion For Sanctions Against Plaintiff, Martin
oy e, ounsel of Recor , e 'Boyle w trm, ,, onathan O'jeic And
" ould
not be the subject of harassment Intimidation and air raids by oaoosina counsel
and their client." We would ask for any Public Records confirming that both Plaintiffs
uounsei and Plaintiff (both) engaged in harassment, Intimidation and air raids.
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 REQUEST BE FULFILLED FILLED IN ELECTRONIC
FORM. IF NOT AVAILABLE IN ELECTRONIC FORaa IT IS REQUESTED THAT THIS
CORDS REOUEST BE FULFILLED ON I1 X 17 PAPER. NOT : IN ALL CASES (UNLESS
IMPOSSIBLE) THE COPIES SHO n BE TWO SIDED AND SHO LD BE BILLED IN
ACCORDANCE WITH Section 119.07(4) (a) (2)
ALL ELECTRONIC COPIES ARE REO lFCrEb TO B ENT BY F f 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 (as defined In
Florida Statute, Chapter 119.01 (Definitions)), in advance of any costs Imposed to the Requestor by
the Agency.
):P/NPR/PRR
042113 FORM
1276
P.0021003
RECEIVED 08/08/2014 13:08 5613946102 SEV
06/0812014 1329 Commerce Group ffA*543600807 P.0031003
MartN 8.0 %0* v. Town of Gulauum
undartakcn to pressure and intimidate defense counsel into not pursuing the issue of whcthor the
O'Boyle Law Firm is a bona fide Interstate Law Firm.
I5. The issue of whether the O'Boyle Law Firm is a bona fide Interstate Law Finn 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. 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 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 instituting
reprisals against counsel, their client and families.
19. While O'Boyle has the right to continue to make a spectacle ofhimseli; 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 novel ty for 0 'Boyle, who has lcft a historic trail ofabusive litigation.
5
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