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PRR 14-1277
1277 RECEIVED 08/08/2014 13:10 5613946102 SBV 06106/2014 13:30 Commerce Group ffpN)9543600801 P.002/005 RECORDS REQUEST (the "Request ") Date of Request: 8/8/2014 Requestor's Request TD #: 106 REQUESTEE: Custodian of Records - Sweetappla, Breaker, Varkas, P.L. REQUESTER: Commerce Group, Inc. REQUESTOR'S CONTACT INFORMATION: E -Mail: records@commerce- gmup.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 statements that he made in numbered subparagraph 4f. (excluding Subparagraphs 4, 4a., 4b., 4c., 4d., 4e., 4g., 4h„ 41., 4j., 4k., 41. and 4m.) of the -- Befendeht's Is, Counsel of Record The O'Boyle Law Firm P.C., Jonathan O'fsicl And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy of subparagraph 4f. of the referenced Mellon Is attached. 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). TIM 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 IN ELECTRONIC FO_ RM. IF NOT AVAILABLE IN ELECTRONIC FORM rr [c REnUESTED THAT THLS RECORDS RF.OUEST BE FULFILLED ON 11 X 17 PAPER NOTE 1N ALL CASES (UNLESS IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119.07(4) fat (2) ALL ELECT TO BE ENT BY E-MAIL DELIVERY PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULPML THIS PUBLIC RECORDS REQUEST IN ADVANCE. It will be required that the Requeator 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 Requester by the Agency, LPMPR/FRR 04.1: -13 FORM RECEIVED 08/08/2014 13:10 5613946102 08/08/2014 13:30 Commerce Group Filing 415549445131ectmnicaUy Filed 071032014 01:14:36 PM MARTIN E. O'BOYLE, Plaintiff, V. TOWN OF GULF STREAM, Defendant saV ff'O543600807 P.0031005 11' THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502014CA0044747000CM8 DIVISION: AG Defendant, Town Of Gulf Stream, moves this Court for the imposition of sanctions against PlaintA Martin E. O'Boyle, Counsel of Record, the O'Boyle Law Firm, P.C., Inc., its President, Jonathan O'Boylq 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 De&ndant's Motion to Disqualify the O'Boyle Law Firm, P.C., Inc, or in the Altetnative, for an Evidentiary Hmkg (hereinafter the "Motion'). 2, This Motion has been withdrawn without prejudice as Defendant is seeking other remedies With regard to the matters addressed 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 E. 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 Firm,% As at Florida foreign profit corporation, the O'Boyle Law Firm raw 0"=o'SWssrAPnA SWURA & VAUAa, P.L. 205.8.10STRW, BeeARATo ,PLOWA 4323911 RECEIVED 08/08/2014 13:10 5613946102 S13V 0810812014 1331 Commerce Group ff X 95436Q0807 P.0041005 Martin 8.O'Boyle V. Town ofOulfiftam appears to have had no real business presence in Philadelphia, permsylvanie. Although it was registered as a pennsylvania Corporation on November 14, 20I3, it further appears that: a. The O'Boyle Law Finn did not own or lease any commercial space there. 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. I The O'Boyle Law Firm did not pay city, state or federal taxes because it had no employees. e. The O'Boyle Law Firm did not obtain an occupational license to conduct business in the City of Philadephia. f: 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 member ofthe Pennsylvania Bar, but not of the Florida Bar. h. Jonathan O'Boyle advised the Pennsylvania Bar that he is an out -of -state attorney with an address in Florida. i. Jonathan O'Boyle advised the Pennsylvania Bar that his address is in the Town of Oulf Stream, Florida at 23 N. Hidden Harbour Drive, his parent's home address. j• At the time of the opening of the O'Boyle Law Firm in Florida, Jonathan O'Boyle resided and was domiciled in Florida. It. When tha O'Boyle Law Firm opened in Florida, it was operated out ofhis father, Martin O'Boyle's, office at West Newport Center Drive, Deerfield Beach, Florida. It is still operated out of this building, which is owned or controlled by Martin O'Boyle. 2 LAw OFWces orSwaerarPi.e, eao®cea k VMJL%3, AL. 205.6.3 STMar,B=Raor{ tLoamA33432.3911 P.ECEIVED 08/08/2014 13:10 56139461B2 SBV 0810812014 13:31 Commerce Group TW5436000807 P.0051005 Marla E. O'Boyle v. Town of Qujatreem CASE NO, 502014CA004474XXXXMBAQ (PALM BEACH COUBrM I. 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 (bereinafler "O'Boyle ") and hie 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 of Jones Foster, Mr. Stubbs was not in attendance. 7. O'Boyle indicated tha meeting should be confidential in nature as it was called for the purposo of arriving at a settlement. However, plaintiff then proceeded to issue implicit threats, stating 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 made 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 die 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 1-kW OFnc S OFSWEErAY , BRORR6a$ VAMM, P.L. 20 S.S.3"S rF=, BOLA dATOn, FIABIOA 33432.3911 Detail by Entity Name Detail by Entity Flame Forelan Profit Corporation THE O'BOYLE LAW FIRM, P.C., INC. Filing Inkmiatlon Document Number F140000006M FEBEIN Number NONE Dale Filed 02/10/2014 State PA Status ACTIVE 1288 FL 33442 Changed; 02/14/2014 Mailing Address 2148 E. HUNTINGDON STREET PHILADELPHIA, PA 18195 Realstered Anent Name & Address NITMER, RYAN L 1288 W. NEWPORT CENTER DRIVE DEERFIELD BEACH, FL 33449 Address DP E. HUNTINGDON STREET yDELPHIA, PA 19125 Annual Reverts No Annual Reports Filed Pago 1 of bttp:tl se= h. sunbiz. orgll nquity/ CotpomtionSeamh/ SenrchResultnelnVFSditvNnmrlfnm r andr)w The Disciplinary Board of the Supreme Court of Pennsylvania PA Attorney Information Jonathan Reilly O'Boyle PA Attorney ID: 314500 Current Status: Active Date of Admission: 11/13/2012 Lawfirm: Other Organization: District: O County: Out -of State Public Access 23 N HIDDEN HARBOUR DR Address: GULFSTREAM, FL 33483 Tel: 1 758 -1223 Fax: Professional Liability I do not maintain Professional Liability Insurance pursuant to the provisions of Rule of Insurance: Professional Conduct 1.4(C), but I do have private clients and /or a possible exposure to malpractice actions. Comment: Discipline: 02W7.2014 The Disdplinary Board d the Supreme Cmrt or Pamsylvanie. I eiadalmer Fw questbm or m memo regarding the webaile, please mraad us at web.suppor flp urla.us 11/) 0 PA Attorney Information I Pennsylvania Disciplinary Board Page 2 of 2 PA Attorney Information Jonathan Reilly O'Boyle PA Attorney ID: 314500 Current Status: Active Date of Admission: 11113/2012 Lawflrm: Other Organization: District_ O County: Cambria Public Access Address: 1001 BROAD ST JOHNSTOWN, PA 15806 Tel: 661 768 -1223 Fax: Professional Liability I maintain, either Individually or through my firm, Professional Liability Insurance pursuant to the Insurance: _ provisions of Rule of Professional Conduct 1.4(C). Comment: Discipline: ©2007 -2014 The Disciplinary Board of the Supreme Court of Pennsylvania. I Disclaimer For questions or comments regarding the website, please contact us at web.support(ftacourts.us. http : / /Www.padisciplinaryboard.orgl lool c- up /pa- attomey- info.php ?id= 314500&pdcount =0 5/29/2014 " r r . I N T H E a n c u 1 T C O U R T O F T i m 1 5 m J I I D I C i a c m c u r 7 N A N D F O R P A L M B E A C I I , C O U N T Y , F L O R I D A C M U S f O P H E E L F , W H A R H P l � @ f f V S . T O W N O F = S M I A U . W R L I A M H . I B R A S H E & D c f m d m t C a s e N o . 2 0 1 4 C A 0 0 0 7 2 0 D i v i s i o n A l V E R I F I E D M O T I O N F O R A D M I S S I O N T O A P P E A R P R O Z U C W C R P D R S U A N T T O F L O R I D A R U L R O F J U D I C L S L A D M I 1 , M T R A T I O N 2 S 1 0 C o m p s m w . X M A T H A N R . O ' B O Y L R H l n v m t h e r e i o , m d r e s p r L W y r e p m s e n m t h e f o l l o w i n g 1 . A f a m t J o m t l = P O ' B o y l e i s d o m i c i l e d m d p % m m e n t l y r a i d m i a L O N O P O R T , N E W J E R S E Y . M o v m t i s n o t a p e n h a m e n t r e s i d e n t o f t h e S t a t e o f M o t i d a . M o v m t J o n a t h a n R . O ' B o y l e i s a t e m p o m r y m s i d e n t o f f t S t a t e o f F l o r l d a a n d h a s a n a p p l i c a t i m p e n d i n g f o r a d m i s s t i a n t o T b a F l o r l d a H e r m d b a s m t p r e v i o m s l y b e m d e n i e d a d m i s s i o m t o Z h e F l o r i d a H a r . 2 . M o v a n t i s m A t t a m e y a n d a m e m b e r o f t h e l a w f i e u o f ( o r p r a c 6 e e s l a w u n d e r t h e n a m e D o n e O ' B o v l e l A W F l a n , P . C . ( F m m e d v k n o w n a s J o n a t * _ n R . O ' B o y l e P C ) w i i h o f f i c e s a t 2 1 4 4 5 o n t i m e d o a S L P h i l a d e l n l d a P b R a d e l m h i a P e m w 3 v a d a 1 9 1 2 5 5 5 1 - 7 5 8 - 1 2 2 3 ( C o u n t y ) ( S t a t e ) ( Z i p C o d e ) ( T e l e p h m o ) 3 . M o v a n t h a s b e e n r e t a i n e d p e a a n a l l y o r a s a m e m b e r o f t h e a b o v e a e m e d l a i r S n n a n J a r m a r y 1 0 . 2 0 1 4 b y H a t t o m e y L o u R o e d e r ( D a t e R e p m e a a t i o n C o m m e n e d ) ( N m e o f P a d y o r P a r t i e L t o p m v i d e I e g e l a p r e s m t a f i o n I n c o n n e c t i o n v r i d t t h e a b o v o - s t y l e d m a t t e r n o w p e a d i n g b o f a r e t h e a b o v e - o a m e d c o u r t o f t h e S t a t e o f F l o r i d a 4 . M o v m t i s m a c t i v e m e m b e r i u g o o d s t a n d i n g a n d e m r m t i y e l i g r i b l e t o p r a t d c e l a w i a E m the following jmisdiction(s): Include, ettomey orbermanbec(s). (Attach as additional aheetif necessary.) . 1' ! JURISDICTION ATTORNEYIBARNUNMER 5, Theeare no disciplimyproceedings pending against Mavmt, except as provided below (givojudsdiction of disdplinary action, date of disciplinary action, vamnaof(bo violation and the smctioR ifauy, imposed): (Attache¢ additional s�heetifaecusary.) 6. V/ithh the past &o (5) years, Movantbas not baeasubjeat to my disciplinary proceedipp, except as provided below (give jurisdiction ofdisciptinary action, date of disaplinacy action, mmnoftbe violation mdibe sanction, ifsny, imposed): (Attach m additional shat ifnecessary.) ' 7. Movautheari verbeensul�cotto aaysuspeasioaproceedmgs. except sa ptovlded below(givcjmisdiction of4isciplinary action, data ofdiseiplineryactio t, nature of the violation and the sanetion,.ifany, imposed): (Attach an additional sheet if necessary.) . 8. Movant has never bcensubjectto any disbarmeatpmcecdwb�s, emeptas provided below (givaimisdictieo.of disciplinary action, data of discplinazy action,natum oftheviolatlon and the smcfim ifdny, imposed): ( Attach an additional sheetifnecessary.) VV %� . 9. Movant, c4ber byreslgcetton, withdrawal, ar o0mrwise, neverhas terniexted car attempted to temdaste Movaat's office as an attomoyia order to avoid admiuistmtive, disciplinary; disbarmm; orsuspeosignproceedinga 10. Havant ismtaninac(iva mcmberofTbeF7aride.Ber. Il. Havana is mSnoWamembe[ofTha FloridaBar. 12 Movantis note suspendedmam — =ofThs Florida7lar. 13. Movantis not a disbo¢ed member o£Thc FloridaBaraor has Movantreceived a discipliaaryrdiguationfmmThe Mri4Bar. ' 14. Movaathea notpreviouslybeaa disciplined orhdd is mntemptby=maof misconduct rommhtcdwhiEe cagagedin repccseatafioaputsveatta Florida Rule of Judicial Adarinistrsdon ZS10, except as ptnvidedbelow (give dato ofdisciplinary action or contempt, reasons themfor, and comtimposing contempt): (Attach an additional sheetifnecessary.) , , , . . . 15. Movanthas 5ledmobon(s) to appear as couaaal laFtorida. state courts dudog the past five ($ycm in the followingmatfers. (Attach an additional sheetifnecessazy.) Dateof�Mlottioon Case Nana CaseNumher Court Date Motion Qranted/Deoied �h1— 16. Local counselofreconl associated with Movantinthismatteris RG •lj,� e�+ 0�Di563 who s a nactivemrmberiegopdstandngofThohlodda (Name aad Plodda 8 ss Num6m) Bar eodlus offices at MIMP ln]• Nfa�oa'( cfp � ljowt ee4 m"es') (city) 95u -57u -BARS tam") (Zip coda) lidvh— pithmmarts) (If local counsel is not an activemember ofThoFlodda Bain good staeding, pleasepmvide information as to local emmsel•s membership statue 1 17. Movantires read the npplicableprovisions ofFloridaR ale of Judicial Adminia.,gon 2510 and Kyle 1 -3.10 e£ga AvIes RegtdalingTttePlorida Barmd ceadfies that.thia ve[ilied motion complies with.thwemlm. 18. Movant agates to complywith theprpvisiooe of the Florida Rules ofFroiemionet Conduct and weeseatsto the judsdietion of the courts and the BaroftheState of Florida. VATEREFORB, Movantrespec tfidlyrequestspennission to appear in this court for Us cause only. DATED tide day of t4nvKrw z� d Case 9 :1 - 80530 -DMM Document 25 Entered 0n FLSD Docket 06/17/2013 Pag eril 01 FILED by UNITED STATES DISTRICT COURT JUN 17 2013 cCp� SOUTHERN DISTRICT OF FLORIDA amei erERK II Mar 8•e, 'yec�t- Cast No, 13.80530- M- MIDD OF LEBROOKS "Wen !3- Uc3o MARTIN E. O'BOYLE Plaintiff, VS. TOWN OF GULF STREAM Defendant. MOTION TO APPEAR PRO HAC VICE CONSENT TO DESIGNATION AND REOUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILINGS In accordance with Local Rules 4(b) of the Special Rules Governing the Admission and Practice of Attorneys of the United States District Court for the Southern District of Florida, the undersigned respectfully moves for the admission pro hoc vice of Jonathan R. O'Boyle of 2146 E. Huntingdon St, Philadelphia, PA 19125,561-758-1223, for purposes of appearance as co- counsel on behalf of Mattln B. O'Boyle in the abgve -styled case only, and pursuant to Rule 2B of the CM/ECF Administrative Procedures, and to perritit Jonathan R. O'Boyle to receive electronic filings in this case, and in support hereof states as follows: 1. Jonathan R. O'Boyle is not admitted to practice in the Southern District of Florida and is a member in good standing of the Pennsylvania Supreme Court (PA Bart1314500). 2. Movant Robert S. Gershman, Esquire, of the law firm of GERSHMAN & GERSHMAN, P.A., 2160 W Atlantic Avenue, 2d Floor, 561 - 684-5898, is a member in good standing of the The Florida Bar and the United States District Court for the Southern District of Florida, maintains an office in this State for the practice of law, and is authorized to file through the Court's electronic filing system VF71 ' __144`1; Case 9:13 -cv- 80530 -DMM Document 25 Entered on FLSD Docket 06/1712013 Page 2 of 5 Mgvaot consents to be designated as a member of the Bar of this Court with whom tho'Court and Opposing counsel may readily communicate regarding the conduct oftho case; upon whom filings shall be served, who shall be required to electronically file all documents and things that maybe filed electronically, andwho shall be responsible) for filing documents in compliance with the CM/ECF AdministradveProoedmes. See Section 2B of the CM/ECF Administrative Procedures. 3. In accordance with the local rules of this Court, Jonathan R. O'Boyle has matte payment of this Court's $75 admission fee. A certification in accordance with Rule 4(b) is attached hereto. •4. Jonathan R. O'Boyle, by and through designated counsel andpursuant to Section 2B CM/ECF Administrative Procedures, hereby requests the Court to provide Notice of Electronic Filings to Jonathan R. O'Boyle at email address; Jonathanroboylr@gmail.com. WHEREFORE, Robert S. Gershman, moves this Court to enter an Order Jonathan R. O'Boyle, to appear before this Court onbehalf of Martin E. O'Boyle, for all purposes relating to the proceedings in the above -styled matter and directing the Clerk to provide notice of electronic filings to Jonathan R. O'Boyle. Date: June 17, 2013 Respectfiilly sgbmitted, P ert S. Gershman Flo 'da Bar No. 91,7397 Robert@rgiawfirm.us GERSHMAN & GERSHMAN, P.A. 2160 W. Atlantic Avenue, 2d Floor Delray Beach, FL 33445 (561) 684 -8898 (telephone) (561) 998 -5868 (facsimile) Attorney for Martin E. O'Boyle Case 9:13 -cv- 80530 -DMM Document 25 Entered on FLED Docket. 0611712013 Page 3 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 13- 8 0 5 3 0- Civ- MMDLEBPOOKS MARTME. O'BOYLE Plaintiff,. VS. TOWN OF GULF STREAM Defendant CERTIFICATION OF JONATHAN R. O'BOYLE Jonathan R O'Boyle, Esquire, pursuant to Rule 4(b) of die Special Rules Governing the Admission and Practice of Attorneys, hereby certifies that (1) I have studied the Local Rules of the United States District Court for the Southern District of Florida; and (2) I son anumber in good standing of the Pennsylvania Supreme Court. P 9AtCy Oyrg374500 Case 9:13 -cv- 80530 -DMM Document 25 Entered on FLSD Docket 06/17/2013 Page 4 of 5 CERTIFICATE OF SERVICE . IHEREEY CERTIFY that atrue and correct copy of the foregoing Motion to AppwPm Xnc Trice, Consent to Dcsigoation and Request to Electronically Receive Notices of Electronic Filings was served by uploading smo to the'CWECF. SERVICE LIST Joanne M. O'Connor jaconnw jonmforier.cam JONES FOSTER JOHNSTON & STUBBS,, P.A. 505 South Magler Driw Suito 1100 West Palm Beach, FL 33401 561 -659 -3000 (telephone) 561 - 650- 530D(faratmile) Anomeys for Defendant Town ofOulfStm= Case 9:13 -cv- 80530 -DMM Document 25 Entered on FLSD Docket 06117/2013 Page 5 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 13- 60530- CIV- MIDDLEBROOKS MARTINS. O'BOYLE Plaintiff, VS. TOWN OF GULF STREAM Defendant ORDER GRANTING MOTION TO APPEAR PRO HAC VICE,, CONSENT TO DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING THIS CAUSE having comebeforethe Court on the Motionto AppearPro Hac Vice forSonathanIt. O'Boyle, CoesarttoDesignation , and RequesttoFlocU nicallyReceiveNotices of Electronic Filing (the "Moti& ), pursuant to the Special Rules Governing the Admission and Practice of Attorneys in the United States District Court for the South District of Florida and Section 2B of. the CMYECF Administrative Procedures. This Court having considered the motion and all other relevant factors, it is hereby of Florida. ORDERED OR ADJUDGED that The Motion is GRANTED. Jonathan R. O'Boyle, may appear and participate in this action on behalf of Martin E. O'Boyle, The Clerk shall provide electronic notification of all electronic filings to Jonathan R. O'Boyle at Jormffmroboyle@gmail.com. DONE AND ORDERD in Chambers, West Palm Beach, Palm Beach County, Southern District of Florida, on June , 2013. DONALD MIDDLEBR05KS United States DistrictJudge Copies flunished to: All Counsel ofRecord Case 9:13 -cv- 80530 -DMM Document 27 Entered on FLSD Docket 06/19/2013 Page 1 of 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.13- 80530- CIV- AMDLEBROOKS MARTIN E. O'BOYLE, Plaintiff, VS. TOWN OF GULF STREAM, Defendant. rn THIS CAUSE comes before the Court upon a Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notice of Electronic Filings (DE 25) ( "Motion"), filed June 17, 2013. The Court has reviewed the record and is fully advised in the premises. Pursuant to Local Rule 4(b) of the Special Rules Governing the Admission and Practice of Attorneys in the United States District Court for the Southern District of Florida, the Motion requests permission for the limited appearance of Jonathan R. O'Boyle, of 2146 E. Huntington St., Philadelphia, PA 19125, as co- counsel on behalf of Plaintiff in this matter. The Motion has been properly filed with the required documentation, and the attorney appears to be in good standing. Accordingly, it is hereby ORDERED AND ADJUDGED that the Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notice of Electronic Filings (DE 25) is GRANTED. Jonathan R. O'Boyle may appear and participate as co- counsel in this action on behalf of Plaintiff. The Clerk shall provide electronic notification of all electronic filings to Jonathan IL O'Boyle at ionathanroboyle(g4mail. com. DONE AND ORDERED in Chambers at West Palm" each lorida, this day of June, 2013, UNITED STATES DISTRICT JUDGE Copies to: Counsel of Record Y l ) i 1 Y i S I UN=f) S'CATES DISTRICT COURT FORTHE SOU1BM1 RN DISTRICT OF FLORIDA wES'f pAl:xBBACHbrMl:oN CASD Nor 9:13- cv,81053 -49 CMUS Q'HAPM . Fla{atiff, VS. TOWN OF GOLF STREAM et, al. Defendants. T" iP T .TV N i 'i RF MINC, . In accordance wM Local Rules 40) of the Sp o ul Rules Qoveraing the Admits !on and Practice ofAttomeysofthe:United States District Count far the Southern Districtof Florida, the uudcrsigned respectfully modes'for the admission pro liae vice of Ionathan R. O'Boyle of2146 Lr.1huntingdon St., Pldlndelphla PA 19125, 561 -75& 1223, for purposes of appearance as oo- corursol on behalf of Chris O'Hara In the above- styledosse only, and ptirsaant to Rule 2B of the CM/ECF Administrative Pracodures, to permitlouuthan R.O'Baylote Mcolvaelcatonic filings in this.oase, and iasupport thereof states as follows: 1. Ionalban R. O'Boyle is not admitted to practice In the Southern District of Florida and is a meoillw in good standing of the Pennsylvania Supreme Court (PA Bar* 314500). 2. Die undersigned is a member in good drending of the Thdflorida Bar and the United Stales District Court for the Southern District of Florida, maintains an office in this State for the practice of law, and is authorized to file through the Court's electronic filing system. Movant consents to be designated as a member of the Bar of this Court with whom the Court and Opposing connsel may readily nommunhoateregarding the conduct of the case; upon wlimh filings shall be served, who shall be requircdto electronically fi I a all documents and things that may be filed electronically, dnd who shall bo responsible for filing documents in compliance with the CM/BCF Administrative procedures. See Station 213 of the CM /SCP Administrative Procedure, CEI i F JAN I a 2914 'H v-A .s •�Y. 3. In accordance with the local, rules of this Court; Jonathan R- O'Boyle has made paymentof this Court's $75 admission,foe. Acertificstion, in accordance with Rnle 4(b) is being filed eautcmporaneously with this Motion. A bopy is attaeltod hereto, 4_ Jonathan R O'Boyle, by and througlh designatbd copnsoi and pursuant to Seaton 213 CWBCF Administrative Procedures, hereby requests the Court to provide Notice ofHdeotrnnla Filing to Jonathan IL O'Boyle at email address: Jonathanmboylc@gmail.eom. W IiEREFORE, Mark J. Hanna moves tltls Courtm enter an Order permitting Jonathan R O'Boyle to appear before this Court on behalf of Chris O'Hara for all purposes rdlsting to t Pb draeadingg In the Above - styled matter and directing the Clerk to provide notice of eleotrohie filings in Jonathan R O'Boyle. I PILREBY CERTIFY that on January 10, 2014,1 filed the foregoing document with the Clerk of Court via conventional method due to the nalutc of the motion. I further certify that mailed the furegahhg doeurnant via ptepaid first class U.S. niailto tba following: Mabel R Piper Christopher.), Stearns JOHNSON, AN6MM(I, MURDOCH, BURKL, PIPER & HOCBIM14, P.A. 7455 Bast Sunrise Boulevard, Suite 1000 Fort.Lauticrdale, Florida 33304 Tolophone.: (954) 463-0.100 piper @ja mbg.com steamsQa runbg.00m Dated: Jobuary 7, 2014 OMMMADISON P.A. 441 South f truly Rnad #3272 Palm Bpadh ,380.9991 Te1:56 dh, 999 Florida Bar'Np. 0045251 561 - 723-8284 (cell & text) mhanmQg3minw.com UNrMD STATES))VF ICT COURT FOR T33E SOUTHERN DISTRICT OF FLORIDA WEST PALMHRACH DIVMOW CASE NO: 9t13eV•BL053 -RIIi CMUS O'1IARE PIaIA31ft; vs. TOWN OP GULF STREAM eL aL Dohudaatt. Twiddled R O'Boyle, F.sgpire, pursuant to Rqla 4(b) of the Spatial Rules Owetaiog did Admlaslaft end Friction ofAttomeys, haoby ceiCifes Wat(11)Iheva studied the Local Rules dithe Untpd Status District Court for the Southern District aFFlprlds, an (2) I am a mamba' in good standing of tha Pennsylvania Supreme ComL Inudl gh O ogle, Bsq. IpmAlign R. O'Boyle, P.C. 2146 B.Huath%den SL PlidaddlplJR PA 19125 Al; 561 -74$ -1223 Fpx:215 -8'XJ -3641 'ml,hylof7YmlaW edm Pennsylv¢nia BnrNo.314500 1 HEREBY CERM'V that on January 10, 2014, IRIpdBa foregoing domiment with the Clerk of Cant via Waventionul method dua (o the nature ofthemotion. I thither eMify tliat m¢fled Iho foregatng dommeantvia prepaid Punt elan U.S. mail to the fallowing Waltdal lt. Piper ChrlsmpbprJ. Steards JOHNSON, ANSBMMO, MURDOCH, BURKE, PSPF,R § HOMMAN, PA. 2455 Ent SunriseHoalevard, Solid 1000 FartLaudenlale, Florida33304 Telepbona.:(954) 463 -0100 ptpergambg.oam stemnagambli.oam DuWd: January %2014 OMAivJADiSON PA. 401 South County Road 03272 NftnBpacb pL33410 -9991 Tcl: 561-221 -9990 Mark 3. Hands Florida BarWo, 0045251 561.723.6284 (call do nut) mhenna@g3mlcw,com UNITED STATES DISTRICT COURT FOR THE SOVJ IZW DISTRICT OF FLORIDA WEST PALM BEACII DMSI'ON CASE NO: 9:I5- cv- SI05� -XLR yar • e ' a Flnlntitf Ps. YO'WN OF GULF STREAM et al. Defendan,M THIS CAUSE having come before We Court on the Motion to Appear Pro Hire Vice for domithan R, O'Boyle; Consent to Dasignation, and Request to Bloctrohically ReceiVeNotioes of Election to Filing (the "Motion "), pursuant to the Special Rules Cto¢urning die Admission and I'mcdec: ofAttomeys in Via United States District Cohitfor fire Southern District of Florida and Section 2 B ofthe CMIECF Administrative Prpcedures. This Court having considered the motion and all other relevant f ctom, it is licreby ofi•lorlda ORDERED OR ADJUDGED that: The Motion is GRANTED. Jonathan R. O'Boyle, may appear and participate in this action on behalf of Chrls O'Hare. The Ciark sliall provide electronic notification of all oloctronia filings to Jonathan R. O'Boyle atjonathanroboyle@gmail,com. DQNE AND ORDEREp in Chambers, WestPAlm Beach, Palm Beach County, Soulh'em District of Florida, on January 2014. Copies furnished to; All Counsai of Record KENNME L, RYSICAMF United States District Judge TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail September 29, 2014 Commerce Group, Inc. [mail to: records @commerce - group.com] Re: GS #1277 (106) Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4f. (excluding subparagraphs 4, 4a., 4b., 4c.,4d., 4e., 4g., 4h.,4,4j., 4k., 41. And 4m) 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, which was filed by Attorney Sweetapple. A copy ofsubparagraph 4f of the referenced Motion is attached. Dear Commerce Group, Inc. [mail to: records @commerce - group.com], This letter provides you with the full production of public records you have requested in your email dated August 8, 2014. Your original request can be viewed at the following link: htip://www2.gulf-streain.org/WebLink8/0/doc/20070/Pagel.asRx . Be advised that the responsive records are available at the same link. We consider this matter closed. Sincerely, Town Clerk Custodian of the Records